Finding a Vision for Change
| 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. | ||||
In 2007, the Ontario government released Go Green: Ontario’s Action Plan on Climate Change (“Action Plan”), which established three targets for greenhouse gas (GHG) emission reductions. The government’s GHG reduction targets are as follows:
- 6 per cent below 1990 levels of GHG emissions by 2014;
- 15 per cent below 1990 levels by 2020; and
- 80 per cent below 1990 levels by 2050.
The government publishes annual reports outlining efforts it is taking to achieve these targets. These reports are published under the auspices of the Ministry of the Environment and are prepared by the Climate Change Secretariat. On December 2, 2009, the government released its Climate Change Action Plan Annual Report 2008-09 (“CCAP Annual Report”). The Environmental Commissioner of Ontario (ECO) is responsible for reviewing the government’s progress in achieving these targets and independently reporting our findings to the legislature. This document is a response to the CCAP Annual Report and represents the ECO’s second annual review of the progress made by the Ontario government in achieving its GHG emission reduction targets. Click here to read the ECO's first annual review.
The CCAP Annual Report indicates that the government will not meet either its 2014 or its 2020 reduction targets. In 1990, Ontario’s GHG emissions were 175 megatonnes (Mt) as measured on a CO2 equivalent (CO2 eq) basis. By 2007, the latest year for which actual (historic) GHG emissions data is available, Ontario’s GHG emissions had increased to 197 Mt – an increase of 22 Mt or 13 per cent. To achieve the 6 per cent reduction target, Ontario must reduce its GHG emissions to 165 Mt by 2014. The CCAP Annual Report indicates that the “impact of current [plan] initiatives” is forecasted to reduce Ontario’s 2014 GHG emissions to 180 Mt or 15 Mt short of the 2014 reduction target of 165 Mt.
To achieve the 15 per cent reduction target, Ontario must reduce its GHG emissions to 149 Mt by 2020. The CCAP Annual Report indicates that despite current and planned initiatives, Ontario’s GHG emissions could increase to about 184 Mt between 2014 and 2020; nearly 10 Mt above the 1990 baseline and 35 Mt short of the 2020 reduction target of 149 Mt. The fact that GHG emissions are projected to rise between 2014 and 2020 (even with the stated assumption that the 14 key GHG emission reduction initiatives will be delivered 100 per cent successfully) points to a serious deficiency in the government’s planning. There are problems with the CCAP Annual Report’s nominated suite of initiatives and with the long-term vision the Action Plan presents.
The Action Plan attributes over three-quarters of the forecasted emission reductions delivered by 2014 to one initiative: the phase-out of coal as a fuel at the four remaining coal-fired thermal power plants in the province. The ECO has a major concern with the CCAP Annual Report’s method of forecasting the timing of final coal phase-out and its contribution to the achievement of the government’s short-term target. The ECO also believes that there is considerable short-term risk in a plan that relies overwhelmingly on the phase-out of coal to deliver the 2014 reductions. The CCAP Annual Report refers to this risk in its Appendix B in the context of “[e]xternal [f]actors…beyond the control of the government” such as demand for peak electricity either from within or outside Ontario’s jurisdiction.
The government’s focus on electricity conservation with an apparent blind spot for natural gas, the source of 26 per cent of the province’s GHG emissions, is also an area of risk the ECO has noted. This is particularly concerning in light of the CCAP Annual Report’s own information which places natural gas at the top of the list of ‘remaining emissions’ sources for three key sectors – industry, electricity and buildings. Since the mid-1990s, the province’s two major natural gas distribution utilities have reduced their customers’ use of natural gas through comprehensive conservation and demand management (CDM) programs. The contribution of these CDM programs to the government’s broader Climate Change Action Plan targets needs to be more clearly articulated in government planning and in future annual reports.
The ECO had expected to see a greater focus on initiatives to reduce GHG emissions associated with transportation, especially modes such as heavy vehicles and freight. All modes of transportation were responsible for 64 Mt, or 31 per cent of Ontario’s GHG emissions in 2007. Road transportation represented just over 48 Mt of these GHG emissions, and within this category, passenger vehicles were responsible for just under 35 Mt. The ECO commends the government’s focus on initiatives that are designed to reduce commuting and personal automobile use as this category represents a significant volume of GHG emissions. However, the ECO believes that any serious attempt to reduce tailpipe emissions must consider the potentially significant role of road pricing in this effort.
There is significant medium-term risk in the government’s heavy reliance on a proposed North American cap-and-trade regime to close the gap in projected 2020 GHG emissions. While it is encouraging that the government is engaged in discussions concerning the design of several proposed tradable permit systems in both Canada and the United States, the ECO remains concerned about the risks inherent in a process where key decisions about a future trading regime are largely in the hands of other jurisdictions.
The ECO notes that the government is identifying and assessing options to deliver GHG reductions “that are additional to cap-and-trade.” However, the ECO still sees considerable risk in a plan that has an over-reliance on a cap-and-trade system to the apparent exclusion of other initiatives that are likely to be needed to close the 35 Mt gap by 2020.
There is also a concern with the transparency of the governance process that exists to ensure the Action Plan achieves its objectives. In our 2007-2008 Special Report we asked 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. Unfortunately, this was not provided in this year’s CCAP Annual Report. The ECO and the public need to understand the roles and responsibilities of the key ministries and government agencies, and – equally important – where accountability lies for meeting the government’s GHG emission reduction targets. This is important because, despite the good intentions displayed in the CCAP Annual Report, neither the ECO nor the broader public has any clear understanding about the government’s management and control procedures, who is accountable, when (or if) due diligence is confirmed and how performance is recognized.
As this report was being finalized, the government released Adapting to Climate Change in Ontario: Report of the Expert Panel on Climate Change Adaptation. The ECO is encouraged to note that the Panel’s report has recommended that the Minister of the Environment launch, “by the Spring 2010, a province-wide climate change adaptation plan” and strategy. The ECO made a similar recommendation in last year’s Special Report.
The lack of such a strategy is of some concern in light of the fact that a significant amount of money will be allocated towards critical infrastructure projects over the next two years. The government has committed $32.5 billion towards renewing, expanding and enhancing public infrastructure. In the absence of 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) could proceed without a solid integration of adaptation considerations.
On a more positive note, the ECO applauds the government’s implementation of the Ontario Public Service Green Transformation Strategy; the government is serious about getting its own house in order by setting a good example. The government recognizes that the process of setting and meeting GHG emission reduction targets is an iterative process; learning by doing. It has made the commitment to work with other stakeholders and the Premier's Climate Change Advisory Panel to search out new initiatives to deliver GHG emission reductions. Recognizing the importance of being able to defend its results going forward, the government is committed to retaining third-party verification expertise. This is all to the good as the learning process continues.
- Next section: Overview
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. 3-5
