Finding a Vision for Change: Conclusions
| In December 2009, the ECO released its second annual review of the progress made by the Ontario government in achieving its GHG emission reduction targets. Click here for more information on this report, including videos and communications materials. | ||||
It is the ECO’s function to review and evaluate the progress the Ontario government is making in achieving its GHG emission reduction targets. This role includes giving credit where credit is due, but it also involves pointing out areas the ECO believes need to be improved.
The CCS staff are messengers and co-ordinators in this process and are performing their role well. The ECO is impressed with their considerable efforts over the past year to develop realistic and defendable metrics and to provide co-ordination across the various ministries and agencies whose actions, policies and programs will determine the success or failure of the Ontario government in achieving the GHG emission reduction targets set out in the Action Plan.
Of particular note in the CCAP Annual Report are the efforts in the OPS to reduce GHG emissions from operations and activities within OPS’ control. The OPS Green Transformation Strategy is pursuing a commendable target to reduce the government’s carbon footprint to 27 per cent below 2006 levels by 2020.
The CCAP Annual Report clearly recognizes, and the ECO agrees, that the process of meeting GHG emission reduction targets is a formidable task. The government acknowledges that the current suite of initiatives, even when implemented 100 per cent successfully, will not allow it to meet either its short-term 2014 or its medium-term 2020 GHG emission reduction targets.
The government is also transparent in identifying where and in what sectors it anticipates it will get its short-term GHG emission reductions. The ECO is pleased to see that the government has obtained third party assurance regarding the modelling of projected initiative impacts and that subsequent annual reports will include third-party verification of actual measured savings as they become available.
There are, however, many areas in which improvement is needed.
Clearly, in order to find a way to meet its targets, the government needs to identify and develop more tools for its GHG mitigation tool kit. Future annual reports must also explore scenarios wherein the implementation of key initiatives occurs at adoption rates that are less than 100 per cent successful because success cannot depend on the rosiest scenario.
The ECO has other major reservations, particularly regarding the efficacy of several of the existing initiatives. For example, we see some short-term risk (to 2014) associated with a GHG mitigation plan that places an inordinate amount of faith in the execution of one key initiative – the phase-out of coal use at OPG’s four remaining coal-fired plants. The government as much as agrees with this concern as the CCAP Annual Report provides a discussion of risk management and the potential impacts on emission forecasts due to such ‘external factors’ as demand for peak electricity, presumably leading to either delays in the phase-out of coal or some unseen imperative that requires the re-starting of idle units after 2014.
Similarly, we see considerable medium-term risk (to 2020) associated with the government’s positioning on the potential GHG reductions in the economy that may be delivered by a cap-and-trade system. The ECO has noted above its concerns regarding the risks inherent in a process where Ontario becomes a ‘policy taker’ if many of the key cap-and-trade policy decisions are made in other jurisdictions. The CCAP Annual Report is particularly lacking in clarity relating to the process of Action Plan governance. The process of how decisions are made, and by whom, must be clearly articulated not just to the ECO but to the broader public and other stakeholders who will read the CCAP Annual Report and make decisions based on this reading.
Now that the Premier’s Expert Panel on Climate Change Adaptation has released its report, the ECO will expect to see clarity on how mitigation and adaptation strategies are co-ordinated and reported within the government’s broader climate change planning mandate. The roles, responsibilities and accountabilities of the various government ministries and agencies as well as private sector stakeholders must be more clearly articulated in future annual reports. While the CCS and MOE may be the co-ordinators of Action Plan information, tracking and reporting, they are not the keepers of the policy levers that can minimize risks of competition for funding or delays in approvals or implementation.
The ECO agrees with the Climate Change Secretariat’s description of the implementation of Ontario’s Climate Change Action Plan as an iterative journey. We remain hopeful that the areas in need of improvement noted in this review will lead to an improved plan and a clearer vision for change going forward.
Citing This Article:
Environmental Commissioner of Ontario. 2009. Annual Greenhouse Gas Progress Report 2008/2009: Finding a Vision for Change. Toronto, ON : Environmental Commissioner of Ontario. pp. 30-31
