Dear Madam/Sir, Please…

Dear Madam/Sir,

Please accept this submission as Environment Hamilton’s comments on the proposed Bill 4 – Cap & Trade Cancellation Act, 2018. Environment Hamilton is a local not-for-profit organization, established in 2001 with a mandate to provide Hamiltonians with knowledge and skills to enhance and protect the environment. We have been involved in climate-related initiatives for many years now – including playing an active role in efforts to develop and implement a community climate action plan in Hamilton and serving as an active organizational member of the Urban Climate Alliance – a collective of 5 ENGOs active in Hamilton, Toronto, Ottawa Windsor and Oakville.

First, we would like to suggest that it would have been appropriate to post this proposal for longer than the minimum 30-day comment period. This is a significant proposal for change with very serious implications for the environment both now and into the future and Ontarians deserve to have adequate time to review and comment.

At the same time, we are painfully aware of the fact that we simply do not have the luxury of time when it comes to the climate crisis. Ontario was already several years into a Climate Action Plan – supported by legislation – and that plan was beginning to have an impact. Do not take our word for it – just consider carefully what the Environmental Commissioner of Ontario, Dr. Dianne Saxe had to say in her latest provincial gHg emissions report to the Legislature.

In her October 2018 report entitled ‘Climate Action in Ontario: What’s Next?’ Saxe refers to Ontario having become a ‘world climate leader’ after ‘years of hard work’ that included:
• closing coal plants
• slowing urban sprawl and promoting conservation
• the 2009 Green Energy and Green Economy Act
• the 2016 Climate Change Mitigation and Low-carbon Economy Act and its cap and trade system
• joining the shared carbon market with California and Quebec, and
• joining the Pan-Canadian Framework on CleanGrowth and Climate Change.

Further, Saxe explains that, despite some flaws, these policies were good and having an impact. She emphasizes the fact that ‘(O)ntario’s greenhouse gas emissions dropped to the lowest level ever reported, while the economy and
population grew.’ Again, our greenhouse gas emissions DROPPED TO THE LOWEST LEVEL EVER REPORTED WHILE THE ECONOMY AND THE POPULATION GREW!

So, we have to ask, why on earth would the Ministry want to eliminate this legislation and all of the policies and programs that flow out of it? It is beyond our ability to comprehend, especially when the planet is on the brink of climate crisis. Just this week, the IPCC released what is probably its most dire assessment to date of where we humans are pushing the planet. Their report is an urgent call to action with the fundamental message that time is running out if we hope to avoid extreme climate disruptions. Climate scientists have sounded the warning bell that if we allow the planet to go beyond a 1.5 degree Celsius temperarture increase, we are risking the planet’s livability. And that 1.5 degree Celsius increase may be reached within 12 years. We wonder, does this provincial government want to be remembered in history as the government that pulled us off of the right track and down a dangerous, uncharted path? Will you answer to future generations?

As Commissioner Saxe points out:
Cap and trade was providing the motivation and billions in funding for meaningful emission reductions across
the province; climate leadership was enhancing Ontario’s reputation and drawing in foreign investment. In
short, there was some inefficiency, but cap and trade was on its way to producing many economic and
environmental benefits for the people of Ontario.

Given this reality, we find it completely unacceptable that the Ford Government is pushing Ontario in the direction that it is. To make matters worse, we have seen no indication to date of any viable alternative climate action plan to the measures that the government is proposing to eliminate. What is this government proposing to do to address the climate crisis? We do not have any time to spare; the need to take action is urgent!

Thank you

Lynda Lukasik, PhD
Executive Director
Environment Hamilton