Robert Lyman: Stop the regulatory pancaking via fpcomment
The Trudeau government endorsed “net-zero emissions by 2050” in December 2019 but the initiative was never debated in or approved by Parliament. It remains largely undefined, especially in terms of what will be “netted out” to attain the zero emissions. It has not been endorsed by the United Nations. There is good reason to question whether it is even feasible in technical and economic terms. Nor has any benefit-cost analysis ever been done to demonstrate that it is in Canada’s interest.
Among other things, a proponent must estimate: the greenhouse gas emissions produced directly by the project in its construction, operation, and decommissioning phases; the GHG emissions of its project suppliers; and the upstream emissions, defined as the “domestic and non-domestic emissions from all stages of production from the point of resource extraction or utilization.” It then must provide a projection of these emissions in detail, year-by-year, over the life of the project.
During the review, the proponent must provide a credible plan for how it will offset any emissions that depart from the “net-zero” goal. Required engagement with Indigenous peoples, local communities, other jurisdictions, the public, and federal authorities will be demanding and time-consuming. No doubt many groups will use the opportunity for “consultation” to extract economic benefits.
The impact of the new regulations will fall mainly on the energy and mining industries and the regions where they play prominent roles in the economy. But the many GHG emissions-intensive plants in the cement, steel, metal fabrication, petrochemicals, pulp and paper and other industries will not be affected.
No one questions the desirability of ensuring that, before deciding whether to issue a permit, governments assess the environmental, social and economic implications of a project’s proceeding. Until now, however, environmental assessment has focused on assessing direct and reasonably foreseeable project impacts and how they might be mitigated so as to protect Canada’s environmental quality.
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