Summary
Beginning this month (January 2019), the federal Output-Based
Pricing System (OBPS) for large emitters will apply in Ontario and
other jurisdictions that had not met the federal carbon pricing
benchmark as of September 2018. The federal fuel charge will also
apply in Ontario beginning in April 2019. The application of the
federal regime in Ontario comes as a result of Ontario's
decision, in the latter part of 2018, to cancel its cap and trade
regime. The province has since (i) introduced its proposed
environmental plan, which includes greenhouse gas (GHG) emissions
reduction targets that are less onerous than the reduction targets
mandated by the previous government, and (ii) announced it will
soon release its proposed approach to reduce GHG emissions for
large industrial emitters in the province (the
"Proposal"). This Update considers the
implications of the recent developments in overlapping federal and
provincial climate change laws and initiatives for
