Prince Edward County and the PCP Program: A Closer Look at Costs, Liabilities, and Data Concerns

Open Letter to Prince Edward County Council

During my presentation to Prince Edward County Council on January 28, 2025, Councillor MacNaughton, as the council's appointed representative for the FCM-ICLEI Partners for Climate Protection (PCP) Program, provided a response to my concerns . Given her role, her perspective is valuable in understanding the intentions and perceived benefits of the program. Her insights reflect the views of those advocating for PCP and offer an important point of engagement for ongoing dialogue.

While I was not granted the opportunity to respond during the meeting, this open letter serves as an opportunity to ensure a broader audience, including both residents and those currently supporting the PCP program, can carefully review our concerns and engage in a more informed discussion.

For those who wish to review the presentation and Councillor MacNaughton's comments, they can be viewed at thislink: Watch here.

The intent of this letter is not to be adversarial but to continue the conversation, ensuring that all aspects of the program—its commitments, costs, and implications—are fully understood by council and the public.

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Open Letter to Prince Edward County Council

Subject: Continuing the Dialogue on PCP – Response to Councillor MacNaughton

Dear Councillor MacNaughton,

I would like to sincerely thank you for your thoughtful comments during my presentation to Council on January 28, 2025. Your efforts to clarify aspects of the FCM-ICLEI Partners for Climate Protection (PCP) Program and ensure an accurate discussion are very much appreciated. We are not trying to be contrarian but rather to bring forward concerns about a program that has existed for 30 years with little public awareness or discussion until now. Given the FCMs evident impact on municipal policies and budgets, I believe it is important that we continue this dialogue to ensure accuracy in our advocacy as well as transparency and informed decision-making moving forward.

I would like to respond to a few key points you raised and provide further clarification.

1. The PCP Program as a “Framework” vs. Long-Term Commitments

You described PCP as a voluntary framework that provides methodology and expert access rather than a mandate. While that may be the intent, in practice, the program’s five-step structure guides municipalities toward adopting a series of financial, administrative, and policy commitments over time.

Each milestone introduces new potential costs and obligations. If the County is expected to advance through these stages, then a full cost assessment should have been conducted before committing to PCP. Instead, the long-term financial implications remain unclear, leaving taxpayers and future councils progressing through a program without a clear understanding of the true cost.

Furthermore, PCP follows a structured path with specific recommendations, yet these recommendations were not disclosed to the public or Council before the County joined. It is Council’s responsibility—not that of residents or community advocates—to assess the financial and policy impacts of such commitments. Staff have access to the necessary budget data, projected recommendation costs, and case studies from municipalities further along in the program.

Instead of requiring municipalities and residents to piece together cost estimates on their own, why is the PCP program itself not responsible for compiling a comprehensive cost breakdown? With over 30 years of implementation across cities, towns, counties, and villages, there is no reason why the program cannot provide a full list of endorsed projects along with cost ranges per municipal tier or population size.

A transparent cost analysis is essential to responsible governance. The request for a cost breakdown of past PCP recommendations is entirely reasonable, yet the program continues to claim that participation is "free"—raising serious concerns about transparency. This approach feels more like a marketing strategy than responsible policy-making.

The program is "free" in name only. Municipal staff must commit time and resources to extensive data collection, which is then handed over to third-party organizations at no cost to them, but at a cost to taxpayers. The next step is to set reduction targets, develop an action plan, and implement the plan—at which point municipalities are given a list of recommendations that often involve significant expenses for upgrades, infrastructure changes, and expanded data collection technologies to track ongoing progress.

This continuous data collection cycle ensures municipalities are funneled into purchasing specific solutions. Essentially, participation is “free” because municipalities themselves become the customers—providing free data, spending taxpayer money on recommended projects, and implementing policies that ultimately benefit corporate interests more than local communities.

I also hope that Councillor MacNaughton recognizes the irony in nodding along when Jane Lesley claimed that my cost estimates were 'pulled out of thin air.' As a member of the public, I have done my best with the limited information available, yet my report explicitly called on Council to fulfill its responsibility by directing staff to conduct a proper cost assessment—something that falls under Council’s duty under Ontario’s Municipal Act and its oath of office.

A Mutually Beneficial Recommendation

Instead of requiring municipalities or residents to piece together these costs on their own, the PCP program itself should be responsible for compiling and publishing a comprehensive cost breakdown. Given that the program has existed for over 30 years, a detailed cost analysis should be available, outlining the expenses associated with each of its recommended actions based on municipal tier and population size.

This cost analysis should include:

• A breakdown of all potential costs aligned with projects endorsed by the program.

• A cost range analysis based on municipal tier (small town, rural county, mid-sized city, large urban center).

