I’d like to thank the MECP…

I’d like to thank the MECP for the opportunity to provide feedback on the proposed Bill 4.

Certainly the Cap and Trade Program had problems and short-comings, but without a solid, strategic plan to replace the Climate Change Mitigation and Low-carbon Economy Act, we have nothing.

Regarding “Targets”, as stated on Bill 4: There is no reference to what reductions should the targets aligned to (the Paris Accord?, Canada’s, etc.). A target with no overarching alignment can quickly fail to achieve its purpose. In addition, there’s no reference to those targets having to adhere to science-based findings and be based on robust financial and economic modelling.

Regarding “Climate change plan”, the single sentence presented on section 4(1) of the Bill fails to identify the following crucial aspects of any plan:
1. Timeframe: When will the plan be prepared and ready? How many years will the scope of the plan cover? The difference between a 4-year plan and a 20-year one are massive and would significantly alter its content and approach;
2. Link to targets: The climate action plan is not linked to reflect the targets set under section 3(1);
3. Objectives: There are no minimum provisions as to the scope of the plan, leaving in the air what objective(s) the plan is supposed to fulfil. Is it meant to be for climate change mitigation? Or will the plan tackle climate change adaptation? Perhaps both? Or just for emissions reduction? Will it include scope 1, 2 and 3 carbon emissions or just scope 1? Is it meant to cover all sectors?... My point with these questions is that there are no objectives established to set a framework for what the climate action plan is supposed to do.
4. Performance indicators: How and when will the success of the plan be evaluated? As the old adagio says, we can’t control what we don’t measure.

I think a major component that has been overlooked in the past is the importance of education. And it's still been missed on this Bill again:
a) Including sustainability and climate change (perhaps in the form of efficiency and conservation) in all curriculums (from FDK to higher-ed) would set the basis for our children to make informed decisions on a topic that will significantly affect their lives when they’re older;
b) Improve communications with Ontarians, where there’s currently a gap in understanding the effects of climate change and how we can all take action.

I’m sure you’re aware of the increased incidence of flooding, droughts, forest fires, and other extreme weather. While carbon pricing doesn’t have a direct link to mitigating or preventing any of those events, it does have a part to play in curbing Ontario’s emissions. When looking at the World Bank forecasts of the assets that will be exposed to increased flooding alone by 2050 (close to $150 Trillion USD) it makes sense to invest and plan now to mitigate those risks.