metrovancouver SERVICES AND SOLUTIONS FOR A LIVABLE REGION

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1 metrovancouver SERVICES AND SOLUTIONS FOR A LIVABLE REGION Office of the Commissioner/Chief Administrative Officer Tel, Fax File: CP GHGR-03 Ms. Susanna Laaksonen-Craig, Head, Climate Action Secretariat Ministry of Environment PC Box 9486 Stn Prov Govt Victoria, BC V8W 9W6 VIA susanna.laaksonencraig@gov.bc.ca Dear Ms. Laaksonen-Craig: Re: Metro Vancouver Phase II Input to the Provincial Climate Leadership Plan A strong and ambitious Provincial Climate Leadership Plan will be critical for Metro Vancouver (representing the four legal entities: GVRD, GVS&DD, GVWD and the MVHC) to reach its greenhouse gas reduction targets and to support its communities in preparing for the impacts of climate change. It will also be important for the Province to quantify how the Climate Leadership Plan policies will achieve the stated greenhouse gas reduction targets and describe how climate adaptation policies will directly and indirectly increase the resiliency of communities in the face of the impacts of climate change. As part of the Phase I Consultation period for the Climate Leadership Plan, Metro Vancouver provided detailed policy feedback to the Province. In September 2015, the GVRD Board sent a letter conveying four foundational policies for climate action. This letter was followed by a Metro Vancouver staff letter which provided more detailed policy suggestions in support of the four foundational policies endorsed by the Board. Subsequently, the Board endorsed staff s detailed policy suggestions in December 2015 and conveyed its recommendation to the B.C. Minister of Environment in a letter dated January 4, This letter constitutes the Metro Vancouver staff comments for the Phase II Consultation period that was initiated by the Province on January 25, 2016, and summarizes the following: 1) The alignment of Metro Vancouver s Phase I recommendations with submissions from the public and the recommendations from the Climate Leadership Team; 2) Important gaps in the CLT recommendations; and 3) Recommended changes to consultation process. This letter presents the views of Metro Vancouver staff, which have not been reviewed or endorsed by the Metro Vancouver Board. It should be noted that because of time constraints and meeting schedules, the Metro Vancouver Climate Action Committee considered this staff letter at its April 6, 2016 meeting and has requested that the GVRD Board endorse the staff comments contained in this letter at its April 29, 2016 meeting. If the Board endorses or amends staff comments, they will be resubmitted to the Province at that time Kingsway, Burnaby, BC, Canada V5H 4GB Greater Vancouver Regional District GreaterVancouver Water District Greater Vancouver Sewerage and Drainage District Metro Vancouver Housing Corporation

2 Susanna Laaksonen-Craig, Head, Climate Action Secretariat, Ministry of Environment Metro Vancouver Phase II Input to the Provincial Climate Leadership Plan Page 2 of 6 ALIGNMENT OF SUBMISSIONS WITH METRO VANCOUVER S PHASE I RECOMMENDATIONS In reviewing the survey results and the written submissions from Phase I, there is strong alignment between the public feedback, the Climate Leadership Team recommendations, and Metro Vancouver s submissions. A detailed table comparing feedback has been attached to this letter. In Phase I, the Metro Vancouver Board communicated four foundational policies necessary to reach provincial and local greenhouse gas reduction targets: 1. Widespread adoption of low/zero carbon vehicles; 2. Transition to net-zero-carbon new buildings and near net zero carbon existing buildings; 3. Support for local government actions to reduce and shorten vehicular trips and increase trips by walking, cycling, and transit; and 4. carbon pricing to create a market signal to stimulate adoption of low carbon technologies and practices. Reflecting on Metro Vancouver s detailed Phase I policy recommendations, Metro Vancouver recommends a fifth foundational policy critical to reaching provincial climate adaptation goals: 5. Tools and resources that can assist local governments to adapt to current and future climate change. Listed below are more detailed comments on how the public feedback and the CLT recommendations align with each of the five foundational policies and Metro Vancouver s detailed policy recommendations: Low/Zero Carbon Vehicles The public survey and a number of written submissions by stakeholders emphasize the importance of supporting the expansion of low and zero carbon vehicles. Accordingly, the CLT recommends a zero emission vehicle mandate and increased support to motivate the adoption of low and zero carbon vehicles in the market. Metro Vancouver made similar recommendations, particularly pointing to the need to set mandatory targets and requirements for zero emission vehicles. Low Carbon Buildings The public feedback reflects broad, general support for greener buildings. Likewise, the CLT made recommendations to implement standards for high efficiency equipment, create financing mechanisms for energy retrofits, and demonstrate green building leadership when constructing new public buildings. Metro Vancouver recommended establishing policies that outline a clear pathway to net zero buildings and using tools and data such as home energy labelling, energy benchmarking, and incentives to support this market transformation.

