Impact Assessment and Project Appraisal

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Climate-change mitigation in Canadian

environmental impact assessments

Takafumi Ohsawa & Peter Duinker

To cite this article: Takafumi Ohsawa & Peter Duinker (2014) Climate-change mitigation in
Canadian environmental impact assessments, Impact Assessment and Project Appraisal, 32:3,
222-233, DOI: 10.1080/14615517.2014.913761

To link to this article: https://doi.org/10.1080/14615517.2014.913761

Published online: 06 May 2014.

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Impact Assessment and Project Appraisal, 2014
Vol. 32, No. 3, 222–233, http://dx.doi.org/10.1080/14615517.2014.913761

Climate-change mitigation in Canadian environmental impact assessments

Takafumi Ohsawa* and Peter Duinker
School for Resource and Environmental Studies, Dalhousie University, 6100 University Avenue, Suite 5010, Halifax, NS,
Canada B3H 4R2
(Received 22 January 2014; accepted 7 April 2014)

Environmental impact assessments (EIAs) are still developing approaches to address the issue of climate change. The aim of
the study is to examine how recent EIAs in Canada have approached the issue of greenhouse gas (GHG) emissions when
evaluating each individual project’s contribution to and impact significance on climate change. Twelve EIAs performed
under national legislation in Canada were analyzed. Canada developed approaches to GHG emissions more than a decade
ago, and it is now common to assess the emissions and propose some mitigation in EIAs. Large emitters have proposed some
substantial measures, typically the latest technologies, to reduce emissions. However, other proposed ideas may still be
ambiguous and hard to examine in terms of real effects. Furthermore, there were many ambiguous and/or inconsistent
definitions of GHG emission levels as well as significance of GHG emission impacts. The expressions of GHG emission
amounts using percent are potentially misleading. In response to these situations, we suggest the use of clear and reasonable
evaluations and definitions of GHG emissions as well as their significance.
Keywords: climate change; GHG emissions; mitigation; EIAs; significance; Canada

Introduction climate, and it is challenging to incorporate such impacts

Climate change is one of the most serious environmental
issues globally, possibly causing drastic changes to
everyone’s lives. The latest report by the Intergovern-
mental Panel on Climate Change (IPCC 2013) documen-
ted that the mean temperature of the Earth’s surface
increased by 0.898C between 1901 and 2012. Furthermore,
the temperature would increase by 1.0 – 3.78C in the period
2081 –2100 in comparison with 1986– 2005 (IPCC 2013).
Considering its serious impact, many researchers have
called for early actions against this issue (e.g. Stern 2006).
The main reason for climate change is greenhouse gas
(GHG) emissions caused by various human activities, such
as burning fossil fuels and deforestation (Karl & Trenberth
2003). In this regard, regulating and improving human
activities and lifestyles are important to tackle this issue.
At an international level, the Kyoto Protocol was
adopted in 1997, urging developed countries (listed in its
Annex I) especially to implement measures to reduce
GHG emissions (UNFCCC 1997). Since the Kyoto
Protocol came into force in 2005, the Annex I countries
have struggled to meet their commitments. Generally,
implementable measures can be classified into two types:
mitigation and adaptation. Mitigation refers to reducing
the causative factors of climate change, whereas
adaptation refers to changing our societies and their
ecosystems to be able to adapt to climatically altered
environments (Pielke 1998).
Environmental impact assessments (EIAs) are
designed to evaluate various influences of certain projects
on the environment so that these projects, ideally, will
have negligible effects on the environment (Rosenberg
et al. 1981). Environmental impacts of projects due to
GHG emissions are only realized at the level of global
into EIAs (Benidickson 2013).
Recently, guidelines and best practices for how EIAs
should consider climate change have been produced.
For instance, Byer et al. (2012) recommended that each
EIA assess not only the potential impacts of each project
on climate change but also vulnerability of the project to
a changing climate. These two ideas correspond
to mitigation and adaptation respectively.
Linking the GHG emissions from an individual project
to their impact on climate change is difficult (committee
on climate change and environmental assessment in
Canada 2003; hereafter CCCEAC) (Figure 1(a)) because
of the tremendous uncertainties associated with climate
change as well as a huge gap in scale between the global
climate and each project (Slotterback 2011). In this sense,
each individual project’s contribution to climate change is
insignificant and essentially impossible to estimate.
For example, it is not possible to predict quantitatively
how much the global temperature would increase due to
GHG emissions from a project. It is therefore challenging
to motivate people and organizations to mitigate the
contribution to GHG emissions at the project level, and
there may be differing views on the degree to which and
how GHG emissions should be assessed and controlled in
each project. Reviewing previous EIAs could help
understand these views and may identify reasonable and
practical approaches to GHG emissions at the project
level. Several previous studies investigated this issue of
mitigation with environmental policies or sustainability
appraisals at regional scales (Posas 2011a, 2011b;
Slotterback 2011; Wende et al. 2012). As well, Sok et al.
(2011) and Watkins and During (2012) investigated this
issue at project scales, but their approaches were unique

*Corresponding author. Email: aa56258@hotmail.co.jp

q 2014 IAIA
 Impact Assessment and Project Appraisal 223

Figure 1. Relationships between climate change or goals to stabilize the climate versus mitigation of GHG emission in each project.
Each arrow is a relationship between an assumption and an induced conclusion, and arrows in light colours with dotted lines are those
which may not yet be realized. (a) A pattern of evaluating a project impact on the climate, which cannot be technically addressed. (b) –(d)
Patterns of incorporating climate-stabilization goals into each project.

(e.g. focusing on terminology use in EISs or questionnaire
survey).
The main aim of this study was to identify how recent
EIAs at the project level have approached the issue of
GHG emissions. In the study, EIAs undertaken in response
to national EIA regulations in Canada were examined.
This is because Canada has much experience with EIAs
(Robinson 1992) and has incorporated both GHG
mitigation and adaptation into EIAs earlier than other
countries (Agrawala et al. 2010). Some guidelines relevant
to the issue of GHG emissions are also available in Canada
(CCCEAC 2003, Nova Scotia Environment 2010). Such
guidelines are important for controlling impacts of GHG
emissions on climate change (Sok et al. 2011). In the
following sections, we first introduce the Canadian EIA
system. Subsequently, case studies of mitigation of GHG
emissions are analyzed. Finally, possible solutions and
suggestions to address detected problems are discussed.
Particularly, as mentioned later, the current evaluation of
impact significance and possible improvements to it are
pursued. This is because the process of determining impact
significance has still not been fully studied and agreed
among stakeholders, despite the fact that it is the most
central concept in EIAs, a threshold being influential on
final decisions of these assessments (Lyhne & Kørnøv
2013; Murphy & Gillam 2013).
Current national EIA system in Canada
The Canadian federal government began its EIA program
under the ‘environmental assessment and review process’
in 1973 (Robinson 1992; Doelle 2008). In 1995, the
Canadian Environmental Assessment Act was proclaimed,
and the Canadian environmental assessment agency
(CEAA) was established to deal with its administration.
The act requires proponents to prepare EIAs that describe
the necessity of, alternatives to, and environmental
impacts of each proposed project, and also to implement
public involvement. The Canadian Environmental Assess-
ment Act, which was amended in 2012 (Benidickson 2013;
CEAA 2013a), applies to the construction of various
facilities (e.g. power stations, dams, mines and highways)
(CEAA 2013b). For instance, construction of any power
stations burning fossil fuels with a production capacity of
200 MW or more in Canada would be assessed under the
Act (CEAA 2013b). According to this amended Act, EIA
analysis results from proponents are evaluated through
either a report by a federal authority or a panel review
(Benidickson 2013). Furthermore, the Act urges the
responsible authority for each project to consult other
relevant authorities (Benidickson 2013). Consequently,
opinions of relevant provincial governments are also
considered, if necessary.
Guidance to proponents on how to address GHG
emissions in federal EIAs in Canada is provided by the
CCCEAC (2003) which recommends that assessors
conduct the following steps: (i) scoping, (ii) identifying
GHG emissions, (iii) assessing identified GHG emissions,
(iv) identifying mitigation measures and (v) follow-up
including monitoring. Specifically, the third step requires
comparisons between estimated GHG emissions and total
GHG emissions in an industry/province/country. If the
224 T. Ohsawa and P. Duinker
estimated GHG emissions are judged as ‘medium or high
emissions’ (CCCEAC 2003, p. 9), then the EIA should
move to the fourth step referring to jurisdictional policies
and/or controls. The CCCEAC (2003) introduced some
examples of mitigation, such as emission credit trading,
best practices of industries and making GHG management
plans.
Analyses of the approach to GHG emissions in
Canadian EIAs
Materials and methods
We collected the latest cases of EIAs prepared under national
regulations in Canada to determine how they have
approached GHG emissions. With each EIA, basic
information was extracted, such as project name, project
type, proposed location and proposed date. Second, EIA
coverage of GHG emissions was surveyed, including
assessment methods, main sources of GHG emissions,
estimated quantities of GHG emissions, comparisons of the
values with national and/or regional inventories and
proposed mitigation. Finally, responses by agencies and
final decisions by the Minister of Environment were
examined as well. Here, responses by agencies consisted of
opinions on whether they agree or disagree with proponents’
ideas and suggestions or requests about mitigation.
More specifically, we targeted all the EIA projects
which were listed as ‘EA completed’ on CEAA’s website
(2013c) as of November 2013. Incomplete EIAs which
were still under way were not used here. According to the
CEAA (2013c), these EIAs are principally those subjected
to the new law (The CEAA 2012). However, this list also
included a few EIAs that started under the former act and
continued under the transition provisions of the amended
act (CEAA 2013c). Thus, we examined EIAs which were
assessed mostly after 2012, although a few earlier EIAs
were also investigated. Yet, the amendment in 2012 did
not change essential approaches to GHG emissions, and
therefore we treated any cases before/after 2012 equally in
the following analysis. Documents of environmental
impact statement (EIS) and/or agency’s response (e.g.
comprehensive study report) were available for most EIAs
but not all. The EIAs whose documents were unavailable
in CEAA (2013c) at all were precluded from the data-set.
Exceptionally, only one case (New Bridge for the
St. Lawrence) was a screening assessment performed by
Transport Canada, which was its proponent and the
responsible authority, under the former CEAA. Thus, this
case used different terminologies and methodologies of
EIA process from those of other cases. Herein, we
regarded its assessment reports as its EIS, and an agency’s
response was extracted from its screening report.
As a consequence, while 17 Canadian cases were
found, EISs or other documents of 12 cases were available
for the study. A case-study number was then assigned to
each project (e.g. C1) in Tables 1 and 2, and this number
would be used to refer to certain projects in the following
text. In the following subsections, the analysis results of
EISs, the national agency responses, and the other
stakeholder responses are given in order.
Use of the guideline of CCCEAC (2003)
Nine of the 12 reviewed projects in Canada approached
GHG emissions with a quantitative assessment for both
construction and operation phases (Table 1). This result
suggests that assessing GHG emissions has become
common in Canadian EIA probably thanks to CCCEAC
(2003). In support of this, each EIS cited CCCEAC (2003)
in four (C1 –C3 and C9) out of seven cases whose EISs
could be available to read (C1 – C3, C5, C8, C9 and C11).
Such EISs briefly introduced the basic policy of CCCEAC
(2003) and then documented the actual GHG emission
assessment.
Definition of GHG emission levels
