Manitoba Municipalities: Re-evaluation of Climate Action Plans and FCM ICLEI
Partners for Climate Protection Program Participation (Version 2)
Date: January 22, 2025
To: Manitoba Municipal Councils
Subject: Concerns Regarding Climate Action Plans and the FCM ICLEI’s Partners for Climate Protection Program Framework

Executive Summary

This report advises Manitoba municipalities to critically reevaluate participation in the FCM ICLEI Partners for Climate Protection (PCP) Program and the implementation of Climate Action Plans. While marketed as progressive climate initiatives, these programs often impose significant financial and administrative burdens on municipalities without yielding proportional benefits.

Manitoba is a net carbon sink due to its extensive forests, wetlands, grasslands, and agricultural lands, which naturally absorb more CO₂ than the province emits. This fact challenges the necessity and cost-effectiveness of adopting net-zero frameworks.

Furthermore, Manitoba municipalities face full financial and legal liability for any failures in implementing PCP programs, while the FCM, ICLEI and its funding partners explicitly disclaim responsibility.

Redirecting municipal resources from externally driven climate programs to locally prioritized issues—such as ensuring community growth through housing and energy availability, adaptive infrastructure, economic development, and public safety—will better serve residents.

Key Recommendations:

1. Pause and Reevaluate PCP participation and Climate Action Plans.

2. Ensure Transparency through financial audits and public consultation.

3. Withdraw from the PCP Program and redirect funds to local initiatives.

4. Prioritize Practical Environmental Stewardship over costly net-zero targets.

5. Address Immediate Municipal Needs such as housing, energy, and public safety.

The Manitoba Municipal Act and Council Authority

Under The Municipal Act of Manitoba, specifically section 82, a council is responsible for:

• Developing and evaluating the policies and programs of the municipality.

• Ensuring that the powers, duties, and functions of the municipality are appropriately carried out.

• Carrying out the powers, duties, and functions expressly given to the council under this or any other Act.

Each member of a council has the following duties as outlined in section 83(1):

• To consider the well-being and interests of the municipality as a whole and to bring to the council's attention anything that would promote the well-being or interests of the municipality.

• To participate generally in developing and evaluating the policies and programs of the municipality.

• To participate in meetings of the council and of council committees and other bodies to which the member is appointed by the council.

• To keep in confidence a matter that is discussed at a meeting closed to the public under subsection 152(3) and that the council decides to keep confidential until the matter is discussed at a meeting of the council conducted in public.

• To comply with the code of conduct for members of council.

• To perform any other duty or function imposed on the member by the council or this or any other Act.

These legal duties confirm that decision-making authority rests solely with elected councils, not unelected staff or external consultants.

A councillor’s Oath of Office, as required by section 104(1) of The Northern Affairs Act, further reinforces this authority:

• "A person elected as a member of a council must make and file with the community administrative officer an oath of office in the form approved by the minister, and the person may not carry out a power, duty or function as a member of the council until the oath of office is filed."

This sworn commitment obligates councillors to uphold the law, act in the best interests of residents, and make independent, informed decisions.

While staff and consultants may provide recommendations, their role is advisory, not decision-making. Councils alone hold the final authority to approve, modify, or reject programs like the ICLEI Partners for Climate Protection (PCP) and associated Climate Action Plans.

Given this mandate, councils must carefully evaluate whether such programs align with local priorities or impose unnecessary costs and external controls.

Municipalities in Manitoba operate within a framework of international, federal, and provincial climate policies. While international agreements and federal legislation set overarching goals, they do not impose direct legal obligations on municipalities. Provincial policies provide guidance, allowing local governments to establish their own priorities.

Legal Context: International, Federal, and Provincial Requirements

1. The Paris Agreement

• Scope: The Paris Agreement is an international treaty obligating countries to set Nationally Determined Contributions (NDCs) for reducing greenhouse gas emissions.

• Implications for Municipalities: Participation in initiatives like ICLEI’s Partners for Climate Protection (PCP) is voluntary. Manitoba municipalities are not legally required to implement net-zero policies in alignment with the Paris Agreement.

2. Federal Legislation—The Canadian Net-Zero Emissions Accountability Act

• Commitment: This Act commits Canada`s federal government to achieving net-zero greenhouse gas emissions by 2050.

• Municipal Autonomy: The Act does not impose mandatory requirements on municipalities, allowing them to determine their own climate action priorities and approaches.

