Attn: Elizabeth Elder…

Attn: Elizabeth Elder
Senior Policy Advisor
Ministry of Economic Development, Employment and Infrastructure
Infrastructure Policy Division
Policy and Planning Branch
900 Bay Street, Floor 5
Mowat Block
Toronto ON
M7A 1C2 
Phone: (647) 643-6832

Introduction

Clean Energy Canada is a pleased to submit comments on Building Better Lives: Ontario’s Long Term Infrastructure Plan (LTIP) to Ontario’s Ministry of Infrastructure.

Clean Energy Canada is a climate and clean energy think tank within the Morris J. Wosk Centre for Dialogue at Simon Fraser University. We work to accelerate our nation’s transition to clean and renewable energy systems by telling the story of the global shift to clean and low-carbon energy sources. We conduct original research, host dialogues and aim to inspire and inform policy leadership.

Clean Energy Canada applauds the leadership shown by the Government of Ontario in the LTIP. We support the plan’s overarching commitment to “fiscal responsibility; economic growth and productivity; innovation; social and community benefits; effective maintenance and asset management; and environmental sustainability,” and therefore wish to focus our comments on two specific sections:

2.1 Planning Based on Evidence

The LTIP’s commitment to Life Cycle Assessment will make Ontario a leader in both cost-effective infrastructure planning and climate action. We agree that the province’s infrastructure policies must ensure that the government receives value for money for all contracts. Currently, value for money is a major factor in the way governments select contracts, and that shouldn’t be abandoned.

Presently, value for money is assessed on initial costs, or volume per dollars spent: the greater the volume for the least amount of dollars spent, the better the deal. For example, the most desktop computers acquired for the least amount of money, or the most kilometers of road built for the least dollars invested. There is a need to update this approach.

In determining the concept of value, the government should consider the following:

•Climate change and the increasing frequency of extreme weather events creates negative impacts on infrastructure. Direct impacts from increasing numbers of freeze-thaw cycles, flooding and the intensity of storms can wreak havoc and cause costly damage to buildings, roads, bridges, and more. Even if the infrastructure does not fail, climate change can have indirect impacts on infrastructure, such as shifting our energy peak use, causing water shortages, and provoking sewer failures. According to 2011 estimates from the National Round Table on the Environment and the Economy, “The cost of inaction is greater than the cost of action: climate change could cost Canada $21-$43 billion per year by 2050”.

•Reducing GHG emissions requires a change in policy and purchasing. That is, buying goods and services that result in a reduction of carbon emissions. In a traditional volume-to-dollar assessment, the purchase of cleaner materials may erroneously appear to cost more, because a value calculation does not account for the savings the government receives over time, such as increased efficiency, reduced energy use and reduced GHG emissions. A rubric, such as Life Cycle Assessment, for metrics on these attributes should be included to guarantee the government is receiving true value for money.

Evaluating true value for money, including the impacts of climate change, over the life of a project is an opportunity for the government to make better decisions in how it spends its money. It is, in short, an opportunity to spend less.

2.3 Considering Climate Change

The Plan focuses on Life Cycle Assessment (LCA) as a tool for incorporating GHG mitigation and broader environmental impacts, and the imperative of building infrastructure resilient to our changing climate. These considerations must be measured over the “construction, operation, maintenance, retrofits and decommissioning” phases of infrastructure.

We support the proposed timeline for phasing in LCAs as a requirement for all proposed infrastructure projects by mid-2020, however feel this commitment needs to be strengthened:

1.All categories of infrastructure that receive public funding should be covered. Currently, municipal projects receiving provincial funds would appear to be outside the scope of the requirement.  The need to ensure these projects properly incorporate the principles of value for money and guarding against climate change are no less important in the case of these projects.

2.The minimum thresholds ($50 million for transportation expansion, $75 million for transportation rehabilitation, and $20 million for other sectors) should be significantly lower. Under these minimums it is unlikely that a major infrastructure investment, such as a highway interchange project, would fall below the transportation threshold. Using LCA for this type of project would ensure that the infrastructure is more resilient results in a lower carbon footprint over time. We would be open to supporting a $2 million threshold to trigger the LCA requirement, while smaller projects below $2 million could be offered a simpler, more template-based approach to fulfilling the obligation based on established best practices.  We would encourage the Province to commit to developing approaches for projects that fall below the “major project” threshold during the pilot phase of the Plan in 2018 to ensure all infrastructure is ultimately covered by the LCA requirement.

3.Achieving the objectives of this section of the LTIP is heavily dependent on the existence of a robust valuation of the broader social cost of carbon, and, most importantly, incorporating that cost into the bidding process. This will ensure that procurement decisions reflect the need to address climate change mitigation and adaptation and resiliency.  Ontario should set an explicit goal to base its procurement decisions on a robust social cost of carbon, in line with the Province’s 2030 and 2050 GHG reduction targets.  

4.While many LCA inventories and tools exist today, it is an evolving field and most effective when able to accommodate continuously improving data and analytics. The Province should encourage the ongoing improvement of LCA data sets and analytical tools to drive continuous improvement and ensure that LCA approaches to infrastructure stay current with cutting edge technologies and practices.  

Once again, we thank the Ontario government for the vision put forward in Building Better Lives, and look forward to continuing to work with you to support its full and effective implementation.

CONTACT

Sarah Petrevan
Senior Policy Advisor
sarah@cleanenergycanada.org
647-999-2992

[Original Comment ID: 212141]