However, CCCEAC (2003) used the three terms ‘small’,
‘medium’ and ‘large’ emissions, without any numerical
definitions (Murphy & Gillam 2013). Consequently, these
words were defined differently among the reviewed EISs,
possibly confusing assessors. For instance, a technical data
report written by the proponent of C1 stated that there is no
available strict definition of low-, medium- and high-
intensity emitters. Likewise, the EISs of C3 and C9, which
cited CCCEAC (2003), could not give any clear definitions
of different levels of emissions, concluding subjectively
that their projects’ GHG emissions would be ‘not large’
and ‘very small’ respectively. Exceptionally, the three
levels described by CCCEAC (2003) were defined in the
EIS of C2 by numerical values (on a tonnes of CO2e per
annum basis) of less than 105, greater than 105 and less
than 106 and greater than 106. Furthermore, EISs which
did not quote CCCEAC (2003) used other adjectives to
show the intensity of GHG emissions (e.g. ‘negligible’ in
C5) or defined three levels (e.g. low, moderate and high
emissions in C11) differently from the case of C2.
How to show GHG emission amounts?
Overall, most cases compared estimated GHG emissions
with those of Canada or their host provinces, concluding
that these projects would emit only a fraction of the
Canadian and provincial emissions (e.g. , 1%; Table 1).
Such a statement may be true, but they do not necessarily
mean that the emissions are not environmentally
influential. Also, the small fraction may be just due to
comparisons with too large amounts of emission
inventories. For instance, the EIS of C2 stated that GHG
emissions in operation phase would be 451,000 CO2e t/yr
with the largest effort of mitigation, which corresponds to
only 0.07% of Canada’s annual GHG emission. However,
the same amount is equal to around 10% of the annual
GHG emission in Iceland, which emitted 4,542,000 CO2e t
in 2010 (Statistics Iceland 2012). Here, we call this
phenomenon ‘a scale trick’.
 Table 1. GHG assessments in environmental impact statements of the projects which were already completed under the Canadian Environmental Assessment Act 2012 in Canada.
Project name
C1: Canpotex potash terminal
project
C2: Donkin export coking
coal project
C3: EnCana shallow gas infill
development
C4: Fairview terminal phase
ii expansion project
C5: Inuvik to Tuktoyaktuk
highway project
C6: Little Bow reservoir
rehabilitation and upgrading
project
C7: Mining and milling the
midwest project
Date GHG assessment
2011. 11. Quantitative assessment
with single scenario
2012. 7. Quantitative assessment
with multiple scenarios
2007. 5. Quantitative assessment
with single scenario
2009 Quantitative assessment
2011. 5. Just quotation of reference
2011– 2013 Quantitative assessment
2011 Quantitative assessment
Environmental impact statement
Main cause of GHG changes
(con) Exhaust from con-
struction and decommission-
ing phase equipment
(ope) Marine vessel engines
and railroad locomotives
(ope) Fugitive emissions of
methane that is trapped in the
coal-bed
(con þ ope) Diesel fuel
combustion and venting of
CO2 and methane (CH4)
(con) Motor vehicle and
construction equipment
exhaust
(con) Construction vehicles;
transporting staff to work
site; camp activities
(ope) Highway traffic and
maintenance vehicles
Vegetation clearing and
subsequent flooding of the
upland area of Little Bow
reservoir
(ope) Direct mining activi-
ties [including the McClean
Lake Operation]
Estimated GHG Comparison with GHG Proposed ideas of
emission changes inventories mitigation
(con) þ 15,654 CO2e t/yr þ0.004% of Canada BATEA (but no examples
(ope) þ 21,114 CO2e t/yr in 2020 þ 0.05% of specific to GHG
British Columbia in emissions)
2020a
(ope) þ 451,000 CO2e þ0.07-0.20% of Gas collection/energy
t/yr with the largest Canada in ?? þ recovery, oxidization by
mitigations 2.2– 6.4% of Nova ventilation air methane,
Scotia in 2012a developing a GHG man-
agement plan, annual
monitoring of GHG
emissions etc.
(con) þ 22,419 CO2e t/yr þ0.002% of Canada in Proponent’s existing
(ope) þ15,042 CO2e t/yr 2004 þ 0.006% of efforts (e.g. energy
Alberta in 2004a assessment and its original
method for reducing
flaring)
(con?) þ 162,677 CO2e ?% of Canada in 2015 BATEA during operation
t/yr [updated data] ?% of British Colum- (e.g. minimizing ship
bia in 2015 idling and locomotive shut
down)
N N N
(con) þ 494 CO2e t/yr, þ 0.000008% of –
(ope) þ 1,462 CO2e t/yr Albertaa
(ope) þ 42,855 CO2e t/yr þ 0.19% of Saskatch- Best management
ewan in 2006 practices (but no examples
specific to GHG
emissions)
(Continued)
Impact Assessment and Project Appraisal
225
Table 1 – continued
Project name
C8: New bridge for the St.
Lawrence
C9: Prosperity gold– copper
mine project
C10: Randle reef sediment
remediation project
C11: Renard diamond project
C12: Redevelopment of the
port hope conversion facility
Notes: (con), construction stage; (ope), operation stage; BATEA, best available technology economically achievable. Italic information is based on comprehensive study reports. ‘– ’ means no data due to inaccessibility to
neither EIS nor other relevant documents, whereas ‘N’ means no statements in each cited document.
a
On the basis of GHG during operation.
Environmental impact statement
Date GHG assessment Main cause of GHG changes
2013 Quantitative assessment (con) Movement of vehicles
(rough graphical and machinery on temporary
approach) roads
(ope) Road traffic
2009. 3. Quantitative assessment (con) Site clearing, grubbing
and subsequent burning of
vegetative debris
(ope) Motor vehicles, con-
struction, and mining equip-
ment, diesel-fired generators
– – (con) Increased diesel com-
bustion emissions from con-
struction equipment, and
truck traffic
(ope) Increased green space
2011. 12. Quantitative assessment (ope) Diesel-fired generator
with multiple scenarios
– (con) Excavation, demolition
and construction activities
(ope) Increase of buildings
Estimated GHG
emission changes
(ope) If car speed is
doubled (from 40 to
80 km/h) and traffic flow is
increased by 7.5%, for
instance, GHG emission
would be decreased by
0 – 10%.
(con) þ 57,408 CO2e t/yr
(ope) þ 52,636 CO2e t/yr
(closure) þ 31,205 CO2e
t/yr
– –
(ope) þ 75,000 CO2e t/yr
– –
Comparison with GHG
inventories
N GHG emissions from
þ0.006% of Canada in
2015 þ 0.067% of
British Columbia in
2015a
N Monitoring of GHG emis-
226
Proposed ideas of
mitigation
machinery will be offset
by buying carbon credits
or carrying out
independent projects (e.g.
planting trees)
BATEA (aiming at GHG
T. Ohsawa and P. Duinker
emission mitigation),
including speed limit,
reduction of vehicle
idling, minimizing dis-
turbance, maximizing
revegetation, annual
inventory of GHG etc
BATEA (e.g. ‘no idle’, on-
site speed limit, but no
examples specific to GHG
emissions)
sions
–
 Impact Assessment and Project Appraisal 227