3 Susanna Laaksonen-Craig, Head, Climate Action Secretariat, Ministry of Environment Metro Vancouver Phase II Input to the Provincial Climate Leadership Plan Page 3 of 6 Urban Form that Supports Walking, Cycling, and Transit Both the public survey and many of the written submissions reflect that the public recognizes the importance of expanding walking, cycling, and transit in reducing greenhouse gases. In broad terms the CLT supported increased use of public transit and other mobility options that reduce GHG emissions. However, the CLT did not provide detailed recommendations on how Climate Leadership Plan policies could support local governments in making investments in walking, cycling, and transit infrastructure and adopting integrated land-use and transportation policies. Carbon Pricing The public feedback supports carbon pricing and gives a strong sense that the associated revenues should be invested back into public and private climate actions, The CLT spent the majority of its time and effort coming to an agreement on an effective and fair carbon pricing scheme. It supported an increase in the carbon tax and broadening of the tax to cover all emissions sectors. It also supported using the incremental revenue to lower the PST, eliminate PST on electricity, and to fund technology and innovation and local government projects. Similar to the CLT, Metro Vancouver recommended an incremental increase in the carbon tax and the use of that increase to fund local government projects. Also, Metro Vancouver recognized the importance of reducing impacts of increased carbon tax on vulnerable populations and addressing other unintended consequences. Climate Adaptation The public submissions focused less on climate adaptation than on reducing greenhouse gases. However, there was strong support for local food production, which is an important aspect of increasing local climate resilience and accordingly Metro Vancouver s adaptation recommendations also included increasing support for local food production. The CLT recommendations regarding climate adaption focused largely on specific resources and tools to support planning and investment in climate adaptation such as hazard mapping, monitoring of climate impacts, and establishment of a policy framework to address climate impacts in communities. Metro Vancouver submitted an extensive list of policy recommendations to support both planning and actions related to climate adaptation. Similar to the CLT, hazard mapping was identified as a need, but Metro Vancouver also included recommendations for specific research on, and investment in infrastructure including urban green infrastructure (e.g. green belts, street trees, etc.), agricultural drainage systems, and climate-ready road infrastructure. IMPORTANT GAPS IN THE CIT RECOMMENDATIONS The Climate Leadership Team has acknowledged that it spent most of its effort on coming to agreement on an effective and fair carbon pricing scheme that would support an economy-wide shift to low carbon technologies and practices. The CLT recommendations are an interlinked package of high impact policies, but should not be considered the definitive comprehensive policy set that is necessary to meet the existing or proposed greenhouse gas reduction targets. Nor should the CLT s adaptation recommendations be considered robust enough to ensure communities have the support

