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1 March 27, 2015 Kathy Hering Senior Policy Analyst Ministry of the Environment and Climate Change Climate Change and Environmental Policy Division Air Policy and Climate Change Branch 77 Wellesley Street West, 10 th Floor Toronto, Ontario, M7A 2T5 Phone: (416) ; Dear Kathy, Environmental Bill of Rights Registry Number: Sustainability CoLab provides direct support and an approach for member organizations to launch and grow target-based sustainability programs for businesses. These programs connect local networks of organizations that are setting and achieving sustainability goals of which carbon reduction takes significant precedence. Currently, the CoLab Network consists of seven member organizations across Ontario, three of which have active programs: Sustainable Waterloo Region, with the Regional Carbon Initiative; Niagara Sustainability Initiative, with the Carbon Project; and Durham Sustain Ability, with Durham Partners in Project Green. Four additional organizations are set to launch target-based sustainability programs by 2016, including EnviroCentre in Ottawa, Windfall Ecology Centre in York Region, rethink Green in Sudbury and Sustainable Kingston. CoLab s vision is for an economy that makes environmental sustainability, human well-being and business success synonymous. We welcome the public consultation process brought forward by the Ministry s Climate Change Discussion Paper 2015, and see this as an important step in Ontario s commitment to tackling climate change and accelerating progress towards the low-carbon economy. A target-based sustainability program was first piloted in 2009 by the Regional Carbon Initiative (RCI) in Waterloo Region and has now scaled to seven regions across the province. To date, our Network Members programs engage nearly 100 businesses across a diversity of sectors that have either set a target to reduce their carbon emissions, or have made public their intention to do so (See Appendix A for a full list). The willingness of businesses to take meaningful action on climate change is clear. We strongly encourage the Province of Ontario to build on this progress by setting ambitious policy that will accelerate what target-based sustainability programs like those of CoLab Network Members have already achieved. With a price on carbon, the business case for reducing emissions will be stronger, and voluntary reduction targets will be higher and more numerous. Informed by the work of target-based sustainability programs across the CoLab Network, our submission emphasizes: 1) A look at progress underway in Ontario; 2) Tracking a readiness for ambitious action; 3) Accelerating the low carbon economy through ambitious policy; and 4) How the Province of Ontario can demonstrate commitment to taking action on climate change and growing the low carbon economy.

2 Revealing the low carbon economy in Ontario The Climate Change Discussion Paper 2015 states the need to redesign and build a strong, carbon neutral economy. The work of our Network Members programs demonstrates progress already being made across the province towards this goal. The Core Approaches CoLab requires of all target-based sustainability programs emphasize that they are embedded in the contexts of local businesses, led by community networks of support, setting clear targets and reporting on them, and structured with revenue generation in mind to shift towards long term selfsufficiency. These programs are formed on the simple premise that what matters gets measured and that sustainability is in business best interest. Over the past 5 years, the RCI has convened a network of more than 65 member organizations representing almost 15% of Waterloo Region s workforce from every sector. Member organizations have increased their individual profitability, while collectively committing to reduce 53,000 tonnes of greenhouse gas (GHG) emissions over the next 10 years equivalent to taking 12,000 cars off the road every year. Moreover, the program has created a marketplace for the low carbon economy as member organizations work with local professionals to complete their sustainability projects: in 2013 for example, 5 organizations spent $160,000 on projects that allowed them to set GHG reduction targets while providing each an acceptable financial return on their investment. In Niagara and Durham Regions, where the program has been adapted to local contexts and new innovations introduced, 35 additional member organizations have set or stated their intention to set carbon-reduction targets across sectors including health, non-profit, education, energy, automotive, manufacturing, technology and government (see Appendix A). Independent of provincial legislation, businesses are working collaboratively to reduce their impact. Ready for Reductions: Tracking a shift in business as usual The CoLab Network Members engagement with businesses of all sectors and sizes points to a measurable shift in thinking towards business as usual. To date, the number of businesses engaged in CoLab Network Member programs has increased eight fold since 2009, and is continuing on this trajectory. As a result, the tonnes of carbon committed to be reduced has increased from 1,200 to nearly 60,000 tonnes in 2015 an average rate of growth of over 500 per cent. This is a strong indicator of a shift towards voluntary emissions reduction, and provides ample proof of the Private Sector Leadership referenced on page 13 of the Climate Change Discussion Paper This leadership transcends the key sectors referenced in the Discussion Paper. Using the pilot example of the RCI in Waterloo region, the collective commitment to reduce 53,000 tonnes of GHG emissions includes manufacturing, extraction, retail, health, education, technology, non-profit, automotive and energy sectors and more. In Sudbury, where rethink Green is on track to launch a target-setting sustainability program in early 2016, the economic landscape is notably different, with the mining sector playing a significant role. While this segment of the economy is often perceived as emissions-heavy, the potential and impetus to set meaningful emissions reductions targets and generate cooperative buy-in is there.

