PEOPLES CLIMATE PLAN FOR ONTARIO - BACKGROUND DOCUMENTATION
Here are some excerpts from the many excellent submissions sent to the government by the November 16th submission deadline in the climate plan consultation. We’ve also included some reactions to the plan by organizations like Canadian Physicians for the Environment (CAPE). Finally, we’ve listed some of the points mentioned in the plan that we could potentially encourage.
Ambition of Plan
Accountability around Money
Green Infrastructure & Job Creation
Ambition of Plan
1)Ideas to support the urgency of more ambitious climate targets, bringing emissions down quickly, keeping global warming blow 1.5°C and a quick transition off of fossil fuels:
Climate Action Network (CAN) states: “The Ford government’s plan purports to be Paris-compliant as it aligns with Canada’s baseline 2020 commitment to Paris. In fact, Canada’s existing Paris pledge is inadequate and falls far short of Canada’s fair share toward the Paris Agreement’s global temperature goal of limiting warming to no more than 1.5ºC this century, instead putting us on a pathway to closer to 4-5ºC of warming.”
CAPE explains: “At a time when the International Panel on Climate Change (IPCC) and the Lancet Countdown report on health and climate change are calling on countries to make deeper cuts in climate emissions to avoid the most catastrophic outcomes for humanity, the Ontario Government is proposing an emission reduction target that is about one third of Ontario’s previous target…[allowing] Ontario to emit 30 MT more by 2030 than did the former Climate Change Action Plan. This is more than the emissions reductions Ontario saw by closing all its coal power plants.”
The Environmental Commissioner’s report "Climate Action in Ontario: What's Next", 2018 (EC Report) says “Even at current global GHG emission rates, today’s toddlers can expect to face temperature increases in Ontario during their lifetimes similar to those that ended North America’s last ice age (average increase of 4o C-7 C degrees). Such increases would cause severe, widespread and irreversible impacts, far beyond what they may be able to adapt to. Whether we want to believe it, or not, the actions we take now to reduce GHG emissions really matter to our future and to the future of generations to come. Every tonne counts, and every action matters.”
From the Testimony to Ontario Legislature, Steve Shallhorn, Labour Education Centre Working Green project/Toronto & York Region Labour Council: “[We] support the shift to a low carbon economy. Indeed we have no choice….Last month United Nations Secretary-General António Guterres warned us all that we have until 2020, just two years, to avoid runaway climate change….This month the United Nations Intergovernmental Panel on Climate Change…warned that the goal of keeping warming to within 2 C degrees will not be sufficient to avoid catastrophic climate change, requiring stronger action than contained in the 2015 Paris Convention. It is important to note that UN FCCC is a very conservative forecasting body, as every national government has to sign off on its conclusions. (Canada, the United States, Saudi Arabia, China, etc)”
The water temperature of the Great Lakes has gone up an average of 3 C degrees in just the past year. This temperature rise is leading to algae blooms and threatens the commercial and sports fisheries. We have seen start/stop spring temperatures affect crops in Niagara and other regions, and kill evergreen growth in Ontario’s North. Here in Toronto, we are well on our way towards twice the rainfall, longer heat waves and temperatures as high as 44 C degrees from the first decade of the 21st Century to the fifth decade (2000-2050). Property insurance rates are already on the rise from events such as the 2012 ice storms, persistent flooding in both rural and urban areas, and the recent Ottawa-Gatineau tornados….Together these events cost Ontarians billions of dollars in damages a year and disrupt our lives and livelihoods….We have all benefitted from the burning of fossil fuels. But we now know that an unintended consequence of burning those fuels puts us all at risk.”
2)Ideas to support the People’s Climate Plan point: “Commit to and invest in 100% renewable energy by 2030 and stop spending taxpayers’ money on expensive, dirty energy sources. Take advantage of low-cost electricity options, including energy conservation strategies and by purchasing Quebec water power.”
Based on the peoplesdemands.org:
Resume the 758 renewable energy projects that were cancelled.
