Dr. John Hollins, past Chair CACOR, reviews Bill C-69.
Some thoughts
An Act to enact the Impact Assessment Act and the Canadian Energy Regulator Act, to amend the Navigation Protection Act and to make consequential amendments to other Acts.
Fundamental issue
Thoreau captured the essence of the matter in 15 words some 150 years ago:
What good is a house if we haven’t a respectable planet to put it on?
Henry David Thoreau
American essayist, surveyor, and historian (1817-1862)
The fundamental issue is securing a reasonable and respectful balance between the state of the natural environment, upon which we and all other living species depend, and the collective economic and social practices and interests of humankind. The acid test for Bill C-69:
o is the balance right?
Background
During a century and a half, Canadian policy and practice has been dominated more often than not by economic thinking. Attention to a respectable planet began only in the 1960s and has rarely been accorded the same weight in government or private enterprise as economic considerations.
Environmental issues during the past five decades were often considered in two categories:
- issues driven by a substantial environmental concern (policy issues); and
- environmental assessment of a project driven by economic considerations (practical issues, often a function of economic policy).
For the existential issue of global warming, two primary policy issues interact, relating to environment and energy, but also engaging social and business interests. Once policy is determined, the balance selected may well become the major factor in the assessment of specific energy projects.
Environmentally driven
Major issues in the first category provide a few notable successes, for example,
o a national problem — the insecticide DDT was banned in 1972 because of its damaging effects on wildlife and humans;
o a continental problem — substantial reduction in the emissions that result in acid rain, leading to the recovery of freshwater and benefits to human health; and
o a global problem — reduction of emissions of CFCs to reduce depletion of the stratospheric ozone layer and damage to living species (humans, animals, and vegetation) caused by ultraviolet radiation from the sun (Montreal Protocol).
o (The latter two examples both occurred during the term of the Mulroney government.)
So while Canada has been able to create reasonable balance on these major environmentally driven issues, it was not easy and it requires ongoing attention. For the existential, environmentally driven issue of the 21st century, global warming, Canada is nowhere near finding a reasonable balance. It is barely competent. Contradictions that are evident to a dispassionate observer are brushed aside by some in authority (the political tool bullshit is used).
Economically driven
Addressing environmental issues that were the consequence of specific economic projects was first tackled in Canada in 1973. Environmental assessment has evolved during the following years [1]. It has been a tag on to decisions based on policy in other domains, a brake on decision making rooted in economics, rather than a consideration in equal terms in the development of a proposal. In June 2012, the previous Canadian Environmental Assessment Act was repealed and replaced with CEAA 2012. The current Bill C-69, if and when adopted, will be a further evolution.
Systems approach
Bill C-69 sets out to take a broad systems approach to the matter:
o to understand how the various factors across four domains interact and how they are likely to work together.
As a professional engaged for a long time in energy and the environment and with experience in the analysis of physiological and energy systems, I concur with an approach that addresses entire systems, not just part of a system. It is more demanding than addressing one part of a puzzle at a time, but the approach is much more likely to reach sound conclusions. (The nature of most research in the natural and social sciences is to concentrate one specific topic [2] at a time. The role of a senior or emeritus professor is to stitch together findings across a broader area. Assessments of science to inform policy are routine practice in the UK and the USA, undertaken but rarely in Canada [3].
Systems analysis
Systems analysis derives from mathematical approaches to management of wartime logistics developed by scientists [4] in the UK during the Second World War (then called operational research). Systems analysis means to recognize and address the interactive nature and interdependence of all the many external and internal factors that determine what happens in a system, any system. It provides substantial and useful insights into policy beyond conventional economic analysis because it takes scientific and technological, as well as economic factors into account.
For example, in 1974, the Club of Rome published a report on Limits to Growth that was based on systems analysis done at the Massachusetts Institute of Technology. The findings are still valid today, 45 years later, although they may still be unpalatable to conventional economic thinking.
An impossible dream?
The summary of Bill C-69 states:
(b) provides for a process for assessing the environmental, health, social and economic effects of designated projects with a view to preventing certain adverse effects and fostering sustainability;
This is an extraordinarily difficult task — the management of a complex system with myriad variables, perhaps an impossible dream.
Management of complex systems
There is a fundamental problem: to manage any system successfully the mechanism of management must have a repertoire of tools which is at least as broad as the factors to be managed (First Law of Cybernetics).
