Holding the line on emissions reduction targets, new plan puts “pragmatism first,” with many details to be determined

NOVEMBER 30, 2018

  • The Minister of the Environment, Conservation and Parks, Hon. Rod Phillips, released the PC government’s closely-anticipated environment plan in Nobleton yesterday, fulfilling an important commitment made after the government’s repeal of the cap-and-trade system implemented under the previous Liberal government.
  • In sharp contrast to recent events south of the border, the Ford government’s plan clearly affirms the environmental challenges facing Ontarians: the impact of human activities on climate change, water and air quality issues, waste management, and invasive and endangered species.
  • With the important exception of replacing the cap-and-trade system with the government’s new emissions reduction plan, today’s announcement broadly maintains and accepts the premise and structure of Ontario’s existing environmental legislative and regulatory framework.
  • The Province is holding the line on the emissions targets set in the 2015 Paris Agreement, and remains committed to meeting the 30 per cent emissions reduction target by 2030. The government is quick to note that Ontario is already 22 per cent below its 2005 emissions levels, while the rest of the country is collectively at a three per cent reduction. The Ford government’s message is clear: Ontario has done its fair share and won’t be doing more while other provinces lag behind.
  • In contrast with the former government’s plan, the new plan commits to what the PCs see as a more targeted, pragmatic and flexible approach to achieving the Province’s environmental objectives. while balancing Ontario’s economic interests. This includes a strong focus on the impacts on Ontario businesses and jobs, and more effectively recognizing the contributions of industries that have already made significant strides to green their operations.
  • To achieve the 2030 emissions targets, the new plan lays out a multi-pronged strategy, including increased uptake of low emissions vehicles, clean fuels, and other innovations. Centrepieces of this new strategy are two measures that will likely occupy stakeholder and opposition party attention: forthcoming emissions performance standards for large emitters, and a new $400 million Ontario Carbon Trust.
  • The plan does not outline the emissions standards to be imposed on large emitters. This is partly by design, as the plan and the Minister have indicated that they will be output-based (modeled on the approach taken in Saskatchewan to comply with the new federal requirements), while making it clear that they will be targeted on a sector-by-sector – and even facility-by-facility – basis.
  • The lack of broadly applicable standards makes the consultation process announced as part of the plan critical as ultimately tough decisions will have to be made with implications across many sectors of the economy. Until sector and/or site-specific limits are established it will be difficult for affected businesses or environmental advocates to evaluate the real implications of this approach.
  • The Ontario Carbon Trust, which the province is committing at $400 million over four years, will be overseen by an independent board tasked with leveraging private sector dollars to fund private sector and municipal investments in emissions-reducing technology and infrastructure. With the lion’s share of this commitment earmarked to come from taxpayer dollars, the plan is already being framed by the opposition and critics as an unproven replacement for the cap-and-trade system that sees taxpayers paying directly for emissions reductions rather than putting the onus on the polluters themselves.
  • The government is expecting wide consultation to precede the implementation of most parts of the new plan. As a result, significant emissions reductions aren’t forecast until 2021, with the largest reductions occurring after 2025.


  • The environment plan also lays out a number of other new priorities for the government, including:
    • Removing regulatory barriers to the wide-scale installation of EV and low carbon refueling stations, predicting that lack of refueling infrastructure – rather than cost – is the largest market barrier to low carbon vehicle uptake;
    • Modernizing Ontario’s Environmental Approval system, which has long come under fire from the private sector and municipalities for its slow pace and onerous rules and process;
    • Implementing a polluter responsibility principle across Ontario’s waste diversion and management landscape;
    • Considering a ban on organics in landfills, while seeking opportunities to capture the resource value of waste, particularly renewable natural gas produced from waste;
    • Providing municipalities with a greater say in landfill approvals, while maintaining a sufficient supply of landfill space to meet Ontario’s waste management needs;
    • Work with Indigenous organizations, forestry industry and communities to implement forest management plans that recognize forests as important carbon sinks and promote the use of renewable forest biomass;
    • Creating a pollution incident reporting platform where Ontarians can report local environmental issues and see real-time response on how they’re being addressed and cleaned up.
    • Implementing a climate change advisory panel to advise the Minister on the implementation of the plan and further measures to achieve the plan’s objectives.
  • The environment plan is currently open for consultation on the Environmental Registry of Ontario until January 28, 2019. Ongoing targeted consultations with stakeholders will kick off in early 2019 on a host of measures proposed in the plan.