Replace natural gas as a source of electricity with renewable energy by 2030, currently 10% of our total electricity generation based on 2015 figures
End all fossil fuel subsidies, and fully divest from fossil fuel and fossil fuel related companies by 2030
Institute an immediate ban on fracking in Ontario
Institute a moratorium on new fossil fuel expansion and extraction techniques in 2018 (now)
From Good Jobs for All coalition: Invest in publicly owned renewable energy, and do not privatize Hydro
Lee Adamson (Green Neighbours Network) suggests: “Promote ground-source and air-source heating and cooling, and phase out natural gas. Natural gas (methane) is an extremely potent green house gas. It is not safe or clean. It is relatively short-lived in the atmosphere, so phasing it out would yield relatively rapid benefits for the climate. Start by making natural gas use now the peak – so no new pipelines, no expansion of infrastructure will be approved. Natural gas companies can expand their customer base with more efficient use of their current supply, and by adopting alternatives (e.g. ground-source heating & cooling, hydrogen, bio-gas).”
Steve Shallhorn, Labour Education Centre Working Green project/Toronto & York Region Labour Council (TYLC) suggests:
a 2040 date for prohibition of the use of fossil fuels to generate electricity in Ontario; a 2050 Prohibition on the burning of fossil fuels in Ontario
Accountability around Money
3)Ideas to support the People’s Climate Plan point: “Do not misuse public money. Account for the money that was raised in cap and trade auctions and was earmarked for things like public building retrofits. Do not spend $30 million in tax dollars taking the federal government to court to fight a carbon fee that will be returned directly to Ontario’s schools, hospitals and households (an average family will receive $300 in 2019).”
ClimateFast suggests: “Economic signals are very important. We need to have a carbon price –therefore the province should drop its challenge of the federal carbon tax. Now that the province has dropped the income from cap and trade - how is the province going to finance the transition to a renewable energy future that is required to do our part of lowering global GHG emissions? Even business groups understand the need for carbon pricing to achieve our climate goals: https://thebusinesscouncil.ca/news/business-council-statement-on-the-proposed-federal-carbon-pricing-and-rebate-system/.”
The EC Report, Pg. 69, emphasizes that the money collected from cap and trade program should be used accountably to fund climate action and shows that there is about $500 million unaccounted for to date.
Toronto350 suggests that the costs of climate change also be factored into the equation: “Climate change affects every one of us and represents rising costs of living across the board. The rapidly rising social costs include threats to human health, food production and lowered work productivity. Climate disruption costs are also rising exponentially, estimated at about $5 billion a year for Canadians by 2020. Ontarians face significant losses as a result of storms, floods and forest fires. As of this year, there are about 120 heat-related deaths in Toronto alone (EC Report). While important, focusing heavily on adaptation is not a tenable strategy because it is costly, too slow to implement and because of increasingly unpredictable conditions. It makes a lot of sense to use our new climate plan to head off these potential costs and losses and minimize the wide-reaching “climate tax” that climate change creates.”
“$400 million to support clean technology and a reverse auction (out of the $500 million for the whole plan) sounds like a lot. But there is no evidence that this will be enough to achieve the necessary reductions. What we do know is that this plan proposed $500 million in total funding over four years. Cap-and-trade provided $1.9 billion in a single year.” ONTARIO’S NEW CLIMATE CHANGE PLAN GETS A FAILING GRADE, DEC 03 2018, Sarah Buchanan, Program Manager, Clean Economy, Environmental Defence
4)To support the People’s Climate Plan point: “Create jobs and save Ontarians money by accelerating the adoption of renewables, significantly increasing energy efficiency programs and restoring incentives to building retrofits, including those for solar, heat pumps and geothermal. Increase energy efficiency requirements in the building code by 2020, leading to net-zero emissions in new-builds by 2030.
Drawdown suggests: “Set a date for mandatory Net Zero buildings….Help the construction industry get the necessary training and education to allow all workers to succeed in the Net Zero future.”
Lee Adamson (Green Neighbours Network) advises: “Upgrade the building code to reduce embedded carbon in construction materials and methods, and to increase energy efficiency of new buildings. Also update the code to require minimum energy efficiency standards for all major building renovations and retrofits.”
“Promote conservation of energy with incentives, programs that lessen the barrier of up-front-costs. Conservation is the cheapest solution. And can save tax-payers a lot of money over time. Make this the priority for remaining cap and trade funds; short term funding creating long term expense reductions, and lots of jobs.”