3. Manitoba’s Climate Policy Framework

• The Climate and Green Plan Implementation Act (2018): This Act requires the province to develop a Climate and Green Plan aimed at reducing emissions and addressing climate change impacts. It introduces a Carbon Savings Account, setting cumulative emissions reduction goals for five-year periods. However, it does not mandate municipalities to adopt net-zero targets. Canadian Climate Institute

• Captured Carbon Storage Act: Introduced to establish a licensing framework for carbon capture and storage projects, this legislation facilitates industries in reducing greenhouse gas emissions. While it promotes large-scale emission reduction efforts, it does not impose specific obligations on municipalities. Government of Manitoba News

• Provincial Support for Renewable Energy: The Manitoba government collaborates with the federal government to support projects that transition farms and organizations to renewable energy sources. These initiatives aim to reduce emissions and work towards net-zero targets but do not legally bind municipalities to specific actions. Government of Canada

In summary, while Manitoba's provincial policies encourage emission reductions and provide frameworks for action, municipalities retain the flexibility to pursue climate initiatives that align with their specific community needs and resources.

Liability Waivers and What They Mean for Municipalities

Although ICLEI, the Federation of Canadian Municipalities (FCM), and the Government of Canada fund and administer programs such as PCP, these organizations have explicitly disclaimed liability for the outcomes or impacts of municipal participation.

Key Disclaimer (PCP Webpage):

• “This project was carried out with assistance from the Green Municipal Fund[6], a Fund financed by the Government of Canada and administered by the Federation of Canadian Municipalities, and from ICLEI – Local Governments for Sustainability (Management) Inc. Notwithstanding this support, the views expressed are the personal views of the authors, and ICLEI Canada, the Federation of Canadian Municipalities, and the Government of Canada accept no responsibility for them.”

What Does This Mean for Ontario Municipalities?

1. Voluntary Adoption: Programs modeled after PCP milestones are voluntary, and municipalities can opt out without facing legal penalties.

2. No External Accountability: ICLEI, FCM, and the Government of Canada have waived responsibility for any financial losses, policy failures, or legal disputes arising from participation.

3. Local Risk: Municipalities bear full legal and financial accountability for any cost overruns, compliance challenges, or policy impacts associated with their climate plans.

4. Financial Uncertainty: While programs may include grant funding, municipalities must cover long-term costs for implementation, monitoring, and reporting—often millions of dollars—without guarantees of success or protection from liability.

Data Collection Concerns

The Climate Action Plan requires extensive data collection at both the corporate (municipal operations) and community levels. These data collection requirements, outlined in the PCP Milestone One Protocol Handbook [8], are repeated annually or biannually and include:

Corporate Data Collection Requirements:

• Tracking energy consumption from all sources, including non-CO₂-emitting sources.

• Recording electricity usage for all municipal lighting annually.

• Monitoring energy consumption for water and wastewater facilities.

• Reporting fuel sources and emissions from all municipal buildings and facilities.

• Conducting waste audits to categorize and measure all waste materials, from food waste to electronics.

• Calculating the methane potential of landfill waste and assessing decay rates annually.

• Collecting data on fuel usage for all municipal fleet vehicles, including public transit and staff commuting patterns.

Community-Wide Data Collection Requirements:

• Emissions from residential, commercial, and industrial buildings, including fuel and electricity consumption.

• Fuel sales data and kilometers traveled by all vehicle types, public transit, and private transportation within the county.

• Monitoring emissions from industrial processes and wastewater treatment.

• Detailed solid waste data, including livestock counts and methane potential.

These requirements represent a significant administrative burden and raise serious ethical and privacy concerns, such as:

• Infringement on privacy: Residents and businesses may not be aware that their energy and waste habits are being tracked, leading to potential distrust in local government.

• Data security risks: Sensitive information is often managed by third-party organizations such as ICLEI, raising concerns about data breaches and potential misuse.

• Profit-driven motives: Data collected is often used to market "green energy" products, benefiting corporate interests rather than prioritizing genuine environmental stewardship.

This level of surveillance and data harvesting could be seen as disproportionate where local environmental initiatives can be achieved without such invasive measures.

PCP Cost Projections

Participation in the PCP program is often marketed as a low-cost initiative; however, significant hidden costs exist [7]. These financial demands disproportionately burden rural and smaller municipalities with recurring expenses tied to externally driven objectives.

Estimated Costs for PCP Participation and Implementation

Milestone/Initiative

Estimated Cost Range*

Baseline Emissions Inventory

$10,000–$50,000

Emissions Reduction Targets

$5,000–$25,000

Local Action Plan Development

$20,000–100,000

Implement Action Plan

$50,000–1,000,000+

Monitor and Report Results

$10,000–50,000 annually

Municipal Fleet Upgrades

$500,000–5,000,000+

EV Charging Stations

$100,000–1,000,000+

Municipal Building Upgrades

Smart City Technology

$1,000,000–10,000,000+

$500,000–5,000,000+

Circular Economy Initiatives

$1,000,000–10,000,000+

15-Minute City Model

$5,000,000–50,000,000+

Active Transportation Networks

$1,000,000–20,000,000+

Urban Densification

$5,000,000–100,000,000+

Total Cost Range:

• Modest Implementation: $8.2 million

• Comprehensive Implementation: $212 million+

These conservative estimates underscore the financial burden imposed by PCP participation and Climate Action Plan implementation. A thorough cost analysis of the program expenditures to date and anticipated future costs is essential.

Manitoba’s CO₂ Emissions and Carbon Sequestration Capacity

Provincial Emissions Based on National Context

To estimate Manitoba’s carbon dioxide (CO₂) emissions, we first consider Canada’s share of global CO₂ emissions and then scale it to the provincial population.

1. Canada’s Global CO₂ Emissions Contribution

   • Canada contributes approximately 1.6% of all human-caused CO₂ emissions.

   • Human activity accounts for approximately 4% of the 0.04% CO₂ concentration in Earth's atmosphere.

2. Canada’s Total CO₂ Emissions

   • Canada’s estimated annual CO₂ emissions are approximately 573 million tonnes (Mt).

   • With a population of 40 million, this equates to an average of 14.3 tonnes of CO₂ per person annually.

3. Manitoba’s Estimated Emissions

   • Manitoba’s population is approximately 1.4 million.

   • Using the national per capita emissions average: 1.4 million residents×14.3 tonnes per resident per year=20.02 Mt CO₂ annually1.4 \text{ million residents} \times 14.3 \text{ tonnes per resident per year} = 20.02 \text{ Mt CO₂ annually}1.4 million residents×14.3 tonnes per resident per year=20.02 Mt CO₂ annually

   • Thus, Manitoba’s gross annual CO₂ emissions are estimated at approximately 20 million tonnes.

Manitoba’s Carbon Sequestration Capacity

Net-zero programs often fail to account for existing carbon sinks, which already absorb significant amounts of CO₂. Manitoba’s natural landscapes—including forests, peatlands, and agricultural lands—act as carbon sinks, offsetting a substantial portion of the province’s emissions.

Key Carbon Sinks in Manitoba

• Forests

  • Manitoba’s boreal forests cover an estimated 26 million hectares.

  • Average sequestration rate: 7.5 tonnes of CO₂ per hectare per year.

  • Estimated CO₂ absorbed annually: 195 million tonnes.

• Peatlands

  • The Hudson Plains region contains extensive peatlands covering 9 million hectares.

  • Average sequestration rate: 5.5 tonnes of CO₂ per hectare per year.

  • Estimated CO₂ absorbed annually: 49.5 million tonnes.

• Agricultural Soils & Grasslands

  • Manitoba has 9 million hectares of farmland and native grasslands.

  • Average sequestration rate: 3.1 tonnes of CO₂ per hectare per year.

  • Estimated CO₂ absorbed annually: 27.9 million tonnes.

• Wetlands

  • Manitoba has 1 million hectares of wetlands.

  • Average sequestration rate: 1.8 tonnes of CO₂ per hectare per year.

  • Estimated CO₂ absorbed annually: 1.8 million tonnes.

Net CO₂ Balance for Manitoba

20 Mt (Emissions)−274.2 Mt (Sequestration)=−254.2 Mt CO₂ annually20 \text{ Mt (Emissions)} - 274.2 \text{ Mt (Sequestration)} = -254.2 \text{ Mt CO₂ annually}20 Mt (Emissions)−274.2 Mt (Sequestration)=−254.2 Mt CO₂ annually

Manitoba is a significant net carbon sink, absorbing approximately 254 million tonnes more CO₂ than it emits each year.

Additional Unaccounted Carbon Sinks

• Urban Green Spaces – Parks, tree-lined streets, and gardens contribute additional sequestration.

• Riparian Zones – Vegetated areas along rivers and lakes enhance CO₂ absorption.

• Aquatic Vegetation – Algae and submerged plants store carbon in Manitoba’s lakes and waterways.

Manitoba is Already Carbon Negative

Manitoba’s substantial carbon sequestration capacity far exceeds its emissions, reinforcing the need to reassess costly net-zero policies that do not acknowledge the province’s environmental strengths. Redirecting resources toward local environmental initiatives—rather than externally driven climate programs—would better serve municipal priorities.

Redirecting Resources to Local Priorities

In Canada, municipalities operate under the authority of provincial and territorial governments, which delegate specific responsibilities through legislation such as Municipal. While responsibilities may vary slightly by province or territory, the core municipal responsibilities generally include:

• Housing Availability: Addressing rising costs and availability challenges to ensure safe, accessible housing for all residents, while protecting property rights and preventing the over-classification of rural land that displaces people and limits rural development opportunities.

