Pollution Probe is pleased…

Pollution Probe is pleased to have the opportunity to comment on Bill 4, Cap and Trade Cancellation Act 2018. Our comments will be restricted to the requirement that the Minister prepare a climate change plan for Ontario. We would encourage the Ontario government to maintain a commitment to GHG reduction targets that will contribute to the Paris Agreement..

We are pleased that the government understands that climate change is a global concern and that Ontario must do its part. We also understand the governments commitment to ensure that policy is affordable, ensures competitiveness, is balanced and delivers results.

For these reasons, Pollution Probe recommends that, as part of its climate change plan, the Government of Ontario:

• Develop a transportation strategy which will and improve air quality and reduce greenhouse gas emissions from the largest polluting sector in the province.
o Transportation is responsible for the largest and fastest growing share of Ontario’s greenhouse gas emissions. These emissions have grown by 28 per cent since 1990 and totalled 58.7 Mt in 2014. Over 80 per cent of these emissions come from on-road passenger and freight vehicles such as cars and trucks.
o Ontario’s climate plan should include options to address emissions from passenger cars and trucks, as freight trucks are the fastest growing vehicle segment in terms of both air pollutants and GHG emissions.
o Pollution Probe supports the Government of Ontario’s recent announcement to tackle heavy duty vehicle (HDV) emissions as part of the redesign of the Province’s Drive Clean Program. This action which will target the on-road freight transportation sector is urgently needed given its major and growing role in contributing to climate change and air pollution.
o In addition, we would encourage the Ontario Government to:
 Develop programs incentivizing the retirement of older, heavily polluting vehicles.
 Partner with the automotive industry to accelerate the deployment of electric and hydrogen vehicles to deliver cleaner air, reduced greenhouse gas emissions and secure the economic benefits of these new technologies. A Canadian automotive manufacturer recently started production in Windsor of its plug-in electric hybrid vehicle, and there is an opportunity to encourage increased production of electric vehicles in Ontario.

• Develop programs that enable innovative, clean energy technologies to compete in Ontario’s electricity system.
o Ontario has made great strides in reducing greenhouse gas emissions from electricity generation. Maintaining that low-emissions profile has had significant benefits for both climate change mitigation and clean air. A variety of innovative private sector clean energy solutions exist that could ensure that Ontario’s electricity systems retains its low emissions profile following the closure of the Pickering Nuclear Generation Station. In addition, innovative energy solutions can reduce costs to electricity customers through avoiding expensive energy grid investments.

• Explore opportunities to increase carbon sinks in the province through enhanced forest carbon management.
o Some estimates indicate that up to 15% of Canada’s commitment to reduce GHG emissions can be met through the inclusion of existing forest management (FM) and agricultural soils sinks in its accounting. Afforestation, reforestation, the reduction of deforestation and enhanced forest management may provide further contributions.
o Creating or enhancing forest sinks also contributes to the achievement of other environmental, social and economic objectives that are not related to climate change. Depending on the type of forest sink, they can further existing efforts related to wildlife habitat conservation, endangered species recovery, soil and water conservation, and the provision of recreational and economic opportunities.
o Forest sinks also provide a transitional strategy for GHG emitters.

• Help Ontarians to adapt to a changing climate by supporting research and analysis (including predictive analytics) to help municipalities, businesses and homeowners prepare for and deal with extreme weather and its environmental impacts.
o This research and analysis should address risks in key areas such as:
 Critical infrastructure
 Water security,
 Energy security, and
 Food security.

The four suggestions we offer for consideration, to be part of a climate change plan, are based on a substantial body of work that Pollution Probe has developed over many years. We hope you find our suggestions helpful. We remain committed to working with Ontario Government to advance the environment, economic and social well-being of our province.

Yours truly,
Pollution Probe