Meeting Responsibilities
| In May, 2011, the ECO his released third Annual Greenhouse Gas Progress Report. Click here for more information on this report, including videos and communications materials. | |||||
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The ECO’s Mandate
This report represents the Environmental Commissioner of Ontario’s (ECO’s) third Annual Greenhouse Gas Progress Report. Under the Environmental Bill of Rights, 1993, the ECO is responsible for reporting annually to the Speaker of the Legislative Assembly of Ontario on the progress of activities in Ontario to reduce greenhouse gas (GHG) emissions. In fulfilling this mandate, the ECO is to review any annual report on GHG reductions or climate change published by the government in the year covered by the ECO report.
In previous years the government released its Climate Change Action Plan (CCAP) Annual Report at the end of the year, with the last report being issued in December 2009. Despite repeated commitments to report annually, the ECO notes with dismay that the government delayed the release of its CCAP Annual Report 2009–2010 until April 2011.
Setting the Context
Climate change policy is currently in a state of uncertainty. At the international level the global community has yet to agree on a treaty to succeed the Kyoto Protocol which expires in 2012. At the national level the federal government has chosen to harmonize its climate policy with that of the United States which, due to significant opposition from the Republican-controlled House of Representatives, remains in limbo. Provinces and states have attempted to fill the policy void through regional initiatives such as the Regional Greenhouse Gas Initiative and the Western Climate Initiative, but these are challenged by a lack of regulatory readiness on the part of participating jurisdictions and outright withdrawal of some states from these programs. A further discussion of these developments is contained in Appendix 1.
Despite this policy uncertainty, Ontario must remain firm in its commitment to reduce its contribution to global GHG emissions. Present climate change impacts (e.g, exacerbated droughts, floods, etc.) are predicted to worsen over the century if global GHG emissions continue to grow beyond 350 parts per million (ppm) – they are currently at 392 ppm. A clear moral obligation is owed to future generations. Strong action must be taken today to address this challenge.
Sector Targets are Necessary to Track Progress
Ontario’s total GHG emissions in 2009 were 165 megatonnes (Mt). This represents a decrease of 12 Mt (or 6.5 per cent) from Ontario’s 1990 base year emissions of 177 Mt. The majority of this drop is due to decreased emissions in 2009 from electricity generation and reduced industrial activity due to the economic downturn.
The Ontario government has set three emissions reductions targets:
- 6 per cent below 1990 levels by 2014;
- 15 per cent below 1990 levels by 2020; and
- 80 per cent below 1990 levels by 2050.
These reduction targets represent overall totals. The contribution that each sector is expected to make to these total reduction targets is obscure because the government has not established sector-specific targets. If the mid-term 2020 target is met, it will likely result from larger proportionate reductions in some sectors compared to others. This is certainly true for the short-term 2014 target, where the bulk of reductions will come from phasing out the use of coal in the electricity sector.
In the absence of sector targets, it is difficult to assess if the reductions being planned and achieved within a given sector are adequate or on track. The current CCAP tools are not sufficient to meet mid- to longer-term targets. In order to achieve a cohesive plan, it would be wiser to break the plan down into sectoral targets so that progress in each area can be evaluated. With such targets in place the public, and the ECO, will be in a better position to determine what proportion each sector is anticipated to contribute and whether the individual initiatives within each sector are both sufficient and on track to achieve the three overall targets.
Sector targets would also benefit the government in terms of its monitoring and evaluation functions. Sector targets can confirm the efficacy and absolute benefit of existing sector initiatives, assist with the development of new ones (‘policy learning’), while enhancing and confirming accountabilities for achieving results (‘performance management’).
Decoupling Emissions from Growth
According to its CCAP Annual Report 2009–2010, the government has not altered its disappointing projection from last year that neither the 2014 nor the 2020 targets will be met. GHG emissions, which were 200 Mt in 2007 (the initial year of the CCAP) dropped to 190 Mt in 2008. The most recent federal National Inventory Report indicates that Ontario’s emissions took a precipitous decline to 165 Mt in 2009. This volume is more than six per cent below the restated 1990 base year amount of 177 Mt, which at first glance makes it appear that the 2014 target has been met five years in advance. One has to be cautious of this interpretation, however, as these recent declines are, in large part, attributable to the economic recession. With economic growth predicted to resume in the years ahead, the challenge of meeting Ontario’s first two targets will become more acute.
Meeting this challenge will require Ontario to further decouple its GHG emissions from provincial economic activity, as measured by gross domestic product (GDP). GHG emissions measured in terms of each dollar of economic output (i.e., emissions intensity) have decreased over the past two decades, which is encouraging. In 1990, Ontario emitted about 530 grams of CO2 per dollar of GDP (g CO2/$GDP). By comparison, the 2009 federal data indicates that the relationship between emissions and GDP had improved to 320 g CO2/$GDP. In 2009, the Ontario economy contracted by 3.6 per cent so one would expect a corresponding reduction in overall emissions, which is what the data shows.
The economic contraction of 2009, due largely to a substantial slowdown in the industrial sector, is in the process of reversing. The economy grew by an estimated 2.8 per cent in 2010 and is projected to grow by a further 2.4 per cent in 2011. As industrial output rebounds overall emissions can be expected to grow, but even if one assumes that the emissions intensity of 320g CO2/$GDP can be maintained, the challenge of meeting the 2014 target is considerable. The extrapolated economic growth, even at that low intensity, will add approximately 23 Mt to Ontario’s tally. Eliminating the use of coal by the end of 2014 has the greatest potential for reductions, but even the net reductions associated with coal phase out (because of the expanded use of natural gas peaking plants) will only represent about 10 Mt, leaving about 13 Mt still on the table. The tools required to achieve a much larger reduction have yet to be identified by the government.
The problem associated with a shortage of tools to decarbonize the economy gets more acute as the timeline extends beyond 2014 to the 2020 target of 150 Mt. The challenge of an expanding economy necessitates even greater restructuring and innovation. The government’s CCAP Annual Report 2009–2010 clearly indicates that emissions are projected to rise during the 2014–2020 period due in part to the shift back to natural gas during the lag when older nuclear facilities are retired and not yet replaced by new construction. At this time there is no plan, mechanism or tools in place that would allow the 2020 target to be met.
Pricing Carbon in the Economy
One of the stated goals of the government’s CCAP is to pursue initiatives that will support the transition to a low-carbon economy. The ECO believes this will only happen if the cost associated with the release of GHGs into the atmosphere is reflected in the price of goods and services bought and sold in Ontario. The ECO remains agnostic on the instrument used to establish this carbon price – whether it is through a tradable permit system (i.e., cap-and-trade) or via a carbon fee or tax. While public acceptance of higher energy prices is often perceived as a political barrier to climate policies, both the general public and major industry associations support the implementation of a carbon price.
The government has been working with other provinces and U.S. states through the Western Climate Initiative to establish a regional cap-and-trade program that is to launch in January 2012. In December 2009, Ontario laid the foundation to participate in a regional cap-and-trade system through two pieces of enabling legislation. Bill 185, the Environmental Protection Amendment Act (Greenhouse Gas Emissions Trading), 2009 amended the Environmental Protection Act to allow GHG emissions trading, and Ontario Regulation 452/09 – Greenhouse Gas Emissions Reporting, made under the Environmental Protection Act, requires facilities emitting more than 25,000 tonnes of CO2 equivalent CO2(e)per year to begin reporting their emissions in 2011. In April 2011, however, the government indicated that it would not participate in the initial launch of the Western Climate Initiative cap-and-trade program because of economic competitiveness concerns and a lack of verified emissions data.
The ECO believes that policy delay in Ontario will likely result in higher overall costs to meet the 2020 target. By acting now to introduce a carbon price, the government will provide time for individuals, businesses and municipalities to adjust without imposing significant nearterm economic impacts. According to the National Round Table on the Environment and the Economy, a moderate carbon price of $30 would only reduce Ontario’s GDP growth by 0.1 per cent per year between now and 2020. Thus it is important that the government push forward with the development of a carbon pricing policy.
However, putting a price on carbon does raise concerns. Issues surrounding carbon leakage and so-called “trade-exposed industries” will need to be addressed and the ECO discusses potential options in Appendix 2 that should be considered in the interests of broadening Ontario’s climate change policy agenda. The bottom line is that the ECO believes these issues are manageable going forward and that the time to act is now. The longer Ontario waits for other jurisdictions to move, the longer the transition to a low-carbon economy will be delayed and the higher will be the costs of this transition.