• Energy Security: Ensuring affordable, reliable energy to support households, businesses, and community infrastructure, including the expansion of natural gas to meet growing demand and support economic development.

• Land Use Planning and Development: Ensuring balanced growth and zoning policies that support both urban and rural communities, resisting centralized "sustainable development" policies that disproportionately favor urban areas at the expense of small and rural communities.

• Infrastructure Maintenance and Expansion: Ensuring the upkeep and improvement of roads, bridges, water, and wastewater systems.

• Public Transit: Providing accessible, efficient, and affordable transportation options for residents, while avoiding transportation models that discourage private gas-powered vehicle use or limit parking near small businesses in favor of active transportation.

 • Emergency Services and Public Safety: Supporting police, fire, and paramedic services to enhance community safety and response capabilities, including mental health supports and emergency preparedness.

• Waste Management: Overseeing efficient collection, recycling, and disposal services to promote environmental stewardship.

• Parks and Recreation:  Maintaining and expanding green spaces, recreational facilities, and community programs to enhance quality of life.

• Economic Development: Promoting job creation and local industry growth to sustain vibrant and resilient communities, with a focus on organic local growth, small businesses, and entrepreneurship. It is not acceptable to prioritize global investors and big-box stores over locally owned businesses that are the backbone of the community.

• Public Health and Social Services: Collaborating with health agencies to address community well-being and social support programs.

• Government Accountability: Strengthening transparency and fiscal responsibility to restore public trust and confidence in decision-making.

Municipal governments must focus on core responsibilities that directly impact residents and avoid diverting funds toward global initiatives that fall outside their jurisdiction, such as internationally driven climate action programs.

Redirecting funds and efforts toward these critical community needs better serves residents and ensures that municipal governments remain focused on local priorities. This approach avoids imposing costly net-zero policies that are misaligned with Ontario's existing natural carbon advantage and the immediate concerns of its citizens.

Recommendations

1. Pause and Reevaluate the PCP Program and Climate Action:

• Conduct a comprehensive review of the program and climate action plan, including public consultation, to ensure it aligns with local priorities and financial capacities.

• Assess the cost-effectiveness and feasibility of continuing with the data-driven milestone-based framework. 

2. Improve Transparency and Accountability:

• Disclose all costs already incurred under the PCP program and Climate Action Plan, including consultation fees, data collection expenses, and projected liabilities.

• Conduct a financial audit of climate-related spending to assess the long-term impact on taxpayers and municipal resources.

• Engage residents and stakeholders in public consultations to restore trust and ensure accountability for policy decisions.

3. Withdraw from the PCP Program and Halt Climate Action Plan Implementation:

• Immediately withdraw from the ICLEI Partners for Climate Protection (PCP) program or similar 5 Milestone frameworks to end participation in externally driven climate action plans that do not reflect Ontario’s net-negative carbon status or local priorities.

• Cease development and implementation of the Climate Action Plan to prevent further financial commitments, administrative burdens, and policy constraints tied to net-zero targets.

• Redirect resources toward practical, locally driven initiatives that deliver measurable benefits to residents and the municipality.

4. Prioritize Local Environmental Stewardship and Practical Solutions:

• Focus on protecting natural carbon sinks—forests, wetlands, peatlands and agricultural lands—that already absorb more CO₂ than the province emits, maintaining Ontario’s net-negative carbon status.

• Develop cost-effective programs to improve pollution prevention, water quality, and waste management, ensuring local control and economic sustainability.

• Develop practical, locally driven programs that enhance carbon sequestration without imposing excessive costs or reliance on data collection and “green” technologies.

• Support infrastructure resilience and emergency preparedness to protect against natural disasters and improve community safety.

5. Address Immediate Municipal Priorities:

• Housing: Limit restrictions on land-use and green tape on construction to increase access to safe, affordable housing and meet urgent local needs.

• Energy Security: Invest in affordable, reliable energy infrastructure to protect residents and businesses.

• Economic Development: Promote local job creation and industry growth to support sustainable economic activity.

• Public Safety and Community Programs: Strengthen fire services, policing, and emergency response capabilities to safeguard lives and property.

• Government Accountability: Maintain transparency and fiscal responsibility to ensure trust and confidence in decision-making.

Conclusion

Manitoba’s net-negative carbon balance proves that net-zero frameworks and climate action plans are misaligned with the province’s environmental strengths, immediate local priorities and municipal responsibilities. We respectfully request the councils to reevaluate climate policies, prioritize transparency, and safeguard the interests of its residents.

Sincerely,
Maggie Braun, KICLEI Canada, info@kiclei.ca
Concerned Residents and Stakeholders of Manitoba Municipalities