TEA, along with Environment Hamilton and Ecology Ottawa, submitted the following comments in response to the Ministry of Environment and Climate Change report called Ontario's Climate Change Discussion Paper 2015.

We the undersigned want to applaud the Ministry of Environment and Climate Change for releasing Ontario’s Climate Change: Discussion Paper 2015. The Discussion Paper is an important document that sets out in detail the challenges and opportunities facing Ontario and outlines some critical actions that could be taken by the Province. In particular, we fully support the introduction of a carbon pricing system in Ontario as a tool to assist in the transition away from fossil fuels.

However, we do want to point to a major weakness in the Discussion Paper: the lack of acknowledgement that most Ontarians live in cities and that municipalities are a key partner that can help the Province reduce greenhouse gas pollution and prepare for climate change.

The fact is that cities are where most of the activities that create greenhouse gas pollution occur. Cities are also vulnerable to damage that climate change is causing in ways that are quite distinct from other spaces in the Province. Yet, the Discussion Paper does not apply any geographical lens to its analysis. As a result, there is no discussion of the unique challenges cities face (as well as the unique challenges rural residents face).

Imagine if such a lens had been applied. For example, imagine representing the data in Figure 3 (Ontario’s Greenhouse Gas Emissions by Sector) in a way that identified emissions that took place in cities and rural areas. Doing so would have helped those reading the Discussion Paper identify that most of the emissions are produced in cities as well as what sectors are responsible for these emissions.

Such a representation of the data would also have benefitted from an analysis of the role municipalities play in actions that create these greenhouse gas emissions. This analysis, in turn, would then have led to a discussion of the importance of the Province engaging with municipalities in developing short term and long term actions to reduce fossil fuel use.

A similar sort of approach could have been used to understanding the challenges that climate change will bring to Ontarians. For example, in Toronto, the July 2013 flood and December 2013 ice storm led to significant damage to key urban infrastructure and major property damage to residents (severe weather events in rural areas have other sorts of impacts and create other types of damage that require other sorts of assistance). Again, this sort of geographical analysis would have made it clear municipalities play a key role in preparing for climate change and that the Province must have a plan that acknowledges this partnership.

Accordingly, we call on the Minister of Environment to make sure that any new plans, policies, regulation and/or legislation related to climate change acknowledge the important roles cities and municipalities play in an overall strategy. In particular, we call on the Minister to include in future plans/policies/regulations/legislation:

1. A requirement for municipalities to develop climate change plans that:
• Protect people from severe weather and the impacts of climate change;
• Provide people with real and affordable transportation choices; and
• Help people save money and transition towards 100 percent clean energy.

2. Provincial regulations/legislation and funding that help municipalities reduce greenhouse gas pollution and prepare city infrastructure for climate change.

Finally, every Ontarian is going to be harmed by the changing climate and every person plays a role in creating the solutions that will minimize the impact climate change has on us. But we cannot pretend that where we live does not impact how we will be harmed and what we can do to implement solutions. The reality is that people who live in cities have special problems that require special solutions. This, sadly, was not acknowledged in the Discussion Paper. The good news is that it can be acknowledged and acted on in the future by acting on the suggestions we make above.

Regards,

Toronto Environmental Alliance
Environment Hamilton
Ecology Ottawa