4 Susanna Laaksonen-Craig, Head, Climate Action Secretariat, Ministry of Environment Metro Vancouver Phase II Input to the Provincial Climate I.eadership Plan Page 4 of 6 required to prepare for the full 5pectrum of climate change impacts. Metro Vancouver suggests that the following key policies should be included or strengthened in a draft plan: Inclusion of evidence-based findings on the role of decisions related to urban form in longterm carbon neutrality, healthy communities, resiliency, and quality of life In a communication following the release of their recommendations, CLT members recognized the limited attention that they gave to transit, active transportation and land-use policies as important tools for reducing transportation-related fossil fuel use. As such, they acknowledged that these policies should be given further consideration in the final plan. As outlined in Metro 2040 and the Mayors Regional Transportation Plan, investments in expanding transit, walking, and cycling and the supporting land-use and urban design policies are key regional priorities. The Climate Leadership Plan needs to place a stronger emphasis on enabling policies that further support and enable the creation of, and investment in: compact, walkable, transit oriented communities including sustainable funding for transit, active transportation infrastructure investments and smart growth planning. Set incremental targets and policies outlining the market transformation pathway(s) to net zero buildings Over the past few years, there has been an increased understanding and acknowledgement that voluntary and regulatory requirements for high performance buildings, including net zero buildings, are an important and achievable strategy to reaching GHG reduction targets. Other jurisdictions have already mapped a voluntary and regulatory pathways to net zero buildings including European Union, California and Washington. The CLT recommendations for the buildings sector focus on specific requirements whereas setting incremental shortterm and long-terms targets and predictable stretch building codes to net zero buildings can stimulate the market innovation and transformation. RECOMMENDED CHANGES TO THE CONSULTATION PROCESS In response to Climate Leadership Plan Phase II consultation that was initiated on January 25, 2016, Metro Vancouver has gathered feedback from municipal staff, through several municipal advisory committees including the Regional Engineers Advisory Committee (REAC) and the Regional Planning Advisory Committee (RPAC). In addition, Metro Vancouver and municipal staff have participated in a number of stakeholder consultation sessions held by the Province including workshops organized by the Provincial Office of Housing and Construction Standards and webinars organized by the Ministry of Community, Sport, and Cultural Development. Several Metro Vancouver municipalities are also members of the Energy Efficiency Working Group for Part 3 Buildings. Although this working group s mandate is to prepare recommendations for the energy efficiency of buildings that are actionable by local governments and the Province when the Building Act comes into force, the working group s recommendations will have significant influence and implications for the buildings policies in the Climate Leadership Plan.

5 Susanna Laaksonen-Craig, Head, Climate Action Secretariat, Ministry of Environment Metro Vancouver Phase II Input to the Provincial Climate Leadership Plan Pages of 6 Despite these opportunities there are three critical inadequacies to the consultation process: 1) The lack of opportunity to review a draft Climate Leadership Plan before the final version is released; 2) a consultation period that was too short to allow for Coordinated response from local governments; 3) absence of an integrated land-use and transportation working group. Lack of the Draft Climate Leadership Plan and Extension of Consultation At the outset of the Phase I Consultation period, the Province indicated that a draft Climate Leadership Plan would be released in late 2015 with a final document to follow in spring Metro Vancouver and other local governments expected to have an opportunity to participate in consultation on these versions of the Plan. On January 26, 2016, however, the Province released a high level Consultation Guide in place of a draft plan. The Consultation Guide summarizes broad directions from the first Discussion Guide, the feedback from the public, and the recommendations from the CLT, but does not provide detailed policies that would constitute an effective and meaningful plan. According to the revised consultation process that has been outlined by the Province, there will not be an opportunity to review and comment on a detailed draft plan. Instead, the Province has indicated that the Phase II Consultation will be the last consultation opportunity before the release of the final plan. In the absence of a detailed draft plan, it is difficult for local governments to evaluate which Climate Leadership Plan policies are being given the most serious consideration by the Province and how well those policies will achieve Provincial and local targets and support local climate priorities. Although the Province did allow the minimum consultation period (60 days) requested by Metro Vancouver in the Phase I consultation, feedback from municipalities (particularly the Regional Planning Advisory Committee) is that an extension would be needed to develop a more coordinated response. In conjunction with an opportunity to review a draft Climate Leadership Plan Metro Vancouver requests a longer consultation period to facilitate more detailed input from stakeholders. Creation of an Integrated Land-Use and Transportation Working Group Finally, as noted earlier integrated land-use and transportation policies and investments are fundamental climate action policies. In order to advance Provincial level support for local government efforts on integrated land-use and transportation, Metro Vancouver requests the creation of province-led, regional working groups on integrated land use and transportation planning to inform the final Climate Leadership Plan and the implementation process.

