October 11, 2018 Cap and…

October 11, 2018

Cap and Trade - Help Desk
Cap and Trade Branch
77 Wellesley Street West
10th Floor, Ferguson Block
Toronto ON M7A 2T5
Canada

Dir Sir/ Madam,

RE: RPWCO Response – Bill 4: Cancellation of Cap and Trade Act, 2018 – ERO 013-3738

These comments are submitted on behalf of the Regional Public Works Commissioners of Ontario (RPWCO).

RPWCO represents the public works commissioners in 17 of Ontario’s largest single-tier cities and regions. Collectively, its members are responsible for building, operating, maintaining and renewing over 75% of Ontario’s public infrastructure.

GENERAL COMMENTS

Municipal Stake in Provincial Action to Combat Climate Change

Municipalities have a significant stake in the Province’s actions to combat and adapt to climate change. Seventy percent of global GHGs are generated in cities. The way we plan, build and operate our transportation systems, our housing stock, and our water and wastewater systems all have a direct impact on reducing GHGs. We are also the first responders in emergency situations resulting from extreme weather caused by climate change. Finally, it is our responsibility to create resiliency in our communities, amongst our residents and businesses as well as in our capital assets.

 
Impact of Climate Change on RPWCO members

The impacts of severe weather due to climate change have been devastating to a number of our member municipalities, both in terms of property damage, and recovery costs. The City of Windsor experienced flooding in 2017 that caused property damage to over 6,000 residences. In 2012, the City of Thunder Bay experienced severe flooding that caused $23 million in municipal recovery costs and rendered its wastewater treatment plant inoperable. The City of Toronto has experienced multiple flooding events over recent years, including flooding during the summer of 2017 that caused over $8 million in costs to the city as a result of closing a partially submerged Toronto Island for three months. The 2013 ice storm caused widespread damage in the GTHA and led to more than $16 million dollars in expenditures for York Region and its cities and towns.

Due to growing concern over the impacts of climate change on our member municipalities, the RPWCO has recently formed a Climate Change subcommittee to focus on climate mitigation and adaptation. The purpose of the subcommittee is to find ways to improve our resiliency in the face of extreme weather impacts and to share practices and resources to further mitigate GHGs.

Cancellation of Cap and Trade has adversely impacted municipal GHG reduction efforts
Most of our members have already adopted climate change plans and are working towards meeting their GHG reduction targets. Doing so requires investments and the cooperation of residents and businesses. The Cap and Trade Act assisted municipalities in these efforts by providing resources to industry, residents and municipalities to invest in GHG mitigation measures, whether in transit, green energy generation, or building retrofits. For instance, the cancellation of Cap and Trade has resulted in a $25 million loss in mitigation opportunities within York Region alone, including the cancellation of an electric bus pilot program. The loss of the Cap and Trade revenue towards these efforts has dealt a severe blow to the momentum in meeting municipal GHG reduction targets.

BILL 4: SPECIFIC COMMENTS

The imperative to reduce GHG emissions to limit global temperature increase to 1.5C

Section 3(1) of the Act requires GHG reduction targets to be set.

This month, the International Panel on Climate Change released a report that underlined the imperative to reduce GHG emissions to keep global temperature increases to a maximum of 1.5C within the next twelve years. Above this threshold, hundreds of millions of people will be devastated by extreme heat, drought, extreme storms and flooding. This is predicted to cause the greatest mass migration in human history.

In the face of this stark future, it is imperative that the Province of Ontario put in place measures to achieve the targets set out in Ontario’s 5-year Climate Change Action (2016-2020), to achieve reductions from 1990 emission levels of 15% by 2020, 37% in 2030 and 80% in 2050. In the absence of a market mechanism like Cap and Trade, there are few options available to the Ontario Government other than direct regulation of Ontario’s largest GHG emitters.

Provincial policy in support of local climate action

Section 4(1) requires that the Province of Ontario develop a Climate Change Plan. This plan should include both measures to achieve GHG reduction targets (see above), as well as adaptation measures to address the impacts of extreme weather caused by climate change.

The Province can support local climate action through provincial policy and investments. These could include:
• Developing more detailed land use policy that support climate mitigation and resiliency at the local level;
• Supporting transit projects and transportation policy that reduce dependence on single occupancy car travel.
• Changes to the Ontario Building Code that would drive improvements in construction standards to ensure more energy efficient buildings and more effective stormwater management.
• A review of the MECP’s draft Low Impact Development and Stormwater Guide based on a more sophisticated and strategic assessment of the use of green infrastructure to support infiltration and reduce flooding.
• Streamlining of approvals for vital infrastructure to support transit and improve environmental services infrastructure.

RPWCO stands ready to assist the Government in preparing these climate-ready policies that will both reduce GHGs and help build more climate-resilient cities.

Input from Municipalities

Section 4(2) provides authority to create an advisory panel to help shape the Province’s Climate Plan.

Beyond the input of the advisory panel, the Province needs to commit to broad engagement of Ontarians, including residents, businesses and community leaders. These stakeholders will be the driving force behind any Climate Action Plan. The Province must seek their input and buy-in into its Climate Plan.

The input of municipal staff and elected officials is particularly important in this process. As noted above, municipalities account for 70% of GHG emissions, and are the key to meeting GHG reduction targets.

RPWCO recommends that a committee dedicated to municipal mitigation and adaptation be created to inform the development of the Provincial Climate Plan.

Thank you once again for the opportunity to comment on the Cap and Trade Cancellation Act.

Sincerely,

Fred Jahn
Chair, RPWCO
Commissioner of Engineering and Public Works, District of Muskoka