Audit uncovers inconvenient truth behind London’s climate ‘emergency’ action plan

A new report shows the City is nowhere near to its carbon emission targets.

London won’t meet its 2030 greenhouse gas emissions target, and getting the council-approved Climate Emergency Action Plan (CEAP) back on track will require renewed commitment, additional funding, and provincial changes to electricity generation.

In 2019 city council declared a climate emergency, and by 2022 an action plan was approved for London to reach net zero greenhouse gas emissions by 2050.

However, a report by audit firm MNP makes several high-risk observations about the CEAP, its implementation, and the more than 200 planned actions.

The five high-risk observations identified in the audit report:

• The CEAP is descriptive, not directive. The plan reflects work already happening but does not shape priorities, sequencing, or resource allocation.
• There’s limited funding allocated to support the implementation of many CEAP actions. Limited funding approved through the Multi-Year Budget constrains city hall’s ability to implement the full scope of CEAP actions.
• Overstates progress by city staff because ‘On Track’ and ‘Complete’ designations frequently reflect administrative milestones, not measurable outcomes.
• Implementation capacity is distributed across municipal departments. No formal assessment has been conducted to confirm whether this capacity is sufficient to achieve CEAP commitments.
• The CEAP’s scope exceeds what can be delivered within the approved funding and resources, limiting its effectiveness as a prioritized and actionable implementation plan.

“I wasn’t surprised,” admits Coun. Skylar Franke about missing the 2030 emission target of 55% below 2005 levels. “I don’t think that we’ve been doing enough to achieve the Climate Emergency Action Plan, the targets, and actions that we’ve set aside for ourselves.”

“I think a lot of it has to do with budget and resourcing,” she says. “Staff asked for about $45 million over four years to fully implement the Climate Emergency Action Plan, and at first (council) gave them about $1 million a year. And then through our budget deliberations, that’s been cut down to $182,000 a year.”

The auditor cites the provincial government’s decision to generate more electricity with natural gas as a significant contributor to London missing its 2030 target.

In their response, city staff write, “The 2030 community GHG milestones were ‘stretch goals’ based on the city doing its fair share to reach the Paris 1.5C goals. As such, they were always aspirational in nature, similar to Vision Zero for road safety.”

In addition, staff chose to remove the words ‘emergency’ and ‘action’ from its references to an updated version of the plan coming in 2028.

“We will refer to the renewed version of the CEAP as the ‘updated climate plan’ for the purposes of this audit response, noting that the CEAP is likely to be renamed during the update,” the response reads.

Franke suggests the reasons behind the creation of the action plan haven’t changed, “It’s very important that we continue to try and achieve our targets, even if we know that the 2030 target is out of reach, because for every degree that we do not increase the global temperature, the better it is for all humans.”

Asked whether climate change remains an emergency for her colleagues on council, Franke replies, “I think that this term of council unfortunately did not focus enough attention and priorities towards climate change, but I will say the work that we’ve done on transit and moving towards Bus Rapid Transit (BRT) has been a significant improvement.”

The Audit Committee will consider the report on June 17.

Among the strengths identified in the audit:

• Regulatory and Infrastructure Progress in Buildings & Transportation Departments (elimination of parking minimums, mandatory EV charging in new developments, BRT construction)
• Waste Diversion and Landfill Gas Management (green bin implementation, increasing methane captured at W12A landfill)
• Climate Considerations Embedded in Core Planning and Asset Systems (Mobility Master Plan, Corporate Asset Management Plan)
• Building Energy Retrofits
• Community and Business Engagement Infrastructure