Marking the Way: How Legislating Climate Milestones Clarifies Pathways to Long-Term Goals

Long-term climate targets are difficult to achieve. Accountability measures can clarify pathways and progress toward these far-off goals.

Executive Summary

Climate accountability frameworks can help bridge the gap between medium- and long-term goals and the policy action required to achieve them. They break long-term greenhouse gas (GHG) emissions reduction targets into interim milestones. They establish clear governance structures and processes for linking milestones to policy actions. And they hold governments to account for policy implementation by requiring regular, transparent taking stock, progress reports, and—if necessary—action plans to help correct course.

Here in Canada, achieving climate goals is made more complex because jurisdiction and influence on climate- related matters overlap across provincial, territorial, municipal, Indigenous, and federal governments. In this context, adopting climate accountability frameworks could also provide forums and processes for tackling head-on the challenges and opportunities of shared jurisdiction within the federation.

Accountability frameworks are not a silver bullet. They cannot guarantee that a jurisdiction achieves its long- term climate objectives (since they cannot bind the actions of future, democratically elected governments). Nor can they sweep aside the complexity of implementing climate policies across multiple orders of government.

Nevertheless, climate accountability frameworks could help Canada to achieve its 2030 and 2050 climate targets. International and domestic experience shows that the transparency and accountability they provide can play an important role in keeping governments on track. If designed well, a national accountability framework could create institutional incentives for coordination and alignment between different orders of government.

This paper reviews experience with implementing climate accountability frameworks and explores how they can be implemented in the Canadian context. It does not focus on what Canada’s specific milestone pathway to its long-term targets ought to be. Instead, it focuses on the process for determining those pathways—and delivering on them.

Learning from case studies

Governments from Germany to Aotearoa/ New Zealand to the United Kingdom have implemented climate accountability frameworks as a way of meeting their long-term climate commitments. Such frameworks are also found in two Canadian provinces: Manitoba and British Columbia. These jurisdictions provide valuable examples for other Canadian governments looking to implement accountability frameworks.

Six common elements emerge from these case studies. Together, these elements establish the governance processes, policy development protocols, and transparency measures that can hold governments accountable for implementing policy that is consistent with their long-term targets.

The six elements are as follows:

▶  Formalizing climate governance structures and processes

▶  Clearly defining roles and responsibilities

▶  Establishing interim emissions reduction milestones

▶  Producing action plans to meet milestones

▶  Requiring monitoring and reporting

▶  Broadening the scope beyond reducing emissions

A set of best practices emerges when comparing how various jurisdictions have implemented these common elements of climate accountability frameworks. We define a best practice as an element of policy design that increases government accountability for meeting long-term targets and interim milestones—and implementing the necessary policies— while keeping the framework robust to changing governments, new political mandates, and shifting policy needs. Table 1 summarizes the common elements and best practices that emerge in the case studies.

Table 1: Elements of Climate Accountability Frameworks and Best Practices in their Implementation

ELEMENTBEST PRACTICES

Formalizing climate governance structures and processes

Establishing a set of governance structures and formal processes for setting, meeting, and monitoring progress against a country’s long- term emissions targets.

Legislating governance structures and processes and long-term targets

Cementing a long-term emissions reduction target in law, as well as a broader governance framework, increases government accountability for reaching targets while also supporting transparency, credibility, and predictability.
Clearly defining roles and responsibilities

Outlining the duties of specific institutions as they relate to the attainment of long-term targets.

Ensuring independent advice and assessment

Having advice and assessment provided independently of government can help depoliticize climate policy debates and ensure that governments are receiving evidence-based, non- partisan advice.

Supporting a whole-of-government approach

Distributing responsibility for climate policy and target attainment across a wide range of government actors supports collaboration and cooperation across policy areas, thereby increasing the effectiveness and efficiency of climate policy overall.


Establishing interim emissions reduction milestones


Setting interim emissions reduction milestones as a way of setting out a path to long-term targets.


Providing clarity on how milestones are set and how they will evolve

Extending milestone planning at least 10 to 15 years into the future and defining clear and codified rules and processes for how milestones are set and when they can be adjusted increases predictability and accountability.

