What we heard from you on the 2018 greenhouse gas National Inventory Report
These are the results from the public comment period on the 2018 National Inventory Report.
Context
As a signatory to the United Nations Framework Convention on Climate Change (UNFCCC), Canada is obligated to prepare and submit an annual national greenhouse gas (GHG) inventory covering anthropogenic emissions by sources and removals by sinks. Environment and Climate Change Canada (ECCC) is responsible for preparing Canada’s official national inventory with input from numerous experts and scientists across Canada. The National Inventory Report (NIR) contains Canada’s annual GHG emission estimates dating back to 1990.
The NIR and Common Reporting Format (CRF) tables comprise Canada’s inventory submission to the UNFCCC and are prepared in accordance with the UNFCCC reporting guidelines on annual inventories.
For the first time, Environment and Climate Change Canada (ECCC) posted preliminary greenhouse gas (GHG) inventory data for public comment. The objective of the comment period was to receive feedback on the transparency and accuracy of the inventory.
The comment period ran from February 16 to March 2, 2018. The following preliminary documents were made available on the ECCC Science Access website:
- Draft Executive Summary of the 2018 National Inventory Report (NIR)
- Draft Chapter 2: Emission Trends
- Draft Chapter 8: Recalculations and Improvements
- Preliminary GHG emission data tables covering 1990 to 2016 at the national, provincial and territorial levels by both Intergovernmental Panel on Climate Change (IPCC) sectors and Canadian economic sectors
Final facility-reported GHG data covering the period 2004 to 2016 and the related Overview Report from the Greenhouse Gas Reporting Program were also made available on the canada.ca website.
The final 2018 NIR was published on April 13, 2018, after taking into consideration the comments received.
What we heard: overview
The first comment period offered for the NIR received a limited response, likely due to a lack of awareness of the process and the short time period provided. Despite the limited number of respondents, the detailed and thoughtful comments received will be very useful in improving subsequent comment periods as well as the transparency and accuracy of the NIR.
Respondents offered comments both on the NIR and on climate change policy more generally. They strongly expressed the need for greater action on climate change across Canada and for Canadian governments at all levels to implement the policies needed to achieve Canada’s GHG reduction target and accelerate transition towards a low-carbon economy.
Figure 1: distribution of comments by theme
Long description
This is a pie chart showing distribution of comments by four themes.
| Theme | Climate change policy | Process | Transparency | Accuracy |
|---|---|---|---|---|
| % of comments | 40% | 23% | 17% | 20% |
Of the 35 comments received from three respondents, 40% focused on climate change policy issues. The remaining comments were relatively evenly split between process (23%), transparency (17%) and accuracy (20%). The three respondents were from a First Nation, an Inuit organization and a municipality.
What we heard: process
While respondents were pleased that the NIR was available for comment, they felt that the comment period was too short to offer meaningful input and reach out to others within their network. They also felt that they learned of the comment period too late and that others missed the window of opportunity. It was suggested that, in the future, a broader range of tools be used to notify a variety of potentially interested organizations. Some options suggested were to make greater use of social media or to connect into existing government distribution channels, such as the Northern Contaminants Program.
A First Nation respondent also noted that the lack of capacity funding or a formalized engagement process made it difficult to conduct a comprehensive review of material. Another consideration raised was the potential value of having an independent third party audit the NIR and accompanying data as a complement to the comment period.
What we heard: transparency
Respondents felt that insufficient background information was provided. In the future, they would like to have access to more disaggregated data and detail on the methodology used, including emission factors, references and the rationale for changes. They would also like a list of abbreviations used for chemicals and GHGs, and a list of other relevant documents. While most of the above information is publicly available within the NIR, there is an opportunity to improve awareness of where and how to find relevant information. Respondents noted that there are differences in GHG reporting between the NIR and some provincial/territorial reporting that should be aligned in the future. One respondent asked that medium and large emitters be required to file audited GHG data online.
United Nations Framework Convention on Climate Change definition
Transparency means that the data sources, assumptions and methodologies used for an inventory should be clearly explained, in order to facilitate the replication and assessment of the inventory by users of the reported information. The transparency of inventories is fundamental to the success of the process for the communication and consideration of information. The use of the common reporting format (CRF) tables and the preparation of a structured national inventory report (NIR) contribute to the transparency of the information and facilitate national and international reviews.
What we heard: accuracy
Respondents felt there were several areas where GHG emissions were underreported. For example, Canada’s share of international shipping and air travel is not captured. Although Canada reports emissions from these sources to the UNFCCC, there is an opportunity to improve how this is communicated to Canadians. Respondents also felt that fugitive emissions from oil and gas operations were underestimated as based on recent studies. One respondent argued that GHG emissions should be measured on a life-cycle basis, considering all emissions from extraction to decommissioning or disposal. Emissions associated with Canada’s imports and exports could also be identified.
United Nations Framework Convention on Climate Change definition
Accuracy means that emission and removal estimates should be accurate in the sense that they are systematically neither over nor under true emissions or removals, as far as can be judged, and that uncertainties are reduced as far as practicable. Appropriate methodologies should be used, in accordance with the 2006 IPCC Guidelines, to promote accuracy in inventories.
Respondents pointed out several concerns regarding the calculation of emissions. One respondent suggested making greater use of modern technology, such as optical gas imaging cameras, to increase direct measurement of GHGs rather than relying on emission factors. Another pointed to concerns with the emission factors used, while yet another argued that the latest Intergovernmental Panel on Climate Change (IPCC) global warming potential (GWP) values from the Fifth Assessment Report, including climate-carbon feedbacks, should be used. This would imply a much higher conversion factor for methane (CH4). The respondent also felt that combustion of wood should not be viewed as carbon neutral and should be considered under energy emissions rather than under land-use, land-use change and forestry (LULUCF). This argument was based on recent peer-reviewed literature showing the significant 100-year GWP of carbon dioxide (CO2) emissions from biomass combustion.
Next steps
The feedback received from the first comment period has provided significant insights and valuable information to help improve transparency and accuracy of the NIR. It will also help inform the design of subsequent comment periods.
The 2019 NIR is already under development, and preparations are underway to once again provide timely preliminary GHG emissions data and key draft material from the 2019 NIR.