Policy Analysis

The Made-in-Ontario Environment “Plan”

Or: a lesson in grabbing low-hanging fruit

The good old blame game. If it ain’t broke, don’t fix it.

After a week where the federal Conservatives somehow voted to deny climate change, it felt appropriate to tackle the province’s approach.

The Made-in-Ontario Environment Plan (MOEP) replaced the previous Liberal government’s environment plan shortly after the Conservatives took power in 2018, and even the name is infuriating. Made in Ontario? For a provincial instrument? (Although, given the rate of outsourcing in Canada, perhaps this was an important distinction to make and not a populist gambit… but I digress).

The MOEP is a bit sad to be frank. It is allegedly a plan to reduce greenhouse gas emissions and protect the environment, but it reads as something that had to be written to shut people up and will likely – and has been – ignored by the province. Much of the document is taken up by large boxes with “quick facts” and the environmental achievements of the (previous) government; the rest is a lot of finger-pointing and grabbing at low-hanging fruit that does not address the roots of the climate crisis.

Let’s break down this “plan”, shall we?

To begin

Before we dive into the meat of the MOEP, the difference between a plan and a bill should be noted. A plan is a government document that lays out principles and “actions” (general tasks) that will guide government decision-making and policies. Bills passed and decisions made should therefore be in line with the contents of a plan, but it is not a legally binding document. A bill, however, is a proposal to either change, repeal, or enact a law and is therefore legally binding.

In the introduction of this particular plan, we do not get off to a promising start. The MOEP opens with a message from Minister Rod Phillips of the Ministry of Environment, Conservation, and Parks (formerly the Ministry of Environment and Climate Change) and direction for the plan. Right off the bat, there is a prioritization of the economy and the private sector over meaningful public investment. The carbon tax is condemned yet again with a promise to fight it without any committal to a feasible alternative that will actually achieve emissions reductions. Natural gas is also included in a list of “clean” energy sources despite the fact that it is a fossil fuel with damaging extractive processes.

So. Not great. But near the end of the introduction, the MOEP identifies its guiding principles:

  1. Clear rules and strong enforcement
  2. Trust and transparency
  3. Resilient communities and local solutions

These sound good in theory, but unfortunately they wind up not being entirely accurate as we shall see.

The plan

The MOEP is divided into four main sections, each of which has a theme and related actions. The first section is relates to protecting air and water quality. The actions listed for clean air are vague and set the bar low. They include working with communities, lowering heavy-duty vehicle emissions, increasing roadside and pollutant monitoring, and getting the federal government and US to reduce their emissions. The wording of the last sounds rather like shifting the blame for emissions from Ontario to other provinces and states.

The next set of actions relate to clean water. Ironically for a government that prioritizes development above all else, waterfront development is mentioned as a key source of pressure on water sources. The actions in this section mostly relate to continuing past and current lake protection efforts. Indigenous communities are briefly mentioned here with only two communities identified for addressing drinking water contamination. The province commits to protecting the Muskoka watershed but then goes on to weakly claim that it will review and enhance water taking policies and drinking water protections without any firm commitment. The onus for water conservation is placed on citizens through the promotion of conservation technologies instead of creating more stringent regulations for water use for industry, agriculture, and commercial uses. One potential bright spot in this is a brief mention of supports for enhance stormwater management technology and practices at the municipal level, but again this is vague and does not firmly commit to anything.

The next section is on climate change and it is about what you would expect. To be fair, climate change is mentioned several times throughout the document and not just in this section… but most of the actions are meaningless and as with water conservation, the burden of fighting climate change is placed on homeowners and municipalities. The province leans heavily on the private sector for the execution of actions on climate change while claiming that Ontario has done its fair share in the fight.

Before the actions, there is some questionable information as an introduction. A large box right at the top brags that Ontario is “only” responsible for 0.4% of global emissions but fails to mention that it makes up 0.19% of the global population. There are then misleading charts comparing Ontario’s emission reduction performance to that of the rest of Canada that make it seem like Ontario is the only province that is reducing emissions. Meanwhile, both Quebec and PEI are faring better in this arena. The introduction concludes with a promise to both “unlock private capital” and to fulfill their commitment under the Cap and Trade Cancellation Act, 2018. (This act will be explored in an upcoming post where we’ll look at whether or not it may have actually been a good idea).

The very first action for climate change is impressive and has actually been implemented: a province-wide climate change impact assessment, which has never been carried out at this scale in Ontario. However, much of the responsibility for altering behaviour to reduce emissions is placed on the public and on municipalities. Flooding is listed as a major risk without hitting hard at major emitters and fossil fuels as the cause.

The plan claims that it will meet its target of reducing emissions by 30% below 2005 levels by 2030 without saying which metrics were used for its optimistic projection. (These figures were discredited by the Auditor General in 2019 and no, Ontario will not be meeting that target). Nevertheless, several policies are listed for helping to achieve this target including performance standards for industrial emitters, energy storage, low carbon vehicles, and natural gas conservation. On the flip side, there is a heavy dependence on the private sector for innovations and implementation. Supposedly, investments in the private sector will “unlock private capital”… Whatever that means, though it sounds suspiciously like the selling of public assets yet again. Additionally, the plan states that exemptions can and will be granted for industry performance standards where the province deems necessary or for “industries of particular concern”.

The rest of the actions in this section sound good. They include increasing the availability of water and energy consumption information and technology for the public, reviewing the Building Code, increasing access and affordability for clean energy, cross-government collaboration, and support for transit and green infrastructure projects.

The last two sections are on reducing waste and litter and conserving greenspace. I will not delve into the waste section too much; it is about what you would expect in terms of organic and recyclable waste diversion, cutting red tape, producer responsibility, and the responsibility of Ontarians. The section on conserving greenspace, however, is hilarious given the Ford government’s history with development and blatantly bulldozing supposedly protected areas. The actions written in this section espouse exactly the opposite direction for decision-making that Ford has taken with regards to greenspace. What’s worse is that they identify their partners in greenspace protections not as the Conservation Authorities who they conveniently neutered last year, but private organizations such as the Nature Conservancy and Ducks Unlimited that have no accountability to the public. But at least we have some nice condos now.

Okay, but there was some good stuff in there…

Yes, in all fairness, some of the actions and ideas in this plan were not terrible. In fact, some of them were pretty good. Still thinking too small, but pretty good. However, as limited and unambitious as most of these actions were, it was apparently still too much to handle for this administration. In December 2020, Environmental Defence reported that the Ford government had so staunchly ignored its own plan that emissions had actually increased for the first time in years. Little action has been taken on reducing building and transportation emissions with sales of electric vehicles actually decreasing after subsidies for electric cars were cut. No action has been taken on clean energy incentives and natural gas conservation. Several other renewable energy programs have been cancelled. There is no price on carbon. There is no alternative to the carbon tax, though a whole lot of money was wasted on a pointless lawsuit. The phase-in of increased ethanol content has not even started. It seems like a new wetland is pegged for development every other week. There are no clear rules. There is very little transparency, especially in the case of development. There are local solutions, but mostly because municipalities are doing most of the legwork.

There are so many ways that this administration could be combating climate change, some of which, as we have seen, they wrote themselves. The climate change impact assessment, though it will be farmed out to a private company rather than done in house, is promising. It adds a grain of truth to their claim to be concerned about the effects of climate change on public health, the environment. and the economy.

And yet, the whole plan seems to have been forgotten in favour of the the bottom line.

3 comments on “The Made-in-Ontario Environment “Plan”

  1. A good post. Thank you 😊


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