Bill C-69 sets out to manage four factors [Paragraph (b)]:
o environmental;
o health;
o social; and
o economic,
each of which comprises many sub-factors. It is simply not possible to deal with all these factors simultaneously without conflict between them, so compromise and accommodation are essential. The plans and actions need to be realistic and dedicated to reasonable balance between the competing factors.
An observer put it this way:
We must do a better job of managing the world. But believing in unrealistic and unworkable plans is just a distraction and a waste of time.
Brian Wang,
Nextbigfuture, 2018
Sustainable development
This is not a new problem. The concurrent management of economic, environmental, and social factors was addressed in 1987 by the World Commission on Environment and Development (the Brundtland Commission [5]). The Commission coined the term sustainable development as a sweet way of squaring the circle.
Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs
World Commission on Environment and Development,
October, 1987
The origins of the adjective sustainable in English lie in the 17th Century, evolving in the 20th Century to mean capable of being continued. Sustainable development seemed like a good idea at the time, but it is essentially an oxymoron. Interests of all kinds rapidly hijacked the mantra of sustainable development and used it as whitewash. In the real living world, it is evolution that occurs, not indefinite continuation of the status quo.
Both wishful and vested thinking continue to this day, including in Bill C-69 [6].
Evolution
The 44th President of the United States had a clear perspective on one aspect of the dilemma
The path towards sustainable energy sources will be long and sometimes difficult. But America cannot resist this transition; we must lead it. We cannot cede to other nations the technology that will power new jobs and new industries — we must claim its promise. That’s how we will maintain our economic vitality and our national treasure — our forests and waterways, our croplands and snow-capped peaks. That is how we will preserve our planet, commanded to our care by God. That’s what will lend meaning to the creed our fathers once declared.
President Barack Obama
Inaugural speech, 2013 January 22
source: NY Times
President Obama understood that science and technology are essential to the evolution of policy and practice in providing the energy that humankind requires in the 21st Century. I don’t get much sense from what I’ve read so far of Bill C-69 that the authors fully grasp the essential role that energy plays in the welfare of Canadians.
One of the issues that strikes me is the method of appointment of review panels and who will serve on them. Here is a pair of initial questions.
Initial Questions
Possible questions for the Minister or representative based on Summary paragraph (b).
(b) provides for a process for assessing the environmental, health, social and economic effects of designated projects with a view to preventing certain adverse effects and fostering sustainability;
b) prévoit un processus d’évaluation des effets environnementaux, sanitaires, sociaux et économiques des projets désignés en vue de la prévention de certains effets négatifs et de favoriser la durabilité;
The phrase that struck me was “certain adverse effects”.
o Please tell us which “certain” adverse effects do you mean?
and
o Please tell us which “certain” adverse effects are of no concern to you.
When there are no easy answers in an interconnected system, dialogue is essential to understand and address the needs of the diverse world, in order to balance political discourse, policies and individual action.
Lalith Ananda Gunaratne
Member of the Canadian Association for the Club of Rome
[1] There are grounds for argument that a progressive evolution of sorts has occurred in Canadian environmental assessment. Robert B. Gibson, Impact Assessment and Project Appraisal, volume 20, number 3, September 2002.
[2] My Ph.D. supervisor defined the word expert: “X” is the unknown quantity, “spurt” is a drip under pressure. (“Drip” applied to a person is a pejorative term in British English.)
[3] The Green Plan adopted by the Mulroney Government provided for science assessments of environmental policy issues. In practice, just one broad scientific assessment for policy was done, on Biodiversity in 1994.
[4] Prof. P.M.S. Blackett, FRS.
[5] Chair: Gro Harlem Brundtland, former Prime Minister of Norway; Secretary General: Jim MacNeill, former Canadian Deputy Minister.
[6] It reminds me of Neville Chamberlain, Prime Minister of the UK, who visited Adolph Hitler in Berchtesgaden in 1938, signed the Munich Agreement, and returned talking about “peace for our time”. The UK declared war on Germany on 3 September 1939, following the invasion of Poland. (Winston Churchill succeeded Chamberlain in 1940.)
Briefing note by Dr. John G. Hollins, Past Chair of the Canadian Association for the Club of Rome, drafted 2019 January 16. The analysis and views expressed are those of the author.
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