REDUCE EMISSIONS THROUGH NATURE CONSERVATON, ENVIRONMENTAL ASSESSMENT AND SUBSIDY REFORM
Theme: How and Where to Reduce Emissions – Mitigation
ABOUT NATURE CANADA
Nature Canada is the oldest national nature conservation charity in Canada. Over the past 75 years, Nature Canada has helped protect over 63 million acres of parks and wildlife areas in Canada and countless species that depend on this habitat.
Today, Nature Canada represents a network comprised of over 45,000 members and supporters and more than 350 nature organizations across the country and with affiliates in every province.
INTRODUCTION
Nature Canada is pleased to offer the following comments and recommendations on how and where governments can reduce emissions.
This submission offers recommendations to shape the draft Strategy in order that the federal and provincial governments can begin to make serious efforts to achieve a sustainable future.
Nature Canada is a member of the Green Budget Coalition (GBC); the recommendations in this document parallel those of submissions on similar topics, such as the GBC’s Recommendations for Budget 2016.
Nature Canada recommendations for Mitigation – How and Where to Reduce Emissions, are as follows:
RECOMMENDATION 1 – Improve GHG accounting rules by determining and regulating emissions caused by ecosystem degradation, and by recognizing and incorporating natural carbon storage as a mitigation measure.
Capturing the value of carbon naturally stored in ecosystems, and recognizing emissions from these ecosystems in national and provincial GHG accounts, will be an important starting point for guiding decision-making and improving regulatory frameworks.
Canada’s landscapes hold important carbon sinks, including forests, wetlands, coastal waters and native grasslands. Forests are one of the most significant forms of carbon sequestration with grasslands sequestering levels almost as high as forests. Marine ecosystems such as seagrasses also are important carbon sinks.
Protecting natural lands can be used as a mitigation measure as it is an effective means of carbon sequestration – Canada currently has many options to preserve these important opportunities. For example, management of one million hectares of federal pastures under the Community Pasture Program are being transferred to the governments of Saskatchewan and Manitoba. These largely native grasslands – which are a huge carbon sink – were successfully managed under this federal program for eighty years. The pastures in Saskatchewan will no longer be protected due to the provincial government decision to put the lands for sale once they come under provincial control. If these lands are managed only for cattle production and oil and gas development, the carbon that has been stored in these grasslands and wetlands for decades will be at risk of being released into the atmosphere, contributing to a large net increase to Canada’s greenhouse gas emissions.
Environmental groups and the local ranchers of Saskatchewan have come together and proposed the governments continue the community stewardship of the pastures along with other industry and nature conservation groups. Preserving the natural lands including those adjacent to working lands, also provides incredible opportunities to build resilience against climate change impacts such as drought and increasing temperatures. This objective is one stated in the Minister’s 2016 mandate letter.
Indigenous communities hold valuable knowledge of their lands and conserve it accordingly. Tapping into this knowledge and working with the communities to protect the lands would carry out the dual objectives of conserving a large and well-maintained carbon sink as well as continue to deliver important social and economic, as well as environmental benefits.
Mitigation measures should also take advantage of opportunities to sequester carbon in urban nature settings. Small pockets of greenery in an urban setting can still hold a significant amount of carbon while also providing additional benefits especially if they are allowed to expand, such as buffering floods, cleaning air, and supporting biodiversity.
Natural carbon stores can contain large amounts of carbon, and this should also be emphasized and accounted for when these stores are degraded or removed completely. Considering the net carbon store between the mitigation efforts and the release of carbon from the degradation, is an important factor in accounting for GHG emissions.
RECOMMENDATION 2 – Assess proposed projects with high GHG emissions under the Canadian Environmental Assessment Act, 2012 or as part of a strategic environmental assessment under the Cabinet Directive on Strategic Environmental Assessment.
The aim to reduce greenhouse gas emissions during project development and subsequent activities should be clearly outlined in appropriate legislation and assessed prior to implementation. Assessments and development planning should require assessing carbon emissions with consideration to emissions from nature degradation, and mitigation measures for carbon sequestration.
National interest and Canada’s international commitments demand that the federal government apply CEAA 2012 to proposed high-carbon and fossil fuel infrastructure projects that would emit large quantities of greenhouse gases or that build new fossil fuel infrastructure. At a minimum, carbon emissions information from such projects should be provided in CEAA 2012 project statements so that environmental assessments can focus on reducing such emissions before projects are built. Some examples of projects not currently subject to CEAA 2012 are the:
· Construction or expansion of a facility that is expected to release more than 100,000 tonnes of greenhouse gas emissions per year,
· Construction or expansion of a steam-assisted gravity drainage oil sands project,
· Construction or expansion of a hydraulic fracturing (fracking) oil or gas development project,
· Exploratory offshore oil and gas seismic activities, and
· Construction or expansion of a railway terminal or railway line for the purpose of carriage of fossil fuels, proposed initiation of loading or unloading of fossil fuels at a railway terminal, or proposed initiation of carriage of fossil fuels on a railway line.
RECOMMENDATION 3 – Phase-out production subsidies to the fossil fuel industry and instead subsidize economic activities that are carbon-neutral.
Many alternative fuel sources and new carbon-neutral technologies or initiatives are still undergoing research and development, or have a high cost because these technologies or initiatives are not mature. Some still require establishment of stringent regulations. Providing greater assistance to these activities through government subsidies would greatly support development of a carbon-neutral economy.
Most of the current Canadian subsidies benefit conventional oil, oil sands, conventional gas and natural gas production providing tax breaks to exploration activities, field development, and extraction. The Minister of Finance and the Minister of Environment and Climate Change were both mandated to work together “to fulfill the G20 commitment to phasing-out fossil fuel subsidies to over the medium-term”, as outlined in their Mandate Letters.
The Government of Canada, along with 39 other countries and major corporations, has endorsed the Fossil Fuel Subsidy Reform Communiqué submitted at the Conference of the Parties to the United Nations Framework Convention on Climate Change in Paris in November 2015. Supporters of this Communiqué have recognized that the elimination of fossil-fuel subsidies would make a significant contribution to reducing global greenhouse gas emissions and that accelerating the reform of fossil-fuel subsidies is therefore an urgent priority.
Initial progress towards fossil fuel subsidy reform was made in Budget 2016, but earlier federal budgets have increased fossil fuel subsidies such as the introduction of a new Accelerated Capital Cost Allowance for investments in the liquefied natural gas sector. Other countries, such as Germany, have phased out all subsidies to the hard coal industry, and both France and the U.S. have committed to phasing out public financing to the coal sector. Canada should take a leadership role in fossil fuel subsidy reform.