In their Testimony to Ontario Legislature, Steve Shallhorn, Labour Education Centre Working Green project/Toronto & York Region Labour Council state that “Ontario Building codes are to be net zero for new buildings by 2030. We need to make sure this goal is achieved, and need an aggressive approach to refit existing Ontario buildings that includes incentives to home and business owners. Enacting high performance building codes with programs to financially encourage energy retrofits in private, commercial, institutional and industrial buildings, including increased funding for public housing will help us reach this goal. All of these measures create jobs, and when combined with youth training programs, and Community Benefit Agreements, especially around infrastructure projects bring good jobs to communities that need them.”
Things proposed in the current plan to encourage or elaborate on around Buildings include:
Natural Gas Conservation - expanding existing programs delivered by utilities.
Review Ontario Building Code re: cost effective energy efficiency - This is a must.
Encourage voluntary energy efficiency information on homes for sale -this should be mandatory.
Require voluntary renewable natural gas programs - combined with a move to %100 renewables so that the use of renewables is actually a given & natural gas entirely phased out.
Encourage district energy, heat pumps - more details and a firm commitment needed.
The promise to look into tax policy options in order that homeowners can find it easier to become energy efficient and save money
Keeping appliance and equipment energy-efficiency standards among the strictest in North America - As ClimateFast writes, “We need improved standards for appliance and vehicle efficiency and we need incentive programs to help move consumer purchases in this direction.”
Things proposed in the current plan to encourage or elaborate on around Adaptation include:
Modernize the building code to prepare homes and buildings for more extreme weather
The proposed provincial impact assessments to show where and how climate change may affect Ontarians - risk-based evidence gathering and sharing
5)To support this People’s Climate Plan point: “Ensure that green transportation choices are accessible and affordable for Ontarians, including reliable low-carbon public transport, electric vehicles, supporting grid systems, and safe, active options like walking and cycling.”
ClimateFast suggests that “Walkable towns & cities - safer walking routes would be a good investment that would pay off in happier and healthier people, and reduced health care expenditures. This is also a good investment for children and young people -to encourage the provision of safe routes to school that don’t rely on transportation by car….Change the building code or planning requirements so new communities are constructed with safe streets, bike lanes, and public transit built into the plan.”
Drawdown suggests: “Use policy tools to ensure city planning and transit planning are aligned, making it more efficient and cost effective to use public transit to commute in major city hubs. This will not only relieve Ontario’s busy highways while reducing GHG emissions, but also contribute to better quality of life for Ontario’s hard-working labour force.” They also propose the solution, telepresence.
Lee Adamson (Green Neighbours Network) suggests “Set a date for stopping the use of fossil fuels in vehicles. Tie it in with expanding infrastructure support for non-fossil fuel vehicles. Set a date for stopping construction of any new gas stations or other new fossil fuel infrastructure.”
“Use surplus electricity to generate hydrogen, use hydrogen to power public transit vehicles, this way when the sun shines and the wind blows, or when electricity demands are low, our existing electrical generation capacity can be used to generate and store low carbon energy, reducing waste.“
“Continue investments in publicly owned rapid transit, such as LRT lines in Waterloo, Toronto, Peel Region and Hamilton, and other infrastructure, including transfers to municipalities.” from Good Jobs for All
From Ray Nakano: Study the use of hydrogen fuel cell technology for public transit, e.g. GO trains, GO buses. <see this article about the world's first hydrogen powered train.>
To better utilize surplus electricity available during non peak hours:
Study the use of large, storage batteries such as the ones invented at MIT.
Study the generation of hydrogen for fueling hydrogen powered vehicles.
Things proposed in the current plan to encourage or elaborate on around Transportation include:
A strengthened emissions testing program for heavy-duty vehicles and on-road enforcement of emissions standards - however, reinstating general emissions testing may also be desirable
The plan to increase the renewable content requirement in gasoline as early as 2025
Green Infrastructure & Job Creation
6)To Support the People’s Climate Plan point: “Ensure Ontario’s long-term prosperity by taking full advantage of green tech opportunities and our skilled workforce. Build infrastructure to help skilled workers in construction, manufacturing and transportation secure long-term employment in clean tech, rather than in polluting, fossil-fuel dependent industries that are unreliable job providers.
Lee Adamson (Green Neighbours Network): “Expand net-metering and allow virtual net-metering to promote local production of electricity by people and communities. Local production of electricity reduces transmission losses, improves resilience (e.g. avoid wide-spread electricity disruption), and reduces requirement for province to pay high infrastructure costs (e.g. for nuclear stations). Also makes energy production smaller and more nimble – Ontarians will be able to change and adapt more quickly to new energy production technology.”
