Climate Change

WCS Canada Comments - Ontario Environment Plan - January 2019
Our Ontario staff provide comments to the Ontario Ministry of the Environment, Conservation and Parks on Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan. (link: https://ero.ontario.ca/notice/013-4208)
WCS Canada Comments - Ontario’s Approach to Climate Change Adaptation – January 2018
Ontario’s Ministry of the Environment and Climate Change (MOECC) has been leading Ontario’s efforts to address both mitigation and adaptation to climate change. Ontario's actions around mitigation include putting a cap on the greenhouse gas pollution that businesses can emit, along with the carbon market, work with Ontario’s Climate Change Action Plan to move Ontario toward a low carbon economy. Ontario’s actions around adaptation continue to evolve. In this proposal, MOECC describes further actions on adaptation including: 1) Creating a new climate change adaptation organization; 2) Working with climate change adaptation experts to undertake a province-wide risk assessment of climate impacts; 3) Developing an enhanced all-of-government approach to climate change adaptation; and 4) Sharing information on the effects of climate change. Our comments focus on these four actions and our concerns regarding how managed and unmanaged systems, specifically Ontario’s Far North, are being considered in climate change planning, both adaptation and mitigation led by MOECC and the Ministry of Natural Resources and Forestry (MNRF).
WCS Canada Comments – MNRF’s Natural Resource Climate Adaptation Strategy – March 2017
MNRF is the primary ministry responsible for managing the provincial land base and conserving Ontario’s fish, wildlife, and ecosystem services in both managed and unmanaged systems. MNRF also has significant responsibility in decision making about land use and its interactions with climate change and planning for the future of species, ecosystems, and landscapes in managed and unmanaged systems alike. As such, MNRF plays an essential role in addressing both the impacts (e.g., mitigation) and adaptation of ecological and human communities to climate change. The current strategy acknowledges these responsibilities, does a reasonable job of listing and prioritizing the elements of MNRF’s mandate that affect and is affected by climate change, and identifies critical research efforts. We make a number of recommendations to improve the document and overall strategy.
WCS Canada Comments - MNRF Forest Carbon Policy - January 2017
This Ministry of Natural Resources and Forestry discussion paper sets the stage for Ontario’s emerging “forest carbon policy”, which will be directed at managed forests in Ontario. Our comments express significant concerns about the lack of details of the science underpinning the proposed direction of the carbon policy, and weakness of assumptions behind the certainty claimed in this discussion paper that mitigation of climate change will be accomplished by increasing carbon in boreal forests through forest management. We also have significant apprehensions about the limited scope of this policy, which is restricted to forests that are managed for timber production, comprising about half of the forest cover in Ontario. We explain why it is problematic to ignore both the positive and negative contributions of unmanaged forest, including carbon-rich ecosystems such as wetlands and peatlands, particularly in the Far North, and offer five recommendations for a path forward as part of Ontario’s climate change strategy.
WCS Canada Comments - Consideration of Climate Change in Environmental Assessment - October 2016
Ontario’s Ministry of the Environment and Climate Change has developed Codes of Practice to provide guidance on key aspects of the environmental assessment process for considering climate change in the preparation, execution and documentation of EA studies and processes. Although we consider this to be an important first step for proponents who want to address climate change in their proposed projects, we contend that the Guide is not consistent with the provincial goal of reducing greenhouse gas (GHG) emissions, addressing adaptation approaches to climate change, and considering impacts that cannot be addressed through adaptation and mitigation. It ignores the limitations of the Ontario Environmental Assessment Act (EAA) and current EA practice in Ontario.
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