Perceptions of COP20 – UN Conference on Climate Change

I have just returned from the COP20 meeting in Lima, Peru and I thought it might be valuable to offer a few comments and perceptions. This event is, of course, the 20th annual meeting of the Conference of the Parties to the United Nations Framework Convention on Climate Change, which Canada ratified in 1992. The Kyoto Protocol flowed from this process and came into force in 2005, though the first commitment period expired in 2012. (Canada ratified Kyoto in 2002, and then withdrew in 2011).

The main purpose of COP20 was to lay the groundwork for COP21 in Paris in December 2015. Hopefully in Paris we will see the nations of the world come to an agreement on a plan to mitigate greenhouse gas emissions that will come into force in 2020, and will also address how adaptation to the ongoing climate change will proceed, and how much money the developed nations will commit to the global process.

The tasks in Lima included drafting up the elements of a negotiating text which will be the basis of discussion over the next year leading to Paris. There was also the job of rustling up $10 billion in commitments to the Green Climate Fund as an initial good faith gesture. The parties exceeded the $10 billion target, so that was good news. And while the parties did end up with an agreement on the negotiating text, most commentators agree that the substance of the text was very weak and non-committal. Expectations were low for this process and I suppose it was this low bar that was met.

The problem with this process, which has been evident in previous COPs, is that the broad range of national interests includes those nations who are reluctant – or even hostile – to achieving a mandatory international agreement. So in seeking a consensus document they have to deal with parties who are constantly trying to water down or undermine substantive clauses. For example, the agreement asks countries to submit their emission reduction targets (“intended nationally determined contributions” [.pdf]) in the first quarter of 2015 if they are “ready to do so.” This is hardly a definitive commitment.

This milquetoast language was not well received by most of the other groups observing the proceedings. Youth groups especially called for more decisive action and demonstrated frustration with the progress. The President of ICLEI commanded “it is time to be bold, ambitious and inclusive.” Al Gore exhorted, “we must change, we can change and we will change!” The frustration in the rank and file was palpable.

But at Lima there was also a much more positive development. Led by Ontario, Quebec and California, there was a strong push to establish a sub-national collaboration on climate change among provinces, states and even large municipalities. In contrast to the national negotiations, this group is a collaboration of the willing. Those that oppose need not be part of it. As such, the initiative has a strongly positive tone which resonated with sub-national jurisdictions on several continents, as well as civil society, the environmental sector and even some business groups.

The sub-national initiative was quickly recognised as another channel to achieve progress on GHG emission reductions that by-passed the frustrating UNFCCC process. It is early yet, but Ontario has already offered to host a Climate Summit of the Americas in July 2015, which could, if successful, result in a completely different international narrative developing on climate change in 2015.

The international situation with respect to taking action on the existential problem of climate change is, to say the least, uncertain. It is not the time for optimism but it may be the time for some hope.

If you’d like to hear more, I’ll be hosting a live chat today at 2 p.m. To participate, you can sign up here, or you can tweet your question using the hashtag #ECOLive.

The ECO is Off to Lima

¡Hola! ¿Que tal?

It happens every December: the annual United Nations climate change conference. In previous years you may have noticed a flurry of media stories on climate right before the holidays. The first meeting was in 1992 in Rio de Janeiro, where the United Nations Framework Convention on Climate Change, an international treaty, was first opened for signature. The treaty entered into force in 1994; as of 2014, 196 countries are party to the treaty. Its aim is to stabilize global greenhouse gas (GHG) emissions to avoid dangerous climatic changes. The parties to the treaty have met every year since 1995, which is known as the “Conference of the Parties” or COP.

The most famous recent COP was perhaps in 2009 in Copenhagen, when U.S. President Obama made a last ditch plea for an agreement – known as the Copenhagen Accord. (Both the U.S. and Canada agreed to reduce their GHG emissions by 17% below 2005 levels by 2020. The U.S. is on track to meet this commitment; by its own admission, Canada will not). Many people have become skeptical of this annual conference, due to the lack of tangible outcomes even as climate change continues to worsen.  But hard work gets done behind the scenes.

