Ontario Court rules that government broke the law by failure to consult on repeal of Cap and Trade regulations

doug ford scrap the taxA suit against the Conservative Ford government of Ontario was dismissed by the Ontario Divisional Court on October 11, but in the decision, a majority of judges wrote that the government breached Ontario’s Environmental Bill of Rights (EBR) by repealing the province’s Cap and Trade regulations without the required public consultation.  The CBC summarizes the decision and the National Observer writes,

“the judges found the Ford government was in “clear breach of the EBR” and that “its apparent efforts to avoid judicial review of this conduct raises serious concerns – not about whether the government had the lawful authority to repeal the Cap and Trade Act, but of its respect for the Rule of Law and the role of the courts, as a branch of government.”

The suit was brought by Greenpeace and Ecojustice in 2018.  The Greenpeace reaction on October 11 states:

“Scrapping cap-and-trade not only undercut a successful program that was helping Ontario reduce climate change-causing greenhouse gas emissions, it also cancelled 227 clean energy programs that would have benefit schools, hospitals, small businesses and public housing projects. It’s especially concerning that the Ford government did this in a way that silenced groups like Greenpeace and Ontario’s youth – who do not have a voice to vote, but stand to lose the most from climate inaction… Ontarians are marching in the streets demanding real action in response to the climate emergency and we call on the Ford government to listen to the people this time, starting with an abandonment of its challenge of the federal carbon tax.”

The Greenpeace statement also refers to Failure to Launch , a progress report on climate action in Ontario released on October 10 by Environmental Defence. A blog summarizes the findings; the full report is here , describing the destruction of climate change policies from the previous Liberal government, and making recommendations for improved future action.

Updating the political battle of carbon pricing in Canada

Justin TrudeauOn October 23,  Prime Minister Justin Trudeau announced that the federal government will hold its resolve to impose a carbon pricing policy across all Canadian jurisdictions in 2019 – see the press release, “Government of Canada Putting a price on pollution”   (Oct. 23).  Key to the plan: the Climate Action Incentive, whereby all carbon revenue will go directly back to people in the provinces from which it was generated.  David Roberts of Vox hits the nail on the head with  “Canadian Prime Minister Justin Trudeau is betting his reelection on a carbon tax” (Oct. 24) , stating,  “It’s a thoughtful plan, remarkably simple, transparent, and economically sound for something cooked up in a politically fraught context. If it’s put into place (and stays in place), it would vault Canada to the head of the international pack on climate policy.”

Reaction from the Canadian mainstream media: From the Globe and Mail, an Editorial:  “For the Liberals, a spoonful of sugar helps the carbon tax go down” ;  “Arguments against the carbon tax boil down to a desire to do nothing” (Oct. 24)   by Campbell Clark ; “Carbon tax vs. climate change will be an epic contest” by John Ibbitson  and “Trudeau’s carbon tax rebate is smart – but complicated”  by Chris Ragan of the Ecofiscal Commission . From Andrew Coyne in the National Post: “Liberals’ carbon tax plan has its faults — but who has a better option?”  and from Chris Hall of the CBC, “How the Liberals hope to escape the ‘Green Shift’ curse in 2019”  (Oct.23)  .

The National Observer provides some detail to the complex calculations of the backstop rebates of the Climate Action Incentive, but the detail is at the government’s webpage, Pricing Pollution: How it will work  which provides links to individual explainers for each province and territory.

Other Responses: Rabble.ca Elizabeth May of the Green Party of Canada ;  Canadians for Clean Prosperity ;  and the Smart Prosperity Institute , which also provides a compilation of reaction and reports .

There seems to be general agreement that it is politics, not economics, which will determine support for the carbon plan.  Ontario Premier Doug Ford has been making the rounds with other Conservative politicians in Canada to coordinate their messaging and opposition to the federal carbon tax – culminating in the introduction of Bill No. 132—The Management and Reduction of Greenhouse Gases Amendment Act , 2018 in Saskatchewan on October 30, and on October 31, passage of Ontario’s Bill 4, The Cap and Trade Cancellation Act.  The National Observer describes the events of October 31 and summarizes the recent  political dance in “Doug Ford and Andrew Scheer play fast and loose with facts about carbon tax”  . Other press coverage: from the CBC:   “‘The worst tax ever’: Doug Ford and Jason Kenney hold campaign-style rally against carbon levy”  on Oct. 5 ;   “Doug Ford attacks ‘terrible tax’ on carbon alongside Saskatchewan Premier Scott Moe” on Oct. 29; and  “Doug Ford meets Andrew Scheer as carbon tax war heats up”  on October 30, describing their meeting in Toronto.  The gist of their arguments:  the carbon tax is a money-grab which will “drive up the price of heating your home”, with Doug Ford stating “It’s just another Trudeau Liberal tax grab. It’s a job-killing, family-hurting tax. ”  After the rebate details were announced on October 23, Ford has added that the promised rebates are “a complete scam”, “trying to buy Canadians with their own money.”   But as iPolitics reported on October 26, “Ford gets his facts wrong while bashing federal carbon tax”  and  “Ford doubles down on falsehoods about federal carbon tax”  .  iPolitics cites the independent analysis of the carbon tax’s impact by  Ontario’s Financial Accountability Officer, Ontario financial office cap and tradewhich supports the federal government’s numbers, and differs from Premier Ford’s public statements.  Meanwhile, the Ontario government promises to release their climate plan in November,  according to the Toronto Star   (Oct. 29), and Andrew Scheer also promises a climate plan “in 183 days”.

Activists force consultation re Ontario’s cap and trade policy as Environment Commissioner pans government’s actions to date

Ontario commissioner Report-Cover-In the annual Greenhouse Gas Reduction Progress Report for 2018, titled Climate Action in Ontario: what’s next? , the Environmental Commissioner of Ontario has published a blunt critique of the Conservative government’s actions to date.

As was widely reported, the  government in Ontario (among other actions) tried to dismantle the province’s cap and trade program after its election, introducing  Bill 4, the Cap and Trade Cancellation Act, 2018  on July 25 .  The Environmental Commissioner wrote:

 “Unfortunately, cap and trade was both complex and poorly communicated; for some, its costs were more obvious than its benefits. Today, cap and trade, the low-carbon programs that it funded, and 752 renewable energy projects have all been swept away, with nothing in their place. The government’s proposed replacement, the Cap and Trade Cancellation Act (Bill 4), currently lacks most of the features of a good climate law.…. There is no perfect answer, but the best international model for long-term consistency is the United Kingdom’s Climate Change Act. The U.K. Parliament sets legally binding long-term emission limits, plus five-year carbon budgets 12 years in advance, based on non-partisan, expert advice and reporting. Ontario should do the same.”

The Commissioner’s report includes appendices, including Appendix B: Revenue from cap and trade: What was it used for?

On September 11, environmental activists filed a lawsuit against Bill 4, alleging that it violates the Ontario Environmental Bill of Rights because no public consultations were held on the  matter.  On the same day, a notice appeared in the Environmental Registry,  allowing  for comments online or in writing, until October 11.    EcoJustice, one of the groups behind the lawsuit, (along with Greenpeace  and the University of Ottawa) has posted a summary of all these developments on September 25 in “Let Premier Ford know where you stand on climate action”, urging comments.

Jumping in to this debate:  Canadians for Clean Prosperity, which commissioned a study to examine the costs and benefits of carbon “costs” (e.g. fuel and household heating) in Ontario, Saskatchewan, and Alberta, in the event that the federal carbon price backstop is triggered in 2019.  The author, Dave Sawyer of EnviroEconomics, concludes that most households, regardless of income, would receive more money through rebates than they would pay out through a carbon price, assuming that all fees are rebated to consumers.   The report summary is here ; the formal report is  Federal Carbon Price Impacts on Households in Alberta, Saskatchewan and Ontario  .  An economist’s (Brendan Frank) explanation of the EnviroEconomics report appears in an  EcoFiscal Commission blog “How carbon dividends affect incentives (hint: they don’t)”  (Sept. 26).

Ford government sued by Greenpeace for cancellation of cap and trade without consultation

Doug FordUpdated September 11:

On September 11, CBC News broke the news that “Greenpeace suing Ontario government over cancellation of cap-and-trade program” The lawsuit was filed  in Ontario Superior Court by EcoJustice and the University of Ottawa’s Ecojustice Environmental Law Clinic.  It asks the Court to quash the legislation, on the grounds that the Conservative government “unlawfully failed” to hold public consultations before cancelling  the program, as required by Ontario’s Environmental Bill of Rights. An expedited hearing on the matter has been granted and scheduled for September 21.  The EcoJustice press release of September 11 is here .

At issue is Bill 4, The Cap and Trade Cancellation Act, 2018 , introduced in July to honour a campaign pledge to repeal Ontario’s cap and trade program, authorized through the Climate Change Mitigation and Low-carbon Economy Act, 2016  of the previous Wynne government.  Yet as the National Observer  reported on August  15, “Ontario legislature adjourns without adopting Ford government bill to cancel cap and trade” .  The article also compiles expert opinion and reaction to the move, and notes  that the government will be expected to propose new greenhouse gas emissions reduction targets when the Ontario legislature returns for its fall sitting on Sept. 24.

In “Ford government does U-turn, expands electric vehicle rebates for Tesla buyers”  (Aug. 31), CBC reports on another Court case involving the rookie Ford government.  The Court ruled against the government and in favour of  Tesla, which had claimed that it had been discriminated against when the government discontinued electric and hybrid vehicle sales incentives.   The CBC quotes Sara Singh, an Ontario NDP MP, who stated in August:  “This is likely only the first of many decisions against the Ford government’s decision to rip up hundreds of cap-and-trade and green energy contracts.” The Huffington Post compiled a list the legal actions against the government, on a variety of fronts, on Sept. 5.

Others who have weighed in on Ford’s climate and energy policies: Climate Action Network, along with 37 signatories,  sent an Open Letter to Premier Ford  on August 8.  It documents the heat and fire emergencies throughout the province in the summer of 2018, and calls for a public commitment, along with a detailed plan,  to achieve Ontario’s existing legislated emissions reduction goals.  Environmental Defence maintains an online petition calling for similar action.

Regarding Ford’s cuts to renewable energy programs: A widely-cited article appeared in Forbes magazine: “Ontario’s Economic Investment Outlook Dims With New Government Energy Actions”  (Aug. 13)   (and was re-posted by the Pembina Institute )  stating:  “In one fell swoop Ontario’s government has dramatically slashed a source of funding for clean transportation infrastructure to help consumers lower travel costs, erased hundreds of clean energy projects to help consumers reduce electricity costs, dimmed the prospects for jobs and economic growth from clean tech industries, and took a major step backwards in making the province an attractive climate for business and investment today – and into the future.”

Against the evidence for its efficiency, Ontario’s Cap and Trade program axed

Doug Ford clappingIn Ontario, newly-elected Premier Doug Ford quickly fulfilled a central campaign promise, as the Province revoked the cap-and-trade  regulations and prohibited all trading of emission allowances, officially announced on July 3, 2018.   A further July 25  press release  announced the introduction of Bill 4, The Cap and Trade Cancellation Act, 2018  and claimed that “The average Ontario family will receive $260 in annual savings thanks to the elimination of the cap-and-trade carbon tax.”  All programs currently funded through the cap-and-trade revenues have been cancelled, including the immediate wind-down of the Green Ontario Fund, which funded many energy efficiency incentive programs.  The Cap and Trade Cancellation Act repeals the Climate Change Mitigation and Low-carbon Economy Act, 2016  of the previous Wynne government “and provides for various matters related to the wind down of the Cap and Trade Program.”

Earlier, on July 13, the province had announced  the cancellation of 758 renewable energy projects, calling them “unnecessary and wasteful” – one notable example, the almost-completed White Pines wind project in Prince Edward County.  And on August 2, in addition to the previously announced court challenge  to the federal government’s carbon pricing requirements under the Pan Canadian Framework,  Ontario’s  Attorney General announced a second court challenge  – this time in  the Ontario Court of Appeal.  “Doug Ford’s Ontario pursues ‘doomed’ plan to stop Trudeau government’s efforts to fight climate change”   in the National Observer (August 2) summarizes the development from a political viewpoint, and the Globe and Mail’s editorial is titled: “Caroline Mulroney’s carbon-tax court challenge is a partisan waste of money

Reactions :

Ford government Attempts to minimize Ontario taxpayer losses after abandoning carbon markets”   (July 25) in the National Observer;

“Ontario’s fiscal watchdog to probe cancellation of cap and trade,at Horwath’s request”   in the Globe and Mail (July 24);

From Professor Mark Winfield, York University:  “Doug Ford’s energy shake-up could cost Ontario”  in The Conversation (July 25)   ;

Clean power advocates disappointed but defiant in the face of Ford’s sweeping cuts” from the National Observer (July 17)

Solar companies may exit Ontario for Alberta after Doug Ford kills rebate program”  from CBC News (June 21) ;

Scrapping of cap and trade revenues a big loss for Ontario tenants badly in need of apartment retrofits”   from ACORN Canada;

  “From Cap-and-Trade to White Pines: What Lies Ahead In Ontario’s Energy Sector” from Toronto law firm Gowlings .

Before his election but based on the platform statements,  Unifor said in June  : “Workers in Ontario need forward-looking policies with the intention to build a green economy, but instead Ford announced his intention to cancel a successful program and pick an unnecessary fight with the federal government…. “Workers accept that climate change is real and need our government to lead with a real, predictable plan to reduce emissions and grow green jobs.”

Was there a problem with Ontario’s cap and trade system?  The April 2018 WCR article “New evidence supports benefits of cap and trade policies”  summarized several favourable studies, including  A Progress Report on Ontario’s Cap-and-Trade Program and Climate Change Action Plan: Year One ,  published by the Clean Economy Alliance –   which concluded that, in the first year of cap-and-trade employment had grown at the same time that Ontario economy grew to a 7-year high.  Environmental Defense published “Carbon pricing has no downside: why are we still arguing about it?” , which summarized the Clean Economy Alliance report, as well as No Bad Option: Comparing the Economic Impact of Ontario Carbon Pricing Scenarios  by Hadrian Mertins-Kirkwood, published in April 2018 by CCPA in partnership with the Clean Economy Alliance.

More recently, Dale Beugin, Don Drummond, Glen Hodgson and Mel Cappe asked “If not carbon pricing in Ontario – which works well – then what, Mr. Ford?”   in a blog published by the Ecofiscal Commission.   The purpose of the brief summary is to “correct the record on some of the myths and misunderstandings surrounding carbon pricing. The economic evidence clearly contradicts some of the recent rhetoric coming from Ontario.”  Earlier Ecofiscal opinion appeared in “Tread Carefully: Ontario’s cap-and-trade system meets a fork in the road” (June 8)  , and  “Can Ontario hits its targets without carbon pricing?”  .

In the U.S.,  economist Marc Hafstead  recently published “Carbon taxes and employment: Rhetoric vs research” in the Summer Issue of Resources, the online newsletter of Resources for the Future (RFF) , stating  “Opponents of policies to price carbon will likely continue with the “job-killing” rhetoric, but careful economic analysis suggests that these arguments are seriously exaggerated.”  (the brief article is based largely on his academic working paper Unemployment and Environmental Regulation in General Equilibrium: Considering a US Carbon Tax: Economic Analysis and Dialogue on Carbon Pricing Options  )  .

 

Doug Ford has begun to dismantle Ontario’s climate leadership – Step 1, exit the cap-and-trade agreement

Doug FordAs a result of the provincial election on June 7, Progressive Conservative leader Doug Ford will take power as the premier of Ontario on  June 29, 2018.  Even before that hand-over date, he has begun to make the changes many feared –  announcing on June 15 that Ontario will exit the cap and trade market of the Western Climate Initiative (which includes California and Quebec)  and on June 19,  cancelling the $377-million Green Ontario Fund,  financed by the proceeds of cap-and-trade auctions and which provided consumer incentives for energy efficiency improvements.  On June 21, he committed to keep the Pickering Nuclear Generating Station in operation until 2024  –  in the name of protecting 4,500 local jobs and an additional 3,000 jobs province-wide.  Some general articles about the Ford government appeared in The Tyee  “Green hopes, NDP fears, and PC Dreams: The challenges that await Ontario in Ford Nation” (June 15);  “What does a Doug Ford victory mean for the climate?”  in The Narwhal (by DeSmog Canada),  and “Doug Ford’s Environmental policies light on details, advocates say” on CBC News (June 13).

Ford’s decision to end the cap and trade market has many implications – the possibility of lawsuits from investors and companies who had bought carbon credits, as well as a direct confrontation with the federal government, which requires all provinces to enact carbon pricing by 2019, under the Pan-Canadian Framework for Clean Energy and Climate Change.  Additionally, the federal government  just passed Bill C-74, which includes Part 5: The Greenhouse Gas Pollution Pricing Act on June 14 , the day before Ford’s announcement.  For discussion of the carbon pricing issue, see  “Ontario’s Doug Ford says the province is abandoning its price on carbon pollution” in the National Observer (June 15) ;  “PC’s will end Ontario cap and trade program, Ford vows” in the Globe and Mail (June 15).  An official reaction from Environmental Defence is here , with more detail in their blog, “What you need to know about Ontario’s carbon pricing drama” . From the Ecofiscal Commission, “Tread Carefully: Ontario’s cap-and-trade system meets a fork in the road” (June 8) , and “Can Ontario hits its targets without carbon pricing?”  (June 21) , which discusses the two remaining options for reducing emissions: regulations and incentives.  Finally,  the arguments are summed up in the Unifor press release, “Unifor urges Premier-designate Doug Ford to maintain the cap and trade system” : “Workers in Ontario need forward-looking policies with the intention to build a green economy, but instead Ford announced his intention to cancel a successful program and pick an unnecessary fight with the federal government…. Workers accept that climate change is real and need our government to lead with a real, predictable plan to reduce emissions and grow green jobs.”

New evidence supports benefits of cap and trade policies – an important issue for Ontario voters

With a June 2018 election approaching in Ontario,  climate change policies and the cap and trade program are already emerging as  key issues.  Several relevant reports have been published since the Environmental Commissioner of Ontario addressed these issues in her audit report,  Ontario’s Climate Act: From Plan to Progress  in January 2018.

