Policy and Political Action

Policy & Political Action

Bill 185: to the Standing Committee on General Government

Submission on Bill 185 to the Standing Committee on General Government
November 2, 2009

List of Recommendations

  • Endorse the KYOTOplus target of reducing Ontario's greenhouse gas emissions to 25 per cent below 1990 levels by 2020.
  • Preserve the option of implementing carbon taxes, such as taxes on energy use.
  • Include in the preamble of the Bill an endorsement of the environmental justice or equity principle and the precautionary principle.
  • Mandate transparent public consultations on any resulting regulations that are broadly accessible, particularly to vulnerable populations.
  • Amend the Bill to ensure that all greenhouse gas emission permits are auctioned, and that they do not confer a permanent right to emit.
  • Strictly limit offsets to a small percentage of an individual emitter’s emissions, and ensure that they are for real, verifiable, permanent reductions in greenhouse gas emissions.
  • Remove the section of the Bill that generically enables regulations governing economic and financial instruments for environmental purposes. Failing this, augment it by allowing the named instruments to be distributed by auction, sale or other means that are not free of charge.

The Registered Nurses’ Association of Ontario (RNAO) is the professional organization for registered nurses who practise in all roles and sectors across this province. Our mandate is to advocate for healthy public policy and for the role of registered nurses in enhancing the health of Ontarians. We welcome this opportunity to present this submission on Bill 185, the Environmental Protection Amendment Act (Greenhouse Gas Emissions Trading), 2009, to the Standing Committee on General Government.

We are pleased that the Bill acknowledges in the preamble the work of the Intergovernmental Panel on Climate Change and its conclusion that strong and sustained action is needed to minimize the risks due to the climate change arising from human activities.

The government has taken other steps to address climate change, including Bill 150, the Green Energy and Green Economy Act, 2009. This Bill is part of the government climate change plan. Bill 150 if properly supported has the potential to help transform Ontario into a greener province that would rely increasingly on clean renewable energy like solar and wind power. The Government has also issued a draft regulation under section 16 of the Environmental Bill of Rights, 1993, on greenhouse gas emissions reporting. This regulation would support Bill 185.

Huge changes and bold steps are required now to avert a climatic and humanitarian disaster. There is broad consensus that part of the solution is putting a price on greenhouse gas emissions. This would deliver more appropriate economic signals to resource users. Bill 185 would enable one approach to pricing carbon: a cap-and-trade system.

Our submission argues for a carbon tax over a cap-and-trade system on grounds of efficiency, simplicity, transparency, comprehensiveness and speed of implementation.

In the event that the government proceeds with a cap-and-trade system, our submission identifies features that will be required to deliver adequate protection to environment and health.

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