Climate accountability in practice

A climate accountability framework is a set of governance structures and processes that connect long-term climate targets and pledges to near-term policy planning and implementation through regular, transparent stock-taking and progress reporting. Why are governments pursuing climate accountability frameworks? How are they implementing them, both here in Canada and internationally? And what best practices emerge from this experience?

Problem definition: Getting from here to there

Transitioning to a low-carbon economy takes time. But while ambitious long- term targets are important, they are not always helpful in guiding near-term policy and spurring action.

Simply defining long-term targets—with timelines much longer than electoral cycles—tends to be insufficient. Historical experience in Canada demonstrates this: Canadian governments have repeatedly set ambitious GHG emissions reduction targets decades into the future— including for 2000, 2005, 2010, and 2020— and failed to meet them each time.

Unfortunately, governments have incentives to defer stringent climate policy. However, delaying policy ultimately makes achieving long-term targets more challenging and more costly.

Failing to connect near-term policy planning and implementation with long-term targets also introduces risk and uncertainty. In the absence
of a credible path to these targets, businesses, consumers, and investors do not have clear expectations regarding the future directions of climate policy, which increases their vulnerability to sudden changes in policy. It also makes it more challenging for them to plan medium- and long-term investment decisions. And this lack of certainty can stifle the innovation necessary to meet long-term targets.

Climate accountability frameworks can help address these challenges. As we discuss below, they can identify a more concrete pathway to long-term emissions targets. They can create incentives for governments to follow through on policy consistent with their long-term commitments. They can, where necessary, enable—or even require—course correction by mandating clear and accessible progress reporting. And they can support greater policy certainty, lowering risks for businesses, consumers, and investors.

Climate accountability frameworks can also help support increased ambition at the global level. Domestic processes for setting emissions reduction milestones could act as an input to the five-year cycle of monitoring, reporting, and ambition-setting outlined in the Paris Agreement. Aligning a Canadian process with the international process in this way would help to reinforce the credibility and transparency of both systems, as well as reduce reporting burdens on governments.

Learning from international experience

Canadian governments can draw important lessons from the way climate accountability frameworks have been implemented internationally and at home. The United Kingdom (U.K.) was the first country to introduce a climate accountability framework through its 2008 Climate Change Act. Since then, jurisdictions around the world have followed suit with similar frameworks to help governments deliver on their long-term emissions reduction targets. Manitoba was the first Canadian province to introduce a climate accountability framework through its Climate and Green Plan Implementation Act, 2018. British Columbia followed shortly thereafter with its 2019 amendments to the province’s Climate Change Accountability Act.

To understand the fundamental components of climate accountability frameworks, we reviewed a number of international and domestic cases where they have been implemented. These jurisdictions include British Columbia, France, Germany, Manitoba, Aotearoa/ New Zealand, Oslo, the U.K., and the U.K.’s devolved administrations in Scotland and Wales. We also prepared detailed case studies for the U.K., Aotearoa/New Zealand, British Columbia, and Manitoba. The frameworks we analyze in these case studies vary in the types of processes and governance structures they implement, as well as how much flexibility they afford governments in setting and meeting short- and long-term targets.

Based on this review, we identified six common elements of climate accountability frameworks, as well as best practices in their design and implementation. 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. We describe the common elements and best practices below.

The best practices drawn from the case studies do not, however, represent the complete spectrum of possible approaches. As such, while Canadian governments can learn from the domestic and international best practices, they should not be constrained by them.

Formalizing climate governance structures and processes

A first common element of climate accountability frameworks is that they establish a set of governance structures and formal processes for setting, meeting, and monitoring progress against a jurisdiction’s long-term emissions targets. These governance elements include a number of components: clearly defining roles and responsibilities, establishing a process for setting interim emissions reduction milestones, laying out requirements around the development of action plans to meet them, detailing formal monitoring and reporting processes, and broadening the scope beyond a strict focus on reducing emissions. We describe each of these components in detail below.


Legislating governance structures, processes and long-term targets

Cementing a long-term emissions reduction target using the law increases a government’s accountability for reaching it. This is consistent with the approaches of British Columbia, France, Germany, Aotearoa/New Zealand, and the U.K., as well as the devolved governments of Scotland and Wales.