The government’s own progress report on the 5-year Climate Change Action Plan was released on March 14  , and includes an evaluation of the policies and projects funded through Ontario’s cap and trade program. One such program is the “Low Carbon Building Skills” initiative announced in August 2017 under the Ministry of Advanced Education and Skills Development, which  aims to improve training for low carbon building projects –  including retrofits, green construction and building operations.  Other highlighted initiatives relate to hospital energy efficiency; building and school retrofits; social housing; research into climate change impacts on  building codes.

clean economy alliance progress report ontario year 1A more independent view comes in   A Progress Report on Ontario’s Cap-and-Trade Program and Climate Change Action Plan: Year One ,  published by the Clean Economy Alliance – an alliance of Ontario’s  businesses, clean technology firms, industry associations, labour unions, farmers, health advocates and environmental organizations.   In answering its key question, “Is there any evidence that cap-and-trade has hurt Ontario’s economy or cost jobs?” the report concludes that “Rather than shedding jobs, Ontario added 155,000 jobs between January 2017 and December 2017 – the first year of cap-and-trade. Gains were driven by employment growth in wholesale and retail trade, professional services and manufacturing. Cap-and-trade doesn’t appear to have hurt economic growth either. 2017 marked a 7-year high in Ontario’s GDP growth. Forecasters including RBC, TD Bank and the Conference Board of Canada agree that in 2018, economic growth will slow slightly, but will remain strong.” The report card evaluates impact on emissions reduction, as well as implementation rates by policy area (transportation, buildings and homes, land use planning, and “others”) . It concludes with a brief case study of the incentives for electric vehicles – noting that 2017 was the first year that  more electric vehicles (EVs) were sold in Ontario than in any other province.

On  April 10, the Environmental Commissioner of Ontario released another relevant report: the 2018 Energy Conservation Progress report, Making Connections: Straight Talk about Electricity in Ontario.  In this statistically-dense report, she acknowledges that the province’s electricity  system was 96 per cent emission-free in 2017, but warns that the province will fall short of its 2030 carbon reduction target unless consumer behaviour changes:  “Looking ahead, much more conservation and low-carbon electricity will be needed to displace fossil fuels as the climate crisis continues to worsen. Ontario is not yet preparing seriously for this future.”

With the explicit purpose of informing the policy discussion before and after the Ontario election in June 2018, Ontario 360  has been established at the University of Toronto’s School of Public Policy and Governance, as an “ independent, non-partisan, and fact-based” resource.  On April 18, their first briefing on Climate Policy was published, written by Trevor Tombe, associate professor of economics at the University of Calgary. The briefing reviews the cap-and-trade system and the various initiatives which have been funded by its proceeds, and provides a top-level explanation of the merits of carbon pricing in general, with a comparison of cap and trade and carbon taxes. His conclusion: “while the evidence finds that pricing should be the backbone of any credible climate policy in Ontario, it is not a magic wand. There are areas where it may not be administratively feasible, and therefore narrow complementary policies should also be on the table. And even where pricing is appropriate, reasonable people will disagree over the appropriate price level and coverage. But whatever path forward future governments choose, they should strive for transparency in costs and benefits, clarity in the goals a policy is trying to achieve, and flexibility as new evidence emerges.”

Finally, a related report from the United States was released on April 17, evaluating the economic and environmental impacts of the cap and trade markets of the Regional Greenhouse Gas Initiative ( RGGI) in the U.S. from 2015-2017 .  The Economic Impacts of the Regional Greenhouse Gas Initiative on Nine Northeast and Mid-Atlantic States   found that the nine states which form the network  gained $1.4 billion in economic benefits over the past three years because of the way they invested proceeds, with the biggest payoffs (including in new jobs) coming from investments in energy efficiency programs.  In the same period, there has been no damage to the reliability of the electricity grid, nor a net increase in electricity bills.    The Economic Impacts of the Regional Greenhouse Gas Initiative on Nine Northeast and Mid-Atlantic States  was produced by The Analysis Group , who also were responsible for two previous evaluations since the RGGI launched in 2009, available here .

Ontario’s GHG emissions at lowest level since 1990 – Environmental Commissioner commends the first year of cap and trade but recommends changes for freight sector, green procurement

Ontario logoOn January 30, 2018  the Environmental Commissioner of Ontario (ECO) submitted her annual Greenhouse Gas Progress Report to the Legislative Assembly of Ontario –  an independent, non-partisan review of the government’s progress in reducing emissions for 2016-2017.  The report, Ontario’s Climate Act: From Plan to Progress  covers the period since the  Climate Change Action Plan was introduced in June 2016, and the  cap and trade market became effective January 2017.  The report provides detailed emissions  statistics by sector and sub-sector, catalogues and critiques climate-related policies, and places Ontario’s initiatives in a national and international context – especially the cap and trade market and its relationship with the Pan-Canadian Framework on Clean Growth and Climate Change.  Top-level findings:  overall, GHG emissions were at the lowest level since reporting began in 1990 and “the first year of cap and trade went remarkably well”. Because  Ontario’s market is part of the Western Climate Initiative (WCI) which  includes California and Quebec, the report warns that prices make weaken because of political  uncertainty in the U.S., and also calls for more “bang for the bucks” in the Greenhouse Gas Reduction Account, which manages the proceeds of the carbon auctions.  Chapter 4 includes an explanation and critique of Ontario’s proposed carbon offsets, which are also tied to the WCI, and states that some sectors at some risk of being little more than greenwashing.  The Commissioner singles out the emissions of Ontario’s transportation industry and  states that it will be impossible to meet Ontario’s emissions reduction targets unless urgent action is taken to rein in emissions from the freight sector, with recommendations to “encourage the freight sector to avoid trucking where possible (e.g., through logistics and road pricing), improve diesel truck efficiency (e.g., through incenting the scrapping of older diesel trucks), and shift freight away from fossil fuels (e.g., providing more targeted support for zero-emission trucks).” UPS electric truck The report also calls for improved green procurement policies in government’s own spending and a stronger climate lens for regulation, taxation and fiscal policies.  The  Ministry of Energy is singled out in this regard:   “For example, the Ministry of Energy by itself governs 70% of Ontario’s emissions, yet its 2017 Long-Term Energy Plan does little to achieve Ontario’s climate targets.”  An 8-page summary of the report is here ; the full report, (all 284 pages) is here ;  eight Technical Appendices are available from this link.

 

Ontario announces initiative re energy efficiency in hospitals, and updates Infrastructure Plan

hospital for sick kidsA press release on November 27 from Ontario’s Ministry of Health announced  an  investment of $64 million through  a Hospital Energy Efficiency Program, which will support 180 projects at 98 hospitals across the province, providing more efficient heating, ventilation, air conditioning and lighting. The funds will be directed from the proceeds of cap and trade auctions, and are in addition to the $9 billion for new hospital projects already announced in the 2017 Budget statement, as part of Infrastructure spending.

On November 28,  the government released Building Better Lives  , an  update for 2017 about the  Ontario Long Term Infrastructure Plan which was launched in 2014, and which integrates climate change priorities in infrastructure planning for public transit, transportation, schools and hospitals.    The government press release cites a study by the Centre for Spatial Economics to defend its program.   The Economic Benefits of Public Infrastructure Spending in Ontario (March 2017) estimates that  in the short-run, gross domestic product rises $0.91per dollar of spending, 4.7 jobs are generated per million dollars spent,  and $0.27 of each dollar spent by government is recovered in additional Ontario and federal and government revenues.

Building Better Lives also includes a Technical Appendix with details on the asset management strategies of key ministries and agencies, as well as information about their assets. The Appendix also provides an overview of the three-year review to be undertaken to identify best practices and to transform the asset management process for government ministries.  This status report and review is required under the Ontario Infrastructure for Jobs and Prosperity Act, 2015.

Proposals for a green transition that is just and inclusive in Ontario

decent_work_in_the_green_economy-coverDecent Work in the Green Economy, released on October 11 , combines research on green transitions worldwide with the reality of  labour market trends in Ontario, and includes economic modelling of  Ontario’s cap and trade program, conducted by EnviroEconomics and Navius Research.  The resulting analysis identifies which sectors are expected to grow strongly under a green transition (e.g. utilities and waste management and remediation),  which will see lower growth (e.g. petroleum refining and petrochemical production), and which will see a transformation of skills requirements (e.g. mining, manufacturing, and  forestry). Section 3 of the report discusses the impacts on job quality (including wages, benefits, unionization, and job permanence), as well as skills requirements.  The general discussion in Section 3 is supplemented by two detailed Appendices about the employment impacts by economic sector,  and by disadvantaged and equity-seeking groups (which includes racialized workers, Indigenous people, workers with disabilities, newcomers, women, and rural Ontarians.) A final  Appendix describes the modelling behind the analysis, which projects employment impacts of low carbon technologies by 2030.

The paper calls for a comprehensive Just Transition Strategy for Ontario, and proposes  six core elements illustrated by case study “success stories”.   These case studies include the Solar City Program in Halifax, Nova Scotia, (which uses local supply chains and accounted for local employment impacts), and the UK Transport Infrastructure Skills Strategy (which incorporated diversity goals and explicit targets in workforce development and retraining initiatives).  An important element of the recommended Just Transition Strategy includes a dedicated Green Transitions Fund, to transfer funding for targeted programs to communities facing disproportionate job loss; to universities or colleges to provide specialized academic programs; to social enterprise or service providers to carry out re-training programs; to directly impacted companies to invest in their employees; and to individuals in transition (much like EI payments).

The authors also call for better data collection to measure and monitor the link between green economy policies and employment outcomes, and better mechanisms for regular, ongoing dialogue.  This call for ongoing dialogue seems intended to provide a role for workers (and unions, though they are less often mentioned). The authors state: “No effort to ensure decent work in the green economy will be successful without meaningfully engaging workers who are directly impacted by the transition, to understand where and how they might need support. Just as important will be the ongoing engagement with employers and industry to understand the changing employment landscape, and how workers can best prepare for it.” And, on page 39,  “Public policy will be a key driver in ensuring that this transition is just and equitable. …. Everyone has a role to play in this transition. Governments, employers, workers, unions and non-profit organizations alike must remember that if we fail to ensure that the green transition is just and inclusive, we will have missed a vital opportunity to address today’s most pressing challenges. But if we design policies and programs that facilitate this transition with decent work in mind, they have the potential to benefit all Ontarians.”