Table 2. GHG assessments of the projects which were already completed under the Canadian Environmental Assessment Act 2012 in
Canada.

Response by the agency or the established panel

Project name Cited document type Date Response Final decision

C1: Canpotex potash Comprehensive study 2012. 9. 1. ‘GHG emissions from operations will Permit
terminal project report from agency be very small in comparison with the
year 2020 GHG emission totals
projected for Canada (about 0.004 %)
and British Columbia (about 0.05
percent).’ (p. 17)
2. The project is unlikely to cause
significant adverse environmental
effects on air quality.
C2: Donkin export Comprehensive study 2013. 4. 1. ‘The GHG emissions resulting from Permit
coking coal project report from agency the operation step of the project will be
about 0.07– 0.2% of national total
(2010) reported emissions (depending
on methane recovery options)’. (p. 19)
2. The proponent should continue to
search for opportunities for methane
recovery and commit to make a GHG
Management Plan.
3. The project is unlikely to cause
significant adverse environmental
effects on air quality, given that the
implementation of the proposed miti-
gation is taken into account.
C3: EnCana shallow Panel report 2009. 1. 1. ‘These emissions would amount to Not permita
gas infill development only about 0.006% of the greenhouse
gas emissions for all of Alberta, and the
expected impact would not be signifi-
cant’. (p. 125)
C4: Fairview terminal Comprehensive study 2012. 10. 1. ‘GHG emissions from the project are Permit
phase ii expansion report from agency relatively small in comparison with
project provincial and national inventories.
Also, they are small compared to
existing projects of similar type’. (p. vii)
C5: Inuvik to Panel report 2013. 1. No response about GHG emissions Permit
Tuktoyaktuk highway
project
C6: Little Bow Comprehensive study 2013. 1. 1. ‘CO2 emissions are minor Permit
reservoir rehabilitation report from agency (0.000008%) in comparison with the
and upgrading project total provincial GHG emission of 244
million tonnes of CO2 equivalents.’
(p38)
2. ‘The proponent does not need
consider vegetation clearing prior to
flooding and its CO2 emission, because
upland vegetation that will be covered
with the increased full supply level of
the Little Bow reservoir is likely in
dormant stage during flooding’.
(pp. 38 – 39)
C7: Mining and Comprehensive study 2012. 5. 1. ‘The project is unlikely to cause Permit
milling the midwest report from agency significant adverse environmental
project effects on air quality’. (p. 129)
C8: New Bridge for the Screening report by 2013. 8. 1. ‘It is difficult at this stage of the Permit by screening
St. Lawrence agency project to establish the traffic
parameters on the new structure, and
thus to know what traffic flows will be.
Traffic studies are under way. Volume
will depend in part on the provision of
public transit and the kind of transport
provided.’ (p. 99)
2. However, simulations showed that
GHG emissions could be reduced with
better traffic fluidity or higher car
speeds.

