Dear Jonathan Wilkinson,
Minister of Environment and Climate Change

We, the undersigned, call into question a number of facets of the recent Bill C-12: An Act respecting transparency and accountability in Canada’s efforts to achieve net-zero greenhouse gas emissions by the year 2050, which has been submitted to the House of Commons. This Act lacks diving urgency and makes clear that the Canadian government does not take the climate crisis and the resulting loss of life, infrastructure, health, and biodiversity seriously. To begin, we want to stress the necessity of aggressive climate action and note that the pursuit and achievement of net-neutrality by 2050, though an important step, is insufficient in avoiding the most catastrophic effects of climate change. Whereas net-neutrality relies on ensuring that, as the Act states, “anthropogenic emission of greenhouse gases into the atmosphere is balanced by anthropogenic removals of greenhouse gases from the atmosphere over a specified period”, this does not account for the detrimental environmental impacts to the land, water, biodiversity, and human life that comes of resource extraction and a carbon-based economy. Carbon offsetting methodologies are poor substitutes to a just energy transition that would lessen both emissions and ecological damage.

It must be addressed that the original goal of the Paris Agreement, to limit global temperature rise to 1.5 °C below pre-industrial levels by 2050 has been surpassed in only 5 years, and we are now fighting for 2 °C. For this reason, it is undeniable that we not simply plan to meet the Paris Agreement, we need to aggressively and effectively go beyond recommendations. We also would like to note that in the introduction to the Act it is stated that, “Whereas climate change is a global problem that requires immediate action by all governments in Canada as well as by industry, non-governmental organizations and individual Canadians”; this statement implies equal blame can be placed on individual Canadians as on industry and governments. It also fails to address the discrepancies in responsibility between class and race demographics within the population.

Lack of Accountability:

We note that this bill has subtitled An Act respecting transparency and accountability in Canada’s efforts to achieve net-zero greenhouse gas emissions by the year 2050, however, we have serious concerns as to how the Minister will support and maintain accountability. As an example, section 16 states: If the Minister determines Canada has not achieved its greenhouse gas emissions target they must include the following in the assessment report: “(a) the reasons why Canada failed to meet the target; (b) a description of actions the Government of Canada is taking or will take to address the failure to achieve the target, and (c) any other information that the Minister considers appropriate.” We are of the opinion these accountability measures are weak and non-binding. These points for assessment are vague and do not cover the scope of accountability that climate consequences demand. They do not require the Canadian government to hold themselves accountable for the climate refugees and death that will result from missed targets. They do not hold the Canadian government accountable for the loss of biodiversity, a social injury that will come from the deterioration of our planet.

We have allowed governments to hold themselves accountable for far too long, and witness that privilege be misused. Without an independent external investigation and body monitoring the Minister’s actions and holding the government liable for misconduct or negligence, there is no meaningful accountability in these processes. We demand there be binding contingency plans in place for the government to make amends for the aforementioned devastations if they fail. Turning to section 11 it is stated, ” The Minister may amend an emissions target set under section 7 or an emissions reduction plan in a manner that is consistent with the purpose of this Act.” Under our interpretation, this allows for the Minister to justify negligence when it comes to setting and meeting targets.

Ineffective Timelines:

We affirm that the timeline targets of this bill are insufficient. Goals that demand immediate action and structural changes are necessary. Reduction targets cannot be set far enough in advance to allow them to be set aside until the last minute. A structured, step by step plan for a transition during the decade leading up to 2030 is required. Based on the lack of clear and immediate deadlines, it is obvious that the Liberal Government does not see the urgency of this encroaching disaster. Thus in order to consider the Act acceptable/passable, we demand a meaningful 2025 target for reduction in carbon emissions from 2010 levels, and plans are made for swift implementation.

Consultation and representation:

The bill states that an Advisory Board will be established, “composed of no more than fifteen members, who are appointed on a part-time basis for a renewable term of up to three years.”

This advisory committee must be both qualified and inclusive. We advocate that youth organizers should be actively consulted in the drafting of bills such as C-12, the process of its amendment, and be included in the Advisory Board to the Minister moving forward.

We note that the bill references UNDRIP, but lacks any clear intention to include Indigenous voices in the drafting of this bill, or in the creation of the Ministries advisory board. Indigenous peoples protect 80% of today’s remaining biodiversity and disproportionately bear the consequence of climate change. It is unacceptable for Indigenous peoples not to have been consulted in the drafting of the Act, nor would it be acceptable to exclude Indigenous voices from the advisory board. As we’ve learned, if climate action doesn’t include and uplift the struggle for Indigenous sovereignty, it is not worth having.

For an Act with the word “Accountability” in its title, it is starkly void of real accountability. This legislation does not hold the Canadian government accountable to the extent necessary to enforce change. With timelines that are weak and counterproductive and no representation from Indigenous peoples or youth, this legislation is another attempt to sway public opinion into believing this government cares about solving climate change, while it stands as a blatant attempt to greenwash the public opinion of the government.

Signed,

Climate Strike Canada

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The Divest Canada Coalition: