Comment
I am outraged at the planned cancellation of the Cap and Trade System. At the same time while recognizing that Climate change and Global Warming is real, the government wants to cancel a multi provincial and state system, which has been effective in delivering climate mitigation projects, while having no alternative plan developed.
My understanding of the government's rationale for change is that it costs too much, and that there is a better way. As outlined below the Cap and Trade system has benefits which reduce current costs (energy eff.) and future costs(electricity market). Please describe the better plan which is intended to replace the current Cap and trade system. Why is the government cancelling the current plan without another developed?
There is a cost for climate ignorance that is a real cost, the do nothing or wait and see approach that will happen with cancelling Cap and Trade does nothing to protect our air, water and environment for future generations. They will have to spend far more than we will "save".
We have an enormously large residential, commercial and institutional building stock that was constructed in the 1960's and 70's which is extremely inefficient, the Cap and Trade program was providing funding and incentives to reduce costs for those who live and work in them while reducing the pollution generated to keep them warm or cool.
There are 3 or 4 million cars driving everyday in Ontario and there is a substantial oversupply of electricity generation in the province. Does the government consider this when removing electric vehicle incentives that would support infrastructure, remove barriers to adoption, and increase electrical use during nighttime lows when it is typically exported out of the province for a loss? Please explain which creates more GHG pollution, gasoline or electric cars? Why are we not going to incentivize them until the are cost competitive as well as supporting increased electrical use (which the province needs)?
My issues are summarized as the following:
1. No consideration for federal legislation overlap - The Ontario government is planning to remove this legislation with no regard or consideration for the impacts that will follow from the Federal Backstop system. In almost every case, the costs of cancelling Ontario's system will result in a more expensive system - How does this reduce costs for the taxpayer? It merely changes the jurisdiction recovering the costs. Why is the government considering cancelling legislation that will only result in another federal legislation coming into effect?
2. Effective and Competitive Funding Process - The funds from the Cap and Trade system are used to accelerate innovative and clean technologies to the market. Green On encouraged the purchase of triple glazed windows, which with increased production ratio's to double glazed would help that product become market competitive, the same with EV incentives and so on. Funding programs for large companies and institutions were funded via revenues but selected based on GHG reductions per dollar invested. How will the government continue to support this economic growth and technology development without these funding streams? How will the government develop competitive funding programs to support the reduction of pollution of GHG's?
3. Cap and Trade Supported reduced Electricity costs - The majority of the cost issues with electricity in Ontario stem from an increased supply of generation capacity, clean generation capacity, conservation and lower than projected consumer and industrial demand. In short we have a lot of generation (supply) and not enough use (demand) and since it is a regulated industry, the fixed costs of the supply are not being shared by enough users or kWh. Much of the Cap and Trade funding was being used to transition to, or support, the use of more electricity in the province. For example, the lowest revenue times for the electricity grid (we are giving it away) is at night from 11 PM to 6 AM - the exact time when electric vehicles would be charging. The Cap and trade system, by encouraging more use of electricity, would lower costs for all Ontarian's, while reducing immensely the pollution from transportation. Not to mention the cost of electricity for a car is 1/10th the cost of gas. If the goal of this policy change is to reduce costs for the residents of Ontario, cancelling Cap and trade will remove legislation that was cleaning the air we breath and improving the balance of supply and demand of the electricity grid. How will the government encourage the use of more electricity in the province to support lower costs for all?
4. Capital Market Based System - The Cap and Trade system is not a tax, ( although it was portrayed as such by the campaigning parties) it is a market based system which provides a competitive platform for companies, business, institutions etc to purchase allowances while slowing increasing the rate at which large businesses had to reduce fossil fuel use. Removing the Cap and Trade system removes a cost effective. With nothing planned and no indications for an alternative source of funding to replace the system, how does the cancellation of Cap and Trade create a cost effective approach to reducing global warming?
5. Removing a functioning system with no transition plan - The cancellation of the Cap and Trade system comes with no actual plan to replace it. Why is the government, which states it will have another, better plan, cancelling the first plan before having another setup to take it's place? The government has been clear in stating it does recognize that climate change is real and needs action. If so, why cancel a functioning program with a delay between it and the time at which a new one can be created rather than keeping the existing in place until the time that it can transition with no lapse?
6. Publish the results of the previous Cap and Trade Program and compare to new program/plan - Will the government produce a report outlining the results in terms of GHG reduction achieved with the current system? Will this information be used to evaluate against any new proposed plans?
Submitted October 11, 2018 8:43 PM
Comment on
Bill 4, Cap and Trade Cancellation Act, 2018
ERO number
013-3738
Comment ID
10590
Commenting on behalf of
Comment status