Ontario Municipalities: Re-evaluation of Climate Action Plans and ICLEI Partners for Climate Protection Program Participation
Date: January. 22, 2025
To: Ontario Municipal Council’s
Subject: Concerns Regarding the Climate Action Plan’s and the FCM ICLEI’s Partners for Climate Protection Program Framework

Executive Summary

This report advises Ontario`s 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.

Ontario is a net carbon sink due to its vast forests, wetlands, peatlands, 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.

Further, Ontario`s municipalities face full financial and legal liability for any failures in implementing PCP programs, while 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 Ontario Municipal Act and Council Authority

Under Section 224 of the Ontario Municipal Act, 2001[1], councillors, as elected officials, are responsible for:

• “Representing the public and considering the well-being and interests of the municipality.”

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

• “Ensuring accountability and transparency of the operations of the municipality.”

These legal duties confirm that decision-making authority rests solely with council, not staff or consultants.

Councillors’ Declaration of Office further reinforces this authority, requiring them to:

• “Truly, faithfully and impartially exercise this office to the best of my knowledge and ability.” [1]

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 advise, their role is not to decide. The council alone holds 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, council must carefully evaluate whether such programs align with local priorities or impose unnecessary costs and external controls.

Legal Context: International, Federal, and Provincial Requirements

Municipalities must navigate various climate policies within international, federal, and provincial frameworks. While agreements like the Paris Agreement set national targets, they do not legally bind municipalities. Federal and provincial policies provide guidance but allow local governments to set their own priorities.

1. The Paris Agreement

   • The Paris Agreement [2] is an international treaty that commits countries, not municipalities, to Nationally Determined Contributions (NDCs) for greenhouse gas reductions.

   • Participation in programs like ICLEI’s PCP is voluntary, and Ontario municipalities are under no legal obligation to implement net-zero policies aligned with the agreement.

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

   • The Canadian Net-Zero Emissions Accountability Act [3] commits Canada to achieving net-zero GHG emissions by 2050 but imposes no mandatory requirements on municipalities.

   • Municipalities remain free to determine their own priorities and approaches without legal enforcement under this federal act.

3. Ontario’s Climate Policy History

   • Ontario repealed its Climate Change Mitigation and Low-Carbon Economy Act, 2016[8], which established a cap-and-trade system aimed at reducing greenhouse gas emissions.

   • Since then, Ontario has not enacted any binding legislation mandating municipalities to adopt net-zero targets or milestone-based frameworks like those promoted by ICLEI.

   • Local governments maintain full autonomy to design policies that align with local needs, finances, and priorities.

Ontario municipalities are not legally required to adopt net-zero policies or participate in programs like ICLEI’s PCP. They have the flexibility to pursue initiatives that align with their community’s 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 [5].

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.

Comparison of PCP Reporting vs. Ontario Energy Report

There is a significant difference between the Ontario Energy Consumption and Demand Report and comprehensive Climate Action Plan frameworks:

The Ontario Energy Consumption and Demand Report focuses solely on tracking and improving energy efficiency within municipal operations, requiring minimal administrative effort and limited costs.

In contrast, the Climate Action Plan frameworks demand broad data collection across both community and corporate sectors, extensive reporting, and costly implementation of emissions reduction initiatives that extend far beyond municipal operations and responsibilities.

The PCP program’s reporting requirements under Milestone 5 are significantly more demanding than those of existing provincial frameworks like the Ontario Energy Report. We have sent an open letter to ICLEI to confirm that they receive the data and to understand their relationship with recommended product suppliers. ICLEI has not responded [10].

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.

Ontario’s CO₂ Emissions and Carbon Sequestration Capacity

Ontario’s CO₂ Emissions and Carbon Sequestration Capacity

Provincial Emissions Ontario has a population of approximately 14.5 million residents. Using Canada’s average per capita emissions of 14.2 tonnes of CO₂ per year, Ontario’s gross emissions are calculated as follows:

• 14.5 million residents × 14.2 tonnes of CO₂ per resident per year = 205.9 million tonnes of CO₂ annually.

Thus, Ontario’s gross annual CO₂ emissions are approximately 205.9 million tonnes.

Ontario’s Carbon Sequestration Capacity Net-zero programs often overlook preexisting carbon sinks, failing to account for natural ecosystems that already absorb large amounts of carbon dioxide. These programs treat all areas equally, ignoring the significant contributions of forests, wetlands, peatlands, managed forests, and agricultural lands to carbon sequestration.

