September 28, 2017…

September 28, 2017

Diane Blachford
Senior Policy Advisor
Ministry of the Environment and Climate Change
Climate Change and Environmental Policy Division
Strategic Policy Branch
77 Wellesley Street West
Floor 11, Ferguson Block
Toronto Ontario
M7A 2T5

Updating the MOECC’s Statement of Environmental Values

Dear Ms. Blachford,

The Ontario Society of Professional Engineers (OSPE) is pleased to offer expert commentary to the Ministry of the Environment and Climate Change (MOECC) to update the Statement of Environmental Values (SEV).

The following comments are from Ontario’s engineers in response to the draft updates communicated by the MOECC, here.

Removing Anthropogenic Greenhouse Gases

In Section 7, it is stated that:

"The Ministry of the Environment and Climate Change believes that the public interest requires a broad effort to reduce greenhouse gases and to build a cleaner and more resilient province.” (p. 4)

OSPE suggests that this statement should be amended to reflect the following: “In the interest of the public, the Ministry of the Environment and Climate Change believes that a broad effort is required to move towards an economy in which carbon is sequestered (i.e. net negative greenhouse gas emissions) and the amount of anthropogenic carbon in the atmosphere is reduced over time”

Fostering a Carbon-Negative Economy and Society

In Sections 2 and 7, the terms "low-carbon economy and society" should be stated as, "carbon-negative economy and society."

Explanation and Justification of Word Choice

OSPE believes that the words communicated in MOECC’s SEV are significant to stakeholders and should reflect the technical requirements of Ontario’s economy and society as a part of Canada’s overall commitment to the Paris Climate Agreement.

As such, the following explanations of word choice and the justification of their selection is communicated below:

"Anthropogenic" (i.e. Human-Made) Most of the greenhouse gases in our atmosphere are natural and are in fact essential to life. If we didn't have a natural envelope of water vapour, carbon dioxide and methane around our planet, the average temperature at the surface would be a shocking 33°C colder. This would have made it impossible for life to have ever evolved. The problem is only regarding the extra amount of human-made gases that are being released into the atmosphere, strengthening the greenhouse effect by a few degrees more.

"Remove" as Opposed to “Reduce” Attempting to reduce greenhouse gases in Ontario's atmosphere is laudable but unrealistic because carbon dioxide is mixed across the entire planet's atmosphere. It is understood that Ontario can not control the planet. However, Ontario can control domestic emissions and withdrawals. If the Canadian federal government leverages Ontario’s goodwill on the international stage to secure and enhance the Paris agreement, Ontario will have played an important role in helping to solve the problem.

"Remove" as Opposed to “Reduce Emissions” Greenhouse gas levels in the atmosphere are high enough to push the Earth's temperature beyond the 2°C threshold set by the Paris agreement. According to the Intergovernmental Panel on Climate Change's 5th Assessment Report, sustained globally negative emissions are required in order to limit warming within 2°C of pre-industrial temperatures. Withdrawing carbon dioxide through bio-energy combined with carbon capture and storage forms an essential component of the response strategy for climate change in the majority of 2°C scenarios in climate science literature. Considering some jurisdictions will exceed their share of the remaining global carbon budget, rich countries like Canada must not only reduce or zero their emissions, but actually lead the way to negative emissions.

"Carbon-Negative" as Opposed to “Low-Carbon” (See "Remove" Above) The environment's capacity to absorb carbon dioxide is practically zero on human timescales. Ontario produced billions of tons of carbon dioxide over the twentieth century. Of that, only about a quarter was reabsorbed by the biosphere. The remainder accumulates in the atmosphere and the oceans causing climate change and acidification. On the principle of restoring the natural environment where reasonable, Ontarians can begin to clean up this historic pollution, while acknowledging that this is a multi-generational project.

[Original Comment ID: 211001]