Decent Work in the Green Economy was published by the  Mowat Centre at the University of Toronto, in cooperation with the Smart Prosperity Institute at the University of Ottawa.  In addition to economic modelling, the analysis and policy discussion is based on an extensive literature review as well as expert interviews and input from government, industry, labour and social justice representatives. Part of the purpose of the report is to initiate discussion “between those actively supporting the transition to a green economy and those advocating for decent work” as defined by the ILO.  Further, the report states: “ Importantly, this conversation must address the need for equal opportunities among historically disadvantaged and equity-seeking groups who currently face barriers to accessing decent work.”

Nova Scotia introduces Cap-and-Trade legislation

A press release on September 29  announced that the Nova Scotia government has introduced amendments to the Environment Act, enabling regulations to set caps on GHG emissions, distribute and enable trading of emission allowances within the province, and set a province-wide greenhouse gas emission target for 2030.  The province will create a Green Fund to support climate change initiatives and innovations, and  money from emissions sales and fines will be deposited there.  Next steps include “developing greenhouse gas reporting regulations this fall and consulting with stakeholders on them”.

The amending legislation, Bill 15, received first Reading in the Legislature on September 29 as a means to satisfy the requirement of the Pan-Canadian Framework on Clean Growth and Climate Change.   However, reaction from the Ecology Action Centre in Halifax urges the federal government to reject the plan, stating that “A carbon pricing system that doesn’t actually put a price on carbon, support low-income people, or incentivize clean growth truly misses the point.” The EAC also warns of the risks of extreme volatility since the plan is structured to create a carbon market within Nova Scotia alone – covering a population of under a million people and about 20 businesses. In  “Time for Ottawa to cry foul over Nova Scotia cap-and-trade proposal” published in the Hill Times and reposted at Pembina (Nov. 2) , the verdict is similarly negative: “Nova Scotia’s cap-and-trade system could cause the province to lose its foothold on climate leadership. In order to secure a clean, prosperous economy into the future, the provincial government should consider other approaches.”

The Ecology Action website has compiled documents and submissions from the provincial consultations leading up to the September announcement. The Canadian Centre for Policy Alternatives Nova Scotia Office published a Backgrounder in May 2017 which outlines its proposals for a stronger cap-and-trade policy.

Ontario, Quebec and California sign formal agreement to link their carbon markets

On September 22, Premier Couillard of Quebec hosted Premier Wynne of Ontario and California Governor Jerry Brown in Québec City, where they signed an agreement which formally brings Ontario into the existing joint carbon market of the Western Climate Initiative (WCI).  This comes as no surprise: the government had announced its intention to join the WCR in April 2015 as part of its Climate Change Action Plan.  When Ontario joins up with Quebec and California, effective January 1, 2018,  the carbon market will cover a population of more than 60 million people and about C$4 trillion in GDP. The three governments will harmonize regulations and reporting, while also planning and holding joint auctions of GHG emission allowances.  Text of the Agreement on the Harmonization and Integration of Cap-and-Trade Programs for Reducing Greenhouse Gas Emissions is here.  Here is  an introduction to Ontario’s cap and trade program, which was announced as part of the  For an up-to-date description of the Western Climate Initiative and its importance as a model for sub-national, international co-operation, see   “Will Other States Join California’s International Climate Pact?”  in The Atlantic (August 10  2017).

The Western Climate Initiative Inc. is  based in Sacramento California, and  is now  “a non-profit corporation formed to provide administrative and technical services to support the implementation of state and provincial greenhouse gas emissions trading programs” .

Federal government about to release its proposals for promised national carbon pricing system as California debates radical changes to its cap-and-trade program

In advance of a consultation paper by the federal government, expected to be released in the week of May 15, the Pembina Institute released a Backgrounder report , Putting a price on carbon pollution across Canada . The Pembina report  outlines the current federal and provincial carbon pricing policies in Canada, and makes recommendations for the national benchmark plan promised by 2018. Recommendations  include that any benchmark should at least  provide guidance on treatment of Export Import Trade Exposed sectors and be designed to minimize carbon leakage and competitiveness impacts; and stipulate that cap-and-trade systems must have a cap decline rate in line with a 30% reduction below 2005 levels by 2030. Pembina places emphasis on the need for a 2020 carbon pricing review, as well as frequent carbon pricing and climate policy reviews to ensure that Canada meets its obligations under the Paris Agreement.

A briefer paper on carbon pricing, also released in May, also summarizes the existing provincial carbon pricing plans – but from a right-wing point of view. From the Fraser Institute:   Poor Implementation undermines Carbon Tax efficiency in Canada  .

Also on the topic of carbon pricing, Pembina posted a blog  on May 11 “Time for Premier Brad Wall to focus on carbon price implementation” , in which Nathalie Chalifour, a Professor of Law at University of Ottawa, explains her opinion that the federal government is within its constitutional authority to impose a carbon pricing mechanism on the provinces, despite Saskatchewan Premier Brad Wall`s recently stated opinion to the contrary.

Meanwhile, as reported in the National Observer (May 4) , “California tables new cap-and-trade plan that jumps ahead of Quebec and Ontario” . Quebec and California  have a linked carbon credit market that expires at the end of 2020, and Ontario`s cap and trade plan is schedule to link to the California−Quebec system in 2018.  Continued partnership with California  will demand that those provinces raise their minimum price per tonne of carbon and abolish offsets, among other changes outlined in the  bill currently before the California state Senate . For a full discussion of the proposed legislation, read “California is about to revolutionize climate policy … again” (May 3) in Vox.  Author David Roberts states: ” The changes that SB 775 proposes for the state’s carbon trading program are dramatic — and, to my eyes, amazingly thoughtful. I know some environmental groups have reservations (on which more later), but in my opinion, if it passes in anything close to its current form, it will represent the most important advance in carbon-pricing policy in the US in a decade. Maybe ever.”

Cap-and-Trade proposals for Nova Scotia – and beyond?

A discussion paper released in early March by the government of Nova Scotia proposes the structure of a cap-and-trade system for the province, as required by the Pan-Canadian Framework on Clean Growth and Climate Change .  Nova Scotia is a reluctant participant in the national carbon pricing regime of the Framework, having walked out of one of the federal-provincial meetings on the topic in October 2016.

The Discussion paper, Nova Scotia Cap and Trade Program Design Options , proposes a plan which covers only those sectors required by the Framework, and grants free allocations to them, including Nova Scotia Power and the suppliers of fossil fuel. Sectors not included represent about 10% of emissions, and would be allowed to sell offsets into the system.  Fugitive emissions will not be included.  As stated in the Discussion paper, the system will not align itself with any other provinces. Yet, days after the release, and in apparent contradiction to the Discussion paper, the CBC reported that the Premier is still in discussion with the provinces of New Brunswick and Prince Edward Island about a regional system : see “Welcome to join: Atlantic cap and trade system explored” .

An excellent summary of the features and failings of the plan appears in a post from the  Environmental Law blog from Dalhousie University.  It states that the proposed plan    seems designed to meet the minimum GHG emission reductions obligations under the Pan-Canadian Framework, while also minimizing any impact on Nova Scotia’s economy. “We are clearly far from getting our C&T system right. To do so, would take time, careful analysis and a public dialogue on priorities and values rather than starting assumptions that all we care about is trying to preserve the status quo for as long as we can.” Unfortunately, the deadline for public submissions was March 31, less than a month after the release.

Political Manipulation Could Derail Nova Scotia’s Cap and Trade System”  in the Halifax Examiner is also highly critical. Author Brendan Haley decries the lack of time and opportunity for public input, and states that political expediency seems to be motivating the design of the carbon pricing system .  The Ecology Action Centre also has concerns over the proposed system   – their position paper is here .

 

 

 

 

Health Impacts of Cap and Trade policies on California’s disadvantaged communities

Acting on a December 2016 Executive Order of Governor Gerry Brown, the California Office of Environmental Health Hazard Assessment released the first in a series of reports which will examine the impact of the state’s climate change programs on communities designated as “disadvantaged”.  The February report,  Tracking and Evaluation of Benefits and Impacts of Greenhouse Gas Limits in Disadvantaged Communities: Initial Report   measuring the effects of  the Air Resources Board’s Cap-and-Trade Program, which regulates greenhouse gas emissions from industrial facilities and other sources.  The report is largely based on 2014 emissions data, and warns that “limited data does not yet allow for comprehensive analysis of the impacts of Cap-and-Trade on disadvantaged communities”.   Initial findings however, are that  major industrial facilities are disproportionately located in disadvantaged communities;  there is a moderate correlation between GHG and other air pollutants, with refineries showing the strongest correlation.   California maintains  a planning and enforcement tool,  CalEnviroScreen, the “ first comprehensive, statewide environmental health screening tool” in the U.S.  In late January, California Air Resources Board   announced the appointment of its first Assistant Executive Officer for Environmental Justice, with a mandate to ensure that environmental justice and tribal concerns are considered in air pollution policy-making and decision- making.

California reaffirms commitment to Cap-and-Trade policies, based on economic evidence

California’s climate leadership position in the U.S.  was solidified on January 20, 2017 – coincidentally Inauguration Day in Washington-  when the California Air Resources Board released its 2017 Scoping Plan Update: The Proposed Plan for Achieving California’s 2030 Greenhouse Gas Target . Proposals include a target to reduce greenhouse gas emissions by 40 percent below 1990 levels by 2030 – the most ambitious target in North America, according to a Reuters report  .  The plan also extends the cap-and-trade program to 2030, based on economic modelling  which concludes that cap-and-trade is the lowest cost, most efficient policy approach and provides certainty that the state will meet the 2030 emissions goals even if other measures fall short.  The Scoping Plan also call for an 18 percent reduction in the carbon intensity of transportation fuels burned in the state, and for 4.2 million zero-emission vehicles on the road.  The proposals, a hearings schedule, and technical appendices are all available at the ARB website .

Another  economic analysis evaluating cap-and-trade was published in January by Next10.    The Economic Impacts of California’s Major Climate Programs On The San Joaquin Valley ,  analyses the  costs and benefits, including job gain and loss, of three pro­grams: Cap- and- trade, the Renewables Portfolio Stan­dard,  and energy efficiency programs, specific to the to the San Joaquin Valley economy. The authors chose to examine the San Joaquin  as a “a bellwether of the state’s transition to a low-carbon economy” since its geography and dependence on agriculture  make it vulnerable to climate change effects , and vulnerable also  to climate policies because “it faces more socioeconomic chal­lenges than the state as a whole”.    After examining the data and using advanced modeling software, they found that the three programs brought over $13 billion in economic benefits to the Valley, mostly in renewable energy, and created over 31,000 jobs just in the renewable energy sector alone.  Research and analysis was done by academics at  the Center for Law, Energy and the Environment (CLEE) at UC Berkeley Law and UC Berkeley’s Donald Vial Center on Employment in the Green Economy .

Carbon pricing in Canada: Recent research, and implementation in Alberta and Ontario

Research about carbon pricing continues in the effort to implement the Pan-Canadian Framework.   In November,  Carbon Pricing and Intergovernmental Relations in Canada was released by the Institute for Research on Public Policy,  evaluating  the federal government’s national carbon pricing plan to that point (i.e. before the announcement of the Pan-Canadian Framework ), with an emphasis on the flexibility required for provincial differences. It then discusses the intergovernmental coordination in other policy fields in Canada ( income taxes, goods and services taxes, and environmental standards) as a possible model for carbon pricing.

As part of the Pan-Canadian Framework in December , the comprehensive  Final Report of the Working Group on Carbon Pricing Mechanisms  was released, providing an overview of Canadian and international practice, as well as a discussion of principles for design and implementation.

Finally, a report about British Columbia, the home of Canada’s first carbon tax. A  December report modelled the impact of the 2016 provincial Climate Leadership Plan and a federal carbon price on GHG emissions. It concludes that even  if all provincial policies were implemented,  B.C.’s emissions will exceed the targets for 2020 and for 2050. The report provides a breakdown of emissions by sector and forecasts that the largest single source of emissions in 2050 will be from shale gas operations and liquefied natural gas projects.  Modelling the Impact of the Climate Leadership Plan and Federal Carbon Price on British Columbia’s Greenhouse Gas Emissions  was commissioned by Clean Energy Canada,  the Pacific Institute for Climate Solutions and the Pembina Institute, with analysis by Navius Research.

In the meantime, two provinces have moved ahead with previously announced policies. Alberta’s carbon levy came into effect on January 1, 2017, cushioned by the government press release of  December 31  titled  “Carbon levy supports diverse, green economy and jobs”  which summarized the details. The levy will be charged on transportation and heating fuels  – diesel, gasoline, natural gas and propane – at a rate of $20 per tonne, increasing to  $30 per tonne in 2018.  As further explained on a government website  , farmers and First Nations are generally exempt; a 33 per cent small business tax rate cut will help offset costs for small businesses, and the direct and indirect costs to consumers  are estimated. Rebates started flowing for a majority of Alberta households on January 5, with a payment  of $200 per year for a single adult earning up to $47,500 per year , and $300 for a couple earning up to $95,000 per year.   In addition to the government explanation, see “What you need to know about Alberta’s Carbon Levy”   from the Pembina Institute ,  or a CBC  interview with Andrew Leach , generally considered the architect of Alberta’s climate plan . “The Cost of Carbon Pricing in Alberta and Ontario”, by professors Trevor Tombe and Nic Rivers, appeared in Maclean’s magazine (Jan. 4). It explains the differences in the two approaches and explains the methodology for their estimate that  “Overall, for the average Alberta and Ontario household in 2017, direct costs will likely be on the order of $150 to $200 annually and indirect costs will add an additional $80 to $100 or so.”  The conclusion:  “heated political rhetoric that suggests carbon pricing will lead to skyrocketing price increases throughout the economy is misplaced at best and misleading at worst.”

Media rhetoric seems to have been directed at Alberta, rather than Ontario, where the cap and trade system, a cornerstone of the Climate Action Plan , also took effect on January 1, 2017.  The government’s Explainer is here , and estimates that “it will cost the average Ontario household about $13 more per month to fuel a car and heat a home in 2017”.  The government also estimates  proceeds of $1.9 billion per year , which must be re-invested to reduce GHG emissions, such as social housing retrofits, public  transit, and electric vehicle incentives.  See details of the related Green Investment Fund here.  The 2016 Annual Greenhouse Gas Progress Report  (November 2016) of Ontario’s Commissioner of the Environment  offers an explanation of how the system works, and discusses pitfalls, solutions, the need for transparency, and the likelihood that the system will deliver the scale of GHG reductions promised.

 

Canada’s Pan-Canadian Framework on Clean Growth and Climate Change: an important first step

first ministers.jpgOn December 9, a Communique from the First Ministers of Canada announced the Pan-Canadian Framework on Clean Growth and Climate Change, following the commitments made in the Vancouver Declaration of March 2016 . The Framework promises that 90 percent of Canada’s energy needs will be met by clean sources by 2030, and  emphasizes carbon taxes and new investment in clean technologies.  For a general summary, see the CBC here  .  Unsurprisingly, Saskatchewan, which has been steadfastly opposed to carbon taxes, refused to sign the agreement; Manitoba, more surprisingly, also refused, and has been accused of attempting political horsetrading by linking support for the climate pact to health care budget needs.  See “Trudeau claims victory on national climate framework”  and  “Inside Christy Clark’s climate change brinksmanship”  in Maclean’s (Dec. 9 &  10) for reporting on what went on behind the closed doors of the premiers’ meeting.

There is scant reference to jobs or workers in the Pan-Canadian Framework.  A weak and unique reference to Just transition appears in this statement on page 40, in the “Section on Clean Technology, Innovation and Jobs”:  “Further development of clean technologies could create new opportunities in Canada’s resource sectors, increase the productivity and competitiveness of Canadian businesses, and create new employment opportunities, while also improving environmental performance. Canada will need to be able to access the skills and expertise of talented workers from around the world to enable Canadian businesses to succeed in the global marketplace. It will also be important to ensure a commitment to skills and training to provide Canadian workers with a just and fair transition to opportunities in Canada’s clean growth economy.” Civil society groups are only vaguely indicated in the statement:  “Governments, Indigenous Peoples, industry, and other stakeholders all have a role to play and must be engaged.”

See a dedicated website with details of the Pan-Canadian Framework on Clean Growth and Climate Change . The Framework document is here .   The Ministers’ discussions were informed by the reports of the four Working Groups struck following the Vancouver Declaration : the Working Group Report on Carbon Pricing;    the Working Group Report on Clean Technology, Innovation and Jobs;  the Working Group Report on Specific Mitigation Opportunities ; and the Working Group Report on Adaptation and Climate Resilience .

Climate Action Network has compiled responses to the Framework  in “ Civil Society Responds to Release of Canada’s National Framework for Climate Action”;  most reactions reflect the  common theme that this is a commendable good start, but much more is required to meet our Paris commitments.  The comment from the David Suzuki Foundation was also typical:  “For a plan to be credible, it must not send mixed signals about national priorities. Responsible action on climate change means shifting from fossil fuels and diversifying the economy to ensure Canadians have good jobs today and into the future while also protecting the environment.”

The Pembina Institute says specifically:   “We applaud the first ministers’ effort made to date and expect continued collaboration and swift implementation of all recently announced climate measures. In particular, it is essential that provinces work with the federal government to adopt strengthened building codes, to implement an effective clean fuels standard, and to increase the carbon price after 2022.”

The Climate Action Network also cites specifics  in  A Canadian Accountability Mechanism ,   asserting: “Canada must adopt a more ambitious climate pledge (NDC) in 2018, by which time all countries should come up with the tougher actions they will take after 2020. …  “It’s time to break the cycle of empty target-setting in Canada. We know it’s absolutely possible to reach Canada’s current goal of reducing GHG emissions by 30% below 2005 levels by 2030. We also know the 2030 target does not represent our fair share of addressing global climate change and that Canada needs to do more. CAN-Rac’s estimations of Canada’s fair share contribution suggests we should be reducing emissions by 50% below 2005 levels by 2030 while increasing our contribution to international climate financing to $4 billion/year by 2020.”

The Framework highlights all the right things, including: “ respecting the rights of Indigenous Peoples, with robust, meaningful engagement drawing on their Traditional Knowledge” , and  “the importance of ongoing collaboration”, “leveraging technology and innovation to seize export and trade opportunities for Canada, which will allow us to become a leader in the global clean growth economy”.  But it is not yet a plan: (“We have tasked our ministers and officials to implement the Framework and report back to us on progress within a year, and annually thereafter.”) Nor will it be implemented quickly: (“ Federal, provincial and territorial governments will work together to establish a review of carbon pricing, including expert assessment of stringency and effectiveness that compares carbon pricing systems across Canada, which will be completed by early 2022 to provide certainty on the path forward. An interim report will be completed in 2020, which will be reviewed and assessed by First Ministers. As an early deliverable, the review will assess approaches and best practices to address the competitiveness of emissions-intensive, trade-exposed sectors.”)    An essay by the Pembina Institute, from the Pembina Institute, “Canada is back” — on Friday, let’s hope for one more time with feeling”  (Dec. 8) anticipates what should be included, and thus   provides a yardstick by which to measure how successful the Framework agreement will be.

