Key Elements of the new Made-in-Ontario Environment Plan


The Ministry of the Environment, Conservation and Parks today released the Made-in-Ontario Environment Plan: Preserving and Protecting our Environment for Future Generations (the EP). The EP addresses four main areas of action (1) protecting air, lakes, and rivers, (2) addressing climate change, (3) reducing litter and waste, and (4) conserving land and greenspace.


The EP is broad and goes well beyond climate. The chapter on climate change is intended fulfill the Cap and Trade Cancellation Act, 2018 requirement for the government to prepare a climate change plan. Generally, the EP is based on three governing principles:


  1. clear rules and strong enforcement;

  2. trust and transparency; and

  3. resilient communities and local solutions.


The government plans to consult on the EP through the Environmental Registry of Ontario. The consultation closes on January 28, 2019 at 11:59pm. The government intends to review and update the EP every four years.


Key elements of the chapter of the EP entitled "Addressing Climate Change" include:


1. Resetting the Ontario emission reduction target to a 30% decrease in greenhouse gas (GHG) emissions from 2005 levels by 2030 (same as Canada’s Paris Agreement targets, but lower than Ontario’s prior target of 37%). This represents a further 8% reduction (2016 GHG emissions levels are approximately 78% of 2005 levels). The government may consult on an economy-wide carbon intensity target (notionally GHG emissions per unit of gross domestic product).


2. Undertaking a strategy to achieve those GHG emissions reductions (see chart on page 24 of the EP) that will include:

  • Expanding natural gas in trucking and accounting for electric and low-carbon vehicle adoption (16%).

  • Establishing and consulting on an Industry Performance Standard, with compliance flexibility mechanisms including offsets and contributions to the Ontario Carbon Trust (15%). This will address emissions-intense, trade-exposed competitiveness issues and allow for potential across-the-board sector exemptions (e.g., the auto sector is identified). The EP includes express reference to Saskatchewan’s output-based performance standards (OBPS) system.

  • Enhancing clean fuels through a target of 15% ethanol content of gasoline as early as 2025, encouraging update of renewable natural gas (RNG) and other lower-carbon fuels (19%).

  • Accounting for the outcome of the federal Clean Fuel Standard (7%).

  • Facilitating natural gas conservation (including existing Demand Side Management) and expansion, subject to discussions with the Ontario Energy Board, mandatory voluntary renewable natural gas (biogas) programs to be available for customers (18%).

  • Establishing The Ontario Carbon Trust (with an independent board of directors), an emission reduction fund that will use public funds to leverage private investment in clean technologies, to be funded at the level of $350 million over a period of four years (intended to be leveraged with private sector at a four-to-one ratio), plus an additional $50 million for an Ontario Reverse Auction for emissions reductions. The government has estimated that initial investment of $400 million could leverage $1 billion of private finance and could be enhanced if the federal government transfers to Ontario the $420 million under the Pan-Canadian Framework Low Carbon Economy Leadership Fund (4%).

  • Enhancing climate-related financial disclosure, consistent with the Task Force on Climate-related Financial Disclosures (TCFD), and encourage the Ontario Securities Commission to improve guidance on climate-related disclosures.

  • Paralleling federal changes to the Accelerated Capital Cost Allowance (making technology investments in clean energy generation more attractive), working with the Ontario Financing Authority to issue Green Bonds by the end of the fiscal year, and considering tax policy options to encourage the creation of clean technology manufacturing jobs.

  • Implementing other waste and transit policies (6%).

  • Facilitating innovation, including energy storage (15%).


3. Undertaking an Ontario-wide climate change impact assessment, including an impact and vulnerability assessment for sectors including transportation, water, agriculture, and energy distribution.


4. Providing user-friendly climate adaptation and risk tools for public and private sector (private sector tools appear to be targeted at basement flooding).


5. Modernizing the Building Code, reviewing the Municipal Disaster Recovery Assistance program, and updating tax policy to support homeowner proactive measures to address extreme weather events.


6. Reviewing land use planning policies and laws with a view to greater climate resilience, building infrastructure resilience using back-up generation and energy storage, improving winter roads, supporting sustainable farm programs, and potentially supporting on-bill financing programs.


7. Encouraging energy efficiency through increased access to energy consumption data (Green Button data standard) and ensuring energy-efficiency standards for appliances in Ontario to be among the highest in North America.


8. Supporting connection of Indigenous communities in Northern Ontario to replace diesel, encouraging use of heat pumps for space and water heating, supporting integration of smart grid and energy storage technologies, removing regulatory barriers to clean technologies, and removing barriers to compressed natural gas (CNG) refuelling stations for trucks, and supporting Indigenous communities to integrate climate action into local plans.


9. Establishing measures applicable to government itself, in order to measure climate change actions, integrate climate change considerations into government procurement, enhance coordination and guidance for municipalities, enhance building renovations, automation, office space to facilitate efficiency; encouraging the federal government to use Article 6 of the Paris Agreement to enhance jobs and market conditions for Ontario's cleantech sector; encourage electric ferries and enhancing energy efficiency in heritage buildings.


10. Committing $5 billion for more subways and relief lines and establishing a two-way GO Transit service to Niagara Falls; support greening of the government’s vehicle fleet.


Please contact Lisa DeMarco at lisa@demarcoallan.com should you wish to discuss the contents of this bulletin.

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