This year, the 20th Conference of the Parties (COP 20) is taking place in Lima, Peru from December 1-12 [.pdf]. Many countries send delegations, which are made up of a mix of government officials, business people, parliamentarians and others. This year I have decided to attend as part of the International Institute for Sustainable Development delegation, for several reasons:

  • The global context for climate change policy has changed profoundly in recent months. The U.S. and China recently signed an agreement where both countries agreed to limit GHG emissions. The European Union also recently strengthened its climate change reduction targets. The COP 20 conference in Lima is the first step towards what many policy makers and political leaders hope will be an ambitious global climate agreement inked at COP 21 in Paris in December 2015. In Lima, many jurisdictions will be positioning themselves to negotiate in the lead-up to next year’s Paris conference.
  • Ontario has a renewed focus on climate change – one clear sign is that it has renamed its environment ministry the Ministry of Environment and Climate Change. It is working on updating its climate change mitigation and adaptation plans, and hopes to re-position Ontario as a climate change leader by Paris 2015. As a result, it is sending its own delegation to Lima this year, including Glen Murray, the Minister, as well as the Deputy Minister, and other key staff. My formal mandate requires me to report on Ontario’s progress on climate change.
  • While an agreement is unlikely to be reached in Lima, it is important for Ontario to have a presence. Behind the scenes, essential conversations take place that help to test policy concepts, spur ideas and partnerships and share lessons learned. Key connections are made and strategic relationships are built. Ontario cannot solve the climate crisis alone and partnerships with neighbouring jurisdictions, both in Canada and North America more broadly, are vital. All the key people will be assembled in Lima. Ontario has recently signed a memorandum of understanding (MoU) with the province of Quebec to collaborate on climate change and energy policy, demonstrating its desire to take a cooperative approach.

I am attending for two purposes: to both witness and participate in the sub-national conversations first-hand; and to inform my discussions with, and recommendations for, the Ontario government on climate change. Watch this space as well as my personal Twitter account and the ECO’s Climate and Energy Twitter account for updates and news from Peru in December.

¡Hasta Luego!

When is a Park not a Park?

How we choose to manage Ontario’s publicly owned Crown lands has been the subject of much heated debate throughout the years. There was a time when Ontario’s forests were viewed almost exclusively as a source of products like lumber and pulp. Ecological concerns and recreational values took a backseat to resource extraction, if they were acknowledged at all. Times change.

Growing public concern over protecting the ecological values of Ontario’s forests pushed the government to develop a Timber Management Class Environmental Assessment, which was finalized in 1994. This Class EA had 115 terms and conditions that reflected a new approach to forestry that showed greater concern for protecting ecological values. This paradigm shift also spurred the development of the Crown Forest Sustainability Act, 1994, which incorporated new concepts of sustainable forest management.

Then, in the late 1990s, the Ontario government undertook one of the largest land use planning processes in the province’s history. The outcome was a historic agreement on the use of 39 million hectares of Crown lands and waters in central and northern Ontario. Ontario’s Living Legacy Land Use Strategy [.pdf] set out how the province would balance competing land uses like mining, forestry, tourism, angling, hunting, and conservation. The strategy adopted a clear distinction between lands that should be protected, and lands that are available for commercial activities like logging and mining. It set a target of 12 per cent of the Crown land and water base covered by the agreement to be set aside as protected areas – with the remainder left open for commercial use.

Protected areas are set aside to allow animal and plant species, as well as entire ecosystems and ecological processes, to function unimpaired. These natural areas must be managed very differently from Crown lands that are open to commercial resource extraction. The Provincial Parks and Conservation Reserves Act, 2006 requires the Ministry of Natural Resources and Forestry to ensure that ecological integrity [.pdf] is the first priority in the planning and management of all of Ontario’s provincial parks and conservation reserves. The ministry succinctly explains what ecological integrity means: the heart of ecological integrity is the “naturalness” of a given protected area.

Algonquin Logging Map

Logging is permitted in the red areas in this map of Algonquin Provincial Park. (Click map to enlarge.)

Unfortunately, the line between protected areas and other Crown land is not always so clear. For example, roughly two-thirds of Algonquin Provincial Park is open to commercial timber harvesting. Even though Ontario foresters employ some of the best forestry practices in the world, commercially logging a provincial park is at odds with managing for ecological integrity.

Managing a forest sustainably for timber, while undoubtedly important, is very different than managing a park for its ecological integrity. For example, protected areas are managed to encourage naturally occurring fires; areas managed for logging typically suppress forest fires. Protected areas are managed as roadless areas; areas managed for logging have extensive road networks. Protected areas don’t have aggregate pits; areas in Algonquin managed for logging do. Protected areas are managed to allow trees to die naturally as part of a bio-chemical process; logging is a mechanical process that robs forests of nutrient cycling. And so on.

