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Environment Canada's Kinder Morgan Review Comes Up Short

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KINDER MORGAN
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Canada has been at the forefront of the climate change conversation more than once during the past several months: In Paris, the newly elected federal government took a strong stance on the global warming limit, and more recently it joined the G7 nations in their pledge to end fossil fuel subsidies by 2025.

But the international stage is not the only place the federal government has been making moves.

In January, instead of pausing and fixing processes like the ongoing Kinder Morgan pipeline review and the not-yet-started Energy East pipeline review, the government announced interim environmental assessment measures for major natural resource projects currently under review.

At first glance, the measures were expected to be a "climate test" for pipelines that would feed into environmental assessments and provide the necessary information to help cabinet make sound decisions on climate change-inducing infrastructure -- information that the National Energy Board (NEB) won't consider in the review process for pipelines. But that's the not the way the measures have turned out.

We now know that Environment Canada has been tasked with reporting to cabinet on projects' carbon pollution, but its methodology for greenhouse gas (GHG) reviews is still in draft form following a public comment period. Not to mention that the government has yet to explain how cabinet will take the GHG review, which is happening separately from the now completed NEB review, into account in its final decision.

Despite more than a few lingering questions, on May 19 Environment Canada published its second draft review under the interim measures, using its draft methodology, when it released its upstream GHG emissions estimates for Kinder Morgan's Trans Mountain pipeline project.

All told, the review fails to match up to Trudeau's promises for bold action on climate change. Instead, the draft review relies on assumptions that minimize Canada's contribution to global emissions and encourages it to avoid accountability for emissions related to oil and gas projects. It reads more like a shrug of the shoulders approach to us.

That's why we are taking a stand and voicing our concerns.

Coming up short

Outlined below are four major failings with Environment Canada's draft review of Kinder Morgan's upstream GHG emissions:

  1. Excludes downstream emissions

Nowhere in the NEB's review process or in the interim measures are downstream emissions counted (emissions from what's done with the oil after it's transported by the pipeline and tankers). And that's a major problem.

We know that the majority of carbon pollution comes from end-use consumption, and yet downstream emissions are not being factored into the equation. While the inclusion of upstream emissions (emissions from extraction, processing and refining) in the measures is a welcome start, they tell less than half of the story.

If Environment Canada wants to have a complete understanding of the real climate impacts of a project, both upstream and downstream emissions need to be considered. You can't accurately evaluate climate impacts of a project without considering the potential effects it could have from wells to wheels.

  1. Ignores the 1.5 degree limit in favour of 2 degrees

In Paris, Canada actively advocated for the world to hold global warming to the more aggressive benchmark of 1.5 degrees Celsius, and yet the draft review only discusses whether Canada's tar sands expansion is compatible with the bare minimum requirement of two degrees.

This disconnect is inconsistent and unacceptable. If the federal government truly wants to back up the aggressive stance it took on the international stage in Paris, it must apply the 1.5 degrees standard in its decisions on major projects. End of story.

  1. Ignores Canada's international commitments

While the draft review does acknowledge Canada's international pledge to reduce emissions 30 per cent below 2005 levels by 2030 (generally considered the bare minimum required), it fails to consider if the project under consideration is actually compatible with that commitment. It instead looks at the 2 degree global limit and uses hypothetical action by other countries to determine if the project under consideration is compatible with that global target. If Canada is serious about living up to its climate goals, it can't merely factor in the assumed actions of other nations; it must consider whether the project will work with Canada's own commitments.

  1. Assumes that for any oil not produced in Canada the same amount will be produced in another country

The draft review states that if tar sands production doesn't occur in Canada, equivalent production will occur elsewhere instead, and global oil production and consumption will not change. This means that Environment Canada will not consider the emissions from additional tar sands production itself, and instead will focus on the difference in emissions intensity of oil production in Canada compared to other hypothetical jurisdictions if Canada were not to produce it here.

In our opinion, this is a failure to take responsibility for Canadian upstream emissions. Canada has national commitments that it must take into account and upstream emissions that occur in Canada should be counted towards those national emissions targets.

Time for leadership

Climate leadership is more than being a persuasive talker and knowing what to say. It's about taking real steps to reduce carbon pollution. When Prime Minister Justin Trudeau stepped into office, he -- along with his ministers -- made bold promises to take action on climate change. We have yet to see any meaningful action. We've heard prime minister Trudeau talk the talk, and now it's time he walk the walk. The Kinder Morgan GHG review is not a promising start.

Currently, the draft GHG reviews on the table are not setting Canada up to meet its international commitments or national emissions target. They fail to account for major climate impacts that will affect Canada's carbon emissions. They also fail to address whether projects are compatible with Canada's national strategy for energy and emissions reductions -- because there still isn't one.

If the government wants to make the GHG reviews a useful evaluator in determining the climate impacts of a project, then it needs to come up with a national strategy. Environment Canada needs to take a good long look at the methodology it's currently using. If the GHG reviews continue to look like this draft review for Kinder Morgan, they are simply a new way to package the status quo, and have little hope of actually improving environmental assessments.

Let's hope this isn't the case, but only time will tell.

This piece was written by Ecojustice lawyer Dyna Tuytel. As Canada's only national environmental law charity, Ecojustice is building the case for a better earth. Learn more at ecojustice.ca.

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