A legally binding climate accountability framework is more resilient to changes in government and political mandates, since future governments can deviate from the framework’s requirements only by outright appealing or amending the legislation. This is a more significant task than, for example, simply revising an accountability framework’s implementing regulations. Including governance structures and processes in the legislation also supports transparency and credibility. It can increase predictability and certainty for the public, interested stakeholders, and other governments.

In the event that a government’s emissions trajectory or policy plans are at odds with its legislated target, citizens and interest groups can sue the government.1 When upheld, this legal backstop increases certainty and predictability around the future emissions reduction pathway.

Clearly defining roles and responsibilities

Climate accountability frameworks clearly outline the duties of specific institutions as they relate to the attainment of long- term targets. This includes establishing ministerial responsibilities and defining the roles of various government departments and agencies. For example, in the U.K., the Minister of State for Business, Energy and Clean Growth is the minister responsible for meeting the legislated long-term targets and overseeing the U.K. carbon budgets.

At the same time, the U.K.’s legislation also recognizes the roles of the devolved administrations of Scotland, Wales, and Northern Ireland in climate policy.2

Climate accountability frameworks may also create new institutions. For example, legislation often establishes a publicly funded, independent group of experts to provide oversight and advice to government on the development, implementation, and monitoring of long-term targets and interim milestones and success in achieving them. Examples include the Committee on Climate Change in the U.K., the Climate Change Commission in Aotearoa/New Zealand, the High Council for Climate in France, and the Expert Advisory Council in Manitoba.

Legislation commonly requires these advisory committees to consider a variety of parameters when developing policy advice. For example, in performing its functions and duties, Aotearoa/New Zealand’s Climate Change Commission must take the following into account: regional and sectoral circumstances; the distribution of benefits, costs, and risks across generations; and the Crown-Māori relationship, the obligations under the Treaty of Waitangi (Te Tiriti o Waitangi), and the specific impacts on Māori and iwi (Māori tribes).


Ensuring independent advice and assessment

Having an independent body provide official climate policy advice to governments and assess their progress enhances the credibility of a climate accountability framework. It helps depoliticize climate policy by acting as a trusted, non-partisan advisor to all parties and all orders of government. And it ensures that governments are receiving evidence-based, non-partisan advice and recommendations on contentious climate policy issues. Best practice involves having both advice and assessment functions independently provided—either separately or in combination—and ensuring that those charged with these functions have clear roles, sufficient resources, and adequate power to perform their duties.

The U.K. Committee on Climate Change (CCC) provides a notable example. The first institution of its kind, the U.K. CCC has provided independent, evidence- based, and non-partisan advice to U.K. governments since it was established in 2008. The CCC also acts as a watchdog of sorts, scrutinizing and assessing government plans and actions, providing both the advice function and the assessment function. For over a decade now, successive U.K. governments have, for the most part, followed the CCC’s advice and relied on its impartial evidence and analysis. This success has led other countries to set up similar independent advisory bodies, notably the Climate Change Commission in Aotearoa/ New Zealand.

Best practice also involves having an independent expert body whose knowledge and experience are both diverse and representative. For example, the U.K. CCC is composed of eight independent members with expertise in the fields of climate change, science, economics, behavioural science, and business. In Canada, a climate accountability framework will have to pay particular attention to ensuring that members of the body have expertise and experience relevant to Indigenous rights and knowledge. Box 2 explores Aotearoa/New Zealand’s approach to ensuring that Māori and iwi perspectives are represented by the Climate Change Commission, and Section 6 explores broader questions regarding how Canada could ensure Indigenous knowledge and perspectives are reflected. This kind of broad representation can help ensure that the expert body’s recommendations reflect not only what is required to reach climate goals but social and economic considerations as well.

While the jurisdictions we examine in our case studies do not take this step, we should note that it is also possible to establish oversight roles for arm’s-length institutions that include some amount of authority over policy-making. The California Air Resources Board (CARB), which we discuss in Box 1, provides a notable example.

Box 1. California Air Resources Board (CARB)

Established in 1967, the California Air Resources Board (CARB) is the state’s lead agency dealing with air pollution and climate change. Its roles include setting the state’s air quality standards, measuring California’s progress in reducing pollutants, conducting research on the causes and effects of air pollution, leading the state’s efforts to reduce GHG emissions, and engaging with the public and stakeholders to review progress and consider new approaches.

