Appendix A: Analysis and Assessment of Individual Measures

The derivation of policy-by-policy emissions reductions

The Government's 2009 Plan provides a breakdown of the expected emissions reductions associated with each individual measure or program aimed at or expected to have a role in reducing GHG emissions. The NRTEE's mandate includes the examination of these measure-level estimates to identify potential sources of estimation error in order to determine the likelihood of achieving the stated emission reductions. In general, emissions reduction estimates continue to be subject to the same critiques as have been brought forward in previous NRTEE Responses; however, the methodology behind some estimates has improved over time.

Three main factors contribute to the overestimation of emissions reductions for individual policies. First, many of the evaluations are subject to concerns about additionality as estimates report more than just the incremental emissions reductions due to the measures. In these cases, actions that would have occurred absent the programs are treated as part of the programs' effects. Second, evaluations of many of the policies do not incorporate empirically established issues that would erode the estimated emissions reductions, in particular the rebound effect. Third, the individual programs are evaluated without considering possible interaction effects.

It is important to recognize a distinction between program design and program evaluation. Evaluation is important to assessing the extent to which good policy design minimizes the impacts of these effects and reporting this outcome accurately. The NRTEE's mandate is not to evaluate whether or not programs have been designed effectively. It should be made clear that the evaluations below look only at the estimation of emissions reductions attributable to each program. For example, with respect to the ecoENERGY for Renewable Power program, information obtained from NRCan for the purposes of this evaluation suggests that substantial steps have been taken to minimize free-ridership. This is important from a design point of view to maximize the cost-effectiveness of the program. However, in evaluating the renewable power program, some free-ridership likely remains that should still be discounted from the emissions reductions. These issues are also relevant for other programs; several program-level evaluations assume that free-ridership and rebound effects have no impact at all; minimizing impact through design is not the same as assuming that the impacts have been eliminated altogether. As Table 2 shows, the same concerns have been addressed in the two previous NRTEE responses with respect to evaluation rather than design, and in many cases are addressed again here, but also shows where improvements have been made by the government.

Table 2: Comparison of Additionality Concerns and Accounting for Rebound Effects in Program Evaluation

	Additionality identified as an evaluation concern (includes free-ridership)			Rebound Effects identified as an evaluation concern
	2007	2008	2009	2007	2008	2009
Regulatory Framework
Energy Efficiency Regulations
Regulating Renewable Fuels Content
ecoENERGY for Renewable Power
ecoENERGY for Buildings and Houses
ecoENERGY Retrofit Initiative
ecoMOBILITY Initiative	N/A			N/A
ecoENERGY for Fleets	N/A			N/A
ecoFREIGHT Program
Clean Air and Climate Change Trust Fund

Legend:

	indicates concern exists
—	indicates no concern exists
N/A	indicates not applicable

Table 3 provides a summary of the projected emissions in the 2009 Plan from programs and policies evaluated in this Appendix. It shows the stated emissions reductions associated with specific programs and actions for each year in the Kyoto period, and programs whose emissions reductions are 1 Mt or greater.[27] Each of these measures is assessed individually in the remaining sections of this Appendix.

Table 3: Reported GHG Emissions Reductions by Policy (Mt)

<< Previous page | TOC | Next page >>
_______________________________

27 As in the 2008 KPIA response, individual program evaluations with estimated reductions less than 1 Mt are not evaluated given that these small estimated reductions are below the level of precision for this evaluation.