The Ontario Government's 2013 Discussion Paper on Greenhouse Gas Reductions (Environmental Bill of Rights Registry Number: 011-7940) correctly identifies improving energy efficiency as an effective and economic way to reach the province's official emission reduction targets.  But the paper presents or reiterates efficiency targets that are unlikely to get us to the official GHG goals.  In our response, we outline the weaknesses in the discussion paper and the benefits of adopting a more robust approach to realizing all cost-effective energy efficiency.