2.0 Main Considerations for the 2009 Response

In approaching this year's KPIA Response, the NRTEE has identified three main considerations informing our analysis and assessment: (1) issues related to the implementation of the Regulatory Framework, (2) the soon-to-be released GHG inventory from Environment Canada, and (3) continued concerns of the NRTEE in evaluating the government's progress in reducing emissions within a short time period given the long-term nature of the challenge in reducing GHG emissions. Each of these suggests caution in any final determination of actual emission reductions versus forecast emission reductions, and should be the context in evaluating annual forecasts such as these and in drawing any absolute conclusions.

1. The Regulatory Framework

The government stated in the 2009 Plan its intention to revise the Regulatory Framework, which is the single-largest contributor to emission reductions in the Plan. It said: "Earlier this year the Government indicated that it was refining this approach to reflect the new realities of the global economic downturn and the opportunities represented by a new Administration in the United States. The Government has committed to releasing detailed plans by year's end.... Given the KPIA deadlines for reporting, the 2009 Plan cannot reflect the new regulatory approach. Therefore, to comply with the Act, this Plan includes the expected emissions reductions for the industrial regulations as described in Turning the Corner, though the final regulatory regime will differ from Turning the Corner."[7] This statement suggests 2009 is a transition year for federal climate policy and that the emission profile for Canada may be different going forward.

2. The GHG Inventory

Later this year, Canadians will see the actual emissions inventory for greenhouse gases for Canada including 2008. This will be the first inventory released during the KPIA period — the period during which the government has forecasted emissions reductions from the measures and policies in the 2007 to 2009 Plans. Canada's GHG Inventory numbers for 2008 by Environment Canada will provide a retrospective measurement of the actual emissions produced by Canada. Only then can KPIA forecasts be compared to actual physical emissions and a more accurate assessment of the government's programs and measures in reducing emissions be determined beyond this particular Response.

3. Continued Concern with the Narrow Time frames of the KPIA Period

In its 2007, 2008, and current Response, the NRTEE reiterates its concern with the short time frames of the KPIA period as a useful tool for judging progress and evaluating effectiveness. This limits the ability of the NRTEE to draw absolute conclusions about emission reductions associated with government policies and measures. While annual assessments can tell us something about emission reduction pathways, the focus should be on creating a comprehensive policy approach and establishing a corresponding evaluation and assessment framework for measuring progress and making the necessary adjustments toward longer-term emission reduction objectives. The 2009 Plan acknowledges this point, suggesting, "The Government of Canada strongly agrees with the NRTEE's assessment.... That is why Canadian action on climate change is focused on the future; on meeting the goal of a 20% reduction in greenhouse gas emissions from the 2006 level by 2020, and a 60% to 70% reduction from the 2006 level by 2050." [8]

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7 2009 Plan, p. 8

8 2009 Plan, p. 3.