CARB operates independently as an arm’s-length government institution. It has a governing board of 12 members (appointed by the Governor), supported by a large professional staff.

CARB is unique among the independent bodies we review in this report in that it is responsible for developing the programs and policies the state uses to fight climate change (i.e., rather than only advising governments and acting as a watchdog). California’s Global Warming Solutions Act (2006) established CARB as the lead agency to implement the Act. This move required CARB to develop and implement regulations and policies consistent with meeting the state’s legislated commitment to reduce its emissions to 1990 levels by 2020. As a result, the Act put CARB in charge of the development and oversight of the state’s primary emissions reduction programs, such as its cap-and-trade program, the Low Carbon Fuel Standard, and its zero-emission vehicle programs. New laws introduced in 2014 and 2017 require CARB to implement measures to reduce GHG emissions by 40 per cent below 1990 levels by 2030 and by 80 per cent below 1990 levels by 2050. While California reached its 2020 emissions reduction target four years ahead of schedule, the 11th annual California Green Innovation Index found that the state is currently not on track to meet its 2030 target.


Supporting a whole-of-government approach

In most jurisdictions, frameworks designate a single minister, most
often the minister responsible for the environment or climate change, as being accountable for meeting long-term targets and interim emissions reduction milestones. However, effective action on climate change requires collaboration and cooperation across all policy areas and government departments.

Best practice climate accountability frameworks distribute responsibility across various government actors to support a whole-of-government approach to meeting targets and milestones. Doing so extends accountability to a broader range of government actors and also supports a more coordinated and collaborative approach that can increase the effectiveness and efficiency of climate policy overall.

A number of jurisdictions have supported a whole-of-government approach to their climate accountability frameworks. For example, in Germany, where the country’s Climate Action Law sets annual sectoral emissions reduction targets, the ministry most responsible for a sector is accountable for meeting that sector’s emissions reduction target. If a sectoral target is missed, the responsible minister must present a revised policy plan to address excess emissions and reach future targets. In the U.K., the government recently followed the advice of the CCC and announced a new Cabinet Committee on Climate Change that will bring together ministers responsible for international and domestic climate policy, in order to drive further action and better coordination across government. In Canada, a whole- of-government approach within the federal government could distribute responsibility across several members of cabinet, for example to the Prime Minister, the Deputy Prime Minister, the Minister of Environment and Climate Change, and the Minister of Finance, or any other combination.

Establishing interim emissions reduction milestones

Countries that have implemented climate accountability frameworks have commonly introduced interim emissions milestones for reaching long-term targets. Milestones either set a target for national emissions in a given year or establish a “budget” for cumulative emissions across an interim period. Typically, milestones align with a stated GHG endpoint objective, such as net zero emissions by 2050. This endpoint is usually informed by a science-based assessment of what is required to avoid dangerous climate change.

Jurisdictions around the world use different methods to set their interim milestones. In the U.K., for example, economic modelling estimates the most cost-effective path to the country’s 2050 target and serves as the basis for setting interim milestones. In Germany, the national climate target is divided amongst economic sectors and then broken out into annual emissions budgets that follow a linear reduction.3

Jurisdictions also vary in the length of their milestone periods as well as how far in advance they are set. For example, the U.K. Climate Change Act (2008) requires budgets to be set 12 years in advance. Aotearoa/New Zealand requires three consecutive five-year budgets to be in place at any given time, whereas Scotland sets annual emissions reduction targets for each year across a minimum 12-year planning horizon. In Manitoba, the province’s Carbon Savings Account sets five-year carbon budgets, one at a time.

Finally, climate accountability frameworks vary in terms of how much flexibility they give governments to adjust milestones— as well as the type of flexibility they have. For example, in Manitoba, where carbon budgets are set one at a time, governments have full discretion on how the long-term pathway of milestones is set. While legislation dictates that any shortfall in realizing a five-year budget must be rolled over as an increased obligation under the subsequent one and that ambition must rise with each budget period, there is no overall pathway for carbon budgets beyond the current budget nor a long-term emissions target to calibrate them to. In contrast, the pathway for Aotearoa/New Zealand’s milestones budgets is calibrated to a long-term, science-based target, and the government’s long-term and interim targets can only be revised if the independent advisory body recommends doing so.


