By: Zach Beers
The reality of climate change and its impacts are beyond scientific dispute. Debate on the effects of greenhouse gas emissions defined the earlier years of climate science, now even the most entrenched interests concede that the climate is in fact changing. The challenge to an effective response to climate change is not the creation of climate strategies but converting these into action. This task engages all levels of government. International and federal levels of government serve as leaders in defining the scope of the challenge and the responsibilities of subordinate powers. Provincial and municipal actors in Canada will move the needle of progress. These local levels of powers are where the EV rubber hits the road in translating international commitments and federal obligations into works.
There is more than one way to decarbonize a cat. Municipal governments have adopted a variety of climate change plans. Municipalities are constrained by their empowering legislation, and thus limited in how much their response can vary from that of the higher provincial authority. Ontario provides an example of how the interrelation of provincial statutory frameworks for municipalities and the ambition of city governments can create a range of responses to the climate crisis.
A review of municipal climate plans reveals a planning to implementation gap which often hinders achieving climate goals as described by Rogers, Adams, and Byrne.1 The weakness rests on several factors:
“Implementation not being built into municipal policies, processes, and long-term plans; no one in a municipal administration ‘owns’ the actions to be implemented; implementation is marginalized; and there is limited external pressure applied on a municipal council to ensure adaptation policy commitments are implemented”2
Creating legal mechanisms to formalize municipal climate change goals improves the success of achieving these targets. This improvement bridges the planning to implementation gap which hinders the success of many municipal climate change frameworks.3 Municipalities in Canada have limited authority as creatures of the province but this does not mean they have no authority. By creating legal tools and structures through creative interpretation of provincial statutes and legal courage in the application of given municipal authority, municipal climate change goals can be achieved without the need for a collaborative provincial government.
Legal formalization of climate goals furthers their success in several ways. The usage of by-laws creates a structure which can inform and influence municipal and private actors in a city. Showing a willingness to interpret granted authority to empower climate objectives signal to other actors in the city that climate commitments are serious and carry legal force. Formal tools provide for open accountability in city administrations to meet their own set targets. Creating legal mechanism focused on implementing municipal climate goals overcomes the planning to implementation gap present in many ambitious climate plans.
A Review of Two Cities
Toronto and Ottawa are Ontario’s most populus cities. Each are empowered by provincial statute.4 Both have modern extensive climate change plans. However, these cities are not the same in how they have approached the challenge of climate change nor in their efficacy.
Ottawa’s approach could be characterized as a principle’s-based plan. The Ottawa Climate Change Master Plan (CCMP)governs the city’s strategy.5 Ottawa has ambition in its climate goals but has not formalized its targets through legal mechanisms. Recent review of progress in implementing the CCMP shows that the city is behind on its targets.6 This audit report focused on implementation actions of the CCMP and not a measure of GHG emissions.7
Toronto’s approach is to create legal mechanisms which entrench targets within the municipal code while applying transparency measures and regulatory tactics to achieve implementation. The primary document governing Toronto’s climate plan is the TransformTO Net Zero Strategy.8 The goals are formalized via the Toronto Municipal Code Chapter 669, a key transparency measure.9 The primary tactics for implementation are the Toronto Green Standard and the Carbon Budget.10 A recent GHG inventory report warned that Toronto was off its 2030 target by about 7%, but with time to accelerate its program.11 This inventory report is focused on calculation of GHG emissions but not on analyzing the implementation of aspects of the TransformTO Net Zero Strategy.
Toronto and the TransformTO Net Zero Strategy
Toronto City Council adopted the TransformTO Net Zero Strategy in December 2021, an ambitious update on the previous climate plan.12 The comprehensive strategy sets a goal of net zero greenhouse gas emissions community wide by 2040. This goal is achieved through solutions ranging from city planning to transport systems.
Central to the plan is a tiered emission reduction strategy. The first tier begins with an accelerated community wide greenhouse gas reduction of 65% from 1990 levels by 2030.13 This is a notable jump on achieving net zero by 2040 and benchmarks against 1990, an unusually early year compared to other GHG reduction targets. Tier two is net zero by 2040 in both community wide and corporate emissions.14 Implementation of the emission goals is supported through two pillars, the Toronto Green Standard (TGS) and the Carbon Budget.
