Greg Jenish…

Greg Jenish
Program Support Coordinator
Ministry of the Environment and Climate Change
Operations Division
Environmental Approvals Access and Service Integration Branch
135 St. Clair Avenue West
Floor 1
Toronto Ontario
M4V1P5

Re: Environmental Bill of Rights Registry No. 012-5806, Consideration of Climate Change in Environmental Assessment in Ontario

Dear Mr. Jenish,

The following submission provides the Clean Economy Alliance’s response to the draft guidance document for the Consideration of Climate Change in Environmental Assessment (EA) in Ontario (Guide).
The Clean Economy Alliance (CEA, or the Alliance) is a group of over 95 organizations representing a broad cross-section of Ontarians that united in 2015 to urge Ontario to show leadership in addressing the crucial issue of climate change. The CEA includes prominent Ontario businesses, industry associations, labour unions, farmers’ groups, health advocates, and environmental organizations. The Alliance supports the Ontario government’s commitments to develop and implement a climate change strategy. We recognize that reducing pollution will bring many benefits, including cleaner air, improved public health, and more jobs and business opportunities in the clean economy.

The CEA also supports Ontario’s proposal to incorporate considerations of the effects of climate change in Environmental Assessment (EA) studies and processes. In Ontario, climate change impacts a spectrum of essential provincial infrastructure including roads, buildings, transmission lines, water treatment services, communication lines and transportation networks. A proactive approach to planning that integrates climate change adaptation and mitigation - such as through the EA process - will help to reduce the province’s vulnerability to a changing climate and assist in reaching significant greenhouse gas emission reductions.

While the Alliance supports many aspects of the approaches outlined in the draft guidance document for the Consideration of Climate Change in EA in Ontario, including considerations of a project’s greenhouse gas (GHGs) impacts and its resilience in relation to a changing climate we make the following recommendations to enhance its effectiveness:

1)  Define a GHG emissions level that will require an Environmental Assessment

Under the Ontario Environmental Assessment Act the EA process is automatically required to come into effect when a project meets a set of defined criteria (e.g. specified size, location, sector, etc.) Currently, the level of GHG emissions emitted by a project is not considered as an automatic reason for EA implementation. This omission of a requirement for assessment whenever a project GHG emission reaches a defined level could seriously undermine the Province’s ability to reduce GHG emissions.

The Alliance recommends Ontario to define a GHG emissions level that will automatically require EA to come into effect that will take into account the lifecycle emissions from the project. The Alliance also believes that GHGs should be assessed for all projects that are undergoing an EA, whether or not they meet a defined GHG threshold for EA implementation.

2)  Projects must describe an “Alternate Emissions ” analysis

To better equip decision-makers with information to determine if the proposed project is the best option, the Alliance recommends the province include an “Alternate Emissions” analysis in every EA that has proponents describe if a less GHG-intensive project could be substituted for the one currently proposed.

The alternative options can inform mitigation measures and cause modification of the initial project plans, and can determine a baseline from which incremental emissions are measured. For example, The European Union Environmental Impact Assessment Guidance Document requires an analysis of alternatives to projects, as does the US Federal Council on Environmental Quality (CEQ) in their guidance document to on climate change in their National Environmental Policy Act (NEPA).

3)  Define a province-wide Carbon Budget in collaboration with other provincial and federal bodies, and measure projects against the Budget

The Alliance recommends the immediate development and implementation of an Ontario carbon budget -a maximum amount of GHGs that can be emitted over a particular time while still achieving a target - to compliment the Ontario cap-and-trade system.

Setting a provincial carbon can significantly aide in provincial planning, as it places a cap on emissions which can then be broken down and allocated to particular projects. Such a budget may assist in conceptualizing and realising the required provincial emissions. After the Budget is set, each project must be measured about the provincial CO2 balance available for new projects.

The CEA looks forward to continuing to work with the Province on the implementation of its climate change strategy, including the finalizing the Consideration of Climate Change in EA in Ontario Guide. If you have any questions or require any clarification on the contents of this submission, please contact:

Mikayla Wujec
Coordinator, Clean Economy Alliance
116 Spadina Ave, Suite 300 Toronto, ON M5V 2K6
Phone: 416-323-9521 X. 244
Email: mwujec@environmentaldefence.ca

[Original Comment ID: 196177]