Ontario's Ministry of Environment (MOE) has released a discussion paper to support a dialogue on the elements of a potential Provincial greenhouse gas (GHG) reduction program (the Program). Greenhouse Gas Emissions Reductions in Ontario: A Discussion Paper (the Paper) considers, among other things, the following aspects of the Program: principles and goals for development; potential elements; scope; emissions reduction targets; certain compliance options; and public consultation.

Since 2009, the MOE has been collecting data on GHG emissions from large emitters. The Paper makes it clear that, moving forward, the MOE intends on implementing the Program with the intent to reduce GHG emissions. However, it is unclear, at this point, the exact form the Program will take. What is clear is that the public and stakeholders will be consulted with any further design of the Program.

The MOE notes the significant progress to reduce GHGs being undertaken in Europe, Australia, Asia, the US, and most importantly, Canadian Federal and Provincial initiatives. The Paper states that Ontario is interested in an equivalency agreement with the Federal Government. Such an agreement would mean Federal GHG regulations would not apply in Ontario where Provincial regulations meet or exceed Federal standards.

The Program's principles and goals include the following:

  • Achieving cost-effective, absolute reductions that considers Provincial competiveness and supports an equivalency agreement with the Federal Government;
  • Simplicity and transparency;
  • Equitable treatment of industry sectors;
  • Rewarding early-movers;
  • Promoting investment in clean technology;
  • Broad alignment with other emission reduction programs; and
  • Integration with other Provincial environmental policies.

The following is a summary of key aspects of potential elements and scope of the Program:

  • Timing: the MOE would seek to have the Program in place one year prior to any Federal industry-wide regulation of GHGs.
  • Covered GHGs: carbon dioxide, methane, nitrous oxide, sulphur hexafluoride, hydrofluorocarbons and perfluorocarbons from covered industries.
  • Covered Industries: at a minimum, those same industrial sectors to be regulated by the Federal regulations. Potentially, the MOE could broaden the scope of large emitters consistent with facilities currently covered under Ontario's Greenhouse Gas Emissions Reporting regulation (O. Reg. 452/09).
  • Inclusion of Electricity Sector: the MOE is considering including emissions from the electricity sector in the Program and setting an emissions limit aimed at stabilizing emissions from the electricity sector over time.
  • Emissions Reduction Target for the Industrial Sector: the emissions limit for industrial sectors are set at the forecast of total emissions expected at the start of the Program, and are to decline by five per cent over five years.
  • Potential Approaches to Emissions Reductions: a mix of 1) production-based benchmarks; 2) energy benchmarks; and, 3) reductions from an historical baseline.
  • Compliance Options: the Paper acknowledges stakeholder's desire for flexible compliance options including investment in technology, trading emission credits, and the use of offsets. 

The Paper concludes with a call for comments regarding the Program from the interested public, industry stakeholders, non-government organizations and Ontario's First Nation and Métis Communities. The Paper has been posted on the Environmental Registry for a 90 day public review that commenced January 21, 2013 and ends on April 21, 2013.

All comments on can be directed to:

Sheri Beaton
Project Manager
Ministry of the Environment
Integrated Environmental Policy Division
Air Policy Instruments and Programs Design Branch
77 Wellesley Street West
Floor 10
Ferguson Block
Toronto Ontario
M7A2T5 Otherwise, interested parties can submit a comment online through the Environmental Registry. All comments received prior to April 21, 2013 will be considered as part of the decision-making process by the MOE if they are submitted in writing or electronically using the form provided in the Environmental Registry notice and reference Environmental Registry number 011-7940.

We will monitor the implementation of this Paper and the development of the Program over time.

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