Assessing the Transparency of the Process
| 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. | ||||
Contents |
6.1 Making the Numbers More Transparent
The ECO accepts that restating the BAU is necessary, and the CCAP Annual Report is transparent in presenting this in the context of the recent contraction in the economy. However, a plan that attributes achieving one-third of its 2014 GHG reduction target to an economic downturn and about one-half to one initiative (coal phase-out) cannot be considered ‘aggressive’. A plan that conservatively focuses on current best practice is no substitute for a plan with a vision of the future. This lack of vision is perhaps best illustrated in the report’s Figure 7, adapted and clarified below as our Figure 3.
Figure 3 more clearly demonstrates where CCAP Action Plan deficiencies lie. The sector discussions in Section 5 provide the details. Our revised figure makes it much clearer to the reader where the sector reductions are expected and, equally clearly, where they are not expected. Compared to the BAU bars in blue, no GHG emission reductions are forecasted in the industrial sector and, with the exception of the electricity sector, those forecasted in the transportation and building sectors are very modest.
6.2 Clarifying the Optics and Metrics
The CCAP Annual Report notes that while Ontario’s absolute emissions increased by 13 per cent between 1990 and 2007, emissions intensity (using either tonnes per capita or tonnes per dollar of real Gross Domestic Product) went down over the same period. The ECO believes that the introduction of emission intensity metrics, while illustrative of one kind of trend, may introduce unnecessary confusion. While such a trend may be commendable, the only true measure of success will be absolute reductions in GHG emissions and the ability of the government to drive the province’s GHG emissions towards (and ideally to exceed) the targets that have been set.
A second area of confusion is the manner in which the 2014 target is being reported and portrayed in Figure 6 of the CCAP Annual Report. Figure 6 would lead one to believe that the target year is 2015, rather than 2014. Let us be clear – the government’s original target was to reduce Ontario’s GHG emissions to 6 per cent below 1990 levels by 2014 and the government continues to state that 2014 is its target year. Claiming that the government has achieved 71 per cent of its 2014 target in one part of the CCAP Annual Report while showing in a figure elsewhere that this won’t be accomplished until 2015 is very misleading.
Common practice in GHG mitigation planning is to report total emissions on a full calendar year basis and to evaluate forecasted emissions and emission reductions in a similar manner. The ECO believes that this is also consistent with the public’s understanding of the issue. For example, emissions for the baseline year of 1990 represent the total amount of GHGs emitted in 1990 and the target for 2014 of 165 Mt represents the total amount which will be emitted in 2014 if the government’s target is met. The government is correctly reporting 1990 GHGs on a full calendar year basis as its baseline. It is confusing, therefore, that the government then changes, and uses an annualized emission rate as the metric for determining success in achieving future forecast targets, rather than a calendar year total. Ultimately, it is only through the future comparison of emissions actually released in 2014 to the amounts actually released in 1990 that the government will be in a position to determine whether the 6 per cent reduction target has been met.
Ontario Regulation 496/07 requires the phase-out of coal by the end of 2014. OPA’s coal plant retirement schedule indicates there will be about 3,290 MW of in-service coal capacity available in 2014 (and assumes an output of 15 terawatt hours (TWh) and a 52 per cent capacity factor). In the interests of clarity and preventing confusion, it would have been more transparent for the government to report that it will miss its 2014 target by an additional estimated 3 Mt (due to the contributions of coal-fired electricity in 2014), but then to provide a clear explanation of the impact and significance of the coal phase-out on GHG emissions post-2014 and towards the 2020 target.
6.3 Need for Other Metrics
In the CCAP Annual Report, projected reductions are provided for 14 key initiatives and are reported in megatonnes of carbon dioxide equivalent (Mt CO2eq). Given that the overriding goal of the Action Plan is to reduce GHG emissions, the ECO agrees that this is the most important metric that should be reported in any government progress report on climate change and, where feasible, should be utilized for as many initiatives as possible. Quantifiable emission reductions could be attached to some initiatives that currently are missing such information. For example, through the provision of capital funding to college and universities for energy efficient retrofits, or through the expansion of high occupancy vehicle lanes (two initiatives that are identified within the CCAP Annual Report), the government should be in a position to attach quantifiable emission reductions forecasts, or at least estimates, to such efforts.
The remaining 56 initiatives that are listed do not have any associated GHG tonnage, but according to the government were designed to be “enablers” in the transition to a lower-carbon, green economy. According to the CCAP Annual Report, the performance (or progress) of the 56 “enabling” initiatives is tracked through proxy measures, rather than through quantifiable emission reductions, and so no emissions reductions have been associated with these efforts. The ECO recognizes that for many initiatives tonnage reduction is not the most appropriate metric to determine progress. For example, the CCAP Annual Report includes several initiatives that are educational in nature and so measuring the GHG emission reductions of such initiatives would clearly not be the most useful metric.