(Continued)
228 T. Ohsawa and P. Duinker

Table 2 – continued

Response by the agency or the established panel

Project name Cited document type Date Response Final decision

C9: Prosperity gold-
copper mine project
C10: Randle reef
sediment remediation
project
C11: Renard diamond
project
C12: Redevelopment
of the port hope
conversion facility
(PHCF)
Panel report
Comprehensive study
report from technical
task group AECOM
Comprehensive study
report from agency
Comprehensive study
report from Canada
Nuclear Safety
Commission
2010. 7. 1. ‘With respect to greenhouse gas Not permitb
emissions, the Panel notes that the total
contribution of the Project would be
very small compared to national and
provincial emission totals’. (p. 121)
2. ‘The contribution to greenhouse
gases from the project would not result
in a significant adverse effect.’ (p. 121)
3. However, the GHG emissions were
requested by participants of public
hearing to be offset in the future.
2013. 1. 1. ‘The adverse effect of the ECF† on Permit
the existing ambient air quality is
expected to be low with some long-term
positive effects’. (p. 172)
2. The magnitudes of both GHG
emissions in construction stage and
GHG reductions in operation stage were
judged as ‘low’ among four levels
(‘Very low’, ‘Low’, ‘Medium’, ‘High’).
2013. 5. 1. ‘Nature Québec requested that the Permit
proponent present a detailed plan for
reducing the greenhouse gases emitted
during the construction, operation and
closure phases of the project. In
addition, authorization of the project by
the Quebec government is conditional
on the proponent using the most
efficient technologies and least pollut-
ing fuels in terms of greenhouse gas
(GHG) emissions. The proponent is
required to submit to the Quebec
government annual monitoring
reports on estimated GHG emissions.
In addition, a re-assessment of the
feasibility of a connection to the
electrical power grid must be conducted
after five years of operation. If this
option proves economically feasible,
GHG emissions would be reduced by
nearly half.’ (p16)
2. ‘Taking into account the implemen-
tation of the proposed mitigation
measures and the monitoring of air
quality and atmospheric emissions
planned by the proponent, the agency
concludes that the project is not likely to
cause significant adverse environmental
effects on air quality.’ (p. 17)
2012. 5. 1. ‘The contribution of project activities Permit
to GHG emission is unlikely to cause
significant adverse environmental
effects on air quality.’ (p. 121)

Note: ECF, engineered containment facility.

a
Although this project was finally rejected, the reasons were some concerns with national wildlife area as well as some lacking environmental information,
but not the issue of GHG emissions.
b
Although this project was finally rejected, the reasons were some concerns with fish and fish habitat, navigation, the current use of lands and resources for
traditional purposes by First Nations and cultural heritage, certain potential on established Aboriginal rights and grizzly bear populations, but not the issue
of GHG emissions.

‘Significance’ and ‘non-significance’ However, three proponents (C1, C2 and C9) among the four
After comparing GHG emission estimates with national and/ citing CCCEAC (2003) emphasized, by repeating, the fact
or provincial emissions, most of the EISs (five out of seven) that it is not possible to assess the impact of GHG emissions
mentioned whether such impacts were significant or not. from each project on climate change, as depicted in Figure 1

