Ontario's Ministry of the Environment and Climate Change (MOECC) continues to roll out its Climate Change Action Plan with its proposed greenhouse gas (GHG) guide for projects that are subject to the province's Environmental Assessment Act. The draft guidance document, "Consideration of Climate Change in Environmental Assessment in Ontario", strives to incorporate climate change mitigation and adaptation considerations into the environmental assessment (EA) planning process.
The draft guide encourages proponents to estimate a proposed project's GHG emissions, assess its potential impacts on carbon sinks, and consider alternatives to minimize those impacts. Proponents are also encouraged to assess the effects of a changing climate on the proposed project. These climate change considerations are intended to improve the adaptability and resiliency of a project undergoing an EA, while maintaining the ecological integrity of the local environment.
On September 12, 2016, the draft guide was posted to the Environmental Registry (EBR Registry #012-5806) for a 45-day public review and comment period.
Application of the Guide
Proponents will be encouraged to consult the Guide, once approved, to prepare terms of reference for an EA or complete an EA study. Proponents of streamlined projects under class EAs are also encouraged to consult the Guide if the approved class EA has no climate consideration method or if that method "does not meet Ministry expectations". MOECC will be encouraging proponents to determine early on in the EA process whether there are likely to be relevant climate change considerations to address.
Assessing a project's effect on climate change
To support the EA process, the Guide references case studies, approaches, and methods for incorporating climate change considerations into project planning. This information will be updated and amended to reflect future policy developments and new methodologies. Since the Guide is not prescriptive, a proponent is not limited in its choice of methodology, approach, or modelling information for an EA.
The table below summarizes the approaches proposed in the Guide for assessing a project's effect on climate change.
Assessing a Project's Effect on Climate Change | |
Questions to consider | Suggested approaches for proponent |
How might a project generate GHG emissions or affect carbon storage or the removal of carbon dioxide from the atmosphere? |
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To what extent have the project's effects on the atmosphere been taken into account in project planning? |
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Are there alternative methods to implement the project that would better take into account any adverse contributions to a changing climate? |
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How might a project give rise to climate effects, positive or negative, on Aboriginal people and/or communities? |
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The table below summarizes the approaches proposed in the Guide for assessing the effect of climate change on a project.
Assessing the Effects of Climate Change on a Project | |
Questions to consider | Suggested approaches for proponent |
How potentially vulnerable is the project to a changing climate? |
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Does the project contribute to the vulnerability or resilience of surrounding ecosystems to climate change? |
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Are there potential effects that climate change may exert on the project that may pose a risk to the environment? |
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Are there alternative methods of carrying out the project that could lessen the negative effects of climate change on the project, thereby reducing the risk to the local environment? |
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Could the project result in disruption to lands or waters associated with Aboriginal cultural resources? |
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Next steps
The Guide will be available for public review and comment on the Environmental Registry until October 27, 2016.
It remains to be seen if the MOECC will introduce similar guidance documents to consider climate change implications in the Environmental Compliance Approvals process.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.