The Region of Peel…

The Region of Peel appreciates the opportunity to comment on the proposed Cap and Trade Cancellation Act, 2018, ERO number 013-3738.
With a population of over 1.4 million people, the Region of Peel is the second largest municipality in the Province of Ontario. Through past growth and commercial development, Peel has transformed into a dynamic urban community with a vibrant economic base. Peel Region is experiencing rapid growth, and by 2041, will welcome more than 500,000 new residents and 250,000 new jobs.
Municipal infrastructure is the foundation for safe, resilient and productive communities. Businesses need safe roads and bridges to deliver goods and services. Commuters need fast, efficient transportation networks to get to work and school. However, climate change is a serious issue facing municipalities. Extreme weather events, such as more frequent flood events and ice storms, are increasingly impacting the condition and sustainability of municipal infrastructure.
For example:
• the December 2013 ice storm cost the Region of Peel, together with the local municipalities and the conservation authorities, upwards of $83 million
• extreme rainfall in July 2013 resulted in 2,082 reported flooding incidents by residents and businesses within the region and over $1.03 billion in insured damages across the Greater Toronto Area
By all levels of government working together to develop and implement adaptation and mitigation plans, municipalities will be able to better realize cost-avoidance savings when extreme weather occurs. This is critical as these extreme weather events are expected to only increase in frequency and intensity.

To reflect the Region’s commitment to leadership and action on climate change, Regional
Council endorsed a Climate Change Statement of Commitment in 2017. The statement contains guiding principles and desired outcomes related to climate change to support the transition to a low carbon and resilient future. It is aligned to the Regional Council’s vision of a Community for Life for Peel residents and the 20 year outcome to live in a community that is environmentally friendly. To better measure action, the Region has adopted a long term mitigation target of 80% greenhouse gas (GHG) emissions reduction below 1990 levels by 2050. Further, a Climate Change Operational Policy and Climate Change Master Plan are currently in development; adding to the suite of climate change initiatives already underway at the Region, including:
• Long term Waste Management Strategy “Roadmap to a Circular Economy in the Region of Peel”;
• Green Buildings and Sustainable Technologies;
• Green Fleet Strategy;
• Long term Inflow and Infiltration Strategy;
• updated Peel Public Health Vulnerability Assessment; and
• Peel Comprehensive Health Status Report 2008-2018 (incorporates climate change impacts)

The Region of Peel has incurred financial impacts from the repeal of Cap and Trade Program and the dismantling of programs financed by its proceeds. A significant portion of the cancelled funding was allocated to social housing providers to complete outstanding capital work on required repairs. The removal of this funding means the cessation of some capital projects, which are needed to support affordable housing and their vulnerable communities, in addition to losing the inherent cost savings from the building improvements.
The following is a list of Region of Peel projects tied to the proceeds of the Cap and Trade Program:
• Municipal Greenhouse Gas Challenge Fund (Round One) for Anaerobic Digestion Facility
o Fund Value: $10 million
o Funding Status: Cancelled – wind down proposal submitted for approximately $260,000 to recover eligible costs specific to spending of the original granted funds
o Project Status: Project is continuing subject to non-Cap and Trade Program fund related considerations
• Workplace Electric Vehicle Charging Incentive (WEVCI) Program
o Fund value: $255,000
o Funding Status: Under review – Continued eligibility dependent on project status and intended completion dates
o Project Status: Project is on hold based on outcome of funding status review. Only partial completion of project will be achieved if Cap and Trade Program funds are cancelled
• Green Ontario Social Housing Project
o Fund Value: $322,970
o Funding Status: Cancelled
o Project Status: Cancelled
• Municipal Greenhouse Gas (GHG) Challenge Fund (Round Two) for energy system enhancements to Peel Manor Long Term Care project
o Fund Value: $2 million
o Funding Status: Cancelled
o Project Status: Project is continuing. In the absence of Cap and Trade funding, some capital work to optimize the reduction of GHGs will not be included
• Social Housing Apartment Improvement Program Year 2-4 (2019 to 2021)
o Fund Value: $43 million
o Funding Status: Cancelled
o Project Status: Cancelled
• Electric and Hydrogen Vehicle Purchase Program
o Fund Value: $266,000
o Funding Status: Cancelled
o Project Status: Project is continuing without Cap and Trade Program funds
In the absence of Cap and Trade Program funding, specific capital projects with the potential to reduce GHG emissions will not be implemented, thus increasing the risk of climate change impacts related to increased warming and extreme weather events.
Effective responses to extreme weather events and climate change will require a strong commitment and coordinated action across multiple levels of government, community organizations and businesses. The Region of Peel recognizes that the province will develop a climate change plan which will include establishing targets for reducing the amount of GHG emissions in Ontario. By establishing a clear, science-based climate changed plan, which includes sustainable funding for transformative action, the province is investing in the future of Ontario and helping local communities prepare for more frequent flood events, extreme heat days, ice storms, and rising GHG emissions. With a provincial climate change plan, municipalities could also receive much needed federal funding for critical infrastructure.
The Region of Peel also understands that the new climate change plan will include strong support for adaptation action. Through the development of our Corporate Climate Change Master Plan, the Region is identifying a spectrum of important adaptation actions to help maintain quality service delivery to residents before, during and after extreme weather disruptions or chronic climate impacts (e.g., extended heat waves or droughts), including:
• Protection of critical assets using a risk-based assessment approach
• More distributed green infrastructure, including tree canopy investments and Low Impact Development
• Policy and Process improvements
• Resilience Standards
• Public outreach and education
The Region of Peel asks that the Ontario government consider the following recommendations to inform the new climate change plan:
• The climate change plan is science-based and supports meeting municipal greenhouse gas reduction targets and that it includes sustained adaptation and mitigation funding consistent with benefits to the local economy;
• Provides long-term, sustainable funding for water and wastewater infrastructure;
• Invests in waste infrastructure to increase resource recovery and strengthen end-markets for recovered resources;
• Sets criteria for infrastructure investments that achieve improved public health and climate change outcomes;
• Provides long-term, sustainable capital and operational funding for affordable housing, including the current housing stock, new rental development and housing subsidies;
• Meets federal criteria to ensure that $1.4 billion of Phase 2 federal infrastructure funding is distributed to municipalities in a timely manner;
• Creates an advisory panel with municipalities and other stakeholders to help inform the climate change plan; and
• The climate change plan is revised, at a minimum, every five years.

The Region of Peel looks forward to building a strong partnership and working collaboratively with the Province to address climate change and create low-carbon, resilient communities in Ontario.
Thank you for the opportunity to provide our comments.