3 The mining sector remains a primary driver of the economy and policy. This includes not only the large companies Vale, Glencore, KGHM but the smaller ones that service and supply them, says Rebecca Danard, Executive Director of rethink Green in Sudbury. If the large companies were incentivized to reduce their emissions, the effect would trickle down the supply chain and lead to emission reduction in the whole sector. We are seeing similar stories in the growing CoLab Network across Ontario, from Ottawa to York Region to Kingston to Durham. The low carbon economy is latent, emerging or already underway in many communities, awaiting capacity to scale towards a critical mass. Accelerating progress through ambitious policy This leadership is part of a groundswell of support across Ontario that validates: the timing is right for the Province of Ontario to take the kind of bold action it cites in Section 3 of the Discussion Paper that will be needed to significantly reduce Ontario s emissions towards 2020 and 2050 targets. Ambition from the Province will increase the capacity and momentum of programs like those in the CoLab Network, and accelerate the progress already underway in communities across Ontario. Demonstrating the Province s commitment to the low carbon economy Echoing the Province of Ontario s stated need to focus on increasingly innovative and productive ways to use energy and capital to reduce emissions (p. 5), our Network Members programs show investing in emissions reduction projects generates bottom line cost savings for businesses. A price on carbon would surely enhance this economic motivator and accelerate buy-in to the low-carbon economy. Going one step further combining a price on carbon with greater provincial commitment to support the capacity of organizations and networks working with businesses at the community level will ensure that targets are met, and that businesses won t merely pay to pollute or move their operations to jurisdictions free of a carbon price. Moreover, encouraging networks of collaboration across sectors and regions of Ontario will create a lasting culture of commitment to carbon reduction, and make any ambitious policy more palatable and easy-to-navigate In this sense, pricing carbon is necessary but not sufficient. We strongly encourage that any mechanism put forward by the province be accompanied by increased support for organizational programming and infrastructure to help businesses achieve their targets while growing the low carbon economy. To summarize, we recommend the province s stated ambition to act on climate change and the low carbon economy be demonstrated in the following ways, in addition to putting a price on carbon: Increase funding to boost the capacity of community based networks, programs and initiatives facilitating target based sustainability programs for businesses and helping to ensure targets are met Develop a communications and outreach program to educate businesses and organizations about programs and networks that can offer guidance and support to help them reduce carbon while increasing cost savings and maintaining a healthy bottom line.

4 We welcome the opportunity to participate in this important public discussion, and look forward to working with the province to accelerate the transition to a low-carbon economy that is underway and growing in communities across Ontario. Sincerely, Mike Morrice, Executive Director, Sustainability CoLab Endorsed by: Brent Kopperson, Executive Director, Windfall Ecology Centre Rebecca Danard, Executive Director, rethink Green Katrina Kroeze, Executive Director, Niagara Sustainability Initiative Shawna Mutton, Executive Director, Durham SustainAbility Jennifer Kiwala, Interim Executive Director, Sustainable Kingston Tova Davidson, Executive Director, Sustainable Waterloo Region Michael Murr, Executive Director, EnviroCentre Ottawa

5 Appendix A: Sustainability CoLab Network Member Programs Members Members who have set targets to reduce carbon Niagara Sustainability Initiative s The Carbon Project 1. Brock University 2. Horizon Utilities 3. Niagara College 4. Quartek Group 5. Walker Industries 6. Water Superstore Sustainable Waterloo Region s Regional Carbon Initiative 1. AET Consultants 2. Athena Software 3. City of Waterloo 4. Conestoga Mall 5. Crawford & Company 6. EY 7. Farm Mutual Reinsurance Plan 8. House of Friendship 9. Just Fix It 10. Mennonite Central Committee 11. MMM Group 12. MW Canada 13. Quarry Integrated 14. Region of Waterloo 15. VeriForm Inc 16. Virtual Causeway 17. WalterFedy 18. Waterloo North Hydro 19. Whiting Design 20. Wilfrid Laurier University Members who have publically stated their intention to set targets Niagara Sustainability Initiative s The Carbon Project 1. Advanced Office Solutions 2. Beatties Basics 3. Canadian Niagara Power 4. City of St. Catharines 5. Fire Monitoring of Canada 6. Fallsview Casino Resort 7. Informed Energy Solutions 8. Local Website Design 9. M T Bellies 10. Niagara Health System 11. Niagara Ina Grafton Gage Village 12. Ridley College 13. Shannon Passero 14. Synchro Engineering 15. Township of Wainfleet 16. Welland Hydro 17. Westbrook Floral Continued on next page

6 Sustainable Waterloo Region s Regional Carbon Initiative 1. Afterglow 2. Borealis Grillhouse and Pub 3. Cambridge & North Dumfries Hydro 4. Canadian General Tower 5. Centre for International Governance Innovation 6. City of Cambridge 7. City of Kitchener 8. Cober Evolving Solutions 9. Community Support Connections - Meals on Wheels and More 10. David Johnston Research + Technology Park 11. Economical Insurance 12. Enviro Digital Printing 13. Fairview Park Mall 14. Gore Mutual 15. Grand River Hospital 16. Greater Kitchener Waterloo Chamber of Commerce 17. Healing Path Centre for Natural Medicine 18. Home Hardware 19. Kitchener and Waterloo Community Foundation 20. Kitchener-Wilmot Hydro 21. Manulife Financial 22. Marsland Centre Limited 23. Mennonite Economic Development Associates 24. Mennonite Savings and Credit Union 25. ProMark Window Film & Blinds 26. Quiet Nature Ltd 27. Read Jones Christoffersen 28. S.G Cunningham 29. Spicers Durham SustainAbility s Durham Partners in Project Green (DPPG)* 30. St John The Evangelist 31. St. Paul's College 32. Stantec 33. Sun Life Financial 34. Sutherland-Schultz 35. Tech Wreckers Inc 36. The Co-operators - Julia White & Associates Inc. 37. THEMUSEUM 38. Township of North Dumfries 39. Toyota Boshoku Canada 40. United Way Kitchener Waterloo Area 41. University of Waterloo 42. Waterloo District School Board 43. Wilmot Township 44. YMCAs of Cambridge & Waterloo Region 1. Blazing Star Environmental 2. Carbon Neutral Shredding Company 3. CMS Web Solutions 4. Covanta 5. General Motors 6. The Regional Municipality of Durham 7. Town of Ajax 8. Township of Uxbridge 9. Tam Heather Curling & Tennis Club 10. Unionville Curling Club 11. Whitby Curling Club *While DPPG members have intent to set targets, the program was launched in January, 2015 and is currently establishing a target-setting framework.