Canada votes to ratify the Paris Climate Agreement

The Paris Climate Agreement will enter into force on November 4, 2016, now that 73 nations accounting for nearly  57%  of GHG emissions have formally ratified it: most recently, India, the European Union and Canada.  According to an October 5 article in The Guardian, even if Donald Trump were to win the U.S. presidency, the U.S. would be locked into the commitment for four years at least. See also “The Paris Climate Agreement is entering into force. Now comes the hard part ” from the Washington Post (Oct. 4). Next step: the COP 22 meetings scheduled for Marrakesh, Morocco from November 7 – 18, which  will  include the first meeting of the Parties to the Paris Agreement (CMA 1).

In Canada,  Members of Parliament voted by a margin of 207 to 81 to approve the Paris Agreement on October 5  – see the brief  government press release, or  read  the CBC report; or  coverage at the National Observer , or the Globe and Mail .  Transcripts of the debates in the House of Commons are here,  for October 3  (Trudeau’s carbon pricing speech) , October 4 and October 5  (when the vote was held) .

Leading up to the Paris vote, in what has been called a “bombshell”, “ultimatum”, and “his government’s most consequential and surprising day to date”   , Prime Minister  Trudeau announced  the “Pan-Canadian Approach on Pricing Carbon Pollution”  in the House on October 3, requiring  that provinces implement either a carbon tax (at a  minimum price of $10 a tonne in 2018, rising each year to $50 a tonne by 2022) or a cap and trade system.  “If neither price nor cap and trade is in place by 2018, the government of Canada will implement a price in that jurisdiction” . Provinces will retain revenues from whichever system they choose to implement.

An article at the CBC   states that, “Trudeau’s pre-emptive announcement landed like a grenade”  in the midst of the the Canadian Council of Environment Ministers’  meeting in Montreal, being chaired by Environment and Climate Change Minister McKenna.     Delegates from Saskatchewan, Newfoundland and Nova Scotia walked out of the room.  For a summary of the political fight, see “Premiers draw battle lines as Trudeau seeks support for carbon-pricing plan”  in the Globe and Mail (Oct. 4). And see the Alberta government press release   of October  3,  which states , “Alberta will not be supporting this proposal absent serious concurrent progress on energy infrastructure, to ensure we have the economic means to fund these policies…..Albertans have contributed very generously for many years to national initiatives designed to help other regions address economic challenges. What we are asking for now is that our landlock be broken, in one direction or another, so that we can get back on our feet.”   A tough demand to meet, according to David Hughes’ report in June  “Can Canada Expand Oil and Gas Production, Build Pipelines and Keep Its Climate Change Commitments?” .

Some reactions to the federal carbon pricing announcement:  From the Canadian Labour Congress:   “The CLC applauds carbon pricing targets …. “As a next step, the CLC calls for a federal strategy to guarantee new opportunities for workers and communities impacted by the transition to a low-carbon economy.”  From the Climate Action Network ;  from the Pembina Institute  (“Pan-Canadian carbon price is big, positive news for economy and environment” );   from DeSmog Canada   (The Good, bad and the ugly)   .  Generally supportive reaction also came  from Smart Prosperity, a group composed of  twenty-two prominent business and civil society leaders (including WWF, Broadbent Institute, Clean Energy Canada, and the Pembina Institute) .   Yet Marc Lee of the Canadian Centre for Policy Analysis  nails it in  “A Reality Check on a national carbon price”  ( October  4) :    “It’s good news that Canada is starting to listen to climate science, but we are still left with a problem around the climate math”  – which requires  no new fossil fuel infrastructure.    Bill McKibben, populizer  of the term “climate math”, also panned the Trudeau announcement in the National Observer on Oct. 3.  Read McKibben’s article  “Recalculating the Climate Math: The numbers on global warming are even scarier than we thought”   in the New Republic (September 22),which updates his earlier, frequently cited piece.

A useful overview  to understand the Canadian situation: Race to the Front,  released by the Pembina Institute on September 28, with recommendations for the politicians and policy-makers  in their Fall  working meetings to finalize  a “Pan Canadian”  policy.  Race to the Front summarizes Canada’s progress at reducing carbon pollution over the last decade, evaluates trends in Canada’s greenhouse gas emissions inventory, and summarizes existing national and provincial  climate policy .

 

 

 

Pricing carbon: views from Marc Jaccard and Unifor

Energy economist Marc Jaccard has written previously on the need for political reality in the discussion of carbon taxes.  In September, he and colleagues at Simon Fraser University released a new paper  Is Win-Win Possible? Can Canada’s Government Achieve Its Paris Commitment. . . and Get Re-Elected?. As described at his own blog , the report uses a national energy-economy model to simulate climate policy scenarios that explore the effect of current Canadian policies, and contrast the current policies with 1. “must-price-emissions” policies  and 2. Flexible regulations, such as those in California.  The  alternative policy approach in Is Win-Win possible assumes that the federal government would apply flexible regulations in key sectors – transportation, electricity generation, industry, etc. – in conjunction with a modest emissions price, reaching $40 by 2030.

Another carbon market piece, released in iPolitics at the end of August summarizes Unifor’s position on Ontario’s cap and trade regulations.“Could Ontario’s climate strategy trigger an industrial exodus? Not if the province acts now to blunt the effects” by Jordan Brennan  identifies industrial leakage as “an obvious threat” to the  cap-and-trade program underway in Ontario.  Stating that firms operating in emissions-intensive trade-exposed (EITE) industries …(like auto manufacturing for instance …)  might relocate to jurisdictions that do not price carbon,  Brennan summarizes recommendations that his union,  Unifor,  has made : “ First, ‘transition credits’ should be allocated to industries that bear an extraordinary burden of change. Second, the cap-and-trade program should include a ‘carbon price border adjustment’ to ensure that commodities entering Ontario from jurisdictions without a carbon price (or with a lower price) do not gain an unfair cost advantage over Ontario producers. Third, the carbon revenue system should not be revenue-neutral. The Green Fund should be used for ‘just transition’ as well as mitigate the impact on low-income people and to foster the development of low-carbon technologies such as energy efficiency, retrofits and renewable energy.” Unifor’s public reaction to Ontario’s Climate Action Plan in June 2016 is here. 

Recent research on Carbon Taxes and Cap and Trade

Before the May announcement of Ontario’s Climate Change Mitigation and Low-carbon Economy Act ,   a working paper released in April by the Institute for Competitiveness and Prosperity at the University of Toronto models the impact of Ontario’s proposed cap-and-trade program on economic growth and greenhouse gas emissions, considers complementary policies that reduce greenhouse gas emissions , and makes ten recommendations.  Read  Towards a low Carbon Economy: The Costs and Benefits of Cap and Trade here  .   The Effect of Environmental Policies on Jobs: Painting a More Complete Picture   explains a new general equilibrium model, developed by economists at Resources for the Future,  which incorporates a job search requirement in the model.   The subsequent Discussion Paper, Unemployment and Environmental Regulation in General Equilibrium  concludes that “a modest economy-wide carbon tax would likely cause a substantial shift in employment between industries, but would have little overall effect on unemployment, even in the short run…An environmental performance standard causes a substantially smaller sectoral shift in employment than the emissions tax, with roughly similar net effects.”

Ontario’s New Climate Change Legislation centres on Cap and Trade and Green Investment

Bill 172, Climate Change Mitigation and Low-carbon Economy Act, 2016 passed 3rd reading in  the Ontario Legislature on May 18th and will become law upon Royal Assent.   The law sets GHG emission reduction targets of of 15 per cent by the end of 2020;  37 per cent by the end of 2030; and 80 per cent by the end of 2050. The bill also sets out the framework for the Cap and Trade program: the official Ontario Regulation 144/16 (May 19)   is here  ; the government summary is here  ; a summary by the National Observer is here .   The first year of the program, 2017, sets  an economy-wide cap of 142 megatonnes per year , declining to 125 megatonnes per year by 2020. All proceeds from the cap and trade program will be deposited into a new Greenhouse Gas Reduction Account,  which will “ be invested in a transparent way back into green projects that reduce greenhouse gas pollution and help homeowners and businesses save energy such as public transit, clean-tech innovation for industry, electric vehicle incentives, social housing retrofits.”   The details of implementation will come in June when the government releases the first of the Climate Action Plans required under the legislation.

Key to the Government’s public relations battle is a report by EnviroEconomics, Navius Research and Dillon Construction: Impact Modelling and Analysis of Ontario Cap and Trade Program , which analyses four alternate program structures and concludes that the proposed program will be least costly  to households and have the lowest impact on provincial GDP ( the proposed plan resulting in the equivalent to a drop in growth of 0.03% in 2020). The Clean Economy Alliance , a multi-sector coalition of 90 green organizations, had called for explicit Just Transition language for workers in the legislation, according to a Unifor press release , but the only “transition” changes in t he final text of the legislation appear in section 2.1, regarding households:  “The action plan must consider the impact of the regulatory scheme on low-income households and must include actions to assist those households with Ontario’s transition to a low-carbon economy.”