Transportation GHGs
The transportation sector contributes the largest volume of GHG emissions in Ontario (56.8 Mt or 34 per cent) with the bulk of emissions resulting from gasoline combustion for personal vehicle use. According to the government’s CCAP Annual Report 2009–2010, several provincial and one federal initiative will result in only a 3.0 Mt reduction in transportation emissions by 2020. (The ECO notes that last year’s projection was that transportation initiatives would result in an 8.1 Mt reduction.) Given the magnitude of the total reductions necessary, this projected reduction is unambitious and disappointing.
Over the past year, the government’s climate change mitigation tool box actually shrank. Some programs, such as the Green Commercial Vehicle Program, the Ontario Bus Replacement Program, and certain tax measures designed to incent fuel-efficient vehicle purchases, quietly came to an end. Others remain in place but, as discussed in detail in Appendix 3, significantly more effort will be required to address this large, and growing, source of emissions. Not only does the government need to strengthen the tools that are currently in place, more tools must be added to the transportation GHG reduction toolkit, particularly with regard to land-use planning to curb urban sprawl and the expansion of public transportation options.
The manner by which current and future communities are developed implicitly “locks in” a particular future emissions curve. The trajectory of that curve depends upon the land-use planning choices that are made today. Increased intensification of already built-up areas and high-density development contributes to achieving a lower-emissions pathway. In the most densely populated region of the province, the Growth Plan for the Greater Golden Horseshoe, 2006 reflects a laudable vision for more mixed use, compact communities. However the targets set to achieve this goal are too weak and do not represent much more than business-as-usual development. As such, the ECO is concerned that the current targets are not sufficiently rigorous to combat the inexorable rise in GHG emissions created by future development.
Complementing stronger land-use intensification targets is the necessary expansion of attractive public transportations options. In the Greater Toronto and Hamilton Area (GTHA) – the area where most of Ontario’s problem traffic is concentrated – the government has, through Metrolinx, made significant progress by developing a 25-year, $50-billion Regional Transit Plan (RTP). Implemented in conjunction with strong land-use planning policies, the RTP has the potential to reduce GHG emissions over the long term by decreasing vehicle kilometres travelled. The key barrier to its full implementation, however, is a lack of adequate and secure funding. Metrolinx is exploring funding mechanisms to close the investment gap and is expected to provide recommendations by 2013. The ECO sees an urgent need for these recommendations to be completed sooner than 2013 in order to confirm Metrolinx funding sources and amounts.
Road pricing must be part of this dialogue. Traffic congestion imposes huge costs on the environment and public health, not to mention the economy. Simply put, there are too many single-passenger vehicle trips being made. Building more roads to accommodate more vehicles is not an option that works. With a projected 7 per cent increase in the number of passenger vehicles in the province by 2020 the problem will continue to grow unless we fundamentally shift the manner by which we move people and goods within the GTHA. There appears to be only two choices: accept more traffic and greater congestion as inevitable; or do something about regulating the demand by putting in place the price signals that can help reduce congestion. While there may be technical and public acceptance barriers, the ECO does not believe these to be insurmountable. A consultation process, followed by a time-limited pilot project, could help to analyze the strength of any perceived barriers and determine ways forward. Simply ignoring road pricing as a possible option for the transportation toolkit does not reflect leadership.
Apart from the GTHA, other aspects of transportation require a re-think. In particular, traffic volumes and domestic air travel along the Quebec City – Windsor corridor have grown dramatically over the years, with GHGs increasing in lockstep. Previous studies have shown that significant emissions reductions would result from implementing a high-speed rail system. Yet another study was commissioned in February 2009, but two years later, no results are available. This is disappointing. The benefits and opportunities associated with high speed rail have long been studied. It is now time to move forward.
Near-term Risk and Opportunities
It is common to discuss policy responses to climate change in the same long-term context that the impacts of global warming are presented by scientists, typically over a 100-year period. This creates the impression that we have a long response time and that there is no requirement to act immediately. However, there are good reasons to be concerned about what happens over the ‘near term’. This presents a serious risk; however the ECO believes that several opportunities have considerable promise as near-term mitigation tools.
The risk over the near term arises from ‘tipping-points’ in atmospheric GHG concentrations. Once these concentration levels are exceeded, certain biogeochemical processes can be triggered and feedback cycles may be created that drive the planet to a severely altered climate state beyond human control. One example of a feedback cycle is the thawing of permafrost. Vast quantities of methane gas are trapped in northern permafrost and, as temperatures increase, more of this gas will be released. Given the short life span of methane, and its potency, any additions of GHGs or other positive radiative forcings are more dangerous now than they would be in 50 years.
