ANALYSIS: Toronto’s TransformTO Net Zero Strategy

Toronto is updating its climate action plan, with a new target of net zero emissions by 2040! Last week, the City released the draft TransformTO Net Zero Strategy. Increasing our targets is critical - but implementing the Strategy is key and it will require a robust plan of action and new sources of funding. Read our analysis of the new TransformTO Net Zero Strategy and our recommendations. 


This updated climate strategy, with a proposed new target of net zero in 2040, represents a significant step up in Toronto’s climate ambition. We are glad to see the focus on reducing emissions to zero faster and on a trajectory to the current 2030 target.

Net zero by 2040 is an important destination, but like any ambitious collective journey, we need a detailed map and the resources to make it happen. 


There are key areas in the Net Zero Strategy where accelerated action can have the most impact on reducing emissions and creating a healthier and more liveable city. These include: 


Buildings are the biggest source of emissions, accounting for 57% of Toronto’s total emissions, and this plan aims at eliminating natural gas heating across the city. If done right, accelerating actions in this area can cut emissions, improve housing and create good, green jobs. Our recommendations: 

  • Determine the City’s powers to accelerate the implementation of - and compliance with - new building standards (Toronto Green Standard and the Net Zero Strategy for Existing Buildings), in order to quickly transition off natural gas for heating
  • Develop a plan to ensure green renovations and energy retrofits don't cause renovictions or affect affordability for tenants and low-income residents


The Net Zero Strategy outlines a number of actions to reduce transportation emissions (many from the original TransformTO plan). This includes increasing active transportation use, expanding and electrifying transit, and electrifying the City’s own fleets. Accelerating action in this area will reduce emissions quickly, and benefit residents across the city. Our recommendations:

  • Accelerate transit expansion plans, and implement RapidTO bus lanes. 
  • Move up the timeline for a zero-emission TTC fleet. 
  • Move the City's own fleet to EVs starting now (vehicles and bikes)
  • Build complete streets that protect pedestrians and cyclists sooner, especially in communities where active transportation infrastructure is the most lacking.


To ensure the City is hitting its ambitious targets, we need stronger accountability and reporting mechanisms. We want to see that the City is seeking out and meaningfully implementing responses received from Indigenous people, and feedback from local residents, organizations, and equity-deserving communities. Our recommendations:

  • We need robust annual reporting on emissions. Otherwise, we won’t know if we are on track to meet our 2025 target until we see the 2025 update report
  • Develop accountability structures that measure progress and outcomes towards TransformTO Net Zero Strategy goals across the array of connected City programs and strategies, such as the Toronto Green Standard for buildings and the Net Zero Existing Buildings Strategy, cycleTO, the Official Plan, and numerous other strategies
  • Accelerate the City's consumption based emissions inventory, to account for emissions from the goods and services we use, and adjust our targets and emissions reduction pathways

The Net Zero Strategy report recognizes that City efforts to engage Indigenous communities have been lacking. Accountability must include recognition of the City’s obligations to Indigenous Peoples. Our recommendation: 

  • The City should articulate how it will do a better job engaging Indigenous communities as rights holders in decision-making on the Net Zero Strategy.

*Link to "Indigenous Climate Action Summary Report: Indigenous Strategic Discussions on City of Toronto Climate Strategies" (2018)


The City plans to engage communities in the implementation of the Net Zero Strategy, but we want to see a concrete plan that enables meaningful involvement of residents in the design, development, and evaluation of actions that goes beyond “advice giving”. Our recommendations:  

  • Establish an Advisory Group that centres the voices of equity-deserving groups and is resourced to produce an independent, annual review of the City’s progress 
  • Create new structures for meaningful resident participation which enable community-led and place-based recommendations and feedback to shape TransformTO
  • Dedicate an action area to supporting community hubs, community centres, neighbourhood pods and other local support networks, as key social and physical infrastructure for strengthening community climate engagement and resilience


In 2019, the City committed to developing a plan to apply the City’s Equity Lens to TransformTO decision-making in order to ensure that strategies include and benefit equity-seeking groups. This plan has not been developed and the Net Zero Strategy does not include a fulsome equity analysis. We recommend that the City clearly outline how it will: 

  • Work with equity-deserving people, including people with disabilities, racialized people, newcomers, and residents with low incomes, to advance benefits and prevent harms
  • Increase youth participation, particularly youth from equity-deserving groups, in developing and implementing climate strategies
  • Develop a municipal low-carbon jobs strategy that supports a decent work agenda and creates workforce pathways and expands the green sector for equity-deserving groups


Since the original TransformTO climate plan was passed in 2017, there have been repeated delays and underfunding of climate action in the City Budget.  The new targets in the Net Zero Strategy increase Toronto's climate ambition, and this necessitates that our Mayor and Council step up their support for implementing and funding this plan. 

Full funding of this plan will require support from other levels of government, but we can’t rely on these sources alone. Over the last several years, civil society groups have been asking the City to commit to creating and implementing new revenue tools - that are fair and equitable - within its own powers. Our recommendations: 

  • Put fair and equitable revenue tools in place in the 2022 City Budget, to create sustained and ongoing funding for climate action
  • Commit to fully funding the climate plan every year
  • Develop robust and transparent Climate Lens criteria to evaluate how climate impacts are being assessed in major City decisions including capital and operating budgets in the 2022 City Budget   

We’ll be sharing more analysis in our deputation and submission to the Infrastructure and Environment Committee on December 2nd. You can speak up for bold, urgent and ambitious climate action - sign up to make a short speech to the committee by emailing [email protected]