“Diversify the production of vehicles in Ontario to include alternative energy vehicles including electric vehicles and hydrogen powered transit vehicles. Jobs in Ontario are extremely vulnerable to a crash in sales of vehicles that use fossil fuels, as alternatives continue to get better and cheaper, and the world transitions away from fossil fuels.”
Drawdown suggests: “To ensure its future economic competitiveness and good, well-paying jobs for Ontarians, it is essential that the Ontario government gets behind the low-carbon transition…Ontario, as a global manufacturing and technology hub, is well-positioned to take the lead…Project Drawdown contains the basic blueprint for Ontario to contribute to preventing global warming while in the process of modernizing its economy.” “Use trade negotiation to bring electric vehicle assembly to Ontario’s automotive manufacturing plants, in order to secure Ontario’s place in the growing electric vehicle industry.”
Resources from the Testimony to Ontario Legislature, Steve Shallhorn, Labour Education Centre Working Green project/Toronto & York Region Labour Council “released its Greenprint for Greater Toronto, Working Together for Climate Action, in 2015. It outlines a number of measures that can be taken in areas such as transit, buildings and energy. Greenprint examines the opportunities that the new, green economy can bring to Toronto.”
From Iron and Earth “Our Four-Point Plan:
1. Build up Canada’s renewable energy workforce by rapidly upskilling energy sector workers through short term training programs and expanding apprenticeship programs.
2. Build up the manufacturing capacity of renewable energy products through the retooling and advancement of existing manufacturing facilities. 3. Position existing energy sector unions, contractors, manufacturers and developers within the renewable energy sector through incubator programs and multi- stakeholder collaboration initiatives. 4. Integrate renewable energy technologies and industrial scale energy efficiency projects into existing non-renewable energy infrastructure.
'Workers need government to support contractors and unions that want to make a clean transition. What they don’t need is to remain dependent on the boom-and-bust cycles of oil and gas.’” Worker’s Climate Plan, Iron & Earth
Also see this document, https://www.wri.org/climate/expert-perspective/toward-just-transition
“Support global efforts for a just and equitable transition that enables energy democracy, creates new job opportunities, encourages distributed renewable energy, and protects workers and communities most affected by extractive economies.”
“Respect and enable non-corporate, community-led climate solutions that recognize the traditional knowledge, practices, wisdom, and resilience of indigenous peoples and local communities, and protect rights over their lands and territories” from peoplesdemands.org
Things proposed in the current plan to encourage or elaborate on around Innovation include:
Encourage Innovation - possible advancements in energy storage; cost-effective fuel switching - this needs to be realizable, include a just transition, benefit everyone and make a science-based difference in GHG reduction.
Promote climate related disclosures in the financial sector and encourage the Ontario Securities Commission to strengthen the guidance they give about these disclosures - these are excellent steps, so that the social cost of carbon is addressed more fully in our economic system
Consider tax policies to encourage more clean tech manufacturing jobs
7)To support this People’s Climate Plan point: “Account for the social cost of carbon and choose an effective way to fund green initiatives. Do not use our tax dollars to pay polluters in a system that already failed when adopted in Australia. Any system chosen should show reduced emissions in line with ambitious climate targets.”
CAN: “With no consumer carbon tax, the proposed Ford climate plan relies on setting new emissions standards for heavy emitting industry. Those standards will be developed in collaboration with the affected industries, allowing concessions to protect competitiveness.”
Testimony to Ontario Legislature, Steve Shallhorn, Labour Education Centre Working Green project/Toronto & York Region Labour Council: “There are many different ways to reach those reduction goals. A cap and trade system, a carbon tax, a fee and dividend system are 3 different strategies that can be used. Each system uses a mix of market mechanisms and each system can be calibrated in seemingly endless ways. But all have some common attributes; they raise money by raising the costs of burning fuel and other GHG emitting processes, by raising the costs of fossil fuels they discourage pollution creating activities, and they have some way to re-distribute monies to reach targets and avoid the worst of climate change….How to distribute those monies and to whom is a political question. As with any complex mechanism, whatever system is adopted it will undoubtedly have to be tweaked as time goes on….Whatever mechanism is decided upon, monies raised should be used to repair existing infrastructure, purchase new low carbon technologies and along the way develop new industries and new jobs.”