One near-term opportunity, however, is provided by a constituent of the atmosphere that is not a GHG but is nonetheless an important source of positive radiative forcing. That material is the portion of tiny suspended soot particles in the atmosphere collectively termed black carbon aerosols. They are created and emitted by various kinds of combustion of organic fuels, not the least of which are diesel engines. The nature of the opportunity is described in Appendix 4. Also discussed in this appendix are two soil carbon mitigation opportunities.
Landfill Methane
Methane (CH4) is a powerful GHG and landfills are the largest source of this gas in Ontario. Landfills have historically contributed 3 to 4 per cent of the province’s annual GHG emissions. Although the diversion of organic waste from landfills is the most effective way to reduce methane emissions from these sources, most of this waste still ends up in landfills and, as a result, methane emissions from this source have grown between 1990 and 2008. Ontario set a target to achieve a 60 per cent solid waste diversion rate by 2008, but reported in 2009 that only 22 per cent was being diverted. Up to one-third of these wastes consist of organic discards such as food scraps, paper, textiles and yard trimmings.
This low diversion rate is problematic, especially given that the Ministry of the Environment (MOE) may be underestimating landfill methane’s contribution to Ontario’s GHG inventory by several orders of magnitude. As discussed in Appendix 5, this is a function of current landfill gas emissions models that significantly overestimate landfill gas control system collection efficiencies, and thus grossly underestimate un controlled, fugitive methane releases into the atmosphere. Given methane’s significantly higher short-term global warming potential, the prevention of fugitive methane emissions from landfills should become a nearterm policy priority.
Complicating this picture of underestimated emissions is a regulatory framework for GHG emissions from landfills with conflicting priorities. In the space of just over two years, the Ontario government has: 1) stated a preference for using landfill methane for energy production; 2) introduced regulatory amendments to require the installation of methane capture in smaller capacity landfills; and, 3) introduced a policy proposal to divert organics away from landfills.
These apparently divergent landfill policy directions beg the question: What is the government trying to accomplish? Is it the control of GHGs? Is it energy production? Is it the stabilization of landfills to limit their contaminating lifespans? Or, is it the diversion of organics away from landfills altogether? Are these goals and objectives compatible? To the extent that they require substantially different landfill design parameters and operating requirements, the ECO believes that they are not compatible.
Viable management options to reduce GHG releases from existing wastes-in-place are urgently required. There are well-established alternatives to landfilling for new organics – including composting, anaerobic digestion, and thermal conversion technologies (such as pyrolysis) – that do not create uncontrolled methane releases. But, there is no real alternative when it comes to existing wastes-in-place – these must be managed to reduce GHG releases. Energy production in existing landfills requires major modifications to landfill management that may actually increase the escape of fugitive methane emissions. The promotion of this option also sends mixed signals to municipal owners and operators of landfills – with the unintended consequence of erecting marketplace barriers to more effective mitigation options such as diversion. The ECO believes that landfills should be managed so that they are as biologically inactive as possible to prevent the release of methane into the environment. Diversion will always produce greater GHG reduction benefits, regardless of the assumptions used.
The government must move quickly to develop a solid waste management strategy that clarifies how existing wastes-in-place will be treated while, on a go-forward basis, articulating the timing and commitments to ensure that all future organics are prohibited from landfills.
Governance and Transparency
The ECO’s Annual Greenhouse Gas Progress Report 2008/2009 stressed the importance of transparency and requested details as to how the government’s GHG emissions forecasting is undertaken, how emission reductions are tracked, to what sector or initiative they are attributed and how monitoring of CCAP results are verified. Our report stressed the need for transparency in the governance process that drives and enables these activities.
Previously, the government indicated that the Climate Change Secretariat (CCS) played a lead role in this regard. The CCS was to co-ordinate government-wide efforts on climate change and track progress – a role the ECO endorsed. The CCS reported progress in CCAP design and implementation to a Climate Change Action Committee (CCAC) chaired by the Minister of the Environment and made up of key deputy ministers whose policy decisions were influential to the achievement of the Action Plan’s objectives and targets (i.e., transportation, natural resources, industry and northern development).
