Downstream Emissions in Canada’s New Environmental Assessment “Climate Test”

The view from my family's cottage, roughly 50km away from the Energy East pipeline's proposed route.

The view from my family's cottage, roughly 50km away from the Energy East pipeline's proposed route. Photo credit: Lindsay Randell

In late January 2016, Canada’s federal Minister of Environment and Climate Change, Catherine McKenna, and Minister of Natural Resources, Jim Carr, announced interim changes to environmental assessment processes as part of “efforts to restore public trust.”

One of the changes is to assess “[d]irect and upstream greenhouse gas emissions linked to projects under review.” This is a tremendous development, but it does not go far enough.

The government must include downstream emissions if they want to fully assess the climate impacts of a proposed project. In this blog post I explain why. Furthermore, I give a couple of examples for further guidance and a jumping off point.

Excluding Downstream Emissions Ignores Too Much

Generally, a pipeline project’s direct emissions include those from the construction and operation of the pipeline itself and its upstream emissions include those from exploration, production, extraction and processing of the fossil fuel products that are transported through the pipeline.

That GHGs from both the project itself and upstream fossil fuel projects will now be evaluated in federal environmental assessments (EAs) is good news. However, the current approach will leave a gap between the total GHGs a project will cause and what the proposed climate test will include. As one might expect, downstream emissions—particularly end-use combustion—would dramatically increase the emissions to be assessed, since the majority of the GHG emissions from fossil fuels are released when they are burned.

International Examples

Should the Canadian government decide to incorporate downstream emissions into the climate test, there are examples they could look to for guidance. Although few in number, there are some jurisdictions whose EAs include an assessment of downstream GHG emissions. I would like to highlight two prominent examples south of the border: the U.S. state of Washington and the U.S. Council for Environmental Quality.

A Washington Department of Ecology guidance document provides that GHG emissions arising outside “its jurisdiction, including local or state boundaries” that are “proximately caused” by a proposed project should be built into the project’s EA. While the guidance document does not conclusively bring in end-use emissions, recent project EAs in Washington include them.

A second U.S. example is the Council for Environmental Quality’s Revised Draft Guidance for Greenhouse Gas Emissions and Climate Change Impacts, which will ultimately be the policy guide followed for EAs conducted under the National Environmental Policy Act. Under the CEQ Guidelines, GHGs resulting from “activities that have a reasonably close causal relationship to the federal action, such as those…as a consequence of the agency action” are included in the project’s EA. Unfortunately, “[a]s a consequence of the agency action” is not defined. However, a positive sign is a hypothetical EA for an “open pit mine” in the CEQ Draft Guidelines that lists GHGs resulting from “transporting the extracted resource, refining or processing the resource, and using the resource.”

These examples are not perfect, however they provide a baseline that can be altered and improved upon with research and collaboration with communities, academics, officials from other jurisdictions, NGOs, etc.


Downstream emissions should be considered in Canadian EA processes even though most of them will not occur in Canada and therefore the Canadian government cannot influence or change them.

Just because most downstream emissions will happen abroad doesn’t mean they do not contribute equally to the total global concentration of GHGs. This is an obvious point, but it needs to be emphasized in the context of Canada’s leadership role in the COP21 negotiations, and assertions that “Canada is back.”

To ignore overseas emissions is to ignore Canada’s actual contributions to climate change. And despite these emissions' foreign sources, everyone will feel their impact.

If Canada is going to be a truly global leader in tackling climate change, our government should fully account for emissions caused by Canadian fossil fuel projects.