Lee Adamson (Green Neighbours Network): “Put a price on carbon that rises slowly to promote innovation and entrepreneurship and job creation in low carbon solutions (energy efficiency, alternative energy sources, energy storage, etc). This will help the Ontario economy by making the transition away from fossil fuels gradual and predictable, rather than risking collapse and massive job losses when the world turns away from fossil fuels.”
ClimateFast Submission re: Cap and Trade bill: “The selling of emission credits from Cap and Trade raised $2.4 billion. Money raised was used to fund energy efficiency upgrades of hospitals, schools, and homes that would save individuals and organizations money on energy bills, renewable energy projects, public transit upgrades and improvements and TransformTO, the City of Toronto Climate Action Strategy.
“TransformTO was expecting to receive $52 million from Cap and Trade to fund 10 programs that would cut 360,000 tonnes of carbon by 2031. Programs included replacing 30 diesel buses with battery powered electric buses, building a system to recover methane from organic waste at Dufferin Organics Processing Facility and a number of renewable energy heating/cooling systems at St. Lawrence Market, Yonge and Eglinton, Liberty Village, Etobicoke Civic Centre Precinct and Scarborough. The loss of these funds is a huge blow to the city which has only set aside $3 million for TransformTO.
“There is the loss of millions to upgrade the subway system in Toronto. The subway system is running at overcapacity and desperately needs another line to get workers into the city on time. Scarborough desperately needs an integrated transportation system. This loss of funding sets Toronto’s transportation system back at a time when the government claims they are $15 million dollars in debt and thus has no alternative source of revenue.”
Ecology Ottawa Executive Director Robb Barnes, “The province’s new plan endangers halting climate progress made by Ontario cities in two ways. First, it starves them of funding for climate change solutions such as transit and building retrofits. Second, it threatens municipal climate plans that rely on price signals from carbon pricing in order to succeed.” Climate Action Network Canada Reacts to Ford Government’s Climate Plan
8)To support this Peoples’ Climate Plan point: “Conserve and protect our cherished wilderness and green spaces including the Green belt. Protect at least 17% of lands and inland waters by 2020; they are our most effective carbon sink.”
Colleen Lynch (of Toronto350) suggests: “Another great risk to us is the loss of biodiversity and habitats. Our green spaces - forests, grasslands, riparian areas, parks, green roofs - are critical for the survival of many species (including us!), our food and water supplies. They are also critical as natural carbon sinks, which may be our best hope to drawdown emissions as required. A third benefit is that they offset the grey spaces in cities, offering heat reduction and stormwater management. Ontario’s climate plan should encourage good land use practices like agricultural practises that support carbon drawdown, plant-based diets, reforestation and biodiversity conservation.”
Drawdown suggestion: “Provide financial incentives and supports for individuals and communities that install Green Roofs and who create perennial pollinator and urban food gardens.”
ClimateFast: “The greening of our communities is vital – tree planting, neighbourhood parks and green spaces reduce the heat island effect in urban areas, and help to protect the most vulnerable. Tree planting, urban gardening and creating green corridors for bike lanes and walking help to create a more livable city.”
“We need to encourage and support low impact agriculture – growing local, reducing meat consumption, and improving the capacity of soil to draw down carbon”
“Rapid Reforestation - Trees are a great way to store carbon for many decades, after which hopefully we will have passed peak carbon when either the trees are harvested or die-off.” from Good Jobs for All
Support ecological restoration to recover natural sinks, and stop all projects that are extremely destructive of Earth’s natural capacity to absorb greenhouse gases. taken from peoplesdemands.org
CAPE explains: “On December 6th, the Ontario Government introduced Bill 66 – Restoring Ontario’s Competitiveness Act. This Bill would allow municipalities to pass “open-for-business planning” by-laws, which would allow them to circumvent provincial policies and their own Official Plans when making decisions about how their communities are developed. The “open-for-business” by-laws would allow municipalities to ignore provincial policies that have been developed to protect ground water, preserve agricultural land, and foster walkable and transit-supportive communities. These provincial policies help to improve the quality of life, protect public health, improve air quality, and reduce traffic congestion. They also help to reduce climate emissions, preserve greenspace, and save taxpayers’ money.”
