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Why a strategic assessment of climate change is critical to meet Canada’s Paris commitments

Wildfire smoke over the Opabin Plateau, BC (Photo: Junaidrao via Flickr)
August 20, 2018

Canada claims to care about climate change, but the reality is that we have missed pretty much every climate promise that the federal government has set to reduce its greenhouse gas (GHG) emissions. Why? One reason is that those promises are not meaningfully considered when it comes time to decide whether to approve new pipelines, highways or power plants.

That is why we sat up when the federal government published a discussion paper setting out proposals for a Strategic Assessment of Climate Change (Climate Assessment). The purpose of the Climate Assessment would be to provide guidance for impact assessments and decisions, so they are consistent with Canada’s international and domestic climate commitments and goals. Its intended outcome is a consistent framework to apply when deciding whether to approve GHG-emitting projects, so everyone knows from the outset what information is needed, how the analysis will be conducted, and what projects need to demonstrate in order to be approved.

Given the current uncertainty and politicization of decisions about GHG-intensive projects like pipelines, a Climate Assessment that gives useful and clear guidance is of critical importance for Canada’s ability to meet its international climate commitments, and to restore public confidence in government decisions.

The government is conducting public consultations on the Climate Assessment discussion paper until August 31st, 2018. This blog post discusses why the Climate Assessment is so important for Canada, and how it should be conducted in order to achieve a framework for making decisions about a project’s climate impacts that will enable us to achieve our international commitments.

For another informative discussion of a meaningful climate test, check out this blog by Meinhard Doelle, Professor Bob Gibson and Karine Péloffy, and check back with us for more information as we participate in the consultation on Canada’s Climate Assessment.

Strategic Assessment of Climate?

Under the Paris Climate Agreement, which Canada ratified in October 2016, we committed to doing our fair share to limit global climate change to no more than 2˚ Celsius and pursuing efforts to limit increases to 1.5˚C.  

As a first step, we have promised to reduce our emissions by 30% below 2005 levels by 2030. That means reducing emissions from the 704 megatonnes (Mt) of carbon dioxide equivalent that we emitted in 2016, to 524 Mt in 2030. (Note that this target does not represent “Canada’s fair share” – the current Canadian government, which had criticized this target as inadequate while in opposition, has said that it is a “ceiling, not a floor”). 

From there, we have committed to making progressively more ambitious efforts to reduce our GHG emissions until we become carbon-neutral by sometime in the second half of this century. That means by 2050 we should be emitting no more GHGs than we can sink through our forests and wetlands, capture through technology, or offset through other means.

But there is nothing in government policy – or in the Pan-Canadian Framework on Clean Growth and Climate Change signed between the federal government and the provinces – that explains how the government intends to ensure that federal decision-making will be consistent with reaching any of these targets.

Meanwhile, Canada has continued to approve GHG-intensive projects, such as Kinder Morgan’s Trans Mountain pipeline and tankers project and the Pacific NorthWest liquefied natural gas project on the north coast of BC, which together would increase Canada’s emissions by over 4% a year. That’s not even counting indirect emissions, such as the climate effects of upstream land use changes like deforestation. Nor does it count the emissions when the oil and gas transported are burned.

The problem is not a hypothetical or academic one. Canada’s Auditors-General have concluded that Canada will not meet its 2020 target, and is not on track to meeting its 2030 one either. In fact, even using the lowest reasonable emissions scenario, Canada’s emissions will increase to 720 Mt by 2020. The Pan-Canadian Framework itself acknowledges that the 2030 target will not be achieved unless new measures are identified and implemented.

When the federal government approved Trans Mountain and Pacific NorthWest LNG, it said that the projects were consistent with Canada’s climate commitments, and politicians continue to state that “the environment and the economy go hand in hand.” But the government did not show how those two projects are compatible with our emissions reductions strategies, or even provide proof that they are.

This “trust us” attitude has failed to assuage the concerns of climate activists or scientists alike, and is not aligned with the government’s commitment to restoring public trust in environmental decision-making. Many experts question that the two projects are in any way consistent with meeting Canada’s 2030 targets, or with more general commitments to do our fair share in keeping global temperature increases well below 2°C.

What Canada needs is a framework for assessing exactly how a project will contribute to climate change mitigation efforts and to achieving national commitments. The new Impact Assessment Act, introduced in February 2018 and set to be reviewed by the Senate this fall, requires decision-makers to consider whether a project will help or hinder Canada’s ability to meet its international climate commitments, including the Paris Agreement.

But without a better understanding of which emissions should be assessed, how to assess them, or even which projects need to be assessed on the basis of their GHG emissions, Canadians should not hope that assessments under the Impact Assessment Act will do a better job of ensuring projects are consistent with our climate goals and obligations.

We have seen project after project approved with decision-makers making vague statements that they are consistent with our GHG-reduction strategies – without any proof that those declarations are true.

The Climate Assessment is crucial to achieving the goals of the Impact Assessment Act, and Canada’s global climate commitments, because it can provide a framework for contextualizing an individual project’s emissions against national and global commitments.

For the Climate Assessment to succeed, it needs a process and terms of reference that will allow it to identify what must get assessed, and set out a climate test for individual assessments that will help ensure we finally succeed on climate change.

Who should conduct the Climate Assessment?

The “who” may be as important as the “what” when it comes to undertaking a Climate Assessment. Right now, the discussion paper suggests that a draft report will be prepared by the very agencies that have prepared inadequate assessments of climate impacts of past projects. After that, an advisory committee would conduct public engagement on the draft report, and prepare a final report for the Minister. 

Instead, in order for the Climate Assessment to have the necessary expertise, vision and transparency – and to achieve public buy-in to the results – it should be conducted from start to finish by an independent expert panel. A panel that is independent of government would help avoid politicized outcomes and enhance the assessment’s credibility. Plus, it would send the signal that this government is committed to transparent, credible and participatory processes when the new Impact Assessment Act comes into force.

The panel should have a chair or co-chairs, and at least one member appointed by Indigenous peoples. Its members should have expertise in such areas as Indigenous knowledge, environmental assessment, climate change and risk, economics, sustainability and just transition. It should have secretariat support from Environment and Climate Change Canada or the Canadian Environmental Assessment Agency, and have the ability and resources to commission expert and Indigenous reports, studies and analysis when and as needed.

How should the Climate Assessment be conducted?

As with impact assessments, early and ongoing collaboration with Indigenous, provincial and territorial governments is key, as is meaningful public participation. Stakeholders and the public should be consulted on the panel’s terms of reference, including the questions the panel will be asked to answer, and consultations should also occur throughout the assessment, and upon the release of the draft report. While consultation on the discussion paper is a good start, the terms of reference are where the rubber really hits the road – and one of the stages in which public input is most critical.

The panel should undertake workshops in key cities in Canada in order to engage the public, Indigenous groups and experts with relevant expertise and experience. The Expert Panel appointed to review Canada’s environmental assessment processes undertook cross-Canada consultations in under four months, and there’s no reason to believe that a Climate Assessment panel would need any longer.  

Both the panel and the government should reflect what they heard in any outcomes, so that people feel their involvement was meaningful and worthwhile. The panel should be required to make all information it receives publicly available, and describe what it heard, along with how it applied that information in its outcomes. For its part, the government should reflect how it applied the panel’s report (and justify any departures from it) in any laws, regulations and policies it enacts pursuant to the Climate Assessment.

What issues should the panel address?

It is critical that the panel have broad terms of reference to identify key questions and propose solutions regarding how to assess climate in project-level assessments. Questions the panel should be tasked with exploring include:

  • When should projects, activities or other undertakings with potential climate impacts trigger an assessment? For example, should an assessment be mandatory for projects with emissions above a particular annual threshold? Projects with emissions above a lifetime threshold? Projects that may be inconsistent with progressive emissions reductions over time?
  • What alternatives should be on the table? For example, if assessing a project like a pipeline transporting natural gas to displace a coal-fired generation plant, should/could renewable energy alternatives like wind or solar be assessed instead? What about energy-demand reduction strategies as an alternative to both natural gas and coal?
  • What information is needed to assess whether a project will help or hinder Canada’s ability to meet its climate obligations? For example, what direct or indirect upstream emissions should be assessed? Over what timescale? What are the types of emissions/projects where assessment of downstream emissions is possible and should be mandated?
  • How to analyze whether a project will help or hinder Canada’s ability to meet its climate obligations? For example, how to assess the project as compared to alternatives? How do we determine whether a project will be viable in a future in which we are meeting our Paris Agreement obligations? Do we discount the social cost of carbon from the economic benefits of the project?
  • How to base decisions on the climate implications of a project? How do we decide whether a project helps or hinders our ability to meet our climate commitments? How do we compare it to the alternatives? If a project like a hydroelectric dam will reduce GHG emissions, how do we compare those reductions against other significant environmental effects, like increased methylmercury levels in our waters?
  • Post-assessment questions: What conditions can the federal government impose on an undertaking within its jurisdiction? What emissions do we track after a project is approved – direct, upstream, downstream, domestic, and/or international?

Conclusion

Environmental assessment in Canada has long failed to ensure that decisions about GHG-emitting projects are consistent with our climate mitigation commitments. With a new Impact Assessment Act that requires projects to be assessed for their contributions to our obligations under the Paris Agreement, the strategic assessment of climate marks a crucial opportunity to learn how to get climate tests right.

For the Strategic Assessment of Climate Change Climate Assessment to succeed, it needs:

  • a well-resourced, independent expert panel comprised of members with a broad range of relevant expertise and perspectives
  • broad terms of reference that allow it to ask the right questions and come up with a detailed framework for project-level decision-making,
  • a firm commitment from the federal government to apply the outcomes in law, regulation and policy, and to explicitly justify any decision to not follow the panel’s recommendations.

The federal government has extended the deadline for comments to September 14, 2018. Read our submission for more detail on how the climate SA can better ensure that decisions on projects like pipelines are consistent with our climate obligations, and submit your own comments by September 14 to help #GetEAright.

Top photo: Wildfire smoke over the Opabin Plateau, BC. (Photo by Junaidrao via Flickr)

Author: 
Anna Johnston, Staff Lawyer