The Toronto Green Standard is the city’s primary compliance tool and pre-dates the creation of the TransformTO Net Zero Strategy. First introduced in 2006, the TGS is updated on 4-year cycles allowing for evolution and acceleration in achieving municipal climate targets.15 The TGS is designed to improve the environmental performance of new buildings by setting increasingly higher standards for sustainable design and construction.
At its core, the TGS is a permit approval condition. There are multiple tiers of the TGS, however only Tier 1 is mandatory. It is mandatory in that all new developments are governed by a site plan approval provision under s114 of The City Toronto Act.16 Further, s108.1 of the City of Toronto Act provides for establishing environmental standards in the construction of new buildings.17 The two provisions serve as the legal foundation for the mandatory nature of tier 1 and for potentially mandating higher tiers in the future. In action, developers must conform to the TGS when submitting their site plan for permit approval. Without compliance, no permits are issued. This regulatory process is an example of how Toronto has creatively interpreted its municipal authority as governed by statute to implement its climate change goals.
Toronto’s second pillar to effective implementation rests on the Carbon Budget. Unlike standard annual fiscal budgets, the Carbon Budget focus is on GHG output and avoiding a carbon “deficit” in the yearly operations of the city. The Carbon Budget operates in parallel to the financial budget, aligned to the financial plans of the city and reported in each budget cycle to measure the carbon impact of each financial measure.18 The addition of the Carbon Budget provides several impacts on implementation of the TransformTO Net Zero Strategy. The elevation of carbon output to the same level as municipal finances gives the GHG reduction targets added weight. To track carbon output effectively, refined tracking and metric practices must be established. The transparency of budget review cycles allows for accountability in achieving goals. The use of the Carbon Budget aligns various city departments and positions around a centralized objective.19
The Carbon Budget is another example of Toronto’s approach to climate goals through the creation of legal mechanisms. The Carbon Budget is entrenched in the broader Toronto Municipal Code Chapter 669, Climate Change Goals and Governance (Chapter 669), formally adopted as By-law 600-2023.20 While the statute is broader than the Carbon Budget, carbon budgeting is core to the bylaw itself.
By-law 600-2023 serves three major functions. First, the bylaw codifies the city’s climate goals as outlined in the TransformTO Net Zero Strategy and any successor plans.21 This formalization elevates the strategy from policy statement to legally recognized objectives. Second, the Carbon Budget is defined under s669 – 2.3, notably under the heading ‘Carbon Accountability’.22 Third, the bylaw establishes numerous targets, metrics, program requirements, and reporting regimes. This raft of definitions creates a robust tracking system to ensure progress is made towards targets. Working in concert, the entrenched targets, reporting structures, and accountability mechanisms are a clear example of Toronto’s approach to creating legal mechanisms for its climate goals.
Beyond the three main aims of the bylaw, the simple elevation of these aspects of the TransformTo Net Zero Strategy into a formal bylaw signals the importance of the goals and sets a higher bar to contravene its provisions.23 The existence of the bylaw is useful for changing behaviour, particularly within long established departments of the city’s administration or long serving senior municipal employees. Focus on transparency and reporting puts the onus on council and municipal departments to translate strategy into measurable performance. If council’s disposition changes over time, contravening the bylaw would require enacting an amendment to change. This high bar requires a deeper level of commitment by council to alter the plan, likely creating political friction and public accountability.24 The pith and substance of the bylaw and the real-world impacts on the city’s administration create a strong bridge to overcome the policy to implementation gap that hinders many ambitious climate change plans.
Ottawa and the Climate Change Master Plan
Ottawa’s approach to climate change can be characterized as principles based. The governing document is the Climate Change Master Plan (CCMP).25 The ambitious goals contained within the CCMP are supported by the Ottawa Energy Evolution (OEE), the primary action plan to translate strategy within the CCMP into measurable progress.26 Ottawa has not formalized either the CCMP nor implementation aspects within legal mechanisms such as Toronto. The plan does include reporting and accountability measures despite their weakness of force.
The CCMP is a forward-looking strategy adopted by the City of Ottawa in January 2020.27 The timeline for the plan is 30 years, spanning to 2050, with a detailed focus on the 2020-2025 period. Included within the CCMP are GHG emission reduction targets and associated priority actions. The goal is a 100% reduction in corporate emissions by 2040 and community emissions by 2050. This target is achieved through 8 key action items.28 Many of these actions focus on integrating a climate perspective into city planning processes and developing supporting strategies based on the addition of a climate lens to municipal activities. Notably, there is a focus on climate adaptation and resilience which is at times missing from comparative plans in other cities.29 To ensure accountability, an independent review of the plan’s progress is embedded within the CCMP; the first audit report was released in June 2024 and measures Ottawa’s implementation over the first 4 years of the CCMP.30
Central to the implementation of the CCMP is the Ottawa Energy Evolution (OEE). Officially titled “Energy Evolution: Ottawa’s Community Energy Transition Strategy – Final Report”, the document’s primary purpose is establishing an action plan to meet the targets within the CCMP. The OEE is a strategy development process. The content of the OEE is focused on a custom energy and emissions forecasting model called CityInSight.31 This data model forecasts emissions growth rates based on a variety of scenarios. Through this custom model, the OEE defines expected emissions by sector depending on whether the emissions grow at current rates or are impacted by municipal intervention. Using this forecasting, the OEE then outlines target areas based on their expected growth. To implement this reduction, several projects are identified based on their potential impact.32 Holistically, the OEE creates a baseline data metric used to target emissions sectors with high impact projects.
The impact of the OEE in achieving targets under the CCMP has recently been assessed. The Audit of the Climate Change Master Plan June 2024 is a report by the City of Ottawa’s Auditor General, Nathalie Gougeon, covering the period of 2020-2024.33 This four-year audit assesses the City of Ottawa’s progress and plans in meeting the goals of its Climate Change Master Plan. The report serves as a guidepost for City Council and Ottawa citizens to evaluate the effectiveness of the City’s efforts in addressing climate change. It offers both reasonable praise and constructive criticism regarding the City’s plans and their implementation.
A central finding of the audit is that Ottawa is lagging its targets set out in the CCMP.34 The report outlines both a lack of clarity and effective implementation of the established Master Plan. Despite the ambitions and breadth of the CCMP, its translation into tangible actions and measurable progress has been insufficient.
The Audit focuses on a lack of effective municipal tools adopted by the City to reach its goals.35 The report points to other municipalities, including Toronto, and their use of tools like the Toronto Green Standard as opportunities for Ottawa to consider.36 Further, there are no effective reporting mechanisms for tracking progress and ambiguity on roles and responsibilities within the organization for delivering progress.37 The Audit reveals weakness in the principles-based approach’s translation into concrete action.
Scholarly Review
Toronto and Ottawa have taken different approaches to plan implementation; scholarly research can qualify each strategy while highlighting general gaps within municipal climate plans more broadly. Authors Guyadeen, Thistlethwaite, and Henstra recommend an evaluation framework and a structured approach to analyzing the content of municipal climate change plans and assess their strengths and deficiencies.38 Their framework provides a method for evaluating the quality of a single plan and for comparing different plans. This allows for a systematic comparison of plan content and quality across jurisdictions to identify strengths, weaknesses, common themes, and opportunities for improvement. The study aimed to determine the state of climate change planning in Canada’s largest municipalities.
Eight aspects in assessing plan quality are listed: fact base, goals, policies, implementation, monitoring and evaluation, inter-organizational coordination, participation, plan organization and presentation.39 The research reviewed plans from roughly 2007 to 2015, making it slightly outdated as the municipal plans for Toronto and Ottawa have since been updated. The binary scoring might overlook the depth or quality of certain elements. The equal weighting of the characteristics might not reflect their relative importance in achieving effective climate action. The study itself acknowledges that a higher quality plan may not automatically lead to better implementation.40
Despite these limitations, this evaluation framework offers a valuable and structured approach to assessing the quality of municipal climate change plans. It provides a foundation for understanding the state of climate change planning in Canada and for identifying areas where improvements can be made. Several key findings on the overall state of Canadian municipal climate plans are relevant to the comparison of Toronto and Ottawa’s current approach. In general, Canadian municipal climate change plans prioritize mitigation over adaptation. There are consistent weaknesses across all municipal plans reviewed in the areas of implementation and monitoring and evaluation. Also, there is usually an insufficient consideration to stakeholder engagement.41 In short, many plans lacked processes to translate goals into actions, had weaker monitoring metrics with little structured reporting on progress, and generally informed stakeholders over engaging with stakeholders in plan development.
Furthering the research, authors Donoghue and Katz-Rosene of the University of Ottawa’s School of Political Studies analyzed the comprehensiveness of municipal climate plans.42 The primary aim of the study is to examine the preparedness of Ontario’s fifteen most populated cities to adapt to the impacts of climate change and extreme weather events. It seeks to systematically analyze the comprehensiveness of adaptation plans by determining the presence or absence of the same eight key aspects of plan quality established by the Guyadeen et al. framework.43 The approach differs slightly from the focus on “quality” as discussed previously, instead the comprehensiveness framework explicitly prioritizes the breadth of the plan’s scope.
Using a content analysis approach, the assessment is on the presence or absence of characteristics rather than the extent to which they are present or their quality.44 Weight of the eight characteristics is equal, which may not reflect their actual importance in practice. Also, the study assesses the plan document itself and does not directly measure implementation or effectiveness in building actual resilience.45
While considering these shortcomings and the shift in focus on comprehensiveness vis a vie climate resilience, the study still provides an updated overview of how Ontario municipalities have improved on the strengths of their plans or shored up the weaknesses of their strategy as assessed by Guyadeen et al. An earlier iteration of Ottawa’s Climate Change Master Plan from 2019 is used in the study’s research, however the current TransformTO Net Zero Strategy is not reviewed.46
Once again, Ontario plans scored well in the areas of information base, goals, and organization and presentation. Stakeholder engagement scores seem to have improved, or at least plans assessed were found to contain qualified stakeholder engagement despite the quality of engagement not being explicitly addressed. Implementation and monitoring and evaluation scores were once again low across all reviewed plans. The consistency of these weaknesses between two separate studies separated by 5 years underlines a persistent deficit in Ontario municipal climate plans.
Comparative Analysis
Equipped with this research, a comparison of Toronto’s TransformTO Net Zero Strategy and the Ottawa Climate Change Master Plan using the evaluation frameworks from both Guyadeen et al and Donoghue & Katz-Rosene is required.
Both Toronto and Ottawa’s plans demonstrate a strong fact base. Toronto’s TransformTO Net Zero Strategy has built upon previous climate action strategies and includes technical modeling. The Ottawa Energy Evolution underpinning Ottawa’s CCMP has robust custom data modeling. Both cities have established clear goals. Toronto has a target of net-zero GHG emissions by 2040 while Ottawa aims for a net zero across the city by 2050. However, Toronto’s goals are more legally formalized and ambitious in terms of timeline.
Numerous policies and actions are outlined in each plan. Toronto’s strategy includes actions across sectors like buildings, energy, and transportation and includes tools like the Toronto Green Standard. Ottawa targets both mitigation and adaptation actions, with policies covering a range from climate considerations incorporated into city planning to developing carbon sequestration tactics.
Both plans are well organized and presented. Each is contained holistically in a readily accessible public document and supported with detailed reports and plans. These plans are well structured and organize data through tables and charts for ease of use. Appendices and citations are fulsome.
Stakeholder participation is included within each plan. TransformTO Net Zero Strategy is supported by a host of community engagement reports reaching back years prior to the adopted version of the plan.47 Priority #7 of the Ottawa municipal plan focuses on city leadership in climate action through stakeholder engagement and outreach.48 However, the Audit of the CCMP found that while there was consultation with stakeholders in development of the plan, Ottawa was failing to lead the outreach and education of the community.49
Inter-organizational coordination comes through in both plans. Each acknowledges the need for inter-departmental coordination within municipal administration as well as external governmental and private sector agencies. Toronto’s approach has secured several federal grants and private sector development projects while also integrating interdepartmental coordination via the Municipal Code 669.50 By contrast, the Audit of Ottawa’s CCMP listed inter-departmental challenges under its recommendation #4 and #5, stating a need to clarify and coordinate roles within the city’s administration.51
Implementation is a significant area of divergence. Toronto demonstrates a stronger approach to implementation through legal mechanisms by embedding climate goals in its Municipal Code Chapter 669, including carbon accountability and budgetary considerations. Further, the Toronto Green Standard is a direct implementation tool, consistently updated to accelerate climate goals. Ottawa adopts a “principles-based approach” without the same level of legal force. The Audit of Ottawa’s CCMP noted a lack of effective municipal tools adopted by the City to reach its goals, directly suggesting implementation tools like the ones adopted by Toronto.52 Ottawa is exploring corporate carbon budgets, but their implementation hasn’t reached Toronto’s level.