Things proposed in the current plan to encourage or elaborate on around Conservation include:
A working relationship with Indigenous organizations, the forestry industry and communities to further sustainable forest management (reduce emissions/increase carbon storage)
Support partners and organizations like the Grassland Stewardship Initiative (farm conservation activities), Ducks Unlimited and the Nature Conservancy of Canada
Pursuing education - curriculum about the environment, including protection of the air, land and water, climate change and waste and litter. This needs to be science-based curriculum.
Support Healthy Parks Healthy People movement to promote link between nature and human health
Explore international best practises and mechanisms for managing provincial parks and conservation areas
Working with partners, governments and using tools to manage invasive species
9)To Support the People’s Climate Plan point: “Create a plan that is SMART - Specific, Measurable, Accountable, Relevant and Timebound - including short and long-term targets, concrete details, clear timelines, and a system to transparently and frequently measure progress. Include ongoing meaningful public consultation, e.g., a working group comprised of academics, scientists, workers and municipal representatives.”
Environmental Commissioner’s report "Climate Action in Ontario: What's Next", 2018 (EC Report), Pg. 103 “To attract talent and investment, and to maximize the chance that its climate policies will be effective and will survive changes in government, the Ontario government should model its climate law on the U.K. Climate Change Act , including:
• statutory emission limits
• legally binding multi-year carbon budgets set 12 years in advance, which apply to the entire term of a single government
• a non-partisan, expert advisory committee with permanent staff to provide reliable advice, and to recommend carbon budgets that will meet the statutory emission limits
• regular government reports on progress towards meeting the budgets and targets, which are publicly evaluated by the advisory committee
requiring essential service providers to prepare for climate risks.
Ontario should also adopt, as far as possible, the Nordic approach of seeking common ground across party lines, and of each parliamentarian accepting individual responsibility for his or her own climate leadership.”
Testimony to Ontario Legislature, Steve Shallhorn, Labour Education Centre Working Green project/Toronto and York Region Labour Council suggests: “Ontario should enact a Climate Change Accountability Act that legislates its greenhouse gas emission targets, and the ways and means to meet those targets. This will involve significant changes to the type of buildings built, vehicles manufactured and driven, industrial processes used, and many other things….This would be similar to what the Ontario’s Environmental Commissioner recommended in the 2018 GHG progress report calling on the government to “‘create a climate change law that drives down emissions, while funding sensible solutions. A meaningful climate law needs to include science based emission budgets, and a legal obligation to stay within these budgets and credible, transparent progress reporting’”
Lee Adamson (Green Neighbours Network) suggests: “We need annual reporting on progress toward the targets; set targets for carbon emission reductions in Ontario. Monitor and publicly report progress with third-party validation. Revise climate action plan and implementation as needed to hit targets.”
CAPE explains: “The new climate “plan” is 19 pages in a larger environmental plan. Those pages contain a series of statements that are broad and vague with few details about how emission reductions will be achieved, monitored, encouraged or enforced.”
“On December 6th, the Ontario Government also passed Bill 57 the Restoring Trust, Transparency and Accountability Act. Counter to its name, the new legislation will, among other things, amend the Environmental Bill of Rights, eliminate the independent Environmental Commissioner of Ontario, which has been in place for 25 years, and substantially reduce transparency and oversight of environmental impacts that occur as a result of provincial decisions. (For more information, click here to see the critique by the Canadian Environmental Law Association.)”
“Regulate Ontario commercial and residential buildings and establishments to operate a a mandatory composition program in all buildings, not only residential.”
“Regulate manufacturers and retailers of food to donate unused food to food banks, community organizations, shelters.”
Lee Adamson (Green Neighbours Network) suggests: “Ban organics in landfills. Put a price on organics to make it a valuable commodity - which it is. Support composting and methane (bio-gas) production. Create jobs in collecting organics, selling compost, etc.”
Things proposed in the current plan to encourage or elaborate on around Waste include:
expand green bin collection systems (big cities; certain businesses); also move toward acceptance of compostable packaging in more green bin programs
make producers responsible for life-cycle of products
explore options to recover resources from waste
move toward banning food waste from landfill
create best practises for food donation
work to create a plastics strategy (reduce waste & micro-plastics in our waters)