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The Ontario Climate Change Plan: An Assessment

December 3, 2018

The Ford government in Ontario released its climate change plan, on November 29. The plan is intended to replace the cap and trade system and climate change action plan of the previous Liberal government. Ideally, from the perspective of the Ford government, it will be enough to avoid the imposition of the federal backstop carbon pricing system in Ontario under the auspices of the December 2016 Pan-Canadian Framework on Clean Growth and Climate Change and the June 2018 federal Greenhouse Gas Pricing Act. Hedging its bets, the Ford government has also continued its dubiously grounded legal challenge of the federal government’s constitutional authority to impose a federal carbon price on individual provinces.

On the good news front, the Ontario plan implies an explicit recognition of the significance of the climate change problem and of the need to deal with its impacts on the province. Considerable attention is paid within the plan to the need to adapt to climate change at the provincial and local levels.

At the same time, the government’s much touted commitment to a 30 per cent reduction the province’s GHG emissions relative to 2005 by 2030 actually represents a significant rolling back of the province's targets relative to those set in the Liberal's 2016 Climate Change Mitigation and Low-Carbon Economy Act. The Liberal legislation committed to a 37% reduction by 2030 relative to a 1990 baseline. The Conservatives are effectively moving the goalposts at both ends, as the province’s 2005 emissions were approximately 25 MT C02e higher than in 1990. The net result, according to the province’s Environmental Commissioner, is a plan roughly one third as ambitious as that put forward by the previous government in terms of the greenhouse gas emissions reductions it seeks to achieve.

The centrepiece of the plan, a proposed regulatory framework for industrial emitters, is riddled with loopholes even at this preliminary stage, including references to “across the board” exemptions. The widely advertised carbon trust for technological innovation seems to be a $400 million one-time only expenditure of the remaining cap and trade revenues, including a very modest $50 million auction for low-carbon transition options. The one time fund falls hundreds of millions short of the amounts that were being generated each year by the cap and trade system. Absent either a meaningful regulatory framework or a carbon price, the trust fund provides little or no incentive for the adoption of whatever new technologies its existence might prompt. It also turns the polluter pays principle on its head, and suggests that taxpayers should pay polluters to reduce their emissions.

At a more micro level there are a number of very interesting and surprisingly progressive provisions in the plan, although most have been carried over from the previous Liberal climate change action plan. In a few cases the language is clearer and more substantive than under the Liberals. Examples of such provisions include references to changing land-use planning rules to take into account climate change considerations, the development of municipal energy and climate change plans, and commitments to take climate change into consideration in government decision-making. There is also a strong emphasis on energy efficiency and conservation. This includes a very large contribution from natural gas conservation programs, although the province is committed to expanding the natural gas distribution network, with the implication of increasing natural gas consumption, at the same time.

There are also some very questionable elements in the plan, like the commitment to increase the ethanol content of fuels. That provision doesn't seem to consider the high carbon footprint of corn-based ethanol. The positive climate change impacts of uploading responsibility for the planning and construction of the Toronto subway system, which is also included in the plan, seems equally doubtful.

On the whole, it is difficult to see how the measures contained in the plan can credibly meet even the greatly reduced emission reductions targets the government is claiming they will achieve. There are no links to modelling or other substantiation to support the claimed reductions. With the government’s parallel curtailment of the autonomy and climate change reporting mandate of the Environmental Commissioner of Ontario, it will be more difficult than ever to obtain a clear picture of the effectiveness of the Ford government’s plans. That may have been the government’s the goal all along.

Federal environment minister Catherine McKenna was quick to reject the Ontario plan as not meeting the requirements of the Pan-Canadian Framework on Climate Change. The federal government seems poised to continue with the implementation its own carbon pricing system in Ontario. The ultimate fate of that initiative, save for a dramatic change in direction by the Ford government, now rests with the courts. In the meantime, the Intergovernmental Panel on Climate Change and the United Nations Environment Program have continued to highlight the urgency of meaningful action if the planet is to avoid catastrophic climate change.