Finally, there is a variance in monitoring and evaluation. Toronto’s Municipal Chapter 669 establishes reporting requirements, including Advanced Plans and Progress Reports for emissions budgets.53 Ottawa’s Master Plan includes metric development and reporting, and the Auditor General’s audit provides an accountability mechanism. However, the Audit of the CCMP makes it clear under Recommendation #3 and #7 that accountability reporting is insufficient and that there is a lack of specific, quantitative metrics for assessment.54
Overall, using the Guyadeen et al. framework, Toronto’s approach appears stronger in legally formalizing its goals and implementation mechanisms, which could address the general weakness in these areas found in Canadian municipal climate plans. Ottawa has a quality plan but lags in adopting concrete, legally binding tools for implementation. Both Toronto and Ottawa have strong foundational elements in their climate plans such as information, goals, policies, participation, and organization. Yet, they diverge in the common Ontario-wide challenges of strengthening implementation and monitoring.
It is difficult to directly link the use of legal mechanisms to improved implementation for Toronto as compared to Ottawa. The scholarly research is clear that entrenching formal implementation tools and accountability measures are key to success in municipal climate plans. Both cities are deserving of some criticism in their underperformance to targets. However, Toronto is on a more direct path to achieving its goals and has the capacity to update tools to accelerate implementation when behind on target. Ottawa is suffering from a lack of clarity in how to achieve their ambitions and does not have established tools to quickly overcome this hurdle. Legal mechanisms have proven useful to Toronto. They will likely be useful for any Canadian city in confronting the climate crisis.
Bibliography:
Legislation:
City of Toronto Act, 2006, S.O 2006, c 11, Sched A
City of Ottawa Act, 1999, S.O 1999, c 14, Sched E
Environmental Assessment Act, R.S.O. 1990, c. E.18
Municipal Act, 2001, S.O 2001, c 245
Toronto, Toronto Municipal Code Chapter 669, “Climate Change Goals and Governance” (18 June 2023)
Toronto, By-law 600-2023, “To adopt City of Toronto Municipal Code Chapter 669, Climate Change Goals and Governance, to codify the City of Toronto’s climate change policies and programs, including targets, reporting requirements, and governance processes” (13 July 2023)
Secondary Sources: Reports and Plans
Office of the Auditor General City of Ottawa, “Audit of the Climate Change Master Plan June 2024 Ottawa”, (Ottawa 2024)
Ottawa, City of Ottawa, “Climate Change Master Plan”, vol 1 (City of Ottawa Planning, Infrastructure, and Economic Development, Jan 2020)
Ottawa, City of Ottawa, “Energy Evolution: Ottawa’s Community Energy Transition Strategy – Final Report”, vol 1 (City of Ottawa Planning, Infrastructure, and Economic Development, Oct 2020)
Toronto, City of Toronto, “TransformTo Net Zero Strategy”, (Toronto: 2021)
Toronto, City of Toronto, “2022 Sector-Based Emissions Inventory”, (Toronto: 2022)
Toronto, City of Toronto, “Toronto Green Standard: Net Zero Transition Study Update”, (Toronto:2024)
Toronto, City of Toronto, “Carbon Budget 2025”, (Toronto:2025)
Secondary Sources: Articles
Burch, Sarah “Transforming barriers into enablers of action on climate change: Insights from three municipal case studies in British Columbia, Canada” (2010) 20 Global Environmental Change 287
Donoghue, Sophie & Ryan Katz‑Rosene, “Evaluating the comprehensiveness of municipal climate change adaptation plans in Ontario, Canada” (2023) 23:44 Regional Environmental Change 43
Guyadeen, Dave, Jason Thistlethwaite & Daniel Henstra, “Evaluating the quality of municipal climate change plans in Canada” (2019) 152:121 Climatic Change 121
Rogers, Nina J. L. , Vanessa M. Adams & Jason A. Byrne, “Factors affection the mainstreaming of climate change adaptation in municipal policy and practice: a systemic review” (2023) 23:10 Climate Policy 1327
Secondary Sources: Multimedia
Allen, Kate, “Can Toronto meet its climate change-fighting goals? The latest numbers show a snapshot — and a setback” (Dec 16, 2024), online
Fung, Nathan & Arthur White-Crummey, “Ottawa behind on climate change targets, city’s auditor general says” (June 11, 2024), online
Toronto, “TransformTO Reports and Resources”, online
Secondary Sources: Interview
Scott Pasternack, City of Toronto Legal Services, “Municipal Climate Change Interview” (March 25 2025) via oral communication [communicated to Zach Beers]