Environment Canada Ignores Science Input on Greenhouse Gas Regulations: Government public consultations on climate pointless

Commentary, Climate, Tom Harris

Many Canadians must be wondering if there is any point giving input to federal government public consultations on climate change.

A form letter initially sent to citizens who gave comment on proposed regulations to restrict carbon dioxide (CO2) emissions from coal-fired electricity generating stations stated: “Your views, along with those of other parties, are being taken into account in the development of final Regulations to be published in the Canada Gazette, Part II“.

It made no difference that many of the commenters had pointed out that the most recent science does not support the need for CO2 restrictions. “Final Regulations” are on the way. Get used to it, was the implied government response.

Their answer softened a bit after complaints. “Your views, along with those of other parties, are being taken into account as we move forward,” was the new reply, giving hope that the input of Canadians about the real impacts of the regulations on climate and air quality might actually be taken seriously.

That hope was dashed last week when Environment Canada announced that, although they are “reviewing” public comments before proceeding, they are still committed to following through on the regulations.

While carefully reiterating the implausible hypothesis that reducing our CO2 output will significantly benefit climate, Environment Minister Peter Kent implies that the regulations are largely about pollution reduction and clean air. Kent stated that the proposed rules “will—literally—let all Canadians breathe easier. Our Government understands Canadians' concerns around the quality of the air we breathe.”

This is a mistake. It was explained to the government in public comment that the multi-billion dollar regulations will have no measureable impact on global warming, and will do essentially nothing for pollution abatement.

The government’s own analysis, as laid out in the proposed regulations, show that there will be negligible, in fact immeasurable, “air quality improvements experienced by typical residents” of Canada by 2030. Specifically, fine particulate matter pollution is forecast to drop by 0.21% and ground level ozone by 0.09% for the country as a whole.

So, why bring up clean air benefits at all?

“The government does not seem to feel that they can sell this as a greenhouse gas policy because it just would not have much traction with people”, said University of Guelph Professor of Economics Ross McKitrick. “They seem to feel that they have to say it is also a clean air and anti-smog regulation.”

The forecast pollution reduction, according to government modelling, yields health benefits from reduced smog exposure of $1.4 billion. This is highly speculative and ignores the fact that, below certain levels, pollution often has no impact on health whatsoever. Regardless, practically all of the regulations’ $1.5 billion net present value—the gap between the benefits and the cost—is accounted for by these alleged health benefits.

The largest supposed benefit of the new rules is “the avoided social cost of carbon” (SCC). Rated at a value of $4.3 billion, the government asserts that those costs will be avoided by reducing Canada’s CO2 emissions by the amount prescribed under the regulations. But Canada’s CO2 emissions have essentially no impact on climate. So SCC is really zero. Therefore the new rules are pointless and every dollar spent on the regulations is a net cost to taxpayers.

McKitrick does not believe that the government’s demonstrations of net benefits of the regulations are meaningful anyways. “It looks like the way Enron used to report profits,” said McKitrick. “They always had just barely a positive number and it turns out there is always some weird assumption necessary to get to a small positive number.”

The reason regulations can be created to control CO2 is that the Conservative government have not rescinded the decision made in the last days of the Paul Martin government to add CO2 to the “List of Toxic Substances” in Schedule 1 of the Canadian Environmental Protection Act (CEPA). Of course CO2 has no place on a list that includes PCBs, mercury, asbestos, lead and sulphur dioxide. It is plant food, an essential reactant in photosynthesis on which all life depends.

Yet even more CEPA-based CO2 rules are coming.  According to Environment Canada briefing notes released last week, draft CO2 regulations on the oil and gas sector are next. These restrictions “will be informed by technology, sector-specific reduction opportunities and competitiveness considerations," said the notes. Science and informed public comment is apparently immaterial.

The costs of Environment Canada public consultations can now be added to the billions of dollars already being wasted on the climate scare.