Thank you very much.
Thank you, Mr. Chair and members of the committee, for inviting the Canadian Environmental Law Association to speak to you this morning.
The Canadian Environmental Law Association is a 48-year-old national, environmental, non-governmental organization, and also an Ontario legal aid specialty clinic dealing with environmental issues. We provide services to clients as well as undertake law reform and public legal education.
One of our primary lenses in analyzing environmental and energy issues is that of impact on vulnerable and low-income residents. We are also a co-founder and continue to oversee the Low-Income Energy Network, along with the Advocacy Centre for Tenants Ontario. I mention that specifically because my comments today are going to focus primarily on the question of national energy data regarding low-income Canadian residents. I expect this is a perspective that other witnesses wouldn't bring to you, and I felt it's the one of most value for us to offer.
First of all, dealing with national energy data needs regarding low-income energy consumers, we do need more data about low-income energy consumers in Canada to design appropriate policies and programs that are effective and meet the basic energy needs of this sector. There is inequity and inconsistency in how each province and territory deals with their low-income energy consumers and keeps their consumers connected to their utility services if they're in utility areas. For the purpose of analyzing impacts of energy policies on low-income consumers, we need to know their housing tenure and housing type. As well, if they're tenants, policy-makers need to know how many of them pay for their energy directly on their bill and not in their rent. It would also be valuable, and has proven to be in the past, for policy-makers to have demographic profiles of the low-income households facing energy poverty, such as how many are single-parent-led families, racialized, first nations, seniors, disabled, rural, or northern residents. I should add, because I used the term “energy poverty”, that the Low-Income Energy Network defines energy poverty as a household spending more than 6% of its income on energy needs.
An example of the type of information that would prove to be very useful would be Canada-wide information emulating the short report—and I presented a link in the remarks that I sent to the clerk. I wasn't able to send them in advance because I have been away for the last two weeks, but I assume you'll get them afterwards. The report was prepared by the Financial Accountability Office of Ontario in 2016, with a bit of a caveat that some of the programs mentioned in that report have since been modified or enhanced. To give you an example of the kinds of things that the Financial Accountability Office looked at, the title of this short report is “Home Energy Spending in Ontario: Regional and Income Distribution Perspectives”.
They looked at home energy spending by region and found, not surprisingly that, in the Ontario context, the highest spending was in northern Ontario, and also, perhaps not surprisingly, that for Hamilton, Niagara, and Toronto, fuels other than natural gas and electricity were trivial. But for eastern, northern, and western Ontario, as would be the case in many other parts of Canada, other fuels were a significant portion of the energy costs of the families. That could include heating oil, wood, and other fuels.
They also analyzed home energy spending by income level, and again, this would be useful on a national basis as well. For example, they found that, while low-income households spend a smaller total amount on energy, the percentage of their household income was much higher at an average of 5.9% compared with the highest income quintile they analyzed, where it was only 1.7%. Quite a considerable difference in percentage of household income is going to energy, and that's useful for policy-makers to know, as I'll describe this morning. Then they analyzed what government programs existed at the time to offset the burden of energy costs by region and income level.
Again, that would be very useful to know on a Canadian basis, in order to understand whether different residents in different parts of the country are facing differential burdens and/or have help with those differential burdens.
We also need analysis and evaluation of how well the various energy poverty mitigation programs are doing across the country in addressing energy poverty. This would help to reveal best practices and help jurisdictions to learn from each other, inform federal policy, and understand what needs to change to eliminate inappropriate barriers to energy security.
I also wish to speak to low-income consumers and climate change policy, and highlight in particular the need for national energy data that analyzes and reports on potential differential impacts on low-income consumers of policies directed to the mitigation of, and response to, climate change.
For example, is there a difference in the percentage of income directed to climate change-specific policies for a household, depending on its income profile or other demographic factors? I had noted the finding with respect to energy-related costs by the FAO in Ontario. Similarly, as different climate change programs roll out across the country, this analysis is necessary for those programs. As a result, low-income consumers without alleviating programs may be spending a much higher percentage of their resources on the programs that alleviate climate change or be unable to participate in the programs that alleviate climate change.
A related question would be whether those differential impacts are imperilling access to necessary energy services, or diverting scarce resources in those families from food, shelter, medication, and other basic needs. In the Ontario context, prior to explicit analysis of these factors—which has happened to some degree—these differential impacts had not been widely understood by policy-makers. Having delved into those impacts, we now have specific programs for access to energy conservation by low-income families, better terms of service for the utilities so they aren't as likely to have their services disconnected, and rate support programs, to name a few.
Similarly, it has not been obvious to all policy-makers in Canada that climate policies may have these differential impacts on low-income consumers. As a result, there's been a mixed response in terms of alleviating undue impacts from those climate policies for those consumers.
California is one notable jurisdiction that we point to that's done good work on this to identify those issues and solutions. We've called for emulation of a study it undertook called the SB 350 low-income barriers study. Again, in the written submission I included a footnote to the study. The latest version is a draft staff report from December 2016. It's very useful.
Some of the things they were studying in looking at barriers, for example, included whether there were barriers to accessing energy efficiency and weatherization programs, whether there were barriers to low-income access to solar energy generation, whether small businesses in disadvantaged communities had extra barriers, and whether there were barriers to accessing zero-emission transportation options. They specifically looked at some of the structural barriers—which I would note, based on our work here in Canada, are similar—which are low-income consumers with low home ownership rates, complex needs, difficulties accessing financial arrangements for these kinds of enhanced climate participation, like solar photovoltaic, and insufficient access to capital, as well as the age of the buildings they live in, and living in remote and underserved communities.
In the written submission, I also pointed to a recent submission my organization did on this topic in an Ontario consultation on climate change adaptation. I would repeat some of those recommendations, such as emulating the California study, taking into account the differential impacts on low-income consumers, and the possible inequities from rolling out the programs without paying attention to those differential impacts.
In conclusion, I want to acknowledge the input of my colleague Mary Todorow of the Advocacy Centre for Tenants Ontario, another Ontario specialty clinic here in Toronto, for her input to these remarks.
I thank you for your attention. I look forward to questions and discussion with you this morning.
As I understand that I'm the only witness, I will do my best to answer the questions you have and maybe the hour will be shorter than usual.