6 Susanna Laaksonen-Craig, Head, Climate Action Secretariat, Ministry of Environment Metro Vancouver Phase II Input to the Provincial Climate Leadership Plan Page 6 of 6 Metro Vancouver appreciates the opportunity to provide input to the Climate Leadership Plan during this consultation period and hopes the Province will give strong consideration to the recommendations above. If you have any questions or would like to further discuss our recommendations feel free to contact me. Yours truly, cj Carol Mason Commissioner! Chief Administrative Officer CM/ROJje cc: Meggin Messenger, Executive Director, Intergovernmental Relations and Planning, MCSCD Jessica Brooks, Executive Director, Transportation Governance and Planning, MCSCD Jennifer Hill, Manager, Intergovernmental Initiatives, MCSCD Ben Finkelstein, Manager, Communities and Built Environment, MoE End: Comparison of Climate Leadership Plan Phase I Submissions: Metro Vancouver, Public Feedback, and Climate Leadership Team Recommendations ( )

7 Comparison of Climate Leadership Plan Phase I Submissions: Metro Vancouver, Public Feedback, and Climate Leadership Team Recommendations Metro Vancouver Foundational Policy Areas Widespread adoption of low/zero carbon vehicles. Public Feedback Expanded regulations and incentives to encourage use of cleaner vehicles and fuels More clean, coordinated transportation such as public transit and shared travel Climate Leadership Team Recommendations Establish Zero Emission Vehicle targets for the sale of new light duty vehicles for 2020, 2025 and 2030 (#19a) Increase the Low Carbon Fuel Standard (LCFS) to 20 percent by 2030 (#19b) Broaden the LCFS coverage to include all vehicle fuel use with the exception of aviation fuel (#19c) Support increased commercial transport efficiency (size of vehicles) and natural gas/propane conversions (#19d) Establish revenue neutral PST for all vehicles based on grams of CO2 per km (#19e) Metro Vancouver Detailed Feedback Zero Emissions Vehicle requirement Creation of a BC Hydro rate category for vehicle charging Funding for Clean Energy Vehicles (CEV) program Require access to electric charging in residential and commercial buildings Increase HOV lanes on provincial roads Align the provincial Vehicle Emissions Standards with other progressive jurisdictions Modern regulatory environment for appbased rideshare Accelerate market penetration of zero emission and near-zero emission vans, tour buses, and trucks Update the provincial Low Carbon Fuel Standard Transition to net-zero-carbon new buildings and near net zero carbon existing buildings. Regulations and incentives for greener buildings Implement standards that support high-efficiency building equipment and appliances (#20d) Require new public sector buildings to use more materials that sequester carbon and meet most of its annual energy needs by on-site renewable energy starting in 2016 (#20a) Require new buildings to use more materials that sequester carbon and meet most of their annual Set incremental targets outlining the market transformation pathway(s) to net zero buildings Mandate home energy labelling Enabling legislation for municipalities to require mandatory building energy benchmarking Incentives for renewable energy retrofits Improve compliance with the energy provisions in the building code Build new affordable net zero rental and social housing