As the Provincial Parks and Conservation Reserves Act, 2006 and Ontario’s Living Legacy Land Use Strategy demonstrate, the fundamental reason for distinguishing between general Crown lands and protected areas is that parks are areas intended for conservation with as little interference as necessary. Parks are the only place where we have chosen to allow nature to run its course. Parks are the unimpaired natural benchmarks by which we can measure whether forestry practices elsewhere are actually sustainable.

Forestry operations in Algonquin Provincial Park are certified as sustainable. Yet, the very presence of commercial forestry in Algonquin Provincial Park means that the areas that are open to logging cannot qualify as a “protected area” under international standards. In other words, even if commercial forestry operations meet sustainability standards, you can’t conduct these operations in a park and still call it a park; the two are mutually exclusive with good reason.

Regulated protected areas managed by the province only cover nine per cent of Ontario. These are the last refuges for wilderness; in the rest of the province, wildlife habitat and ecosystems are open to constant pressure from industry and development. Without actually protecting a special place like Algonquin Provincial Park, it’s only lines on a map. Algonquin Provincial Park was established in the 19th century, in the age of lumber barons. It is time to bring it into the 21st century, and adopt modern protected areas science.

Investing in a Smart Electricity Grid for Ontario

Figure 8 step 1 ThermostatLast week, the Ministry of Energy announced that it is awarding $24 million in funding for 17 new projects through its Smart Grid fund. I discussed this fund in a previous annual energy conservation report when the projects were being reviewed by the ministry.

As Environmental Commissioner of the province, I believe that Ontario’s pursuit of a smart grid is a progressive policy development and a shrewd investment that will benefit both individual consumers of power and society as a whole.

14 SmartGrid Report CoverWant to learn more about these benefits? My recent report, Smart from Sunrise to Sunset, is a non-technical primer that describes how a 24-hour day will be different with the widespread adoption of the smart grid. It focuses on six benefits that the smart grid can deliver:

  • Enabling distributed renewable energy generation
  • Managing consumer demand
  • Facilitating customer use of electricity data
  • Improving reliability
  • Fuelling electric vehicles
  • Storing electricity

I’m pleased to see that essentially all of the funded projects will use technology in innovative ways to deliver one or more of these benefits. Hopefully, some of these projects will successfully scale up and contribute to the wider adoption of smart grid technologies across Ontario.

If you would like to learn more about our report, Smart from Sunrise to Sunset, please join us for a live Q&A with the Commissioner in the new year. Click here to register.

Governments face legal risks relating to stormwater management and climate change

Toronto's Bayview Ave, July 8, 2013

Toronto’s Bayview Ave, July 8, 2013

In August, Burlington received more than 125 mm of rain – two months’ worth – in a mere three hours. It’s only the most recent example of intense rainfall in Ontario. I’ve already discussed in a blog this past summer, and in this year’s Greenhouse Gas (GHG) Annual Report, how municipalities across Ontario are experiencing more intense and frequent extreme weather events due to climate change. In the aftermath of these storms, communities, residents and businesses have been forced to clean up the damaging flood waters that inundate properties and infrastructure. I’ve also talked about how the insurance industry is stepping back from insuring flood-prone properties or is increasing rates while decreasing coverage for sewer back-up costs. As a result, some Ontario residents face higher insurance premiums, lower property values, and/or flooding damage that is not covered by their insurance companies. In certain cases, residents are looking beyond their insurer to recover flood-related costs; instead, they are launching lawsuits against the governments responsible for stormwater management.

Currently, there are several ongoing class action lawsuits with various levels of government named as defendants. In Thunder Bay, a large group of residents has joined a lawsuit against the city seeking $375 million in damages. This lawsuit alleges that, due to a failure to perform routine maintenance on the sewage treatment plant and to properly operate this plant during a 2012 storm, the City of Thunder Bay is responsible for flooding that affected thousands of homes. Similarly, the City of Mississauga is facing a class action lawsuit from residents that have endured repeated flooding and as a result, allege that they have experienced declines in property values. The lawsuit against Mississauga is also notable in that the province of Ontario – specifically the Ministry of the Environment and Climate Change – is named as a co-defendant, as is the Halton Region Conservation Authority and the Region of Peel.