Nevertheless, for initiatives that do not lend themselves to quantifiable GHG emission reductions, the ECO believes that it is fundamental for the purposes of transparency that the government provide progress reports on the development of other such proxy metrics wherever possible. Many of these ‘soft’ initiatives play a role in raising social and cultural awareness of climate change issues and serve a key role in moving towards a less-GHG intensive society and the “culture of conservation” envisaged by the GEGEA. By reporting on the nature of these proxy measures, and the annual progress that is made towards them, the government would demonstrate greater transparency with regard to the efficacy and progress towards its non-quantifiable GHG emission reduction goals. Ideally, this information should be presented in such a manner that the public, at a glance, is able to determine progress.
6.4 Assurance Regarding the Numbers
The ECO is pleased to see that the forecasted reductions from the 14 key initiatives have been validated in a transparent manner with an Assurance Statement by a third-party validation consultant. With suitable caveats regarding “the methods, data sources, and assumptions used to model GHG reductions for the 14 initiatives,” it was determined that the restated Business-As-Usual (BAU) forecast and the restated projections of contributions to GHG reductions from the Action Plan’s 14 key initiatives are a “fair representation” for forecasting purposes.
The one area the ECO does have a concern is with the CCAP Annual Report’s underlying assumption that all initiatives will be fully implemented, achieving 100 per cent of their potential. This is an inherent area of risk that was not analyzed by the validation consultant. The government should be providing GHG forecast scenarios depicting GHG reductions where adoption rates are less than 100 per cent successful (such as 25, 50 and 75 per cent successful). This would provide the government, the ECO and the public with a clearer assessment of the risk associated with penetration rates that are less than fully successful.
6.5 Governance Issues
In our Special Report last year, we asked for greater transparency in terms of how GHG emissions forecasting is done, what the projections are, when the milestones will be achieved and where progress is being made in achieving them. Implicit in this request is the need for transparency in the process which drives and enables these activities. We noted last year that “virtually all government ministries, agencies and related stakeholders will have a role to play in delivering on the [climate change action] plan’s initiatives.” This observation is quoted verbatim in the Minister of the Environment’s message in this year’s CCAP Annual Report where he indicates that the government is in “complete agreement.”
The public and other stakeholders, in addition to the ECO, need to understand the governance process that ensures the government will meet the Action Plan’s targets. To hold the government accountable, this process must be articulated in the government’s annual reports in a clear and transparent way. The ECO asked in our Special Report that a ‘process map’ be provided in this year’s CCAP Annual Report clearly indicating the roles and responsibilities of key ministries and agencies participating in the design and implementation of the Action Plan. The ECO is disappointed that this schematic was not provided. The ECO and the public need to understand who in the government has the responsibility, authority and – equally important – the accountability for meeting the Action Plan’s reduction targets.
The CCAP Annual Report refers to the government’s use of a standardized process for collecting, analyzing and reporting information on the performance of individual initiatives. The CCS shared with the ECO an early version of a template “[l]ike the dashboard of a car” and the ECO strongly supports the use of such a template. We particularly support a template that can incorporate milestone timelines by year (and disaggregated by each quarter) out to 2014 and beyond. The ECO agrees with the CCAP Annual Report that this method of tracking is a key component in the government’s management of risk associated with its Action Plan.
The ECO still has major concerns about the lack of transparency in the Action Plan process. While MOE and the CCS are the designated ‘champions’ of the Action Plan, they have no real power or ability to nominate key expenditures that will deliver on the plan, or to block those expenditures that may compromise it. In fact, the CCS has no real regulatory powers of its own. While its budget is housed within the MOE, the Secretariat reports to the Secretary of the Cabinet, who is also the head of the Ontario Public Service.
So, while the commitment to the Action Plan may be demonstrated (with the caveats noted earlier), the capacity to deliver on the Action Plan’s milestone targets in the face of competition within Cabinet for scarce resources (both human and financial) is not clearly demonstrated in the CCAP Annual Report. The ‘co-ordination’ role of the CCS is clearly noted. Its role is “to provide comprehensive corporate leadership and support for government-wide efforts on all aspects of climate change” including the monitoring and tracking of progress.
In terms of monitoring and evaluation, the process does not clearly indicate how results will be used to adjust strategies for the design and implementation of new (and existing) initiatives (policy learning); nor is it clear how results will be used to enhance accountability for performance (performance management). In discussions with CCS staff over the spring and summer of 2009, it was indicated to the ECO that updates on the planning process were being reported through a Climate Change Action Committee (CCAC), chaired by the Minister of the Environment, and to CCAC Deputies. The roles and responsibilities of the CCAC and its membership are not discussed in the CCAP Annual Report. It is the ECO’s understanding that the decisions and recommendations originating with the CCAC are channelled through the Secretary of the Cabinet to the Cabinet and Premier.
