2009 Fall Report of the Commissioner of the Environment and Sustainable Development The Commissioner’s Perspective—2009

2009 Fall Report of the Commissioner of the Environment and Sustainable Development

The Commissioner’s Perspective—2009


Relevant environmental information

Cumulative environmental impact



Among the broad range of issues examined in our reports to Parliament during the past year, I would like to focus on one important issue that comes up repeatedly—the importance of ensuring the quality of information used to design, implement, and monitor environmental management programs that can deliver measurable benefits to environmental quality.

Informed decision-making is at the heart of sound policy-making. The environmental programs of the federal government need science-based environmental information that is timely, robust, and accessible in ways that both identify patterns of environmental degradation and help programs concentrate on the most urgent environmental problems.

Relevant environmental information

Good-quality information about the environment is critical for Parliament to know if federal programs are working to control pollution, protect species and their habitats, safeguard freshwater resources, and reduce greenhouse gas emissions. Similarly, data on the most pressing environmental problems helps departments design and implement programs intended to promote compliance with laws and regulations, foster partnerships, and provide for regulatory enforcement.

The scope of science-based environmental information is as broad and complex as ecosystems themselves. For instance, the Intergovernmental Panel on Climate Change acknowledges the enormous complexity of the planet’s carbon cycle. Climate change has potential impacts such as increased frequency and severity of tropical storms, hurricanes, and other weather events. In addition, climate change can have other, unforeseen impacts on, for example, the pattern of ocean currents, precipitation, insect pests, infectious diseases, and annual ice flows.

Environmental monitoring and data-gathering systems present the federal government with two key challenges: first, ensuring that the many stand-alone environmental monitoring systems currently in use accurately track trends in environmental quality; and second, determining if these systems can and should work in tandem to provide a composite or cumulative picture of the major challenges to environmental protection. The most recent Science Plan of Environment Canada (2007) includes as a strategic priority developing an integrated environmental monitoring and prediction capability. However, it is unclear whether different monitoring systems—from the National Air Pollution Surveillance network to the Water Survey of Canada—are being linked through a strategic roadmap.

Over the past year, we have examined a variety of individual environmental monitoring and science-based programs. Many are working as intended. One example is Canada’s Greenhouse Gas Inventory. We concluded that it conforms to technical guidelines of the Intergovernmental Panel on Climate Change and provides the government with a reasonable snapshot of annual greenhouse gas emissions—for example, in spring 2009, the Inventory reported that annual emissions had increased to 747 megatons. In turn, this information allows the federal government to track its performance against various climate-related targets. In May 2009, the government estimated that Canada’s greenhouse gas emissions are likely to be more than 30 percent above its Kyoto Protocol commitments.

We have reported on other science-based environmental information systems during the past year. The Air Quality Health Index (AQHI) developed by Environment Canada and Health Canada provides real-time air-quality monitoring data associated with exposure to certain air pollutants. The Index is among the first of its kind in the world, and it demonstrates the practical value of federal leadership in applied environmental research.

In our 2009 Spring Report, we commended Health Canada for its work in reviewing and updating the Guidelines for Canadian Drinking Water Quality in order to take into account recent scientific evidence regarding allowable levels of microbiological, chemical, and radiological contaminants that could be found in Canada’s drinking water. The review of the Guidelines continues to draw upon scientific research from within Health Canada and from universities, research centres, the World Health Organization, the US Environmental Protection Agency, and others.

Another important initiative is the federal government’s national bio-monitoring program, which involves testing 5,500 people for traces of chemicals. This initiative will help inform the federal government about chemical exposure levels Canadians face. When the initiative is completed, the empirical evidence collected should help to show whether federal control systems are focused on the major sources of exposure to chemicals.

Unfortunately, other systems are incomplete, out-of-date, or non-existent. For example, we noted in 2001 and again this year in our Spring Report chapter on fish habitat protection that the government does not know which fish habitat is the most ecologically significant, and where the biggest threats to habitat are created by development projects or industrial water pollution. Without adequate information, it is impossible to know if the policy objective of “no net loss” of habitat is being met, or if the system of compensating for the destruction of one habitat by creating “equivalent” habitat is scientifically sound.

The fragility of fish populations was underscored by the recent collapse of the Fraser River salmon run in British Columbia. The Fraser River was historically among the richest salmon spawning grounds on the planet. Although the specific cause of this recent significant reduction had not been identified at the time of writing, scientists have long recognized that habitat destruction or degradation significantly impact fish populations. In our Spring Report chapter on fish habitat protection we noted that the improper construction of a causeway to access one gravel removal site resulted in the loss of up to 2.25 million pink salmon in 2006.

