By: David V. Wright
PDF Version: Draft Strategic Assessment of Climate Change: Big Steps for Impact Assessment, Baby Steps for Climate Change
Document Commented On: Environment and Climate Change Canada, Draft Strategic Assessment of Climate Change
Earlier this year, Environment and Climate Change Canada (ECCC) released draft guidance for the climate change related requirements in the new federal Impact Assessment Act (S.C. 2019, c. 28, s. 1) (IAA or the Act). While the future of this guidance was uncertain in recent months due to the federal election, as was the future of the entire new regime, the Act is now firmly in force and here to stay. No amendments are expected, as stated by the new federal environment minister. As part of implementing the regime, the new Impact Assessment Agency (the Agency) is now in the process of issuing detailed guidance explaining what information proponents should provide during the planning and assessment phases, including with respect to initial and detailed project descriptions, engagement with Indigenous communities, public participation, and climate change. The final climate change guidance, which ECCC has developed through what it calls a Strategic Assessment on Climate Change (SACC), is expected in early 2020.
This post focuses on the draft SACC. Specifically, I provide relevant background, explain the general threshold-based structure of the proposed regime, and then offer commentary on several key features and one missing piece. Overall, this draft guidance takes a significant step in the right direction by providing details and parameters that should be welcomed by project proponents and those interested in seeing clarity regarding quantification of greenhouse gasses (GHGs) in impact assessment. This is no small feat in the impact assessment realm where integration of climate change considerations has been a challenge for many years across the world. However, in several ways the guidance does not go far enough, particularly in terms of relating project-specific emissions analysis with what really matters: achieving Canada’s climate change commitments and avoiding severe climate change-induced damage on a global scale. As the 25th Conference of the parties (“COP 25”) to the United Nations Framework Convention on Climate Change draws to a close in Madrid, the world is watching. It is not too late for Canada to further clarify how emissions from major projects reviewed under the IAA will fit into the path toward achieving Canada’s targets under the Paris Agreement and achieving the recently announced commitment to net zero carbon emissions by 2050, which has just been included in the mandate letter released today to the Minister of Environment and Climate Change. Continue reading →