8 Comparison of Climate Leadership Plan Phase I Submissions: Metro Vancouver, Public Feedback, and Climate Leadership Team Recommendations Metro Vancouver Foundational Policy Areas Public Feedback Climate Leadership Team Recommendations energy needs by on-site renewable energy, through the building code (#20b) Encourage retrofits that reduce GHG emissions in existing buildings through programs (e.g. on-bill financing) (#20c) Metro Vancouver Detailed Feedback Support for local government actions to reduce and shorten vehicular trips and increase trips by walking, cycling, and transit. Carbon pricing to create a market signal to stimulate adoption of low carbon technologies and practices. Less travel and energy use to be a priority in community planning More clean, coordinated transportation such as public transit and shared travel Expanding the use of carbon pricing to stimulate decisions that reduce emissions Using regulations and incentives to encourage considering the cost of climate risks in important decisions Improving the affordability of solutions for consumers and businesses to address climate change Support increased use of public transit and other mobility options that reduce GHG emissions (#23) Increase the carbon tax in 2018 by $10/yr, maintain certain current tax reductions, and target tax credits and other mechanisms to emissions-intensive, trade exposed sectors and vulnerable groups (#5) Expand carbon tax coverage to all GHG emission sources in B.C. after 5 years (#6) Use incremental tax revenue for technology and innovation and local government projects resulting in reductions (#7b and #7c) Review integration of carbon tax with a cap and trade framework Sustainable funding for transit, active transportation infrastructure investments and smart growth planning Better VKT data to support planning Enable user-pricing options (e.g. mobility pricing, distance based insurance) Review of Provincial tolling policy Province commits to ongoing incremental increases to carbon tax. Consider extending the carbon tax to excluded industrial process emissions or implement cap and trade Return the incremental revenues of future new carbon tax increases to local governments Consider the most effective use of carbon tax revenues in support of climate action and mitigation of any negative impacts of the carbon tax

9 Comparison of Climate Leadership Plan Phase I Submissions: Metro Vancouver, Public Feedback, and Climate Leadership Team Recommendations Metro Vancouver Foundational Policy Areas Tools and resources that can assist local governments adapt to climate change that is already locked. Public Feedback Support for local food production and low carbon businesses Using regulations and incentives to encourage considering the cost of climate risks in important decisions Climate Leadership Team Recommendations for the B.C. context if majority of provinces opt for carbon pricing via emissions trading (#29) Work with federal, provincial and other North American governments to achieve parity with B.C s climate policies (#30) Lower PST and eliminate PST on electricity, supported by incremental carbon tax (#4 and #7a) Amend the Environmental Assessment Act to include the social cost of carbon (#11) Update forest and agriculture policy, regulation and protected areas strategies to account for climate change impacts (#16) Update by 2020 hazard maps for all climate related hazards (#24a) Invest in sufficient monitoring systems to ensure the change in climate can be managed effectively (#24b) Develop a policy framework to guide government's management of the risks associated with a changing climate (#24c) Use First Nations traditional knowledge when appropriate as part of hazard mapping information (#25a) Metro Vancouver Detailed Feedback Program for increasing the resiliency of buildings and other facilities Research approaches and technologies for green infrastructure in urban areas Building code regulations and/or innovative funding to incentivize private property adaptation Up-to-date, downscaled climate projections for local areas and other related tools Tools for local governments to undertake community risk assessments Guidelines for undertaking a risk assessment Decision support tools for developing adaptation policy Adaptation/resilience strategies that address specific risks Up-to-date natural hazard and risk mapping Guidance around flood construction levels Funding mechanisms for building flood protection infrastructure

10 Comparison of Climate Leadership Plan Phase I Submissions: Metro Vancouver, Public Feedback, and Climate Leadership Team Recommendations Metro Vancouver Foundational Policy Areas Public Feedback Climate Leadership Team Recommendations Resource the research of climate change impacts on the inherent and treaty rights of indigenous people (#25b) Metro Vancouver Detailed Feedback Climate risk assessment for provincial transportation infrastructure Design road infrastructure considering the potential impact of increased flooding Adopt a holistic decision-making process that integrates health outcome considerations Research on crop diversification and soil management Capital funding for drainage and irrigation infrastructure within the ALR Maintain the Environment Farm Program Expand scope of the Buy Local program and enable local food procurement policies Research and provide incentives for commercial/industrial gray water reuse Study the opportunities and risks of the use of non-potable water for agricultural uses.* Fund incentives, initiatives, and tools that reduce the amount of food waste * Note this recommendation has been modified based on feedback from Climate Action Committee since the original submission