The following is to raise…

The following is to raise concern on Bill 4 that has been tabled for the province of Ontario.
First concern is that the bill states that there is a plan that will be developed and communicated and reported on. No timelines are set, no set times for when the feedback on the plan will be given. I need to remind you that the IPCC has recently described and quantified the importance of real change to occur in the short term to avoid significant damage to the Earth and the way of life for all the people of Ontario. Climate change is an issue that has been recognized and topic of discussion with every for over a decade, time for planning is done and action is needed. Very accelerated timelines are needed and not discussed in this bill.
Using the date of July 3rd for the date of ending the cap and trade activity is problematic as most industry data is not easy to have outside of a monthly period, this adds complication to the wind down process. Would it not be better to allow the program to end on a clean date at the end of one month to make the final accounting on the GHG emissions side and on the financial side more manageable as this activity is all work that was not anticipated by anyone.

Would it not make more sense to have a wind down plan with the cap and trade that would not require the payment of funds, that were intended to reduce GHG emissions, to companies that have allowances at this time? Companies have been engaged and working with the cap and trade for over a decade. The internal infrastructure at these companies have been created to work with the cap and trade and the tasks associated with it. Asking companies to remove this infrastructure so quickly, asking them to ignore these investments made created business uncertainty and waste. Should companies not be compensated for the work that has been done internally to develop the processes and mechanisms to work in cap and trade. This really is a disruption to our industries and lowers their confidence in the Ontario market and political structure.

The clauses that outline those that have no compensation look very week and don’t allow for companies to address very real concerns about this accelerated change that is occurring in very important legislation. I am a small business owner that has spent years to allow our consulting company to achieve the accreditation for the verification services we provide in GHG emissions. The removal of cap and trade in Ontario will have a big impact on our business and remove any opportunity we have to benefit financially from our work in obtaining and maintaining accreditation for this work. Our small business will have a negative effect from this bill and will reduce our ability to add jobs and will most likely result in the reduction of job positions. What compensation will be available or our small business? Would a slower and more thoughtful exit from the cap and trade not make more sense so the business environment can adapt to these changes and work to any new plan that the government presents?

The bill will result in increased business uncertainty, lose in finances from small and large business, lose of funds that were collected for climate action to be used to pay legal obligations like the gas plant issue that we had years ago. This bill has been developed without much consideration for lessons learned, action against climate change or what is best for business in Ontario. The cap and trade program allow for Ontario to determine how we will address climate change, removing it with no plan means that we will lose control in Ontario and the benefits that the Nobel prize winning economist have shown exist. This bill needs to be revised significantly and the understanding around the work done for the cap and trade needs to be understood more and taking into account, it was a decade long process developed in Ontario with partners in North America that are important trading partners.