2015 Fall Reports of the Commissioner of the Environment and Sustainable Development The Commissioner’s Perspective

2015 Fall Reports of the Commissioner of the Environment and Sustainable Development The Commissioner’s Perspective

Message to parliamentarians

It is my pleasure, as Canada’s Commissioner of the Environment and Sustainable Development, to congratulate and welcome this newly formed Parliament. I appreciate that in your capacity as a parliamentarian, you are faced with many important and competing priorities, and I thank you for taking the time to read these words.

I am writing to you to highlight what I believe are two of the most pressing issues of our times: climate change and sustainable development. United Nations (UN) Secretary-General Ban Ki-moon has described these issues as “two sides of the same coin”—a view I share.

Climate change

I will first address the climate change side of the coin.

In December 2015, at the UN Climate Change Conference in Paris, France, countries entered into a landmark agreement on climate, with a goal of keeping temperature rises to well below two degrees Celsius.

This conference was preceded by rising interest and action among public leaders worldwide about the need to reduce greenhouse gas (GHG) emissions, including setting new targets and developing strategies. For example, China agreed to its first-ever climate change target—to cap its GHG emissions by 2030—and the United States agreed to cut GHG emissions to approximately 27 percent below 2005 levels by 2025. The European Union set its target at reducing GHG emissions by 43 percent below 1990 levels by 2030.

The wave also spread across Canada. At the Québec Summit on Climate Change in April 2015, 11 Canadian premiers, representing over 85 percent of the country’s population, issued a joint declaration. In this declaration, they committed to foster a transition to a lower-carbon economy and increase adaptation initiatives to build resiliency. Some three months later, at the Climate Summit of the Americas in Toronto, Ontario, leaders of state, provincial, and municipal governments across the Americas put forward their own climate change commitments. In July 2015, Canada’s premiers released a Canadian Energy Strategy, in which they recognize the importance of transforming how we use and produce energy as part of governments’ approach to addressing climate change. Several provinces and territories are also taking specific and ambitious actions to reduce their own GHG emissions.

Prior to the UN Climate Change Conference in Paris, Canada indicated it would reduce its GHG emissions by 30 percent below 2005 levels by 2030. This target was preceded in 2009 by a commitment to a 17 percent reduction of GHG emissions below 2005 levels by 2020.

Between 1998 and 2014, the Commissioner of the Environment and Sustainable Development, on behalf of the Auditor General of Canada, audited the federal government’s efforts to mitigate climate change in Canada. We have repeatedly found that reduction targets for GHG emissions were not being met. In 2014, we observed that the federal government did not yet have a plan for how it will work toward the greater reductions required beyond 2020, and that it was not coordinating with the provinces and territories to achieve the target. To truly move forward on reducing GHG emissions, it will be important for the federal government to actively engage its partners at all levels in setting and achieving Canada’s future targets, a commitment the newly elected government has made.

Sustainable development

Let’s turn now to the sustainable development side of the coin. Sustainable development speaks to the way we can manage things today to ensure the well-being of present and future generations.

On 25 September 2015, 193 world leaders committed to Transforming Our World: The 2030 Agenda for Sustainable Development and the related 17 sustainable development goals. Canada and other countries agreed to “take the bold and transformative steps which are urgently needed to shift the world on to a sustainable and resilient path.” To be achieved over 15 years, these sustainable development goals are “integrated and indivisible and balance the three dimensions of sustainable development: the economic, social and environmental.” As a result, the 17 goals address a broad range of issues covering all three of these spheres. They include taking action to tackle climate change and its impacts, sustainably managing natural resources, eradicating poverty and hunger, and achieving gender equality.

However, our yearly audits of federal departments’ and agencies’ progress in implementing their own sustainable development strategies have found that they did not consistently consider the environment in decision making, nor show a commitment to Canada’s Federal Sustainable Development Strategy. Cabinet has formally directed departments and agencies to carry out strategic environmental assessments to ensure that ministers are informed of the environmental impacts of the policy, plan, and program proposals that they receive for approval. However, we found that departments did not adequately carry out this Cabinet directive. As a result, ministers were not always getting information on the potential important positive or negative environmental effects of the proposals submitted to them.