Providing clarity on how milestones are set and will evolve

Ad hoc milestone setting or a focus limited to the short term can exacerbate policy uncertainty and increase risks for businesses, consumers, and investors. Best practice climate accountability legislation therefore requires milestone planning to extend at least 10 to 15 years into the future and contain clear and codified rules and processes governing how interim milestones are set.

In order to support predictability, best practice legislation also sets clear rules on the circumstances under which future milestones can be adjusted.

And to support credibility, it allows adjustment only in the event that the expert advisory body recommends it. For example, Aotearoa/New Zealand’s Zero Carbon Act states that the government can only revise its milestone pathway if the expert advisory body recommends doing do. Moreover, the expert advisory body can recommend revisions only if certain circumstances—also listed in the legislation, such as changes in climate science—have themselves changed. This approach enhances predictability while also allowing for flexibility in the face of changing circumstances.


Defining emissions reduction milestones as cumulative carbon budgets

Best practice legislation defines emissions reduction milestones as cumulative carbon budgets, rather than an emission reduction target set for the end of a given milestone period. For instance, instead of simply setting a target for the level of Canada’s GHG emissions in the year 2030, cumulative emissions budgets establish a set amount of GHG emissions that can be emitted during a given period, such as from 2025 to 2030. Carbon budgets are found across a number of the cases we examine, including the U.K., Aotearoa/ New Zealand, Wales, France, and Manitoba.

Using carbon budgets to define milestones keeps governments focused on cumulative emissions—a more meaningful measure of a jurisdiction’s contribution to global climate change mitigation. A finite carbon budget also makes trade-offs over time, across regions, or across sectors clear for policy-makers.

It forces them to recognize that emitting more now means more significant reductions later and that more emissions from particular regions or sectors necessitate greater reductions in others.

Producing action plans to meet milestones

Emissions reduction milestones and long-term targets are merely aspirational goals unless accompanied by plans and policies to reach them. Recognizing this, climate accountability frameworks typically require governments to prepare policy measures sufficient to meet milestones and develop these policies in close collaboration with experts and stakeholders.

In both the U.K. and Aotearoa/New Zealand, the government is required to table an action plan, complete with policies and measures. Neither country’s legislation prescribes how the government must meet its targets or which policies must be used, but both establish a set of considerations that should be taken into account by government when establishing plans. Frameworks in other jurisdictions are more prescriptive. For example, France’s legislation specifies a series of measures that should be implemented to reduce emissions and achieve targets, including building retrofits, energy efficiency, and renewable energy development, to name a few. And in Oslo, where the city sets an annual climate budget complete with emission reduction goals, the council can only approve spending plans that align with the GHG-reduction objectives its climate budget represents.


Linking progress on milestone commitments to policy course corrections

A best practice noted in the case studies is obliging governments that miss milestones to publish revised proposals and policies, to ensure future milestone periods are adjusted to compensate for the excess emissions. This requirement keeps governments accountable for developing policy consistent with meeting their commitments (particularly when milestones are set as carbon budgets rather than targets) and helps governments stay on track toward their long-term targets.

For example, in the U.K., if the final statement of a budget period indicates that carbon emissions exceed the allocated budget, the Secretary of State must table a report in Parliament that revises proposals and policies so as to compensate for these excess emissions in future budget periods.

Requiring monitoring and reporting

Monitoring and reporting requirements are found in all the cases we examined. Monitoring and reporting are key to ensuring government accountability for reaching milestones, as they allow the public to better understand and evaluate government’s progress against its commitments. And, for governments that are taking meaningful action to meet milestones and targets, regular monitoring and reporting enables them to credibly demonstrate to the public that they are making progress and implementing policy consistent with long-term and interim targets.

Typically, climate accountability frameworks mandate that an independent body table yearly progress reports to government that culminate in a final evaluation report at the end of a milestone period. This regular, transparent reporting permits individuals, experts, and stakeholders to compare a government’s stated emissions goals with its policy implementation plans and record. And when governments miss the mark, reporting can create pressure on policy-makers to adjust their plans and get back on track.