Further, the ECO understood that CCAC decisions and recommendations were channeled through the Secretary of the Cabinet to the Cabinet and Premier. These recommendations were to be informed by contributions from the Premier’s Climate Change Advisory Panel – an entity also endorsed by the ECO. The ECO felt that the Panel could become more visible in its role as a champion for the identification of innovative low-carbon technologies and policies.
The government’s CCAP Annual Report 2009–2010 has revealed a new climate change governance model that apparently does not include either the CCS or the Climate Change Action Committee. The tracking and monitoring functions previously performed by the CCS have now been assumed by a newly formed Climate Change Results Table chaired by the Minister of the Environment. Rather than the deputy ministers, who have the technical expertise and continuity of purpose to identify and champion new initiatives, the members of this Table include ministers of departments that have a role in policy or programming for sectors such as transportation, energy, industry and innovative new technologies. The Results Table is, in turn, co-ordinated by a team within Cabinet Office.
It is of concern to the ECO that the public, and other important environmental stakeholders, were left unaware of a significant change in the climate change governance structure until the release of the most recent climate report. It is therefore ironic to see this new governance model described under a heading entitled “Ensuring Transparency and Progress”. The governance process and accountabilities to deliver program results are not discussed; nor is there any discussion or elaboration on how climate change considerations will be incorporated into ministry business plans and decision-making.
A final concern is one relating to process. The ECO’s statutory requirement is to report to the Speaker of the Legislative Assembly on the progress of activities to reduce GHG emissions and review any annual report on GHG reductions published by the government. In previous years these reports were released in December. By shifting our reporting date to the spring, the ECO had tried to ensure that we had sufficient time to review and consider the government’s results before we submitted our report to the Speaker. This year the government delayed the release of its annual report until April 2011. By failing to provide its annual report in a timely manner, the government has denied the legislature, the public and the ECO the opportunity to assess the government’s progress and to evaluate the full transparency and thoroughness of its plan. The delivery of such information past the eleventh hour frustrates the ECO’s ability to fulfill our duty to report to the Speaker and the public.
Moving Forward
The government’s climate change mitigation actions announced to date do not appear to match the commitments it has made in previous public documents. The government’s CCAP calls for absolute reductions across the entire economy that will contribute to milestone targets at 2014, 2020 and 2050. However, beyond firm and measurable reductions in the electricity sector, the most recent report provides very little intelligence as to how other sectors will contribute to these reductions. Sector targets are needed to monitor the government’s progress and assure the public that the government’s plan is on track. The need for transparency and metrics is especially strong when one recognizes that the industrial and transportation sectors were responsible for 61 per cent of Ontario’s 2009 GHG emissions.
As the economy recovers from the recession and continues to grow, the government will need to pursue further tools to ensure that GHGs do not continue to grow with the economy. The ECO has identified numerous studies that support putting a price on carbon as a key tool in helping to decouple GHG emissions from GDP growth. Industry supports the pricing of carbon and is demanding that this happen sooner rather than later.
The ECO is also concerned about the apparent lack of engagement from key ministries and their deputy ministers in the assessment of climate mitigation risks and opportunities. For example, the uncritical acceptance of – and disjointed management policies relating to – landfill design and operation must be changed. Further, the significant near-term opportunities related to the reduction of black carbon aerosols and the longer-term management of agricultural soils for carbon sequestration must become key components of the government’s climate change mitigation plan. These opportunities are nowhere to be seen in the government’s most recent CCAP Annual Report or in any other ministry documents or research of which the ECO is aware. This is distressing when their significant near-term climate mitigation benefits, as described in this report, are so promising.
The ECO explores these examples of ‘creating opportunities’ in the appendices that follow.
Recommendations
1. The ECO recommends that the Ontario government establish sectoral GHG reduction targets that will allow the government, the public and the ECO to determine the efficacy of current and future Climate Change Action Plan initiatives towards achieving the government’s overall 2014, 2020, and 2050 targets.
2. The ECO recommends that the Ontario government establish a price on carbon as soon as possible to hasten the transition to a low-carbon economy.
3. The ECO recommends that the Ontario government investigate and publicly report on the potential for soil carbon sequestration as a GHG mitigation strategy.
4. The ECO recommends that the Ontario government review its assumptions regarding landfill design and operational requirements and their contribution to the release of fugitive methane emissions and publicly report on the results of this review.