Nevertheless, reaction by environmental groups has been enthusiastic: the Clean Economy Alliance press release welcomes the legislation, and Keith Brooks, Director of Clean Economy, calls the legislation “a big deal”, “a huge step forward, and one worthy of celebration” in his blog; the Pembina Institute says  “ it is laying the foundation for solid success”.  In the mainstream media, pushback started with a story in the Globe and Mail on April 27, “New Ontario agency will be given sweeping mandate to overhaul energy use”  – which summarized details of a leaked, preliminary draft of the the Climate Change Action Plan (still under discussion in Cabinet).  More leaked details were revealed in “Ontario to spend 7 Billion in sweeping climate change Plan”    (May 16) , which states that the province will set lower carbon fuel standards for gas and diesel, change building codes to require all new homes by 2030 to be heated with electricity or geothermal systems (currently 76% of homes are heated with natural gas), and set a target for 12 per cent of all new vehicle sales to be electric by 2025.  In “Ontario passes bill to create cap and trade system”  on May 19, the Globe tempers the storm their reporting has created with: “The Liberals deny a published report claiming their climate change plan would include phasing out the use of natural gas for home heating, and point out they are expanding the gas grid to more rural areas of the province.”  On May 20, Nic Rivers, Canada Research Chair in Climate and Energy Policy at the University of Ottawa, weighs in with “The Ontario climate plan: Should provinces follow or flee?”  .

Ontario reveals its proposals for Cap and Trade

The Ontario government introduced Bill 172, the Climate Change Mitigation and Low Carbon Economy Act to the Legislature on February 24, 2016; a summary is available here ; the Bill and status is available here .  It proposes to establish greenhouse gas emissions targets in statute for 2020, 2030 and 2050, with the option to establish interim or more stringent targets through a regulation. Most notably, it establishes the expected cap and trade program, with  requirements for greenhouse gas emissions quantification and calculation, reporting and verification, the submission of allowances and credits to match greenhouse gas emissions,  the creation , distribution and trading of allowances and credits,  and an offset program. The full and detailed outline of the Regulatory proposals re the Cap and Trade program are available at the Ontario Environmental Registry, open for public comment until April 10, 2016.   .  Other announcements:  $5 million from the Green Investment Fund to provide Indigenous communities with training, tools and infrastructure to address climate change, with additional $8 million to develop advanced microgrid solutions in First Nations communities(March 17);  provincial investment and partnership with a  Japanese company Mitsui High-tec to build the first manufacturing facility in Ontario, in Brantford, to produce motor cores for electric and hybrid vehicles.

Ontario releases Climate Change Strategy and Cap and Trade Discussion Paper

On November 24, 2015 the government of Ontario released its Climate Change Strategy , a broad document that sets out Ontario’s vision for achieving the GHG reduction target of 80 per cent below 1990 levels by 2050. A separate five-year action plan is promised for 2016, which will include specific commitments for meeting the 2020 emissions reduction target, as well as establish the necessary framework for the  2030 and 2050 targets.   The government has also released a discussion paper: Cap and Trade Program Design Options , (summarized in the Globe and Mail  ). Comments about the cap and trade design can be submitted until December 15.  A draft regulatory proposal will be tabled early in 2016, triggering another public comment period. The Clean Economy Alliance released Getting it Right: Design Recommendations for Ontario’s Cap and Trade System , which recommends policies to make polluters pay for the pollution they generate, while being “ fair to workers, families and industries that are disproportionately affected”. The Climate Action Network Canada surveyed 857 Ontarians in September 2015 regarding carbon pricing and cap and trade systems. Results are here .

Deep Decarbonization Pathways Reports released

POLICY PRESCRIPTIONS FOR A DECARBONIZED ECONOMY
The Deep Decarbonization Pathways Project is a consortium of energy researchers from the 16 countries which are the world’s largest GHG emitters. In mid-September, the DDPP released a  Synthesis Report and 16 country studies, outlining policy directions for long-term (to 2050). The Canadian report identifies six decarbonization pathways under three main themes: Deepening Current Trends, Encouraging next generation technologies; and Structural Economic Pathways, for which the report simulated oil price scenarios of $114, $80 and $40 per barrel in current dollars in 2050. The Canada report recommends “regulations that strengthen existing policies for buildings and transport sectors, a cap and trade system to drive abatement in heavy industry, and finally a complementary carbon price on the rest of the economy that returns revenues to reduced income and corporate taxes”. All DDPP reports will be tabled at the COP21 meetings in Paris in December.

China-U.S. Announcements include a National Cap and Trade program for China

On an official state visit to the U.S. on September 25, China’s president, Xi Jinping, announced that China would establish a national cap and trade program in 2017 covering power generation, iron and steel, chemicals and building materials industries. He also committed $3.1 billion in climate financing to help developing countries mitigate and adapt to climate change, capping off a series of recent announcements. The Rocky Mountain Institute summarizes the full slate of pledges made by the U.S. and China on September 25, “Today’s U.S.-China Announcement is the Most Significant Milestone to Date for Battling Global Climate Change”Inside Climate News summarizes the Chinese announcement.   In the New Yorker (September 25)  “What can China achieve with Cap-and-Trade?” cites the irony of a market-based system from a communist country, in contrast to the U.S. approach of regulation from a centralized bureaucracy.

…Also from the Premiers’ Summit: Ontario Announces Cap-and-Trade

The main outcome of the Quebec City meetings occurred beforehand on April 13, with the Joint Statement of Intent from the Ontario and Quebec Premiers. Ontario announced that it would join Quebec in a cap-and-trade system to reduce carbon emissions. The Ontario government press release, provides links to earlier discussion papers and whatever details are currently available. Reactions to the announcement were generally positive but tinged with questions about the effectiveness of the cap-and-trade system. See Want to make Polluters pay? Opt for a carbon tax over cap and trade from EcoJustice or reaction from Environmental Defence. From  the new Clean Economy Alliance of Ontario, launched on April 8 by 50+ Ontario businesses, labour unions, the Ontario Federation of Agriculture, and environmental groups: “Ontario should join with the many other jurisdictions around the world in putting a price on carbon. The province must also take complementary actions in other key sectors across Ontario’s economy including energy efficiency, renewable energy, climate friendly land-use planning, and low-carbon transportation”. 

Cap-and-Trade or Carbon Tax?

Recent reports have examined the strengths and weaknesses of the two systems. On April 7, the EcoFiscal Commission released The Way Forward: A Practical Approach to Reducing Canada’s Greenhouse Gas Emissions which employs policy analysis and new economic modelling to reach recommendations that every province should put a price on carbon, that existing and new policies should increase in stringency over time, should be designed to be as broad as practically possible, should be tailored to each province’s unique economic contexts and priorities, yet should be designed for longer-term coordination.

On April 13, Clean Energy Canada released Inside North America’s largest Carbon Market: Top Lessons from the Front Lines of Quebec’s Fight Against Carbon Pollution. Together with their February report, How To Adopt a Winning Carbon Pricewhich focused on British Columbia’s carbon tax, Clean Energy Canada provides what they call “under the hood” comparisons of the  two approaches to carbon pricing. 

 Sustainable Prosperity also weighed in with two Briefing Notes on April 23; Briefing Note #1

summarizes the rationale for pricing carbon, and the main policy approaches i.e. carbon tax and cap-and-trade. Briefing Note #2 reviews the key policy design criteria and considerations, and how they differ across approaches. 

Mandatory Emissions Trading Scheme for China

China’s Ministry of Finance has announced a plan to launch a mandatory national emissions trading scheme sometime between 2017 and 2020. The country has chosen seven regions where carbon market pilots will begin in the meantime. Eleven regions across China have been conducting pollution trading pilots since 2007, partly modelled after the EU emissions trading scheme. While pilots to date have focussed on carbon dioxide (CO2), the national scheme is expected to include sulphur dioxide (SO2) and nitrous oxide (NOx) as well. One billion metric tonnes of CO2 will be covered under the pilot programs, smaller only than the EU emissions trading scheme.

See “China aims to launch pollution permit market within 3 years” from Reuters at: http://in.reuters.com/article/2014/03/24/china-pollution-idINL4N0ML1OU20140324. By 2020, China has pledged to cut its greenhouse gas emissions per unit of GDP by 40 to 45 percent from 2005 levels.

EU Proposes New Emissions Targets for 2030, Weak Regulation of Fracking, and No Extension to the European Fuel Quality Directive

After hard-fought negotiations, the members of the European Union finally agreed on January 22 to a compromise Framework proposal to cut greenhouse gas emissions by 40% by 2030, compared with 1990 levels, and a goal of producing 27% of all energy from renewable sources by 2030. The European carbon emissions trading system (EUTS) will be reformed, and the goal of improving energy efficiency by 25% by 2030 will be an “indicative target”, not legally binding. Fracking will also be governed by non-binding recommendations rather than regulation. Most significantly for Canada, the Fuel Quality Directive will not be renewed after its expiry in 2020 – a move away from the support of biofuels, and which might allow for Alberta oil to enter the European fuel supply chain. The Canadian government has lobbied actively for such a change.  

ANY_ITEM_HERE

See “EU May Scrap Green Fuel Law in Boon for Tar Sands Industry” at Inside Climate News http://insideclimatenews.org/content/eu-may-scrap-green-fuel-law-boon-tar-sands-industry, and for background, the Natural Resources Defense Council blog, Canadian Tar Sands Exports to Europe could Grow from a Trickle to a Flood Undermining Europe’s Climate Goals (Jan. 2014) at: http://switchboard.nrdc.org/blogs/aswift/canadian_tar_sands_exports_to.html

The European Council will consider the framework proposals at its spring meeting in March.

