July 23, 2020
Last week, the Government of Canada released its Strategic Assessment of Climate Change—a policy document that will guide how climate change considerations are taken into account during impact assessments carried out under the federal Impact Assessment Act.
Accounting for climate change considerations related to proposed projects such as pipelines, mines, oil fields, and others will be absolutely crucial as Canada strives to meet its domestic goal of achieving carbon neutrality by 2050, as well as its international commitment to support global efforts to limit global warming to no more than 1.5° Celsius above pre-industrial levels. The Impact Assessment Act made important strides by committing the federal government to assessing the climate change impacts of proposed projects, but several environmental organizations across Canada are concerned that the Strategic Assessment of Climate Change lacks the strong guidance that government and industry alike will require to make sure that climate change considerations are assessed effectively.
Among the concerns that have been raised is the fact that the Strategic Assessment of Climate Change only requires proponents of projects that will operate beyond 2050 to provide plans for those projects to achieve carbon neutrality by 2050. Proponents that are required to submit a plan are not required to address the interim goals that Canada will be working to reach between now and 2050.
The Strategic Assessment of Climate Change does require all proponents of projects undergoing the impact assessment process to estimate the greenhouse gas (“GHG”) emissions associated with their proposed projects. In addition, proponents must describe how their project will impact federal emissions reduction efforts and global GHG emissions. Unfortunately, the document does not clearly explain how project proponents should consider and address how their proposed projects will accommodate the increasingly stringent emissions reductions targets that can be expected in the coming decades.
Establishing carbon neutrality by 2050 as a primary target without acknowledging the many steps it will take to get there means that crucial information that could help decision-makers to assess the climate impacts of proposed projects will not be collected and taken into account. That will make it difficult, if not impossible, for decision-makers to weigh how a proposed project will benefit or jeopardize the public interest as we work to prevent the worst consequences of climate change.
East Coast Environmental Law shares many of the concerns that have been raised by our colleagues and partners in environmental organizations across the country, and we would like to take this opportunity to amplify their voices.
Read the Statement by Environmental Defence.
Read the Statement by the Pembina Institute.
Read the Statement by West Coast Environmental Law.