October 11, 2018 Cap and…

October 11, 2018

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

To whom it may concern,

RE: Comments on (EBR # 013-3738)

Thank you for the opportunity to comment on the Cancellation of the Cap and Trade Act Regulatory Proposal, EBR# 013-3738. The City looks forward to working with the Ministry on the revised provincial climate change plan.

Comments from City of Guelph
The City of Guelph is seeking innovative approaches to renewing key infrastructure that supports smart growth, the economy and the environmental prosperity of our community. For the City, the Cap and Trade program enabled a number of funding programs and incentives that make implementing energy efficient technology more cost effective, while also taking steps to lessen our negative impact on the environment. Without access to additional funding sources, the City may not realize these goals due to the significant upfront costs of implementation.

Summary of Projects Impacted by Cap and Trade Cancellation

As a result of the termination of the Cap and Trade program, there are a number of funding programs and rebates that have been or are at risk of cancellation. The City respectfully asks the Province to consider comparable funding programs and incentives when developing the new provincial climate change plan.

1. Municipal GHG Challenge Fund
Under this fund the City had received a commitment of $315,000 to support the development of a waste water treatment digester gas storage unit. As per the initial study for the application, approximately 259,000 kg CO2e/yr of GHG emissions are to be reduced through this project. This represents approximately $40,000 annual savings in natural gas cost savings for the City.

The City has already received $15,000 under the grant, however, the remaining $300,000 in funding for the program has been cancelled, resulting in the indefinite hold of this project unless additional funding can be acquired. There are also a number of other projects the City had proposed for funding under this program including wastewater treatment plant upgrades that is no longer eligible for funding due to the cancellation of the program.

Total Funding Forgone: $300,000

2. Electric and Hydrogen Vehicle Incentive Program
Incentives provided under Cap and Trade provided funding to purchase electric vehicles. Electric vehicles are 3-5 times more energy efficient than internal combustion engine vehicles, reduce air pollution and require fewer ongoing operating expenditures, saving the City money over the life of the vehicle.

The City has cancelled the purchase of four electric vehicles that were to replace vehicles in the existing City fleet. These vehicles were eligible for a rebate from the Electric and Hydrogen Vehicle Incentive Program (EHVIP) from the Ministry of Transportation. The rebate was $14,000 per vehicle ($56,000 for four vehicles).

Total Funding Forgone: $56,000

3. Ontario Municipal Commuter Cycling Program
To realize the vision for the City of Guelph’s Cycling Master Plan, Active Transportation Network and Official Plan, the Ontario Municipal Commuter Cycling Program was accessed to fund a major infrastructure project extending cycling paths in a key transportation corridor. The City received $1.19 million to use by December 31, 2020. Although the City has secured the first round of funding, eliminating future funding represents a significant impact to the construction of future active transportation systems.

Other programs including SaveONenergy and the Union Gas Commercial and Industrial Energy Efficiency Incentives that provide financial relief to the City for energy projects have also been cancelled. Without access to additional funding, many of the City’s energy efficiency projects will be unable move forward in the immediate term. Progress on these types of projects would take many years without external funding, as financing results in additional tax burden on developers and residents for municipalities to bear these costs alone. External funding for energy efficient technologies allows the city to redistribute existing budgeted dollars to local infrastructure and service development.

In addition to the funding received from Cap and Trade revenue, the cancellation of the program has resulted in uncertainty surrounding the release of green infrastructure funds under the Federal government’s Investing in Canada Infrastructure Plan. Forgone funding would put significant financial pressure on the City of Guelph, negatively impacting both residents and businesses.

Request for consideration:

• To provide funding opportunities through the Province’s new climate change plan to ensure programs that address the effects of climate change and reduce costs to municipalities can proceed; and
• Work collaboratively with federal partners to ensure the completion of a climate change plan supporting the timely distribution of infrastructure funding under Phase 2 of the Investing in Canada Infrastructure Plan.

Thank you again for the opportunity to comment on this regulatory proposal. As previously identified, we look forward to an opportunity to engage with your government on the development of your new climate change plan.

Please do not hesitate to contact me if you have any questions regarding the City of Guelph’s feedback.

Sincerely,

City of Guelph