(a). These proponents explicitly stated that it is not possible
to assess the significance of such an impact, but curiously
they could somehow conclude that the GHG emission
impacts of their projects are unlikely to be significant. For
instance, the EIS of C9 gave the following statement:
It is not possible to conclude with certainty that a given
source of GHG has a measurable cause-and-effect
relationship on local, regional, or global climate. As such,
the incremental contribution of the Project to national or
global GHG emissions cannot be linked to specific changes
in global climate. Therefore, Project effects on climate have
been assumed to be not significant, and are not discussed
further in the EIS. (p. 2 – 53 of the EIS of C9)
Furthermore, the EIS of C11 initially admitted a
possibly significant impact of GHG emissions but ended
with the conclusion that the impact of the project on total
air quality was ‘low’. This is possibly because impacts on
air quality, other than GHG emissions, may have been
estimated to be light, but still the possibly significant
impact of GHG emissions was not logically denied.
Hence, the rationales for judging of ‘non-significance’ in
these EISs were generally ambiguous and/or inconsistent.
Mitigation measures
Seven reviewed EISs mentioned some implementable
measures against emissions. In addition, proponents of two
other projects (C4 and C10) are likely to have suggested
mitigation measures, although these are just guessed based
on comprehensive study reports, but not EISs. However, six
of these nine cases concluded with just assessing, monitoring
and/or prescribing best available technology economically
achievable (BATEA). Examples of BATEA here were no-
idling and low speed limits for vehicles used for construction
and/or operation of projects. EISs of five cases in the current
study mentioned this concept. Nonetheless, the effect of such
‘eco-driving’, for instance, can be greatly varied depending
on drivers’ efforts as well as traffic crowdedness (Barth &
Boriboonsomsin 2009). The review panel of C9 stated that
speed limits for vehicles may be difficult to enforce. In this
sense, these EISs seem to just assess impacts and note some
well-known mitigational platitudes but not to address the
issue substantially and substantively.
Given the fact that CCCEAC (2003) proposed various
mitigation measures, including not only best practices and
monitoring but also emission credit trading and compen-
satory measures, only some of them have been commonly
considered in most EIAs. GHG offset by buying carbon
credits or carrying out other projects was mentioned only
in the EIS of C8.
National agency’s responses to EISs
CEAA or review panels agreed with the conclusions of
assessing GHG emissions in all the reviewed EISs, although
two projects were not approved to proceed due to other
problems (Table 2). Relevant statements were quoted from
reports by CEAA or panels as original as possible, but some
statements were paraphrased due to their length. Similarly
Impact Assessment and Project Appraisal 229
with EISs, comprehensive study reports and panel reports
compared estimated GHG emissions with national and/or
provincial emissions. Almost all the examined cases, other
than C5, then concluded that estimated GHG emissions were
small and/or not significant.
However, it was not necessarily clarified how they
could reach the conclusion of ‘not significant’. In other
words, there were various and inconsistent ways of using
terms and definitions among different cases. First, many
adjectives were found to express the degrees of estimated
impacts without explicit definitions: ‘very small’ (C1 and
C9), ‘relatively small’ (C4), ‘minor’ (C6), ‘low’ (C10),
and ‘negligible’ (C12). Exceptionally, the comprehensive
study report of C10 gave four levels of impacts, such as
‘Very low’, ‘Low’, ‘Medium’ and ‘High’ with their
definition. For instance, ‘low’ was explained as that which
‘affects a specific group or important habitat for one
generation or less within natural variation’ (p. 152 of the
comprehensive study report of C10). Second, the
definition of ‘significance’ was not precisely offered in
most reports. In the report of C10, there was a definition of
‘significant adverse effect’ by five requirements, any of
which should be met for a finding of significance (e.g. ‘the
duration of the adverse effect is long-term (greater than 15
years)’ (p. 160 of the report)). Furthermore, interestingly,
the comprehensive study report of C6 defined ‘significance
thresholds on climate’ as ‘change in total provincial GHG
emissions greater than 0.1% or change in local or regional
mean surface air temperature greater than 18C (p. 67 of the
report), although there was no scientific rationale for this
definition. Nevertheless, such specific definitions have
rarely been seen in EIAs as of yet. If we then apply the
definition of ‘significance thresholds on climate’ by C6 to
the other cases, at least impacts of GHG emissions from
C1, C4 and C7 would be judged as significant.
Other stakeholders’ responses to EISs
Exceptionally, in the response to the EIS of C11, CEAA
mentioned that the provincial government was concerned
about the impact and that the proponent should make efforts
to consider a more environmentally friendly option (CEAA
2013d). The main sources of GHGs from the project were
likely to be activities linked to energy consumption. In the
EIS, two main alternatives were quantitatively examined, i.e.
the use of diesel generators and hydroelectric supply by
power line. The latter was far more environmentally friendly,
but the first alternative was chosen in C11, mainly because of
the high initial cost associated with the construction of a
power line compared with that of the other. It means that the
proponent prioritized cost saving rather than the assessment
result. Although the opinion of the provincial government
did not lead CEAA to disapprove this project finally, there is
no doubt that this opinion partly influenced CEAA’s
response to the EIS, because the comprehensive report