Defining emissions reduction milestones in terms of cumulative carbon budgets

Defining emissions reduction milestones as cumulative carbon budgets provides a meaningful measure of a jurisdiction’s contribution to global climate change mitigation. It also makes trade-offs over time, across regions, or across sectors clear for policy-makers.


Producing action plans to meet milestones

Requiring governments to prepare policy measures, developed through collaboration with experts and stakeholders, that will meet interim milestones.


Linking progress on milestone commitments to policy course corrections

Obliging governments that miss milestones to publish revised plans and policies that address these excess emissions can help governments stay on track toward their long-term targets.


Requiring monitoring and reporting

Having formal requirements
for transparent reporting on government plans and progress, allowing the public to better understand and evaluate progress against commitments.



Requiring government to provide formal responses to independent advisory reports


Requiring governments to respond to progress reports and forward-looking policy recommendations from an expert advisory body ensures the relevance of independent advice and increases government accountability for reaching milestones.

Broadening the scope beyond reducing emissions

Requiring governments to look beyond reducing emissions
to consider climate change adaptation or the broader social, economic, and cultural impacts of climate policy.

Integrating multiple objectives into pathways and policy

Formally extending the scope of climate accountability frameworks to consider adaptation and clean growth can lead to better, more integrated climate policy. It can help move the focus beyond GHG mitigation to broader questions of economic development and resilience.

We define a “best practice” as a design choice or element that increases government accountability for meeting long-term targets and interim milestones, as well as for implementing the policies necessary to do so—while at the same time keeping the framework robust to changing governments, new political mandates, and shifting policy needs. Best practices are based on a re- view of case study jurisdictions that have implemented climate accountability frameworks, including British Columbia, France, Ger- many, Manitoba, Aotearoa/New Zealand, Oslo, the United Kingdom, and the U.K.’s devolved administrations in Scotland and Wales.

Climate accountability in the Canadian context

While the common elements and best practices we identify from case studies can provide valuable lessons for Canadian policy-makers, accountability frameworks will be most effective if implemented in a way that suits Canada’s unique context. In particular, shared jurisdiction between different orders of government in developing and implementing climate change policy introduces complexity to designing an accountability framework for Canada. Moreover, designing a Canadian climate accountability framework that recognizes Indigenous rights and advances reconciliation will be similarly complex—and critical to success.

We explore three key choices policy- makers will face in designing a national climate accountability framework for Canada’s decentralized federation. These choices will have significant implications for the fundamental approach the country adopts, how it will play out in the federation, and, by extension, how successful it will ultimately prove to be.

1. Where do milestones bind?

What level of resolution do interim milestones have: Are milestones set only at the national level? Or are they broken out such that they are legally binding at the provincial and territorial level—or the sectoral level?

2. What is the process for setting the pathways to reach the milestones?

Where will decision-making power ultimately reside: Will provinces and territories define their own pathways that together determine the national one? Or will the federal government ultimately set the pathway, based on consultation and engagement? Alternatively, will these different orders of government set it collaboratively? Or will the decision instead rest with an independent advisory body?

3. Which orders of government develop policy to meet milestones?

Regardless of where milestones bind and how they are set, who will be responsible for implementing policy to achieve them: Will the federal government act unilaterally, using its policy levers to close any gap between milestones and emissions projected under existing federal, provincial, and territorial measures? Or will provincial and territorial governments be expected to find ways to close the gap? Alternatively, will provincial, territorial, and federal governments all contribute to closing the gap, with federal policy acting as a backstop?

Each of the options available within these three choices present trade- offs and challenges (summarized in Table 1 in the report). In particular, a climate accountability f ramework developed for the Canadian context will inevitably have to contend with complex intergovernmental policy coordination challenges and, at times, diverging priorities among various governments. Still, by providing a forum for constructively addressing intergovernmental challenges, some options are more likely to enable better policy than others, as we discuss in our recommendations.

Conclusions and recommendations

Climate accountability frameworks are a valuable tool, but they also have limitations.

First, “accountability” mostly amounts to reputational consequences. While transparent monitoring and reporting can help individuals and stakeholders hold governments to account, a legislated climate accountability framework cannot require governments to meet their long-term targets, since even binding legislation can be repealed. This inherently limits the certainty that climate accountability frameworks can provide around future policy and emissions reductions.

