Anwaatin Comments on Draft Ontario Climate Change Act - Bill 172 

Our partner company, Anwaatin, recently submitted comments to the Ontario Ministry of the Environment and Climate Change Regarding the draft of Bill 172 (the "Ontario Climate Change Act", know formally as the Climate Change Mitigation and Low-carbon Economy Act, 2016).  We reprint these comments here with permission.  Previous posts from Anwaatin authors include:


Anwaatin's Submission on Bill 172 (Climate Change Mitigation and Low-carbon Economy Act, 2016)

In the face of climate change, Indigenous peoples in Ontario have emerged as Stewardship Warriors. Indigenous peoples must be front and centre in responding to and preventing the worst effects of climate change.

Anwaatin is an Indigenous business working with Indigenous communities in linked Cap and Trade markets that include Ontario, Quebec, Manitoba and California. Our mission is to ensure Indigenous communities are front and center in fighting climate change, and leading emerging markets associated with climate change action. We believe that fighting climate change and revitalizing treaty relationships are two paths coming together.

Our business strategy with our Indigenous partners and clients includes:

  • Territorial climate action – treaty rights and stewardship traditional territories must be understood, documented, asserted and respected
  • Readiness for emerging Cap and Trade – Indigenous communities must understand the scope of their biodiversity and “carbon-sinks” and must know the value of their stewardship activities for actively selling Indigenous Carbon Offsets in Cap and Trade markets,
  • Strengthening biodiversity and resilience in the face of climate change – making sure that communities have plans and strategies in place to deal with the impacts of climate change on natural resources, infrastructure, communities and families
  • Partnerships to create Indigenous carbon offsets ("Indigenous Offsets") to sell competitively on Cap and Trade markets
    We believe the value of Indigenous stewardship of our forests, lands and waters must be made explicit in carbon reduction plans by all levels of government. Indigenous Peoples must have a primary role in the creation and management of such regimes and should be among the beneficiaries of bestowed by such schemes.

Specific Comments on Bill 172 

Bill 172 does not reflect the government-to-government relationships between Indigenous peoples and the Province of Ontario. Bill 172 must reflect this relationship and commit to consultation and accommodation with Indigenous communities at all levels. Indigenous communities must be included in government Cap and Trade implementation through a defined process for direct input into climate change legislation and programs. This requires guaranteed funding to gather traditional/technical knowledge and economic assessments of impacts of climate change, and a commitment from Ontario to work co-operatively and effectively manage the economic and social impacts of Cap and Trade on Indigenous rights and interests.
Furthermore, Bill 172 must:

1) Include firm commitments to incorporate Indigenous knowledge and Indigenous science – not simply “considering” this knowledge and science, but actively and meaningfully integrating this knowledge and science into decision-making

2) Recognize Indigenous co-ownership and stewardship of the lands, waters and carbon-sinks (including, but not limited to, forests, peatlands, and grasslands)

3) Recognize the stewardship roles that Indigenous peoples have with respect to managing carbonsinks throughout history, today and in the future, with full access to the economic opportunities that “Cap and Trade” provides for the stewards of carbon-sinks, and primary beneficiaries of “Cap and Trade” revenues from these carbon-sinks

4) Recognize the full range of carbon offset opportunities available to Indigenous peoples across Ontario within the Greenhouse Gas Reduction Account (Schedule 1), including:

a. Stewardship and management of peatlands – despite Ontario peatlands sequestering one-third of the carbon stored in Ontario, peatlands are not mentioned in the current draft of Bill 172. This is a major oversight in Schedule 1, particularly for First Nations in the James Bay Lowlands

b. Stewardship of the Boreal Forest – this should receive specific mention in Schedule 1

c. Stewardship of other non-forest carbon-sinks, including stewardship of riparian corridors, and stewardship of green areas in relation to freshwater and salt water coastal areas, especially given the significant land claims outstanding for such lands and waters

d. Displacing high-carbon oil fuels with low-carbon natural gas. Indigenous communities, especially those in the north struggle with energy poverty and high emission diesel and other petroleum-based heavy fuels. Most of Ontario’s population in the south can take for granted access to a range of low-carbon fuel options, with natural gas as the major source of heat energy. In the north, many indigenous communities are close to one of the largest natural gas pipelines in North America – the TransCanada Mainline – but have not had access to the low-cost, low-carbon energy transported by that pipeline since it was built in 1958. Given the Government’s understanding* that natural gas is a better alternative in terms of cost and reduction of greenhouse gases when compared to diesel or other high carbon fuels, Schedule 1 should make explicit mention of actions to facilitate access to low-carbon natural gas to unserved communities that currently make use of diesel or other carbon heavy fuels. Quebec’s new energy policy is far ahead of Ontario in this respect**.

Thank you for your time and consideration.



Larry Sault

CEO, Awaatin


* In connection with the Ontario Government’s 2013 Long-Term Energy Plan, the Government stated that it would look at opportunities to expand natural gas service within the Province to areas that are not currently served.  On February 17, 2015, the Ontario Minister of Energy in a letter to the Chair of the OEB encouraged the OEB to examine opportunities to facilitate access to natural gas services to more communities. In the three years since the Long-Term Energy Plan was released, little has happened in Ontario to expand natural gas service to rural, remote and First Nation communities. 

** Quebec’s new energy policy 2016-2030, entitled “Politique énergétique 2030, L’énergie des Québécois – Source de croissance” (Energy Policy 2030, The Energy of Quebecers – a Source of Growth -, recognizes natural gas is recognized as a profitable source of transition energy for Québec and will be called upon to play an important role in supporting the economic development of Quebec, including in Northern Quebec. The province seeks to ensure reliable, secure and stable access to natural gas throughout Quebec wherever demand and economic efficiency are met.  Quebec plans to expand the current natural gas network, develop a supply network for liquefied natural gas and increase production of renewable natural gas.  


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Text Copyright © Anwaatin, 2016

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