mentioned much about this issue, calling for further
consideration of the other alternative.
As well, in the case of C9, the GHG emissions were
requested by hearing participants to be offset in the future.
230 T. Ohsawa and P. Duinker
This fact was documented in the panel report, but there
were no concrete suggestions as to how to implement this
offset.
In other investigated cases, reports by CEAA or panels
did not explicitly mention such opinions from the public,
including provincial governments, in their reports. This
result indicates that there were few opinions from the
public and other intervenors or that such opinions were
unimportant in national EIA processes.
Proposals for the future approach to GHG emissions in
EIAs
Based on the aforementioned analysis of Canadian EIAs,
we offer some suggestions to improve the approach to
GHG emissions.
Uses and definitions of GHG emission levels
From a national viewpoint, any project data with larger
emissions than 50,000 t CO2e/year have been required to
report their GHG emissions data (Sametz et al. 2012).
Also, those in Alberta with larger than 105 t CO2e/year are
regarded as ‘large emitters’ and required to reduce their
emissions (Sametz et al. 2012). The threshold of 105
t CO2e/year has also been used historically to define large
final emitters in Canada, whereas another threshold of 106
t CO2e/year was proposed by Murphy and Gillam (2013).
Likewise, to prevent any unnecessary confusion in EIAs,
CCCEAC (2003) could be revised with precise quantitat-
ive definition of the three terms (‘small’, ‘medium’ and
‘large’). However, we admit that determining specific
thresholds to define these terms is difficult in terms of
science, because impacts of GHG emissions increase
continuously with increases of emissions. In other words,
there are no known thresholds. Simultaneously, CCEA as
well as established panels could use adjectives for GHG
emissions in a coherent way in their reports. In line with
this, Watkins and During (2012) also reported inconsistent
use of words which were relevant to carbon and GHG in
EIAs, suggesting use and thorough definition of fewer
words.
Scale trick
If we compare an estimated emission with an emission of a
larger jurisdiction, for instance, the fraction would be more
likely to be expressed as small. Irrespective of whether
intentionally or unintentionally done, such a trick may
possibly entail a kind of framing effect, which can change
people’s decision-making using different expressions of
essentially the same information (Tversky et al. 1981).
Wang and Johnston (1995) and Shimizu and Udagawa
(2011) tested to which degree each person makes a risky
decision about a certain group’s life/death-related issue, by
changing the group’s scale (6, 60 or 600 persons). They
then found that people were more likely to take a risky
decision with smaller groups, naming it ‘the effect of
contextual group size’. As such, influences of different
scales on decision-making were confirmed by experimen-
tal psychology.
Any amounts smaller than 100 are not appropriate to
be expressed with percent, given the fact that percent is
defined based on 100 (Parker & Leinhardt 1995). In this
respect, numerical information provided by proponents in
EISs should be carefully interpreted. Regional targets (e.g.
10% decrease of GHG emissions (Nova Scotia Environ-
ment 2010)) are useful to be compared with estimated
GHG emissions in each EIA, because such targets at small
scales can also avoid the scale trick. Moreover, to enable
readers to understand such impacts more accurately and
easily, proponents could show the impacts in more diverse
ways (e.g. showing costs to offset GHG emissions). The
importance of such an effort (i.e. increasing under-
standability) was emphasized in an international guideline
about this issue as well (Byer et al. 2012).
Linking between estimated GHG emissions and global
climatic goals
Current EIAs tend to be approved using the most
environmentally preferable technologies. However, even
if some projects adopt the most environmentally friendly
methods and technologies, some of them still may emit
large amounts of GHGs. These cases may counteract some
policies and plans relevant to climate change (Figure 1(b)).
Here, it is important to distinguish ‘technically irrelevant
linking between project impact and climate change
(Figure 1(a))’ versus ‘addressable linking between
relevant policies or plans and mitigation in each project.’
Ideally, relevant policies and plans may be rooted in the
worldwide common climate goal (e.g. stabilizing the
climate with the temperature increase up to 28C) (IPCC
2013), and then mitigation of GHG emissions of projects
should be linked with these policies and plans (Figure 1
(c)). However, due to various constraints in each project, it
may be difficult to design projects to reduce GHG
emissions below certain values which are consistent with
regional targets. If proponents find huge inconsistencies
between estimated GHG emissions versus relevant
policies/plans, for example, it seems sensible that they
consider some compensatory measures to fill the gaps
(IEMA 2010). In this way, it seems possible to link
mitigation to GHG emissions in each project versus the
final goal of climate stabilization (Figure 1(d)). Each
province has a specific target of GHG emission reduction,
and GHG emissions from new projects are likely to be
influential on such regional goals or plans rather than
national ones. Thus, like the case of C11, each provincial
government might need to check whether approaches to
GHG emissions in EIAs are consistent with their targets
more seriously than federal agencies, and their opinions
should be explicitly written in comprehensive reports by
CEAA or review panel reports. Many proponents
emphasized the technical difficulty of assessing impacts
of GHG emissions from each project on climate change,
but this cannot be an excuse for not considering and
implementing analysis of the contribution of GHG
 Impact Assessment and Project Appraisal 231