The ECO strongly supports the creation of the Premier’s Climate Change Advisory Panel in the fall of 2008. The CCAP Annual Report provides a link to this 11-member Panel and summarizes the Panel’s mandate, roles and current research priorities. The ECO believes that this Panel should have more visibility in future annual reports and an expanded mandate that clearly articulates how it will advise key ministries and committees going forward. Process transparency would be considerably improved in subsequent annual reports with the inclusion of a process diagram showing how the outputs from this Advisory Panel relate to the work of the CCAC.
The ECO is assuming the new Cabinet Committee on Ontario’s Economic Future (CCOEF) will play a lead role in ensuring that the GEGEA and the Action Plan are co-ordinated to transform the provincial economy. The CCOEF’s mandate is to “maximize the business opportunities created by the global economy and climate change (emphasis added).” However, beyond listing the members of this cabinet committee, the CCOEF’s web site provides little in the way of details as to how it will carry out its mandate. The real climate change policy levers are in the hands of these CCOEF ministries (and at least two others - the Ministry of Transportation and the Ministry of Municipal Affairs and Housing).
It is also not clear to the ECO how engagement involving CCOEF ministries is being secured to ensure their ownership of (and confidence in the ability to deliver on) the Action Plan’s forecasts and reduction targets. Ideally, a governance process would delineate roles, responsibilities, accountabilities and key metrics that will encourage CCOEF members and recognize their contributions to achieving plan results (including recognition for exceptional performance).
6.6 Climate Adaptation Issues
Along with reducing GHG emissions in order to mitigate the impact of climate change, it is critical that appropriate measures to adapt to climate change are taken, given the inevitability of some degree of climate change in the future. Even if all global GHG emissions could be stopped tomorrow, the enormous inertia in the Earth’s climate systems means that changes to our climate over the remainder of this century are unavoidable. The urgent need to begin preparing for such changes is not an alternative to reducing overall GHG emissions, but a parallel and complementary action. In the absence of a federal climate change adaptation strategy, it is fundamental that Ontario move ahead and develop its own comprehensive strategy given that much of the social, economic and cultural health of Ontario is influenced by climate and many provincial ecosystems are potentially vulnerable to the impacts of climate change. In order to properly address the predicted impacts of climate change in Ontario, a clear understanding of provincial adaptation needs and priorities, and government plans, priorities and opportunities is essential.
In July 2007, the Ontario government announced the establishment of an Expert Panel on Climate Change Adaptation and named its two co-chairs. The remaining Panel members were appointed five months later and are comprised of several scientists and environmental experts. The mandate of the Expert Panel was to “help the Ontario government, municipalities and Ontarians prepare and plan for the impact of climate change in areas such as public health, environment, infrastructure, and economy.”
In November 2009, the government released Adapting to Climate Change in Ontario: Report of the Expert Panel on Climate Change Adaptation. The report contains five key recommendations, including one that calls upon the Minister of the Environment to take “immediate steps to seek Cabinet support for launching, by Spring 2010, a province-wide climate change adaptation action plan…[that is] guided by a strategy” founded on five goals. The strategic goals are to:
- enhance government leadership;
- integrate adaptation;
- support communities;
- develop and disseminate knowledge and tools to manage risk; and,
- collaborate with other governments.
Also included in the report are 59 recommendations that, according to the Panel, “can be used to make a fast start on building a more climate-resilient province.”
The ECO is pleased that the government’s report on climate change adaptation has been finalized and is publicly available. The ECO is also encouraged to note that the first recommendation made by the Panel − to develop an adaptation strategy and action plan − is consistent with a recommendation made by the ECO last year. Clearly there is a significant amount of work remaining to put an approved strategy in place; and the ECO is encouraged by and supports the Panel’s recommendation that this be done by spring 2010.
The urgent need to develop a strategy is clear in light of the significant amount of money allocated towards critical infrastructure projects over the next two years. As the CCAP Annual Report indicates, the government has committed $32.5 billion towards renewing, expanding and enhancing public infrastructure. Without a provincial adaptation strategy, the ECO is concerned that much physical infrastructure renewal (which includes projects that may have up to 50 to 100 year expected lifespans) will proceed without a solid integration of adaptation considerations.
Finally, the ECO believes that government reporting regarding adaptation measures should be kept separate from GHG mitigation and emission reductions discussions. While climate change mitigation and adaptation policies and efforts are complementary (in that some mitigation activities also are adaptive in nature − such as the installation of green roofs) the ECO would suggest that future Action Plan reporting focus solely on mitigation activities and that a separate venue be established for government reporting on adaptation. The ECO is not suggesting that an either/or approach be taken towards mitigation and adaptation, but rather that there is a need to undertake both approaches together as two complementary but distinct issues within an overall comprehensive plan on climate change.
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. 22-28