From the EU Commissioner on Climate Action: “…The details of the framework will now have to be agreed, but the direction for Europe has been set. If all other regions were equally ambitious about tackling climate change, the world would be in significantly better shape.” Read the analysis from The Guardian (U.K.)(Jan.22) at: http://www.theguardian.com/environment/2014/jan/22/eu-carbon-emissions-climate-deal-2030 and the New York Times (Jan. 22) at: http://www.nytimes.com/2014/01/23/business/international/european-union-lowers-ambitions-on-renewable-energy.html?hp. The press release, with links to official documents, is at the European Commission website at: http://europa.eu/rapid/press-release_IP-14-54_en.htm.

Environmental groups disagree with the positive spin: according to the Friends of the Earth Europe, the negotiators “…seem to have fallen for the old-think industry spin that there must be a trade-off between climate action and economic recovery. This position completely ignores the huge financial cost of dealing with the impacts of climate change and the €500 billion the EU is spending every year on oil and gas imports”. (at: https://www.foeeurope.org/2030_climate_energy_plan_220114). About fracking, the FOE had this to say: “… attempts to regulate the fracking industry have been undermined by heavy corporate lobbying and pressure from certain member states intent on fracking their lands.” … “With the heavy support from José Manuel Barroso, the United Kingdom, Poland, and Romania have all played a leading role in undermining shale gas legislation, with allies Hungary, Lithuania, Czech Republic and Slovakia.” See https://www.foeeurope.org/shale_gas_framework_220114. An article in The Guardian (Jan. 14) offers a detailed analysis of the significant role played by the U.K. to weaken the fracking regulations (see at: http://www.theguardian.com/environment/2014/jan/14/uk-defeats-european-bid-fracking-regulations).

Western Climate Pact Seen as an International Model

On October 29, the Pacific Coast Action Plan on Climate and Energy was announced by its signatories: California, Oregon, Washington, and British Columbia. The Preamble of the official document: affirms “our shared vision of Pacific North America as a model of innovation that sustains our communities and creates jobs and new economic opportunities for our combined population of 53 million”… and recalls “the findings of the 2012 West Coast Clean Economy report which projected 1.03 million new jobs could be created in key sectors, such as energy efficiency and advanced transportation, assuming the right policy environment”. The Plan is voluntary, but pledges the parties: to account for the cost of carbon (with B.C. and California retaining their existing carbon pricing programs and clean fuel standards, and Oregon and Washington pledging to follow suit); harmonize 2050 targets for greenhouse gas reductions and develop mid-term targets needed to support long-term reduction goals; to inform policy with findings from climate science, including the IPCC 5th Assessment Reports of 2013; to co-operate to press for international agreement on climate change policy in 2015; to ensure support for research, and take action on, ocean acidification,. An article in Quartz appraises the group as “the new Pacific Rim Environmental Superpower”. The Action Plan will be administered by an organization called the Pacific Coast Collaborative.

See the Plan document at: http://www.pacificcoastcollaborative.org/Documents/Pacific%20Coast%20Climate%20Action%20Plan.pdf. For reaction, see the Clean Energy blog at: http://cleanenergycanada.org/2013/10/28/west-coast-economies-sign-landmark-action-plan-climate-clean-energy/; Pembina Institute blog at: http://www.pembina.org/blog/759; Blue Green Alliance US at: http://www.bluegreenalliance.org/news/publications/david-fosters-remarks-at-pacific-collaborative-climate-pact-event; Quartz at: http://qz.com/141148/meet-the-pacific-rims-new-environmental-superpower/.

Pipeline Politics from Ontario’s Point of View

The Politics of Pipelines: Ontario’s Stake in Canada’s Pipeline Debate, was released on November 12 by University of Toronto-based Mowat Centre, taking a climate change policy perspective on the issue of pipeline development and its impact on Ontario. It says that provinces who don’t necessarily receive adequate economic benefit from the oil sands are obligated to contribute to the nationwide effort to reduce greenhouse gases, and recommends either a national carbon tax or a cap and trade policy to satisfy the “polluter pays” principle. The report does note that local and First Nations communities across Canada will likely benefit from an increase in construction, maintenance, and management jobs, as well spin-off projects near pipeline routes. However, manufacturing sectors may suffer from inflated exchange rates and Dutch Disease. In Ontario, the conversion of the Line 9 gas pipeline to oil sands bitumen would decrease the capacity of the natural gas sector and may increase the consumer cost, while taxpayers would be forced to fund equalization payments.

LINK

The Politics of Pipelines: Ontario’s Stake in Canada’s Pipeline Debate is at: http://mowatcentre.ca/research-topic-mowat.php?mowatResearchID=96

No Carbon Leakage in Europe as a Result of Cap and Trade Policies

A study commissioned by the European Commission has concluded that Europe’s cap-and-trade program has not caused industry to relocate to countries without greenhouse gas regulation in a process known as “carbon leakage”. In a series of sectoral “factsheets”, the report presents historical data on the structure, performance, and competitiveness of sectors (including iron and steel, chemicals, paper, cement, refined petroleum) and assess the degree to which carbon leakage may have occurred. Although the study found that no companies left Europe for unregulated territory between 2005 and 2012, the authors indicate they suspect this may change.

Read Carbon Leakage Evidence Project Report by Ecorys Consultants, Netherlands at: http://ec.europa.eu/clima/policies/ets/cap/leakage/docs/cl_evidence_factsheets_en.pdf, or read a summary at Bloomberg news at: http://www.bloomberg.com/news/2013-10-31/carbon-curbs-haven-t-spurred-production-exodus-eu-study-shows.html.

Quebec and California Link Carbon Markets

On October 1, the governments of Quebec and California announced an agreement outlining the steps and procedures to fully harmonize and integrate the cap-and-trade programs of their two jurisdictions, effective January 1, 2014. It is hoped that this will be a model for more such partnerships. “The sale of emission allowances will generate at least $ 2.5 billion in revenue by 2020 in Quebec. These funds will be fully reinvested in initiatives to fight climate change, including facilitating the conversion to renewable energy, promoting energy efficiency, improving industrial processes and preparing Quebec society to adapt to the impacts of climate change. The electrification of transportation is another major project on which our government will labour over the coming months”, said Minister Yves-François Blanchet. See the Quebec government press release at: http://communiques.gouv.qc.ca/gouvqc/communiques/GPQE/Octobre2013/01/c6398.html, and “Carbon Market: Quebec and California Link Their Respective Cap And Trade Programs” (Oct. 1) in GlobeAdvisor at:https://secure.globeadvisor.com/servlet/ArticleNews/story/CNW/20131001/C6398

 

Carbon Markets the Best Route to Low-Carbon Global Economies

In a new report, Climate and Carbon: Aligning Prices and Policies, the OECD condemns fossil fuel subsidies and tax exemptions, and posits carbon markets as most effective mechanism for transitioning to a low-carbon economy and tackling climate change. The report, drawing on evidence from 15 countries (but not including Canada), points out that “carbon markets are more than 16 times cheaper at cutting greenhouse gases than renewable subsidies paid to power producers”. However, carbon markets worldwide are being undermined by a lack of coherence in government approaches to carbon pricing and financial support for fossil fuels. According to OECD Secretary-General Angel Gurría, limiting global temperature increase to 2ºC requires sending consistent carbon price signals to consumers, producers and investors alike.Climate and Carbon: Aligning Prices and Policies is available at:http://www.oecd.org/environment/climate-carbon.htm

 

Fragmentation the Defining Trend in Canada’s Carbon Policy

The International Institute for Sustainable Development has published a policy brief which analyses Canada’s carbon policy developments in 2012 and identifies key trends to watch for in 2013. The authors note that “accommodating the historical patchwork of provincial policy is pushing the country down a path of further fragmentation, increasing the risk of high-cost compliance and decreasing the likelihood of meeting Canada’s aspirational GHG targets.” And further, “In 2012 the federal government set an important precedent …. The Canada-Nova Scotia Equivalency Agreement has therefore established a pattern of federal policy deferral that is expected to become entrenched in 2013. The splitting of policy responsibility, with architecture provincially tailored but GHG performance standards nationally set, will underscore policy development in 2013.” Among the recommendations for 2013: “Mechanisms for coordination of policy, whether through linkage, equivalency agreements or even common LCDR markets, should be nurtured and supported. Quebec’s experiment with linking permit trade bi-laterally with California is an important precedent to watch”.

Canadian Carbon Policy Year in Review and Emerging Trends, 2012 is available at:
http://www.iisd.org/pdf/2012/regulating_carbon_canadian_policy.pdf

 

Ontario Consultation Period Re a Cap and Trade Policy

The Ontario Ministry of the Environment released Greenhouse Gas Emissions Reductions in Ontario: A Discussion Paper at the end of January, with a public comment period open till April 21, 2013. The discussion paper states that it is not considering a carbon tax, but rather a cap-and-trade system.   According to an article by lawyers at Osler Hoskin and Harcourt LLP, “Ontario intends to seek an equivalency arrangement with the Federal Government so as to render federal regulations inapplicable as long as equivalent Ontario regulations achieve identical (or better) outcomes.”

LINKS

Greenhouse Gas Emissions Reductions in Ontario: A Discussion Paper

is available at:

http://www.downloads.ene.gov.on.ca/envision/env_reg/er/documents/2013/011-7940.pdf

Ontario Ministry of Environment Climate Change website at: http://www.ene.gov.on.ca/environment/en/category/climate_change/STDPROD_078897.html

and also provides links to earlier policy documents, including the November 2012 Climate Change

Progress Report. “Change is in the Air: Ontario Closer to a Cap-and-Trade System” in Osler Updates, February 21, 2013 at: http://www.osler.com/NewsResources/Details.aspx?id=5497