Address available on demand …

Address available on demand (registered on ero web system)

18th September, 2018

Ministry of the Environment and Climate Change
c/o Environmental Registry of Ontario
https://ero.ontario.ca/

To whom it may concern,

Re. Bill 4, Cap and Trade Cancellation Act, 2018; ERO number 013-3738

As a resident of Ontario, I would like to provide comments on Bill 4, the draft Cap and Trade Cancellation Act, 2018. I do not support the proposed retirement and cancellation of Cap and Trade. I have provided my specific comments below in relation to the four principal matters intended to be addressed by the proposed cancellation act:

1. The retirement and cancellation of cap and trade instruments

Irrespective of whether one accepts that climate change is being caused by human activity, the risks of not taking action to reduce carbon emissions would seem far to outweigh the uncertainties. In all likelihood, those demanding firm evidence of human-caused climate change may only be satisfied with the level of evidence when it is too late to do anything about it. Given the risks to our future population, our environment, and the dependent economy, it is essential that the government take meaningful action now. Cancelling any established and accepted carbon reduction program would work against this. However, maintaining the recently established Cap and Trade program should be seen as a positive, objective approach by the government. In particular, such an important aspect for the future should not be seen as an ideological, political factor that represents one political stripe or another. The risks themselves are clearly apolitical and transcend any one party ideology.

For those who may have the view that climate change is NOT being caused by human activity, there would still be significant benefits from reducing carbon emissions, and maintaining the Cap and Trade program. These include cleaner air and reduced pollution (e.g., based on other, earlier carbon reduction initiatives, we no longer have the awful and dangerous smogs of the recent past in eastern Ontario), associated reductions of poor health and related health care costs, and an enhanced public image of a pristine Ontario (which may, among other things, result in increased tourism with economic benefits).

On economic considerations, other jurisdictions have reported not suffering economic decline as a result of implementing carbon restrictions such as Cap and Trade. These include the province of British Columbia, the U.S. state of California, and the United Kingdom. Indeed, there are several Canadian and Ontario companies already active in innovative technological work that could thrive and grow under programs such as Cap and Trade, and result in direct and spinoff economic growth.

Retiring and cancelling the cap and trade instruments would represent an unnecessarily costly action given that the system has already been established (therefore, costs foregone), the private sector has already accepted and invested in this approach (significant related economic activity that has been stimulated would now be stifled; Ontario would face the prospect of legal costs and providing compensation for companies that have engaged in the existing program). Cancelling it would also result in uncertainty for the private sector which would hinder or cancel related investment plans and decisions. Meaningful investment by the private sector relies on a stable and/or predictable policy approach, spanning more than one electoral cycle. In addition, during the period while alternatives were being considered, retirement and cancellation would result in unrestricted carbon emissions, potentially to the detriment of the environment and our future.

Finally, I would like to add that the Cap and Trade program represents an approach to limiting carbon emissions that seems to be neutral-to-positive in terms of public acceptance and so there would seem to be no political advantage to be gained from its cancellation; rather the reverse. Indeed, maintaining Cap and Trade and introducing other carbon-restrictions would demonstrate long-term leadership on the part of the government. Meaningful and sustained carbon restrictions cannot be achieved by rapid changes to programs based on the comparatively short term political cycles and electoral terms. Instead, a long term view, encompassing decades, is needed, and maintaining the Cap and Trade program should remain part of such a long term view.

2. The payment by the Crown of compensation in respect of cap and trade instruments, the amount of which is to be determined in accordance with the regulations.

As a resident and taxpayer of Ontario, I object to the proposal to cancel Cap and Trade as it would result in otherwise unnecessary compensation payments and associated administrative costs. The most appropriate use of public funds and taxpayers’ money would be to maintain the recently established system.

3.Preventing any cause of action from arising against the Crown and specified related persons as a result of various specified matters, including the enactment of the Act and the repeal of the Climate Change Mitigation and Low-carbon Economy Act, 2016.

I presume that this refers to legal defence and therefore costs associated with this could be very significant. As above, incurring these potential actions arising against the crown is unnecessary as it can be avoided by maintaining the established system.

4.The extinguishment of any existing proceedings, and the prevention of any future proceedings, against the Crown and other specified related persons, in relation to specified matters.

I also presume that this refers to legal defence and therefore costs associated with this could be very significant. As above, incurring these potential actions arising against the crown is unnecessary as it can be avoided by maintaining the established system.

Please do not cancel the Cap and Trade program as it is a key part of addressing the uncertain risks from climate change and significant investments and public funds have supported its establishment. To cancel it now would represent a waste of public funds and private sector investments.

Thank you for the opportunity to comment.

Yours sincerely,

Name available on demand (registered on ero web system)