These types of lawsuits against municipalities are not without precedent – in 2010, the City of Stratford paid $7.7 million to settle a class action lawsuit brought on by residents who were flooded in a 2002 storm. This sum is in addition to $1.3 million that Stratford paid to residents in emergency compensation after the flooding took place. The municipal costs of the lawsuit are being paid for by an increase in water, sewage, and garbage disposal rates for all Stratford residents.

Such lawsuits do not always come directly from residents – in the United States, an insurance company recently launched a lawsuit against almost 200 municipalities to reclaim costs it had paid out due to flooding damage, alleging that the municipalities hadn’t done enough to prevent flooding from storms. This case is particularly interesting as the insurance company also argued that municipalities should have known that climate change is altering and intensifying rainfall patterns and, as such, the communities should have been better prepared for this foreseeable risk. The lawsuit was later dropped since the company felt that sufficient attention had been brought to the issue and that it would be more productive to work collaboratively with the municipalities.

It is difficult to say whether the lawsuits in Ontario will succeed – class action lawsuits can take years to reach the courts and there are several criteria [.pdf] that must be met for a municipality to be found liable for damages. What is clear, however, is that the provincial and municipal governments cannot ignore the impacts of extreme weather and climate change on their respective responsibilities to regulate and deliver stormwater management without increasingly facing legal and financial consequences.

Municipalities deliver important services to their residents; the province supports and regulates the municipalities in performing these duties. As I pointed out recently, the province has its own obligations to ensure that Ontario has adequate stormwater management systems. We know that the status quo is no longer sufficient – only by proactive preparation can governments protect their communities, their residents and themselves.

 

Lions and tigers and bears … and apes and rhinos and turtles and … oh my.

elephantsLast week, representatives from over 170 countries met in Sydney, Australia to attend the IUCN World Parks Congress. This global forum on protected areas was not simply about “parks.”  This worldwide effort to expand protected areas is at the forefront of the struggle to conserve rare ecosystems, and to protect the species that rely on these rapidly disappearing landscapes for their survival. In fact, increasing and effectively managing protected areas is one of the key obligations of the Aichi Biodiversity Targets under the international Convention on Biological Diversity. As one of the 194 parties to the Convention, Canada has committed to conserving biodiversity and ensuring its sustainable use.

It seems that every day there are new reports of impending extinctions of iconic animals like Siberian tigers, African lions and polar bears – and these are just a few of the many species that could be lost from the world forever. Climate change is certainly a significant driver for some of these potential extinctions (e.g., Tasmanian devils and sea turtles), but there are many more contributing factors  like human encroachment and habitat destruction (e.g., great apes), and overexploitation of these animals (e.g., Japanese eel) and their prey. Poaching and the illegal trade of items like ivory (i.e., elephants), horns (e.g., rhinoceros) and animals with purported culinary and medicinal value (e.g., pangolin) are also significant threats.

The ecological fallout from these extinctions could be drastic – many of these are keystone species that play a crucial role in maintaining the structure and function of their ecosystems. On a profound human level, these animals also hold immense cultural significance and the extinction of any of these iconic species would constitute a deep and irreparable loss, especially in the regions that are home to these species. Without effective and sustained action to address the underlying causes of species declines, animals like rhinoceros and tigers could become nothing more than a distant memory, joining the growing list of almost mythical beasts that once roamed the earth.

Some real international commitment to taking action on climate change finally appears to be coalescing – but we must remember that Canada has signed equally important international commitments to conserve biodiversity. In 2012, the ECO released Biodiversity: A Nation’s Commitment, an Obligation for Ontario, a special report setting out Ontario’s responsibilities respecting the Convention on Biological Diversity and the Aichi Biodiversity Targets. Our commitment to meeting these targets will determine whether we manage to save species like polar bear – or whether we continue to drive ourselves into an ever more biologically impoverished world.

Lighten Up Your Day with ECO-Live

Too much information? Anyone in the environmental field knows the feeling: too much dense technical detail, too little time. So today we’re launching a new service, offering you bite-sized servings from ECO’s trusted trove of reports and research.

We hope you’ll join us for daily morsels of environmental info; timely, relevant and easily digestible.  Mondays we’ll offer tips on using the Environmental Bill of Rights.  Tuesdays will touch on highlights from ECO’s latest Annual Reports. Wednesdays will share an idea on climate change or energy conservation. Thursdays… you get the picture.