• Historical cost data from municipalities that have implemented PCP recommendations over the past 30 years.

Why has no cost range or projection been shared based on 30 years of PCP adoption across municipalities of all sizes? Why is the public left to guess what the incoming recommendations will be from ICLEI’s software and experts? Why must residents take it upon themselves to provide even a conservative estimate just to challenge the PCP program’s claim that participation is 'free,' as if we are expected to believe that staff time for milestone one's data collection comes at no cost to taxpayers?

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2. Liability Considerations

You noted that that grant funding does not transfer liability to external bodies. That is exactly why a full cost and risk assessment is necessary before proceeding further.

Municipalities that have implemented PCP-aligned policies—such as municipal fleet electrification, building retrofits, and active transportation networks—have faced serious financial and operational challenges:

• Edmonton’s electric bus fleet cost over $60 million, but the contracted service provider went bankrupt, leaving taxpayers responsible.

• Huntsville’s electric school bus caught fire, raising safety concerns and increasing strain on emergency services.

• Montreal’s bike lane expansion led to an ongoing lawsuit from small businesses and residents over economic losses due to restricted access.

• Municipal building “green” upgrades come with high costs, sparking public backlash amid rising property taxes.

• Smart city technology projects have been introduced with little public awareness of long-term costs and privacy risks, often requiring expensive maintenance.

• The 15-minute city model has raised concerns over high-density zoning, rising property values, and affordability, while favoring corporate chains over small businesses.

• Urban densification policies have increased housing costs, displacing long-term residents and changing neighborhood dynamics.

• Urban-centric development models prioritize high-density growth, diverting resources from rural and small-town communities, leaving essential services underfunded.

While some policies may offer savings, these examples show that social, financial, and liability risks must be assessed before making long-term commitments. Without a full cost and risk analysis, Prince Edward County could be committing taxpayer dollars—whether acquired through government grants or local taxes—to policies that create more financial instability than benefit.

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3. Data Collection and Privacy Concerns

You mentioned that you do not believe PCP involves data collection beyond what is already public and that there are no privacy risks. However, the PCP Milestone 1 Handbook outlines extensive data collection requirements that go well beyond Ontario’s provincially mandated Energy Consumption and Demand Report.

Even if some of this data is already publicly available, its collection is not mandatory, and gathering it requires significant staff time or the hiring of consultants. The program demands a large volume of data tracking across municipal and private sectors. Additionally, some of the data required is not currently available (therefore not public) without the implementation of smart city technology, such as:

• Vehicle tracking to measure private transportation emissions.

• Smart meters to monitor real-time energy consumption in homes and businesses.

• Sensors to track emissions from waste, water treatment, and industrial processes.

These data-intensive requirements create an administrative burden that municipalities must manage, even if external consultants or technology providers assist in data collection.

The program explicitly requires tracking data on:

• Municipal operations, including all fuel consumption, electricity usage, wastewater energy use, and methane emissions.

• Fleet operations, including fuel consumption for all municipal vehicles, public transit, and staff commuting patterns.

• Community-wide energy use, including residential, commercial, and industrial fuel consumption.

• Private transportation, including fuel sales data, kilometers traveled, and emissions from all vehicle types, including private vehicles.

• Waste tracking, including detailed waste audits, methane decay rates, and livestock counts.

Collecting this level of data suggests a broader effort to measure and ultimately reduce emissions across all sectors—including private vehicle use. Given that many Canadians now struggle just to afford a vehicle, and most cannot afford the high costs of electric vehicles, any policies aimed at discouraging traditional vehicle ownership would place a disproportionate burden on residents, families, and small business owners.

I and the general public, would appreciate clarification on what policies are being recommended by FCM programs to reduce emissions from private vehicle use. If PCP’s intent is to influence municipal policy in this area, residents deserve full transparency on the potential impacts to their mobility and daily lives.

Moving Forward

I greatly appreciate your willingness to engage critically with this issue, and I welcome the opportunity to continue this dialogue to ensure accuracy and transparency for both Council and residents.

My goal is not to oppose genuine environmental stewardship efforts—it is to ensure that any policies implemented by Prince Edward County or elsewhere are thoroughly reviewed, financially justified, and publicly supported before further commitments are made.

To help gauge resident perspectives, we have launched a community survey. If there is clear public support or opposition to the PCP, I look forward to presenting the results to Council this coming fall. Additionally, I would appreciate access to any past survey data or community engagement results that Council has relied on to demonstrate public support for climate action.

I hope we can continue this discussion in a constructive and collaborative manner. Please feel free to reach out at info@kiclei.ca if you would like to discuss this further.

Best regards,
Maggie Braun
info@kiclei.ca