A clear indicator of Canada’s commitment to sustainable development and responding to climate change will be the full integration of the 2030 agenda for sustainable development and the Paris climate change targets into Canada’s next Federal Sustainable Development Strategy, which is due in early 2016.

Canada has embraced the two sides of the coin: combatting climate change and its impacts, and working to achieve sustainable development. Concrete actions on these commitments will put Canada on the road to meeting the needs of present and future generations. I look forward to reporting to Parliament on the government’s progress in achieving these all-important goals.

Pesticide safety

In addition to departments’ progress in implementing their sustainable development strategies, our 2015 Fall reports of the Commissioner of the Environment and Sustainable Development also present the findings of two other audits.

The first of these audits focused on the safety of pesticides registered for use in Canada. This audit responded to the recommendation made by the Standing Senate Committee on Agriculture and Forestry in its report on the importance of bee health to sustainable food production in Canada.

The Pest Management Regulatory Agency registers pesticide products for use in Canada. There are currently about 7,000 pesticides containing some 600 active ingredients in the Canadian marketplace.

The Agency may grant a conditional registration when it finds that it needs more information from the manufacturer to confirm its assessment of a product’s value, and risks to human health or the environment. During the time that a pesticide is conditionally registered, it can be bought and used. Other products containing the same active ingredient may also be marketed. We found that nine pesticide products remained conditionally registered for more than a decade. Eight of these nine products belong to the neonicotinoid class of pesticides. These products continue to be extensively used in Canada despite widespread concern that they may pose a threat to bees and other pollinators, as well as broader ecosystems.

The Agency is also required to re-evaluate the safety of registered pesticides every 15 years to ensure that the latest scientific knowledge is applied to assess risks to human health and the environment. Ninety-five percent of the Agency’s re-evaluations result in new measures to protect human health or the environment.

During the period we examined, the Agency completed about 14 re-evaluations per year. At the end of our audit, more than six times that number remained incomplete. With more re-evaluations due to start each year, the Agency needs to quicken its pace to prevent unacceptable risks to people and the environment from the unsafe use of pesticide products.

On a related note, I am concerned that the Agency took between 4 and 11 years to remove some pesticides from the market when it determined that they posed unacceptable risks for all uses. A lack of alternative products was frequently cited as the reason for the delay.

Oversight of federally regulated pipelines

The second audit we are presenting examined the National Energy Board’s oversight of federally regulated pipelines. The Board regulates approximately 73,000 kilometres of pipelines, enough to crisscross the country more than 10 times. The safe transportation of oil and gas is critical to Canadians, for economic, social, and environmental reasons.

The Board sets the requirements that companies must satisfy to ensure that pipelines operate safely. Our audit concluded that the Board did not adequately track company implementation of these requirements, namely pipeline approval conditions. The Board also did not consistently follow up on company deficiencies. We found that its information tracking system was outdated and inefficient. We also concluded that the Board has been facing challenges to recruit and retain specialists in areas such as pipeline integrity and regulatory compliance.

The National Energy Board’s mandate is to regulate pipelines, energy development, and trade in the Canadian public interest. The public interest has evolved to include matters such as climate change and the impacts on communities, including Aboriginal groups. Given this evolution, as well as the anticipated near doubling of pipeline capacity by 2020 and the coming into force of the Pipeline Safety Act by June 2016, it is clear that the Board needs to do more to keep pace with the rapidly changing context in which it operates.


It has been 20 years since Canada’s Parliament created the role of Commissioner of the Environment and Sustainable Development to assist the Auditor General of Canada with conducting audits relating to the environment and sustainable development. Over the course of these audits, the Commissioner has built a large body of knowledge and expertise in these areas. These 2015 Fall reports, like previous reports, provide parliamentarians with objective information to hold government accountable.

As always, we are available to appear before parliamentary committees at any time. Your attention to our reports supports accountability. It allows you, as a parliamentarian, to ask senior officials to appear before you to answer questions about our findings, and explain how they intend to implement your direction and our recommendations.

In the years ahead, I look forward to continuing my work to provide you with the independent information that I hope you find helpful in exercising your oversight role.

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