March 29, 2015
Senior Policy Analyst
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Air Policy and Climate Change Branch
77 Wellesley Street West, Floor 10
Toronto, Ontario M7A2T5
Dear Ms. Hering,
Re: Ontario Climate Consortium (OCC) comments on EBR Registry Number 012-3452 Climate Change Discussion Paper
The Ontario Climate Consortium (OCC) is pleased to have an opportunity to provide input on the development of a long-term climate change strategy for Ontario that puts us on a path towards resilient communities that:
1. Are able to cope with the long-term climate change and potential extreme weather associated with a 2 to 4 degree C rise in temperatures, and
2. Reduce carbon emissions to achieve defined targets.
The Ontario Climate Consortium (OCC) was established in 2011 following consultations with climate change researchers and practitioners across the province that identified a need to build capacity at the local and regional level to respond to climate change through applied research and knowledge mobilization. These initial consultations identified a wide range of existing research, data, information, and resources to support the climate change agenda at the local and regional level in Ontario, as well as numerous knowledge gaps which present a barrier to progress in adaptation.
The OCC was established with the goal of identifying and addressing these knowledge gaps, and mobilizing existing research and resources, to support local and regional climate change planning and action. The OCC aims to achieve this goal via interdisciplinary collaboration. To that end the OCC has a growing membership base consisting of Universities, Conservation Authorities, and municipalities who help define our research agenda. To implement our research agenda we collaborate with a wide range of external stakeholders, including the private sector, professional associations, and industry associations.
Since 2011 the OCC has made considerable strides towards achieving its goal. Notable achievements include:
- Municipal risk and vulnerability assessments: The OCC is supporting municipal partners at the Region of Peel, York Region, and the Greater Hamilton Area with climate trends analysis and the development of risk and vulnerability assessments.
- Annual Symposia: The OCC has organized two annual symposia that have brought together academics experts, municipal and provincial policy makers, and the private sector to discuss climate change research needs. Organization of the third annual Symposium is underway, and will be hosted by McMaster University. We are expecting another successful event with more than 150 attendees from across the province.
- Career development opportunities: The OCC has enabled 15 students and recent graduates from five Ontario universities to gain valuable career experience in the climate change field through internships.
- Land use planning policy and climate change: OCC and partners including York University, OCCIAR and Zizzo-Allan-DeMarco are currently working on a research project for the Ontario Ministry of Environment and Climate Change (MOECC) that will identify best practice recommendations for integrating climate change mitigation and adaptation into the provincial land-use planning framework.
- Climate science: The OCC is developing an analysis of Great Lakes climate change science for Environment Canada in collaboration with a PhD. student and Dr. Gail Krantzberg from McMaster University.
The OCC’s top five OCC recommendations emerging from our review of the Ministry’s climate change discussion paper are as follows:
- Emphasize smart growth and transit-oriented development as part of coordinated review of Ontario’s land use plans
- Effectively utilize Ontario’s natural ecosystems systems to help to offset and mitigate GHG emissions.
- Support community-level risk and vulnerability assessments, and adaptation planning through pilot demonstration projects
- Consider a hybrid carbon pricing approach and use revenue to support a virtuous cycle of investment in mitigation and adaptation research and action
- Fund university-based research and help mobilize knowledge and expertise in support of good public policy and investment at all levels of government.
Smart growth and transit-oriented development are critical for long-term success
Based on our experience with current and past projects, we would strongly recommend a land use planning agenda that prioritizes compact mixed use communities. This agenda should be implemented across all settlement types, from urban to rural, in order to protect and enhance existing agricultural and natural areas, and enhance the viability of public transportation options. This smart growth agenda should be designed to deliver “win-wins” or synergies with other public policy goals (i.e. mitigation, adaptation, economic development, food security, public health, affordable housing, mobility, improved public infrastructure, etc.).
From our perspective it is clear that successful implementation of a long-term climate change strategy will require a strong focus on addressing the persistent tendency towards urban sprawl that has characterized land use planning in Ontario over the past several decades. This is not to argue that the Province should emphasize urban climate change policy to the exclusion of rural areas. Indeed, we recognize the important inter-dependencies between urban and rural areas in the province, which may become more important in a future likely characterized by higher energy prices and increased risks to food supply in many parts of the world. Ontario’s urban areas will need to rely more on local sources to maintain food security which implies an increased emphasis on protecting and enhancing existing agricultural land, as opposed to the continued expansion/encroachment of urban land into agricultural areas that has characterized the past several decades in southern Ontario.
We are encouraged by the Province’s efforts to encourage smart growth, as represented by the Growth Plan for the Greater Golden Horseshoe, the Greenbelt Plan, the Oak Ridges Moraine Plan Conservation Plan, and the Niagara Escarpment Plan. The coordinated review of these plans provides an opportunity to strengthen and enforce targets for urban densification – particularly those relating to development in greenfield areas. The bottom line is that Ontario needs an urban development path that emphasizes compact communities complemented by accessible employment centres and amenities where residents can work and play using low impact modes of transportation – including non-motorized modes such as walking and cycling, as well as public transit for longer distance trips.
Effectively utilize Ontario’s natural ecosystems systems to offset and mitigate GHG emissions.
