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Ontario Climate Change Plan – A Preliminary Analysis

November 29, 2018

The Ford government in Ontario released its climate change plan, intended to replace the cap and trade system and climate change action plan of the previous government today.

At the macro level there is a fairly explicit recognition of the significance of the climate change problem and the need to deal with its impact, with considerable attention paid to adaptation issues. At the same time there is a significant rolling back of the province's targets relative to those set in the Liberal's 2016 legislation, and the proposed regulatory framework for industrial emitters is riddled with loopholes even at this stage. The carbon trust is particularly disappointing, and the widely discussed carbon reduction auction is very modest ($50 million). There seems to be no plan for how the trust or auction will be sustained in the long term or if they are one time expenditures.

At a more micro level there are a number of very interesting and surprisingly progressive provisions in the plan, many of the carried over from the Liberal plan, but in some cases with some clearer and more substantive direction than under the liberals. Examples 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 are also some very questionable elements, like the commitment to ethanol content of fuels, which doesn't seem to consider the high carbon footprint of corn-based ethanol.

That said, it is difficult to see how these measures credibly amount to even the reduce emission reductions the government is claiming they will achieve. There are no links to modelling or other substantiation to support the claimed reductions.

Specific Observations:

Impacts and Adaptation

  • Undertake provincial impact assessment and vulnerability assessment of key sectors
  • Improve public and community understanding of CC impacts
  • Modernize building code to deal with extreme weather events; potential tax incentives for homeowners to improve resilience to extreme weather
  • Review provincial land use planning policies to update policy direction on climate resilience
  • Strengthen climate resilience of critical infrastructure, winter roads, agriculture and food sector.



  • Targets
    • Ontario will reduce emissions by 30% relative to 2005 by 2030
      • (This is a substantial reduction relative to the target contained in the Climate Change Mitigation and Low-Carbon Economy Act of a 37% reduction relative to 1990 levels by 2030) – 2005 emissions are approximately 25MT higher than 1990.


  • Key elements
    • Low carbon vehicles
      • References to EV adoption and CNG for freight


  • Industry performance standards on GHG emissions
    • To consider trade exposure, competitiveness, process emissions and to allow for “across the board” exemptions for industries of particular concern
    • May allow offsets or payments to achieve compliance
    • No references to specific targets/standards/sectors


  • Clean fuels (15% ethanol content by 2025)
    • (No discussion of life-cycle carbon impacts of corn-based ethanol)


  • Reference contributions from Federal Clean Fuel standard


  • Energy Conservation
    • Improve data access (Reference to Green Button)
    • Encourage voluntary disclosure of building energy performance in real estate listings
    • Review building code to support energy efficiency
    • Work with OEB to increase Natural Gas Conservation
      • This seems to play a very large role in achievement of overall emissions reductions.
      • Also includes voluntary RNG option for customers
    • Ensure energy efficiency standards for appliances and equipment continue to be among highest in North America
    • Encourage heat pumps and district energy systems
    • Consult on tax measures to encourage EE retrofits
    • Streamline approvals for low carbon technologies
      • Specific references low-carbon fueling infrastructure for EVs, hydrogen, propane, autonomous vehicles, CGN refuelling infrastructure on 400-series highways for transport trucks.
    • Support smart grids and distributed energy resources, including energy storage.
    • Guidance for reduced energy use in heritage public buildings


  • Ontario Carbon Trust
    • $350 million for clean technologies
    • $50 reverse auction for GHG emission reductions.
    • Want $420 million contribution from federal Low Carbon Economy Leadership Fund


  • Government leadership
    • Improve ability to consider climate change in government decision-making
    • Consider CC in purchasing decisions
    • Enhance coordination and guidance to municipalities (and school boards) to help them consider climate change in decision-making
    • Update EBR SEVs
    • Improvements in building operations, new facilities built to LEED standards, review office space utilization
    • Support Ontario clean tech market access in conjunction with federal government.


  • Work with local governments
    • Work with municipalities to develop climate and energy plans to support climate resilience and transformations to the low-carbon future
    • Support climate action in indigenous communities, including community power


  • Other measures
    • Work with financial sector to promote climate related disclosures
    • Encourage OSC to improve guidance on climate related disclosures.
    • ACCA for clean energy and energy conservation investments.
    • Electric ferries for Wolfe and Amherst islands.
    • TTC subway upload
    • Public education on impact of transportation choices.