1.0 Introduction

On June 22, 2007, the Kyoto Protocol Implementation Act (henceforth KPIA or C-288), received Royal Assent.

The KPIA stipulates that the Government of Canada is obliged to prepare — on an annual basis — a Climate Change Plan describing measures and policies enacted by the government to "ensure that Canada meets its obligations under Article 3, paragraph 1, of the Kyoto Protocol" [Subsection 5(1)]. The government's third Climate Change Plan was released on June 2, 2009.

Subsection 10(1) of the Act requires the National Round Table on the Environment and the Economy (NRTEE or Round Table) to, within 60 days of the publication of the Climate Change Plan stipulated in Subsection 5(1), perform the following with respect to the Plan:

a) undertake research and gather information and analyses on the Plan or statement in the context of sustainable development; and

b) advise the Minister on issues that are within its purpose, as set out in section 4 of the National Round Table on the Environment and the Economy Act, including the following, to the extent that they are within that purpose:

i) the likelihood that each of the proposed measures or regulations will achieve the emission reductions projected in the Plan or statement;

ii) the likelihood that the proposed measures or regulations will enable Canada to meet its obligations under Article 3, paragraph 1, of the Kyoto Protocol, and

iii) any other matters that the Round Table considers relevant.

This report represents the third response of the National Round Table on the Environment and the Economy to the requirements created by the Kyoto Protocol Implementation Act with respect to the government's third Climate Change Plan. In carrying out its statutory obligations, the NRTEE has undertaken and gathered information. This activity has focused on addressing Subsections 10(1)(b)(i) and 10(1)(b)(ii). As allowed for under Subsection 10(1)(b)(iii), the NRTEE has also reviewed and commented upon broader aspects of the KPIA as it relates to the government's Plan.

In accordance with the stipulations of the Act, the report has been provided to the Minister of the Environment. This fulfills the NRTEE's current obligations under the KPIA.

The government's 2009 KPIA Plan, A Climate Change Plan for the Purposes of the Kyoto Protocol Implementation Act — May 2009 (henceforth referred to as the 2009 Plan),[1] details expected emissions reductions resulting from specific measures to address climate change, as well as an integrated modelling analysis[2] that presents the reductions expected to accrue from the full suite of policies[3] relative to a business as usual emissions pathway.[4] The stated emissions reductions for individual policies outlined in the 2009 Plan are derived from initiative-level evaluations performed by Environment Canada, Natural Resources Canada (NRCan), and Transport Canada, while the aggregate figures are compiled by Environment Canada.

The analysis in this Response examines whether the stated emissions reductions attributed to the suite of policies as a whole and to individual policies accurately reflect the incremental emissions reductions we should expect to see as a result of their implementation.[5] By extension, it also assesses the degree to which the emissions projections reflect the best expectations of what will be seen in GHG emissions inventories for the years 2008–2012.

The 2009 Plan notes the NRTEE's contribution from previous Responses toward a "continuous cycle of improvement"[6] and the government's commitment to this cycle. The NRTEE wishes to acknowledge at the outset that the government continues to make improvements to its forecasting, particularly in providing additional information and context, rendering it more transparent and accountable. These improvements include providing an estimate range — "high" and "low" — for some measures that can offer a more realistic possibility of outcomes, and an alternative scenario involving different macroeconomic assumptions and considerations. These are positive, useful additions that we support. We hope that the 2009 Response by the NRTEE can further assist the government in its ongoing efforts to improve GHG forecasting and policy evaluation.

This Response is organized as follows: Section 2 lays out three key considerations that inform and provide important context for the 2009 KPIA Response. Section 3 describes the methodological approach taken by the NRTEE. Section 4 provides an overview of the 2009 Plan itself. Section 5 highlights the key issues that emerged from our analysis and assessment. Section 6 evaluates the Plan in the context of Canada's Kyoto Protocol obligations. Finally, Section 7 draws conclusions and provides recommendations. Detailed analysis of individual policies and programs is provided in Appendix A.

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1 Canada, 2009a. See http://www.ec.gc.ca/cc/E653A4ED-120F-4185-9494-9B2946CC73F3/KPIA_2009.pdf

2 In the 2008 Plan, the government introduced its integrated modelling framework for the purposes of the KPIA. The modelling is undertaken using Environment Canada's Energy-Economy-Environment Model for Canada, or E3MC, and models the impacts of all of the policies together.

3 Denoted in the Plan as "projected emissions including government measures."

4 Denoted in the Plan as "projected emissions excluding government measures."

5 Incremental emissions reductions are those which occur over and above what could reasonably have been expected to occur absent the policies or actions.

6 2009 Plan, p. vi.