This report was submitted to the Legislative Assembly by Gord Miller, Environmental Commissioner of Ontario on May 31, 2011.

Watch videos of the Commissioner outlining key points of the report:



As part of its 2007 Climate Change Action Plan, the Ontario government established three targets for reducing greenhouse gas (GHG) emissions. The government’s targets are:

  • 6 per cent below 1990 GHG emission levels by 2014;
  • 15 per cent below 1990 levels by 2020; and
  • 80 per cent below 1990 levels by 2050.


In previous reports, the Environmental Commissioner of Ontario (ECO) has expressed concern about the government’s ability to meet these GHG emission reduction targets. While laudable progress has been made in the electricity sector with the phase-out of coal-powered generating plants, there is a lack of correspondingly ambitious policy tools in other large emitting sectors, such as transportation and industry.

While GHG emissions measured in terms of each dollar of economic output (i.e., emissions intensity) have decreased over the past two decades, economic growth over the period has overwhelmed these improvements. Future projected growth will make the targets even more difficult to reach.

According to the latest figures, Ontario’s GHG emissions were 165 mega tonnes (Mt) in 2009. That’s about 6.5% below 1990 emissions and if it could be sustained would meet the 2014 target.
However, emissions are expected to increase by an additional 23 Mt, because of renewed economic growth.
After building gas peaking capacity the net remaining reductions from the coal plant closures only account for about 10 Mt, leaving a gap of 13 Mt of further reductions to be found.

For more, see page 5 of Greenhouse Gas Progress Report.

Tyranny of the Near Term

While the government has established reduction targets for 2020 and 2050 as well, there are good reasons to act quickly. The severity of future climate changes will ultimately be determined by actions taken over the next ten to twenty years.

For one thing, reductions made now will mean less drastic emission cuts in the future. But there is also a risk of reaching a “tipping point” in atmospheric GHG concentrations. Once these concentration levels are exceeded, certain chemical processes can be triggered resulting in feedback cycles that drive the planet to a severely altered climate state that is beyond human control.

For more, see pages 9 and 43 of Greenhouse Gas Progress Report.

Routes to Success

Carbon Pricing: The government will not be able to meet its 2014, 2020, and 2050 reduction targets until it breaks the link between GHG emissions and economic growth. The ECO believes that carbon pricing is a fundamental element of an effective climate change policy and can be designed to maximize environmental benefits and minimize economic impact. Whether in the form of a tax or an emissions-trading system, an economy-wide carbon price is supported by a wide constituency of the public and business community. The ECO is disappointed by the recent decision of the Ontario government to delay its participation in a regional cap-and-trade system. This delay means that the opportunity for industry to begin moving towards a lower-carbon economy is stalled.

For more, see pages 6 and 22 of Greenhouse Gas Progress Report.

Sectoral Targets: The current 2014, 2020, and 2050 targets are not precise enough to meet mid-and long-term targets. The government needs to establish reduction targets for emissions that come from the transportation, industrial, residential, and commercial sectors. That will allow it to monitor progress in the key transportation and industrial sectors, which together produce about 60% of Ontario’s GHG emissions

For more, see page 4 of Greenhouse Gas Progress Report.

Transportation Changes: Now that the province is on track towards closing its coal plants, the best opportunity for future reductions comes from transportation, which produces 35% of the greenhouse gas in Ontario. There will be no single magic bullet: Governments will have to look at a portfolio of policies, including land-use planning to curb urban sprawl, and the expansion of public transit. But most importantly, it can no longer avoid a discussion of road pricing or road-tolls. While the ECO recognizes there are technical problems, and barriers to public acceptance, simply ignoring road pricing as a possible option does not reflect leadership.

For more, see pages 7 and 28 of Greenhouse Gas Progress report.

Landfill Diversion: The powerful greenhouse gas, methane, is 72 times more potent than CO2 in the first 20 years after its release. The largest source of methane in Ontario is from the decomposition of organic material in landfills. Current models significantly overestimate the efficiency of landfill gas collection systems, and thus underestimate releases of methane into the atmosphere. The best opportunity to reduce their contribution to GHG emissions is to keep organic waste out of landfills, either through composting, anaerobic digestion, or thermal conversion methods such as pyrolysis.

For more, see pages 10 and 50 of Greenhouse Gas Progress report.

Black Carbon: Otherwise known as soot, black carbon is produced by the incomplete combustion of diesel fuels, biofuels and biomass. A recent study has described it as “the second strongest contributor to global warming.” Because of its short life-span, the reduction of black carbon is one of the few ways to reduce the risk of entering a near-term tipping-point. Emission standards could be expanded to older vehicles still on the road, as well as diesel equipment used in construction and stand-by diesel generators. The non-essential burning of agricultural waste could also be discouraged.

For more, see page 44 of Greenhouse Gas Progress report.

Storing Carbon in the Soil: The Intergovernmental Panel on Climate Change says improved agricultural practices can capture close to 3 tonnes of CO2 per hectare per year. This could be done through increased use of manure and compost-based fertilizers. Other studies have found relatively high rates of sequestration through improved pasture practices, and the growing of crops such as switchgrass and Miscanthus for energy.

For more, see page 46 of Greenhouse Gas Progress report.


Establish GHG targets for each sector
The ECO recommends that the Ontario government establish sectoral targets for GHG reduction that will allow the government, the public and the ECO to determine the effectiveness of current and future plans to meet the government’s overall 2014, 2020 and 2050 targets.

Move forward with putting a price on carbon
The ECO recommends that the Ontario government establish a price on carbon as soon as possible to hasten the transition to a low-carbon economy.

Review assumptions made around landfill gas
The ECO recommends the Ontario government review its assumptions regarding the operational requirements and design of landfills and their contribution to the release of fugitive methane emissions. It should publish the results of this review.

Examine soil carbon sequestration (storing carbon in soil) as a possible tool
The ECO recommends that the Ontario government investigate and publicly report on the potential for soil carbon sequestration as a GHG mitigation strategy.

Gord Miller, the Environmental Commissioner of Ontario (ECO), is an independent officer of the Legislative Assembly of Ontario. Under the Environmental Bill of Rights, 1993, the ECO has a responsibility to report annually to the Speaker of the Assembly on the progress of activities in Ontario to reduce greenhouse gas emissions.

For more information contact:

Communications & Outreach Coordinator
416-325-3371 / 416-819-1673
Report is available at

Aussi disponible en français


Return to Top