Climate accountability frameworks also require governments to carry out reporting of their own. These reporting functions often draw on existing government reporting requirements and exercises. In Canada, this would include progress reports under the United Nations Framework Convention on Climate Change and under the Pan- Canadian Framework on Clean Growth and Climate Change.


Requiring government to provide formal responses to independent advisory reports

A number of the jurisdictions we examined require governments
to respond to both progress reports and forward-looking policy recommendations from the expert advisory body. This requirement ensures the relevance of the independent advisory body and increases government accountability for reaching milestones.

In the event governments do not accept independent policy advice, they must provide a rationale for their decision and clearly articulate the alternative policy plans they intend to deliver.

The U.K.’s experience helps to demonstrate the role these kind of reporting requirements can play in climate governance. The U.K.’s climate accountability legislation requires governments to publicly respond to annual reports from the U.K. CCC assessing whether current initiatives are sufficient to meet interim budgets and long-term targets.

While the U.K. met its first (2008 to 2012) and second (2013 to 2017) carbon budgets and is on track to outperform its third (2018 to 2022), it is currently not on track to meet its fourth and fifth budgets, let alone its newly adopted 2050 net zero target (which enhances its previous 2050 target of 80 per cent reductions below 1990). A 2019 report by the CCC flagged that the U.K. government and all devolved administrations must significantly and urgently ramp up policy to get on the path to net zero by 2050. The body has made a number of corresponding policy recommendations as a result. This reporting has sent an early signal to the government that the country’s existing policy plans will be insufficient to meet the new 2050 target. In doing so, this regular reporting helps prompt a re- evaluation of the government’s approach and revision of its plans. And in the event the U.K. government chooses to ignore the committee’s warnings and advice, it will have to publish its rationale and be accountable to the public for its decision.

Broadening the scope beyond reducing emissions

While climate accountability frameworks are generally focused on meeting long-term emissions reduction targets, they often broaden the scope beyond climate change mitigation to consider climate change adaptation. Frameworks can also consider the broader social, economic, and cultural impacts of climate policy. This can include dimensions such as affordability, health, economic competitiveness, and the food, water, and energy security nexus, among others. This broader scope for climate accountability frameworks is exemplified by Aotearoa/ New Zealand’s approach requiring policy-makers to consider dimensions such as regional and sectoral circumstances, as well as potential impacts on iwi and Māori.


Integrating multiple objectives into pathways and policy

Best practice climate accountability frameworks pursue integrated climate policy—that is, climate policy that considers not only reducing GHG emissions but also climate change adaptation, as well as broader social and economic objectives. For example, the climate accountability frameworks in Aotearoa/New Zealand and the U.K. establish adaptation committees to conduct climate risk assessments and advise governments on adaptation policies. And France’s legislation requires policy-makers to lay out pathways for low-carbon economic development.

Formally extending the scope of climate accountability frameworks to include other dimensions of the climate change challenge beyond a strict focus on reducing GHG emissions can lead to better, more integrated policy. It also avoids the divisiveness that can be created when GHG emissions targets are not connected to broader considerations related to economic development and resilience.

For example, Aotearoa/New Zealand’s legislation establishes a broad set of considerations that should be taken into account when crafting policy, including available scientific knowledge; existing and anticipated technologies; social, cultural, environmental, ecological, and economic circumstances; the distribution of benefits, costs, and risks between generations; and Indigenous rights and knowledge. In addition, the government’s action plan to reduce emissions must include strategies for minimizing impacts on workers, employers, regions, and communities.

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


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.
  1. That is, unless legislation explicitly states that targets and budgets are not enforceable in the court of law. Out of all the cases we examine, only Aotearoa/New Zealand contains this kind of provision. This feature of its Zero Carbon Act has been identified by observers as a weakness.
  2. Notably, the devolved administrations have their own emissions reduction targets and climate change policies but also contribute to meeting the U.K.’s carbon budgets and long-term targets, including implementing U.K.-wide policies.
  3. In contrast, the U.K.’s Committee on Climate Change uses sectoral pathways only for consultation with sectoral stakeholder groups, in order to assess the feasibility of milestones and provide a reference point for the cost-effective path towards its long-term target.
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