Natural areas, including forests and wetlands, play a vital role in creating resilience to climate change by, for example, reducing the urban heat island effect that is anticipated to worsen as the temperature rises, as well as managing storm water runoff, thereby reducing flooding associated extreme with weather events. Complementing green infrastructure at the site or district level, larger urban forests can be used to provide a multitude of ecosystem services that enhance adaptive capacity (e.g. clean water, flood attenuation, habitat diversity, climate moderating of urban heat island etc.) while also supporting mitigation efforts by sequestering carbon. For example:
- Urban afforestation absorbs carbon as well as help to infiltrate stormwater, thereby limiting GHG emissions in addition to reducing flood risks during extreme rain events. Urban forests also help to moderate the urban heat island effect, thereby enhancing local adaptive capacity to heat waves.
- Urban/peri-urban agriculture helps to mitigate climate change by reducing the food miles travelled from farm to fork.
- Green roofs reduce GHGs by limiting the need to cool buildings with electricity-intensive systems, and enhance resiliency by absorbing stormwater, thereby helping to reduce flood risk during extreme rain events.
While green infrastructure in urban and rural areas are critical for addressing local and regional vulnerabilities, Ontario’s vast boreal forest holds global significance as a unique ecosystem and carbon sink. A warming climate puts this ecosystem, and the carbon stored within it, at risk. The Government should devote resources to better understanding these risks and options to mitigate them, through collaborative university-based research.
Government should support community-level risk and vulnerability assessments, and adaptation planning through pilot demonstration projects
There is a need for a better understanding of climate risk and vulnerabilities in communities and economic sectors across Ontario. There are existing tools being used in Ontario, such as the Public Infrastructure Engineering Vulnerability Committee (PIEVC) template to assess built infrastructure vulnerability to climate change, and the Ontario Climate Consortium’s P-CRAFT tool that is currently being used to assess the vulnerability of numerous sectors and systems in the Region of Peel, including Mississauga, Brampton and Caledon. The development of these, and other related tools, should be supported by the province through funding support for pilot demonstration projects for both the built environment and the natural heritage system, and knowledge dissemination to actors at the municipal levels to support further implementation of best practice in risk and vulnerability assessment.
Consider a hybrid carbon pricing approach and use revenue to support a virtuous cycle of investment in mitigation and adaptation research and action
One of the key questions surrounding the issue of climate change mitigation and adaptation is funding. How, given the fiscal constraints facing both the Province and its municipalities, can we afford the massive infrastructure investment required to develop low-carbon resilient communities? A potential solution to this vexing problem lies in the province’s approach to carbon pricing.
The OCC supports an approach to carbon pricing that is administratively simple, provides a predictable revenue stream, and addresses the majority of Ontario’s emission sources. While this can be construed as implicit support for a carbon tax, the reality is that the two leading approaches (tax or trade) are not mutually exclusive. Indeed, the province could consider a hybrid approach using cap-and-trade to address stationary point source emissions in the industrial and electricity sectors combined with a carbon tax to address diffuse emission sources in the transportation and buildings sectors. This hybrid approach could be supplemented with a carbon offset system designed to incentivize high-quality additional emission reductions from the agriculture, waste and forestry sectors, thereby creating economic development opportunities across urban and rural communities in the province.
Regardless of the choice of instrument – carbon tax, or cap-and-trade – carbon pricing will provide a significant revenue stream. British Columbia’s “revenue-neutral” carbon tax brings in more than $1 billion annually, which is returned to individuals and businesses via tax cuts. In California, where lawmakers expect sales of greenhouse gas pollution permits to bring in USD$5 billion annually, significant portions of revenue are used to fund low-carbon infrastructure investment. There is empirical evidence to suggest that the California approach of using carbon pricing revenues to support low-carbon investment enjoys higher levels of public support than a revenue-neutral approach. We encourage the Ministry to consider the use of carbon pricing revenue to support a virtuous circle of investment in mitigation and adaptation research, development of new energy efficient technologies and targeted action across the province.
Fund University-based research and help mobilize knowledge and expertise in support of good public policy and investment at all levels of government.
Low-carbon resilient infrastructure investment in Ontario needs to be supported by research and expertise from both the public and private sectors. The OCC’s University partners are home to considerable expertise in the areas of climate change mitigation and adaptation as well as green technology development, but there needs to be financial support from the provincial government to help mobilize university-based knowledge to support decision-makers in policy and investment responses to climate change. Through increased financial support towards climate change research, Ontario can build capacity as a leader in mitigation and adaptation initiatives that are supported by sound science, research and technologies
The OCC appreciates the opportunity to participate in this important provincial discussion. The ideas presented above are just a few of the most important that emerged out of our review of the Ministry’s discussion paper. We look forward to continuing our engagement in the development and implementation of Ontario’s long-term climate strategy and five-year action plan later this year. Please do not hesitate to contact Ian McVey, OCC’s Project Manager responsible for Research Mobilization and Communications, at 416-451-1420 or firstname.lastname@example.org should you have any further questions regarding our comments.
Professor Gordon McBean, C.M., O.Ont, Ph.D., FRSC | Western University
Chair, the Ontario Climate Consortium (OCC)
President, International Council for Science (ICSU)
Director, Research and External Relations, Centre for Environment and Sustainability, Western University
Noel Sturgeon, Dean of Faculty of Environmental Studies, York University
Altaf Arain, Director of the Centre for Climate Change, McMaster University
John Livernois, Vice President for Research, Guelph University
Chandra Sharma, Director Watershed Strategies, Toronto Region Conservation Authority