The Ontario Government’s Tear Down and Replacement of the Provincial Climate Action Plan Would Increase the Target for Year 2030 Emissions by 27%

A Rollback of Ontario’s Ambition to Control Emissions Would Undermine Canada’s Ability to Meet International Obligations Under the Paris Agreement

The global pathway to limit future surface warming to well below 2°C and ideally 1.5°C above pre-industrial temperatures is dependent on transitioning the energy sector of advanced economies. The pillars of this transition are decarbonization of electricity supply, electrification of transportation and many industrial practices, fuel switching to zero and low emissions options and a substantial improvement in energy efficiencies across economic sectors. These transitions will drive down demand for fossils fuel resulting a substantial reduction in emissions from the global oil and gas sector. The Sustainable Development scenario described in the International Energy Agency’s 2018 World Energy Outlook projects a 26% decline in the global demand for oil by the 2040. A key component of this energy transition is 930 million electric vehicles, equal to half of the global fleet, on the roads by 2040.

In Canada, the oil and gas and transportation sectors are the major contributors to emissions with oil and sector activities accounting for 26% of the national total. While only 15% of Canadians live in Alberta and Saskatchewan, these oil and gas rich provinces account for nearly half of Canada’s total emissions at a per capita intensity that is 4-fold greater than the national average.


Under the Paris Agreement, Canada has pledged to reduce national emissions by 30% in the year 2030 relative to emissions on record for 2005. As is the case for almost all countries, this level of ambition is adequate must be increased if future surface warming is to be held to well below 2°C. In general, using the year 1990 as a baseline, advanced economies should target at least a 40% cut in emissions by 2030 advancing to deep decarbonization by mid-century.

While there are opportunities to cut methane emissions from upstream oil and gas sector activities, there is a practical limit as to what can be accomplished in this sector. In addition, access to zero emissions hydro, renewables and nuclear power varies across the country. The economies of Quebec, Ontario, Manitoba and BC are not overly encumbered by emissions from traditional energy resource extraction and have ready access to zero emissions energy sources to produce electricity. As such these provinces are well positioned to achieve ambitious cuts in GHG emissions. Quebec and BC have established aggressive targets of emissions reduction that are aligned with regional obligations to limit future surface to well below 2°C. BC has targeted a 40% cut in emission (relative to a 2005 baseline) while Quebec aims to reduce emissions by 37.5% using emissions on record for 1990 as a baseline.

Nationally, success in controlling emissions over the short-term mitigation period extending to 2030 would be based on low rates of emissions from Ontario, Quebec, BC and Manitoba, that would compensate for emissions associated with continued production of oil and gas in Saskatchewan and Alberta. Going forward to mid-century and beyond, global demand for fossil fuels would decline as would emissions from a declining oil and gas sector in Western Canada.

The previous government in Ontario had implemented an aggressive climate action plan that targeted a 37% cut in emissions using 1990 as a benchmark. By shutting down coal-fired power plants, and establishing a near zero emissions electricity supply sector, Ontario was (and is) well positioned to drive down emissions in the transportation, industry and buildings sectors of the provincial economy. A well-designed plan in Ontario, could readily meet regional obligations and match the level of ambition contained in the climate action plans of Quebec and BC.

The new government of Ontario has chosen to cancel the cap and trade program and otherwise dismantle what would have been an effective set of climate policies put in place by the previous government. The revised target year 2030 emissions reduction target is a staggering 27% higher that the target put forward by the previous government. In the absence of economy-wide market-based carbon pricing all that remains is an Output Based Allocations system of carbon pricing/trading that would apply to companies in select industries, a collection of poorly defined “command and control” regulatory policies and a “Carbon Trust Fund” whereby businesses are paid to take on emissions reduction projects. Canada’s Ecofiscal Commission has reviewed the new plan; however, this assessment is limited by the lack of detail and transparency in the information provided by the government. In their assessment, the Ecofiscal Commission concludes:

“It’s not clear that the plan will even get Ontario to its new, less ambitious target. There’s no transparency on how the emission reduction numbers were developed. The plan provides little detail on what the proposed policies will look like, how they might interact with each other, or what kind of technological and behavioural change they assume. As it stands, it is not clear that Ontario can reach its new 2030 target with this plan.”
Canada’s Ecofiscal Commission. https://ecofiscal.ca/2018/11/29/air-look-ontarios-new-climate-policy/.

The new government in Ontario has simply set a year 2030 target to reduce emissions that matched Canada’s pledge under the Paris Agreement and then fashioned a set of outcomes that add up to this number. In reality, a 27% increase in the year 2030 emissions target is grossly irresponsible and does not begin to acknowledge the opportunity, and indeed the obligation, for Ontario to fully contribute to the national and international effort.

In the absence of carbon pricing as part of an effective climate action plan in Ontario, it is doubtful that Canada would be able to meet international commitments under the Paris Agreement. As it stands, Ontario’s token gesture of a revised climate action plan does not satisfy the minimal criteria specified in the Pan Canadian Framework on Clean Growth and Climate Change. However, under the PCF, the carbon fee and dividend along with other policies within the Greenhouse Gas Pollution Pricing Act are to be implemented within non-compliant provinces. Ontario has filed for intervenor status on behalf of the province of Saskatchewan in the court challenge to the GGPPA. Legal opinion suggests this challenge will not be upheld. Assuming that the court challenge fails, the Federal government will step in and provide the necessary leadership on climate policy that is currently lacking in Ontario.

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