EBR 012-5806 – Guide:…

EBR 012-5806 – Guide: Consideration of Climate Change in Environmental Assessment in Ontario

Comments:

The Ontario Society of Professional Engineers (OSPE) has long stood as a trusted resource and partner to the Government of Ontario in its efforts to combat Climate Change and reduce its negative impacts. With this submission, OSPE continues these efforts by providing the Ministry of Environment and Climate Change (MOECC) with input and comments about the policy guide Consideration of Climate Change in Environmental Assessment in Ontario (the Guide).

Overall the Guide presents a broad-based and easy-to-understand description of elements of environmental assessment (EA) as it relates to Climate Change. Specific comments about individual sections of the Guide are as follows:

Introduction –

The description of what environmental assessments entail and their Codes of Practice are stated in layperson language and clearly understood. OSPE is especially pleased that resilience to future environmental effects is recognized. This is most importantly conveyed in the Provincial Policy Statement 3.1.3 that requires consideration of increased risks associated with natural hazards.

In the Introduction and elsewhere in the Guide, statements are made on procedures and steps involved in preparing and undertaking EAs by proponents. Yet, proponents are not clearly defined in terms of whom or what type of person is typically a proponent. It may warrant specifying the qualifications required to undertake EA work – recognizing that this can be multi-disciplinary work based on the nature of the development project.

Climate Change and Climate Effects –

The two bullet points on Page 8 are important for experts and the general public to understand. OSPE highly supports the conveyance of the two elements essential in addressing climate change: mitigation and resilience. In fact, these two themes are prominent in a course being developed by OSPE with funding from the Ministry of Citizenship and Immigration on workplace culture and communications for newcomers in environmental industries.

Considering the Project’s Effect on Climate –

OSPE agrees with the MOECC that it is prudent to consider both qualitative and quantitative effects on climate by major or substantive projects. There is much to be gained by having a(n) (expert) proponent to first assess the project by summarizing climate mitigation measures from a holistic, descriptive perspective to gain an overall understanding of all variables and characteristics of project development. As an example, the clearing of vegetation for a major project encompasses more than just clearing the land. Lack of vegetation increases erosion and potential of flooding, especially from acute climate events due to climate change, as well as, depending on soil characteristics, increased albedo which could lead to higher temperatures on a micro-scale.

For quantitative considerations, it indeed is essential for a proponent to generate metrics to effectively mitigate the effects of GHG, especially CO2 emissions. In conducting analysis on a study estimating the amount of emissions generated from disposing excess soil from infrastructure projects, OSPE found that determining actual CO2 emitted from vehicles, for example, is a complicated and inexact undertaking. A great many variables are at play such as vehicle type, distance travelled, etc. It would be helpful if the MOECC could take an inventory of emission calculations and estimation factors and develop a generic template or online tool so a proponent can more easily and accurately determine the actual amount of emissions being addressed.

Considering the Effects of Climate on a Project –

OSPE strongly agrees with the tone of statements in this section in terms of the importance of considering all aspects of the environment in EAs including the interrelationships between various components of the environment (i.e. a holistic systems approach). Having said this, the five approaches addressing broad considerations of effects of climate on a project entail a very high number of variables that need to be investigated. While fully realizing that greater protection necessitates greater controls, the MOECC should use caution so that they do not lead to additional red tape or overburdening the process of developing and issuing an EA.

Relating to a specific example: in one consideration, to determine if a proposed project contributes to or diminishes the resilience of ecosystems, is a sample question that asks if the projects alteration of local drainage patterns exacerbates impacts to water resources projected to occur with climate change. This example would require a Qualified Person (QP) such as an individual with a P.Eng. designation. Again, it would be advisable to add more descriptions of the types of proponents that would typically be required (or allowed) to perform EAs to stress that not all proponents are qualified to perform them.

Table 3 is a useful visual to convey a conceptual approach to Climate Change considerations. Use of this type of table should be encouraged when conveying other considerations, if applicable.

Potential Outcomes of Climate Effects Consideration –

This section is straight-forward and easily understood although implies that proponents all have equal qualifications to conduct EAs. This requires further consideration.

Documenting Climate Effects in Environmental Assessment –

This section solidifies and reinforces the fact that EAs are complex and that a wide range of considerations and variables are required to develop a proper, valid, and acceptable EA. Proponents must be highly qualified to document climate considerations as outlined in the Guide. OSPE reiterates that even if many EAs may not require a QP (as this term is now defined under O.Reg. 153/04), a proponent nonetheless must have proper educational and experiential qualifications.

As well, the Guide implicitly infers that all proponents know how to prepare an EA. OSPE recommends that the Guide should clearly indicate that proponents must ensure that they are sufficiently knowledgeable to properly prepare an EA in addition to being qualified to conduct one. If possible, the MOECC should hold info sessions on how to prepare an EA. Even more effective would be to provide funding for OSPE to develop a course or learning tool to prepare proponents on how to conduct and prepare an EA. OSPE would be pleased to discuss this initiative with the MOECC.

[Original Comment ID: 196168]