We’ll offer ECO-lists, such as top tips for energy saving. There will be ECO-likes of good sites, quotes and graphics.  We may share some ECO-lit; good books we’re reading. And yes, there will be some ECO-levity.  You can think of our service as ECO-lite, but for now, we are calling our site ECO-Live. You can find a permanent link to it in the upper right hand corner of our main website at eco.on.ca.

Try it out, and please let us know what you think; help us fine-tune the content, so we can deliver the environmental information you need for your busy life.

Click here to get started!

Ensuring the Polluter Pays: The Need to Reform Ontario’s Approach to Contaminated Site Liability

Those responsible for allowing or causing pollution should be responsible for the costs associated with it (such as the costs of cleaning it up). This is known as the ‘polluter pays’ principle, and is a fundamental tenet of environmental law. At its core, this principle is about fairness to innocent third parties affected by pollution.

While the polluter pays principle is reflected in several Environmental Protection Act provisions relating to contaminated properties, it is not an absolute. Polluters sometimes avoid liability for clean-up costs by declaring bankruptcy or insolvency or by restructuring. In such cases, the ministry can choose to clean up the property at the cost to taxpayers. Alternatively, the Act also allows the ministry to order anyone who ever owned, managed or controlled a property or operation to pay clean-up costs even if they weren’t responsible for the contamination; under the current law fairness is not a relevant consideration.

14ar cover thumb

2013/14 Annual Report

One of the Applications for Review covered in the Supplement to my 2013/2014 Annual Report addresses this state of affairs. The applicants describe “two separate but related problems with the current legislative scheme.” First, they argue that the government needs to better ensure that polluters pay for the costs associated with their pollution. Second, they ask the government to reconsider how it can best manage situations where it is not possible to make the polluter pay and costs fall on innocent third parties.

As you’ll see in the supplement, I agree that these are significant concerns with the existing contaminated site liability regime. Sadly, the ministry did not give these issues the full consideration they deserve. Although the ministry reported that related efforts were already underway to strengthen the polluter pays principle in Ontario, it dismissed the notion that fairness may have a role to play in how the ministry determines liability. The bankruptcies of some large companies in recent years have left the Government of Ontario and other third parties responsible for the costs of necessary (and expensive!) environmental clean-up work; an often unfair situation that cannot be ignored. To read my full comment on this subject, check out Section 2.1.13 of the 2013/2014 Supplement.

What is a “policy” under the Environmental Bill of Rights?

The EBR and You: A guide to exercising your right to participate in environmental decision making.

Under the Environmental Bill of Rights, 1993 (EBR), prescribed ministries are required to post proposals for environmentally significant policies on the Environmental Registry for public notice and comment. This may appear to be a relatively straightforward requirement, but in practice, a diverse variety of ministry initiatives can constitute policies under the EBR.

In general, policies establish principles, considerations and values that are used to guide a ministry’s decisions or actions. They may describe the details of how a ministry will apply a law or outline how a ministry will undertake a program or plan of action within its mandate. Policies may also apply to individuals undertaking activities that are regulated by a ministry; for example, policies may establish mandatory standards or suggested practices for the regulated activity.

The EBR defines a policy as including the following:

  • Programs (i.e. government initiatives, projects, and undertakings)
  • Plans (i.e. a course of action or strategy that sets out how the government will work to accomplish a goal. This may include defining the roles and responsibilities of government and non-government participants.)
  • Objectives (i.e. statements of intent, or specific goals or targets.)
  • Guidelines or criteria used to make decisions about the issuance, amendment or revocation of instruments.

A number of types of documents also fall within this definition, including, but not limited to: policy statements; operational policies; frameworks; guidance documents; technical guidance; best management practices; protocols; standards; strategies; procedures and directives. The requirement to notify and consult the public also applies to “interim” or “draft” policies if they are being applied by ministries.

The EBR only requires ministries to post proposals on the Environmental Registry for policies that may have a significant effect on the environment. This requirement encompasses policies that could have either a negative or a positive effect on the environment. For example, a policy that might result in harm to a species at risk must be posted as a policy proposal, as well as a policy that exclusively focuses on recovering a species.

There is often confusion about whether guidance that is technical or scientific in nature constitutes a policy for the purpose of the EBR’s notification and consultation requirements. Even when direction is science-based, it often constitutes policy direction, especially in cases where there is conflicting or inconclusive science, or where both scientific and socio-economic considerations are applied to develop direction.

