The Ontario Atmospheric…

The Ontario Atmospheric Services team of Golder Associates Ltd. (Golder) is pleased to provide comments and raise questions regarding the draft guidance document “Consideration of Climate Change in Environmental Assessment in Ontario” (the Guidance Document) to help the Ministry of Environment and Climate Change (MOECC) with its continuous work in developing its environmental assessment program.

Overall, Golder agrees with the approach taken in the Guidance Document to modify the consideration of climate change according to the type of assessment and the project being considered (Table 1 of the Guidance Document). In particular, Golder agrees with not limiting the “choices of methodologies, approaches and modelling information used” (page 6 of the Guidance Document), as these are very likely to change with the depth of detail required in the assessment and project type and location being considered.

Considering the Project’s Effect on Climate

Golder recommends that an appendix be developed, similar to Appendix C: Availability and Use of Climate Model Results, for the availability and use of greenhouse gas (GHG) emission factors and calculation methodologies. In Golder’s experience, for sources that are not covered under O. Reg. 452/09, it is important to have guidance on what methodologies the MOECC considers appropriate, especially for indirect sources. For example, the Guidance Document mentions considering the release of carbon from disturbance of peatlands but provides no guidance on how this should be completed in a quantitative manner. In addition, this new appendix could provide a reference for which global warming potentials to consider, ensuring consistency across all project assessments. The Guidance Document does not mention future GHG targets under Ontario’s Climate Action Plan and how these should be considered as part of the climate change consideration in the environmental assessment.

Golder recommends that the targets should be considered but not be included as an indicator for the effects assessment. Golder recommends that intensity-based benchmarks be developed for use in assessing the GHG emissions from a project. Benchmarks could be created from information at a national or global level. This is important for regions where no other significant developments exist and a proposed project will be the major contributor to GHGs.

Considering the Effects of Climate on a Project

In the Guidance Document, Table 3 presents a number of climate variables for considering the effects of climate on a project. While Golder understands this is not meant to be exhaustive, it would be helpful to make sure that the resources mentioned in Appendix C and D provide information on the examples given. In particular, many wind speed variables can be challenging to assess as there are limited observations and future projections available. In addition, in Table 3, fog, hail and lightning should not be listed under “Wind Speed”. These variables should have their own category.

The Ontario Climate Change Scenarios listed in Appendix C are still under development. Would it be possible to include a projected schedule of when additional RCP scenarios and models will become available? Additionally, the IDF curves are only available for AR4:A1B, are there plans to provide updated IDF curves under AR5?

Golder recommends that Appendix D also include the following reference: Warren, F.J., and Lemmen, D.S., editors (2014): Canada in a Changing Climate: Sector Perspectives on Impacts and Adaptation; Government of Canada, Ottawa, ON, 286p.

Closing

Golder appreciates the opportunity to comment on the Guidance Document. We trust that these comments meet the MOECC’s needs at this time. Should you require any additional information or have any questions, please contact either Janya Kelly (jkelly@golder.com) or Sean Capstick (scapstick@golder.com).

[Original Comment ID: 196174]