Second, climate accountability frameworks cannot fundamentally resolve the difficulties associated with climate policy in a decentralized federation. A robust and effective Canadian response to climate change requires activating policy among all orders of government. But a federal climate accountability framework cannot force municipalities, provinces, territories, and Indigenous governments to implement stringent policy. No matter how it is implemented, a Canadian climate accountability framework will have to contend with complex intergovernmental policy coordination challenges.

Despite these limitations, a climate accountability framework can play a powerful role in keeping governments on track. It can create the conditions and institutional processes for both federal and subnational governments to act in an increasingly coordinated and collaborative way over time. And the repeating—and transparent—cycle of policy development, progress checks, and (where necessary) course correction can create pressure among all orders of government to implement policies consistent with each other and aligned with national targets.

We make the following recommendations to Canadian policy-makers looking to implement a climate accountability framework.

1. The federal government should legislate a framework for climate accountability consistent with best practices; other orders of government should consider implementing them as well

Climate accountability frameworks— implemented according to the best practices we identify—can help all orders of government in Canada. Doing so involves not only legislating the frameworks but also formalizing governments’ legal accountability for meeting milestones. We recommend that the federal government legislate a climate accountability framework nationally and that provinces, territories, Indigenous governments, and municipalities explore implementing them as well. A national climate accountability framework could work within the existing division of powers—neither binding provincial government climate policy nor expanding the scope of existing federal powers.

Subnational accountability frameworks could complement a national one by clarifying the intended plans of provincial, territorial, Indigenous, and municipal governments. This could help provide a clear picture of subnational ambition and, where applicable, the gap that would need to be closed (through more stringent policy) to meet national milestones. Moreover, having numerous accountability frameworks would identify where climate policy ambition differs across jurisdictions, clarify regional tensions slowing progress on climate policy under the federal framework, and create conditions for ambition and policy to converge over time.

2. The federal government should set legally binding emissions milestones only at the national level

Emissions milestones are particularly relevant at the national level given commitments under international processes. However, legally binding sectoral or provincial and territorial milestones risk creating rigidities that raise the overall cost of reducing emissions. Moreover, binding provincial and territorial milestones would require governments to directly confront difficult regional burden-sharing decisions, only to have these debates arise again when the details of policy mechanics were being discussed (a sector-level breakout would do the same, albeit indirectly). Forcing these debates to occur at the early, milestone-setting stage is likely to be divisive and risks making it even more challenging to move over time toward better policy coordination and convergence in federal and subnational policy ambition. Potential provincial or sector-level implications of national budgets should be provided as information only, to inform discussions about the contributions of various sectors and regions.

In terms of the process for setting milestones, we recommend that the federal government set the national milestone pathway in consultation with other governments, stakeholders (including environmental organizations and industry), Indigenous Peoples, and an expert advisory body. Allowing the federal government to make the final decision but with requirements that it consult widely ensures that the milestone pathway considers regional and sectoral circumstances and diverse perspectives, without paralyzing the process.

3. The federal government should continue to create incentives for provinces, territories, Indigenous governments, and municipalities to implement stringent climate policies

We recommend that the federal government adopt a combined federal- provincial approach to implementing policy that can achieve national emissions milestones. Different orders of government have different policy instruments available, and efforts to tackle climate change will be most effective when a wide range of these instruments is brought to bear. The federal government should continue to encourage policy ambition, implementation, and coordination across all orders of government through the use of both policy backstops and financial incentives.

A collaborative, multi-jurisdictional approach will require complex and at times difficult engagement, assessment, and dialogue, but it also offers the best chance of making climate policy in Canada politically resilient. An approach that does not rely entirely on policy from one order of government has the greatest chance of avoiding backsliding in the event that future governments aim to reverse course on climate policy. On the one hand, encouraging provinces, territories, Indigenous governments, and municipalities to act meaningfully—and leaving space for them to do so—ensures a strong base of climate policies will remain in place regardless of the level of future federal ambition. On the other, having federal programs and policy backstops ensures that strong climate policy will remain intact across the country in the event that, for example, some provinces or territories elect governments seeking to repeal stringent climate policies.

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