Technical guidance may also have serious implications; in some circumstances, it may inform whether certain activities are in compliance with the law. For example, in July 2013, the Ministry of Natural Resources (MNR) finalized “general habitat descriptions” for 14 species at risk without public notice and consultation. Although these materials were characterized by MNR as technical documents, the ECO’s position is that they are environmentally significant policies, given that they essentially define the areas where the Endangered Species Act, 2007 prohibition on damaging or destroying habitat will apply, and define which activities the ministry considers to be compatible with the affected species’ general habitats.

The EBR contains an exception for proposals that are “predominantly financial  or  administrative  in  nature,” as well as proposals that “form part of or give effect to a budget or economic statement presented to the Assembly.” However, these exemptions should be construed very narrowly in order to reflect the intentions of the legislation to exclude predominantly fiscal or operational decisions from the EBR’s public participation requirements. Policies may have serious environmental effects even if they have a financial or administrative component; therefore, the focus must be on what element is “predominant.” For example, financial tools such as the pricing of renewable energy, water or carbon can nonetheless be predominantly environmental policies. Similarly, environmentally significant policies are not exempted from the EBR’s requirements simply by virtue of being peripherally related to a budget bill, particularly if the bill provides substantial discretion on how to meet budget commitments.

Part of the ECO’s mandate is to provide guidance to ministries on how to comply with the requirements of the EBR. The ECO encourages ministries to contact our office for advice on whether particular ministry endeavours are environmentally significant policies for the purposes of the EBR. Moreover, the ECO encourages ministries to apply a broad and liberal interpretation of its responsibilities under the EBR in order to enhance the transparency of their environmental decision making and receive the full benefit of public consultation.

Find out more in The EBR and You: A guide to exercising your right to participate in environmental decision making.

Pricing Carbon … A Taxing Issue!

Most economists agree that a carbon tax is the best policy instrument to reduce emissions. It is relatively quick and simple to implement, easy to explain to the public and seems to work (i.e., actually achieves emission reductions). And it could raise a fair amount of money. The Ontario government stated very clearly in 2013 that a carbon tax wasn’t on the table (.pdf), but let’s imagine that it is.

We can only speculate on the design of a carbon tax in Ontario, but let’s make a few assumptions in order to estimate the magnitude of the revenues that could be raised. If Ontario’s hypothetical carbon tax was set at the same level as that of British Columbia ($30/tCO2e – tonne of carbon dioxide equivalent), and covered the same companies that now report their annual greenhouse gas emissions to the province (facilities that emit more than 25,000 tCO2e), then the tax would conceivably raise about $1.5 billion per year.

That’s a lot of money. There are many ways the carbon tax revenues could be used, depending on the priorities of the government. There are trade-offs between the various ways to use the revenue – some are more popular with the public than others; some are more economically efficient, and so on. Not everyone will agree on the best way to spend this large sum of money, but how the government chooses to use the revenue matters.

In British Columbia, an early adopter in North America of a carbon tax, the tax was made revenue neutral in order to gain approval from the public. Revenue neutrality means that all revenues from the tax are returned to individuals and businesses through reductions in other taxes, i.e., the money does not go into general government revenues to fund other programs or reduce deficits. People get used to the personal and corporate tax cuts, making it more challenging for future politicians to eliminate. And, it puts that money right back into the economy where it belongs.

Research has shown that public support for a carbon tax hinges on how the revenue is used. In one American poll, the public supported a carbon tax most when the revenues would be used to fund renewable energy.

Other revenue use options include: investing in or subsidizing technological solutions that reduce emissions (e.g. public transit, building insulation, energy efficient appliances, and low-emission vehicles); investing in adapting to climate change; issuing lump sum rebates to lower-income households (who would be most adversely affected by the carbon tax); or reducing the deficit. As in B.C., corporate and personal tax rates could be reduced, although Ontario’s corporate tax rate is already competitive with other provinces (.pdf). Other taxes could be targeted, including taxes on capital investment (corporate taxes or personal income rates on interest, dividends, or capital gains) or consumption. The economic effects of various carbon tax revenue use options has been modelled, at least in the United States, with the most economically beneficial option being reducing other taxes. Of course how the revenue is used has political ramifications, so the most economically efficient use is not always the one chosen.

I support a price on carbon, as I have previously noted, and would like to see Ontario implement some sort of carbon pricing soon. A carbon tax should be back on the table as a viable option. The revenues would provide a boost to the economy, and engage the public on climate change.