Ontario’s climate change strategy released this week represents by far the most ambitious effort so far to lay out a strategy for achieving the province's greenhouse gas emission reduction targets. The strategy, as suggested by environment and climate change minister Glen Murray, is long on financial carrots, and short on economic and regulatory sticks.

The strategy is strongest with respect to buildings, which account for approximately 17 per cent of the province’s GHG emissions, and are projected to be an ongoing source of growth in emissions without significant interventions. The expansion of the use of electric cars also emerges as a major theme, with commitments to subsidize purchases of electric vehicles, develop of charging infrastructure, and provide free overnight charging.

Other elements of the plan, where strong commitments are needed to achieve significant reductions in GHG emissions, are disappointingly vague.  The linkages between land-use planning and transportation, for example, are only very weakly developed.  This is despite the fact that changes in land-use patterns will be critical to achieving modal shifts in transportation towards transit and cycling. The gaps here are particularly noteworthy given that transportation has accounted for the bulk of the increases in the province’s GHG emissions over the past two decades. Moreover, recent the Planning for Prosperity report from the well-respected Netpis Foundation highlights a serious misalignment between where the province is making transit investments and where growth in employment is actually happening in the greater golden horseshoe. The implications is that the province's current portfolio of transit investments may not produce the hoped-for reductions in automobile travel.

In other places there are important commitments to incorporate climate change considerations into the province’s environmental assessment process, promote low carbon fuels, like compressed natural gas, for road freight (i.e. truck) transport – another area of major growth in GHG emissions – and to promote community energy planning and mapping. There are also references to the development of low-carbon natural gas supplies, although the theme is not fully developed.

Significant attention is given to the challenges faced by low-income communities and first nations and indigenous people in terms of the impacts climate change and the need to reduce GHG emissions. At the same time, other important themes, like the role of the province’s forests in carbon management, are left vague and undefined.

The plan suffers from some significant gaps and weaknesses as well. The strong focus on renewable transportation fuels, particularly if they turn out to be corn-based ethanol, could be counterproductive, resulting in greater GHG emissions on a lifecycle basis than conventional fossil fuels.

The risks associated with the province’s scheme to refurbish the aging nuclear reactors at the Darlington and Bruce nuclear facilities are ignored. Even if these refurbishments go according to plan – an unlikely outcome in light of past experience – there will be major increases in the use of natural gas for electricity generation while reactors are off-line for repair. The increased use of natural gas could negate a significant portion of the GHG emission reductions gained through the coal-phase-out. The plan offers no discussion of the development of other low-carbon energy sources, such as low-impact renewables, or hydroelectricity imports from Quebec.

A further key weakness underlies the one real stick in the entire strategy. As it stands the province has adopted a relatively weak approach to pricing carbon. While the cap and trade system seems to have the potential to be able to generate significant revenues to support the implementation of the climate change strategy, the carbon price generated by the system – likely in the neighbourhood of $18/tonne – will be inadequate to produce significant changes in corporate or individual behaviour. The granting of free allocations to large industrial GHG emitters during the initial phase of the cap and trade system further weakens its potential effectiveness as an emission reduction tool beyond revenue generation.

As it stands the action plan represents an impressive series of initial commitments in the direction of climate change mitigation, but is unlikely to enable the province to be able to meet its GHG emission targets. Further measures, particularly in terms of the establishment of a more meaningful price on carbon, strengthening the linkages between transportation, land-use and GHG emission reductions, and the development of more sustainable and resilient low-carbon energy systems will be required.