emissions from each project and comparing them with Ministry of the Environment claimed in its EIAs that the
global targets to stabilize climate change (Figure 1(d)). operation of the new plant should be prioritized so that the
total amount of CO2 emissions can be minimized (e.g.
refreshing thermal power plant of Nishi-Nagoya (JME
Approach to ‘significance’ 2013a)). Likewise, kg CO2e divided by iron ore and
Although such consideration of relevant policies/plans bauxite or copper concentrate was used in an Australian
was recommended by CCCEAC (2003) already, this life cycle assessment (LCA) of mining and mineral
guideline did not say anything about ‘significance’ of processing (Norgate & Haque 2010). Therefore, such ‘eco-
GHG emissions. This might be why many proponents gave efficiency’ (GHG emissions per product unit) could be a
conclusions of ‘not significant emission’ subjectively and good measure to assess GHG emissions in comparison
arbitrarily. Therefore, we would like to consider the with similar projects of the same industry.
definition of ‘significance’ in this issue here. According to As such, the current recommendation by CCCEAC
Lawrence (2007), there are three impact significance (2003) could be useful for determining ‘significance’ in
determination approaches: technical approach, collabora- GHG emissions from technical perspectives. However, as
tive approach, and reasoned argumentation approach. aforementioned, community knowledge and perspectives
Herein, the technical approach is to judge ‘significance’, should also be collected to make a final decision.
quantitatively, mainly based on scientific analysis and
knowledge, whereas the collaborative approach is to do so
qualitatively based on community knowledge and Mitigation measures
perspectives. However, both of these approaches lack the Finally, proponents should clarify how to implement
strengths of the other approach. A third approach, called effective BATEA more concretely in their EISs. In parallel
reasoned argumentation, integrates both technical and with these, to tackle the uncertainty, it would be
community knowledge, facts and multiple perspectives in worthwhile for proponents to publicize their efforts to
qualitative and quantitative fashions (Lawrence 2007). implement BATEA after their projects are initiated.
Reasoned argumentation is, in our view, a much stronger Furthermore, watchdog groups and/or authorities, possibly
approach than the other two. including CCEA, could do spot checks without prior
The most basic technical/scientific information in GHG notifications to confirm mitigation measures including
emission assessment is absolute amounts of estimated GHG BATEA are actually realized in each project (Sok et al.
emissions. All mitigation measures and/or compensation 2011). In contrast, BATEA is common, and it appears that
measures which proponents propose should be considered
here. Also, absolute amounts could be compared with some
thresholds, like the aforementioned instance of ‘large
emitters (.105 t CO2e/year)’ in Alberta (Sametz et al.
2012). It should be noted, however, that the threshold of
105 t CO2e/year does not have any scientifically special
meaning. It means that evaluation of this amount by using
such thresholds is just an arbitrary reference.
Meanwhile, Lawrence (2007) proposed that govern-
ment contributions, such as policies and standards, could
also be available as input information in the reasoned
argumentation approach. In this sense, consistencies or
inconsistencies between pre-existing policies/targets and
estimated emissions, as mentioned in the previous
subsection, could be useful to determine ‘significance’ as
well. Nonetheless, evaluating significance of GHG
emission impacts based on just relations to regional
inventories/targets could also lead to unfair evaluations
among regions (provinces) which emit different amounts
of GHG. This could be serious in Canada, where neither
GHG emissions nor emission reduction targets are evenly
distributed among the provinces (Tang 2011).
Furthermore, CCCEAC (2003) recommended asses-
sing GHG emissions in comparison with emitters in the
same industry, but it did not give concrete methods. In this
regard, some foreign EIAs have already ideas of
evaluating GHG emissions by calculating CO2e amount
per product unit. For instance, several thermal power
Figure 2. An example of addressing GHG emissions in an EIA
plants are or will be renewed in Japan. Due to their lower process following the reasoned argumentation approach of
carbon dioxide emission intensity per generated electricity Lawrence (2007). The underlined parts have been neglected or
compared with that of pre-existing plants, the Japanese not been proposed in recent Canadian EIAs.
232 T. Ohsawa and P. Duinker
relatively easy options have been selectively considered.
In other words, compensatory measures which need
budgets have been less popular. In this regard, CCCEAC
(2003) could develop its guideline to include the details of
the latest compensatory measures for ‘significant’
emitters. For instance, a few other countries have been
approaching this issue by asking proponents to consider
and/or introduce new technologies (e.g. Carbon Capture
and Storage (CCS) in recent Japanese EIAs (JME 2013b)).
Cormos (2012) reported that plants of integrated
gasification combined cycle can capture 90% of generated
carbon by CCS. So, various advancing approaches to GHG
emissions could be shared in such guidelines.
Conclusion
Canada has developed approaches to GHG emissions for
more than a decade, and it is now common to assess the
emissions and propose some mitigation in EIAs. The
guideline about GHG emission mitigation by CCCEAC
(2003) was cited by more than half of the examined EISs.
Large emitters have then proposed some substantial
measures, typically the latest technologies, to reduce
emissions. However, other proposed ideas may still be
ambiguous and hard to examine in terms of real effects.
In the future, more efforts in research and proponents’ actions
will be needed to ensure the implementation of BATEA.
Furthermore, there were many ambiguous and/or
inconsistent definitions of GHG emission levels as well as
‘significance’. The expressions of GHG emission
amounts using percent were also tricky. In response to
these situations, this study suggested to introduce clear
and coherent definitions and more understandable
expressions. As well, multiple proponents emphasized
that it is not possible to assess the impact of GHG
emissions from each project on climate change. However,
linking between relevant policies/plans and mitigation in
each project is crucial to achieve worldwide goals to
stabilize the climate. We should not confound this linking
and the technically irrelevant linking between project
impact versus climate change. Using regional inventories
and/or targets could be useful to overcome the technically
irrelevant linking.In addition, average emission intensity
per product unit in the same industry could be useful for
determining the impact significance of GHG emissions.
To summarize our idea, we provide a diagram as to how
to address this issue in Figure 2, referring to the Figure 3
in Lawrence (2007). A similar idea has been already
proposed in CCCEAC (2003), but it is also true that this
idea has not been fully realized accurately in actual EIAs.
Revisiting such ideas in consideration of how to define
‘significance’ will possibly improve the current situation
which we found in this study.
Acknowledgements
We would like to thank the editors as well as anonymous
reviewers for their advice on our earlier manuscript. The views
and opinions expressed in this article represent solely those of the
authors and do not represent the views of any organization.
Funding
This study was supported by the Japanese Government Long-
Term Overseas Fellowship Program.
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