Ontario’s ecosystems serve as powerful carbon sinks, absorbing significantly more CO₂ than the population emits. Hectares by category and their estimated absorption rates are as follows:

• Forests – Cover approximately 43.2 million hectares (excluding managed forests), absorbing an estimated 7.7 tonnes of CO₂ per hectare annually, for a total of 332.6 million tonnes of CO₂ absorbed annually[4].

• Managed Forests – Cover approximately 27.8 million hectares, absorbing an estimated 11 tonnes of CO₂ per hectare annually, for a total of 305.8 million tonnes of CO₂ absorbed annually[4].

• Wetlands – Cover approximately 96,014 hectares, absorbing an estimated 1.85 tonnes of CO₂ per hectare annually, for a total of 177,626 tonnes of CO₂ absorbed annually[11].

• Farmlands (Agricultural Soils) – Cover approximately 36 million hectares, absorbing an estimated 3.1 tonnes of CO₂ per hectare annually, for a total of 111.6 million tonnes of CO₂ absorbed annually[10].

• Peatlands – The Hudson Bay Lowlands alone cover approximately 26 million hectares, absorbing an estimated 5.5 tonnes of CO₂ per hectare annually, for a total of 143 million tonnes of CO₂ absorbed annually[4].

Net CO₂ Balance:

• 205.9 million tonnes (emissions) − 893.2 million tonnes (sequestered) = -687.3 million tonnes annually

Ontario is a significant net carbon sink, absorbing approximately 687.3 million tonnes more CO₂ than it emits annually.

Ecosystems Not Yet Included in the Calculation:

• Grasslands: Limited data but contribute modestly to sequestration [9].

• Urban Green Spaces: Parks, green roofs, and urban forests remain unquantified [9].

• Riparian Zones: Vegetated areas along rivers and lakes need further study.

• Aquatic Vegetation: Underwater ecosystems, like lake and river plants, are not yet included.

Including these ecosystems would increase Ontario’s total CO₂ sequestration capacity further.

Ontario is a net carbon sink, absorbing approximately -687.3 million tonnes more CO₂ than it emits each year. This substantial carbon sequestration capacity highlights the misalignment between costly net-zero policies and Ontario's existing environmental strengths.

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

Ontario’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 Ontario Municipalities

References

1. Ontario Municipal Act, 2001, S.O. 2001, c. 25. Retrieved from https://www.ontario.ca/laws/statute/01m25

2. The Paris Agreement (2015). United Nations Framework Convention on Climate Change. Retrieved from https://unfccc.int/process-and-meetings/the-paris-agreement/the-paris-agreement

3. Canadian Net-Zero Emissions Accountability Act, S.C. 2021, c. 22. Retrieved from https://laws-lois.justice.gc.ca/eng/acts/C-19.5/

4. Ontario Ministry of Natural Resources and Forestry. Forest Resources of Ontario. Retrieved from https://www.ontario.ca/document/forest-resources-ontario-2021

5. Partners for Climate Protection (PCP) Program. Retrieved from https://www.pcp-ppc.ca/membership

6. Federation of Canadian Municipalities (FCM). Green Municipal Fund. Retrieved from https://fcm.ca/en/programs/green-municipal-fund

7. KICLEI Report. 2024. Cost Breakdown for Municipalities Participating in the PCP Program and Climate Action Plans. Retrieved from https://kiclei.substack.com/p/cost-breakdown-for-municipalities

8. PCP Milestone One Protocol Handbook. 2025. Retrieved from https://assets-global.website-files.com/6022ab403a6b2126c03ebf95/620d73c877f300b64e148909_pcp-milestone-1-instruction-manual.pdf

9. KICLEI. 2024. Open Letter to ICLEI Canada: Request for Information on ICLEI's Origin, Program Implementation, and Funding Sources. Retrieved from https://kiclei.substack.com/p/open-letter-to-iclei-canada-request

10. Greenbelt Foundation. Biodiversity in Ontario’s Greenbelt. Retrieved from https://www.greenbelt.ca/biodiversity_in_ontario

11. Ontario Ministry of Environment, Conservation, and Parks. Ontario's Climate Change Policy. Retrieved from https://www.ontario.ca/page/climate-change

12. Springer Link. Wetlands and Carbon Sequestration Rates. Retrieved from https://link.springer.com/article/10.1007/s11769-020-1122-3