This year, we also examined Environment Canada’s National Pollutant Release Inventory, which helps track emissions of 347 different chemical and waste substances, self-reported by roughly 8,500 facilities across Canada. Facilities required to report range from large factories to hospitals to landfills.

The Inventory has the potential to be a useful tool for informing the public and government about changing levels of pollutants released into the environment. In 2006, for example, when the Inventory showed a sudden spike in the release of acrylonitrile—a substance declared toxic under the Canadian Environmental Protection Act—Environment Canada responded rapidly by identifying the emission source and concluding an agreement with its provincial counterparts to put in place an emission-reduction plan that appears to be working.

However, Environment Canada does not have adequate systems and practices to verify that all facilities required to report their emissions are doing so and that the information they report is accurate. This factor reduces the Inventory’s usefulness. In addition, the Department does not give users enough information on the limitations of the data to understand what the data can reliably be used for.

Since the environmental agenda first took shape, it has been recognized that government environmental information systems—from specific pollution monitoring systems to data that tracks compliance and enforcement actions—should be made available to the public. Making such information publicly available enables groups of concerned citizens, working alone or in non-governmental groups as diverse as those under the Canadian Environmental Network or the network of Riverkeepers, to play an indispensable public service in helping to protect Canada’s environment.

Environmental stewardship has never depended on government action alone. The public—through committed individuals, research organizations, non-governmental organizations, and First Nations—has always been at the forefront of the green agenda. One of the reasons why the Air Quality Health Index carries so much promise is because its design benefited from meaningful participation by non-governmental organizations. The National Pollutant Release Inventory was originally launched in response to the public demand for such information.

Cumulative environmental impact

While national attention is seized by high-profile cases like the collapse of the salmon run in the Fraser River, of deep concern is the cumulative impact of hundreds of environmental pressures that often go unnoticed and that build up over time. Tracking acute problems such as sudden environmental accidents may be relatively simpler than monitoring and understanding the multiple, accumulated effects of longer-term, lower-level, or lower-dose chronic environmental degradation that, over time, is undermining the viability of more than half of the Earth’s ecosystems.

According to the Millennium Ecosystem Assessment—an international science-based diagnosis of the planet’s major ecosystems that was published in 2005—during the past half-century, “humans have changed [major] ecosystems more rapidly and extensively than in any comparable period of time in human history.” Approximately 60 percent of all ecosystem services—benefits of resources and processes supplied by natural ecosystems—are being degraded or used unsustainably, including fresh water, fisheries, and air and water purification.

Our 2009 Fall Report examines how the federal government has applied the Canadian Environmental Assessment Act over the past 14 years. We found that the government does not know whether environmental assessments conducted under the Act are of good quality. Nor has it tracked how effective environmental assessments are at identifying and mitigating environmental problems before they occur. The government has no systematic approach to monitoring whether mitigating measures required in environmental assessment reports have been implemented to reduce pollution or protect habitats and species threatened by development projects.

Over 100 federal departments and agencies are required to comply with the Act. Each has the discretion to decide on the scope of environmental assessments, which in turn determines what type of assessment will be performed. Each department can limit the scope to those aspects that fall within its mandate and under the jurisdiction of the federal government. The result is a process-heavy system in which costly assessments may examine and report separately on only part of a project.

As part of the environmental assessment process, cumulative environmental impacts of projects are to be considered. This step remains a challenge for the government, as the needed information on past and future projects in a given locale is limited. It becomes an important concern in cases such as the oil sands development in Alberta, where multiple projects are undertaken in close proximity, and in cases where past development may have already compromised ecological integrity.

Parliament is scheduled to review the Canadian Environmental Assessment Act in 2010. Our audits point to a number of issues that need to be addressed, from scoping projects and determining their cumulative environmental impact to ensuring compliance with the Act’s requirement for public consultation.


During the past year, we have reported to Parliament on the mixed results of the federal government’s management of environmental programs: some programs are working well, others less well. However, the government cannot answer whether, taken together, federal programs are contributing to the protection of Canada’s major ecosystems from the kind of degradation reported globally through the Millennium Ecosystem Report. Instead, we continue to examine piecemeal monitoring and other data systems that are not connected strategically.

In her report, the Auditor General notes that the lack of a strategic roadmap for many federal programs complicates their effective implementation, and lack of data hinders the evaluation of program effectiveness. Environmental programs are no exception. Until data programs are woven together to meaningfully track major changes over time in the quality of Canada’s environment, we are left examining stand-alone or piecemeal approaches to protecting the environment.


PDF Versions

To access the Portable Document Format (PDF) version you must have a PDF reader installed. If you do not already have such a reader, there are numerous PDF readers available for free download or for purchase on the Internet: