Alternatives North Comments on 2025-2029 Draft Climate Change Action Plan

During the past 12 months the global mean temperature has reached 1.620C, well beyond the Paris goal of <1.5. Impacts, everywhere, are obvious and accelerating in frequency and intensity. In the NWT, our government is going broke from incurring the cost of impacts (e.g. wildfires, floods, droughts) and necessary remediation. Yet given this crisis, how can our first goal be “a strong economy?” Is it not clear by now that we can only have a steadily weaker economy as climate impacts steepen and accumulate? And that we need a clear and focused plan for getting off of fossil fuels as fast as possible with the technology available today? Indeed, our continued reliance on fossil fuels is becoming a key barrier to development of new mines or any other economic development. This does not need to be the case – a combination of energy efficiency, renewable diesel, biomass, and carbon markets could make the NWT a climate leader at net cost that is lower than what is proposed in this Action Plan and the accompanying Energy Strategy.

Urgency needed now to head off impacts

The missing urgency in the document, and the distracting focus on studying the situation, underscores either a lack of understanding of what action is needed, or a failure to appreciate the severity of approaching consequences. None of those many detailed actions listed for Goals 2 and 3 will prevent permafrost thaw, devastating wildfires, community flooding, deeper droughts and so on. Without rapidly reducing emissions, impacts will migrate beyond our ability to adapt.

Expand efforts to reduce emissions

Alternatives North recommends that the appropriate way forward is to substantially reduce consumption of fossil fuels as a clear and focused first priority and clearly elucidated in this plan. It is encouraging to see that this Action Plan looks at ways to reduce emissions that are beyond the scope of the Energy Strategy. There is quite a bit of room to expand on these initiatives.

Better ways to use Carbon offsets

Carbon offsets are mentioned in the action plan, but only in the sense of how the NWT could sell landscape-based offsets to other jurisdictions. Carbon trading goes both ways and the GNWT should use all tools available to meet much more ambitious targets in reducing emissions. Purchasing Gold Standard Offsets on the voluntary market or purchasing credits in the Western Climate Initiative could provide a credible means of achieving rapid reductions in the short term at a relatively low cost.

Carbon pricing should be applied equally across all sectors

The Climate Change Action Plan includes a brief mention of continuing to implement the NWT approach to federal carbon pricing. There is no detail on what this “NWT approach” to carbon pricing is and recent actions by the GNWT have been focused on exemptions rather than effective implementation. We suggest that if the GNWT had a credible, ambitious Climate Action Plan with legally binding reduction targets along the lines we propose, the federal government would be much more likely to provide flexibility in how the GNWT implements carbon pricing. We suggest that the carbon price be applied equally to all sectors of the NWT economy with generous rebates provided to individuals. At the same time, substantial resources must be provided to enable all sectors to transition away from fossil fuels. As carbon pricing is a key emissions reductions policy, we suggest that the lead for setting carbon pricing policy be moved to ECC, while FIN continues to collect the revenue.

Old Vision

This document continues to use the old vision from the original Climate Change Strategic Framework as follows: “By 2030, the NWT will enjoy a strong, healthy economy that is less dependent on fossil fuels (compared to 2005) and will have developed the knowledge, tools, and measures needed to increase resilience and adapt to the changing northern climate.”
It is our understanding that GNWT has already committed to net zero emissions by 2050 in the most recent budget and as reported in the media – N.W.T. gov’t commits to reaching net-zero emissions by 2050 – so it is not clear why the old vision still appears in this document. While our preference is an immediate and continuing focus on rapid reduction of GHG emissions to avoid catastrophic impacts, this action plan should at least reflect the current GNWT position.

Clarity on Mandate, Integrated Planning, and Accountability

We note in the proposed Action Plan that many of the individual initiatives and actions are to be undertaken by multiple parties. This does little to ensure accountability and leadership. There needs to be one department with one Minister in charge of GNWT’s climate change efforts. That authority should be laid in purposeful legislation on climate change. This approach is entirely consistent with the findings of the Auditor General of Canada who conducted an audit of GNWT’s efforts in 2017. GNWT’s current approach is fragmented with little visible coordination among the Climate Change Strategic Framework, Energy Strategy and the carbon tax.

GNWT should develop and put into place, a Climate Change Act to create the necessary leadership and accountability to ensure successful actions and outcomes related to the climate crisis. This will also require bringing together GNWT separate climate change initiatives under its strategic framework (Environment and Climate Change), energy strategy (Infrastructure) and carbon tax (Finance).

• 1. The Act should include specific, legally binding emission reduction targets (compared to 2005 levels) for the entire NWT, including industry:
  • I. 30% by 2027
  • ii. 60% by 2030
  • iii. Net zero by 2050

• 2. The Act should require the purchase of carbon credits through the Western Climate Initiative (WCI) markets to meet reduction requirements, if they are not met by other means
• 3. The Act should apply carbon pricing to all sectors of the economy equally, with generous cost of living rebates for individuals
• 4. The Act should establish an NWT Clean Fuel Standard to require that Fossil Diesel be blended with increasing percentage of Renewable Diesel (similar to BC and Federal Clean Fuel Standards)

Faulty Premise in the Energy Strategy (re: Goal 1 of the Draft Action Plan)

GNWT has made a fundamental error in relying upon the long-term Taltson project and distributing electricity over expensive, long-distance grids, rather than managing energy demand than meeting it with locally and regionally derived renewable energy. As GNWT states on page 6 of the Energy Strategy (which this plan refers to for Goal 1 actions). “Most of the GHG emissions in the NWT are related to industry, and to meet our commitment we need a transformative project to provide renewable energy to industry. Transformative projects like the Taltson hydroelectric expansion are a first step in a longer-term vision to connect the North and South Slave electricity grids with the North American electricity system, and— combined with the development of transportation corridors—to connect mines in the Slave Geological Province to renewable and sustainable energy to support industry.”

Taltson expansion not supported by real world economics

The economics do not support this vision, nor would the expansion yield the emission reductions in the time-frame we have or on the scale needed. Mines must generate their energy needs on-site to the greatest extent possible – in fact, many will prefer to. This is becoming increasingly doable as generation and storage technologies evolve, and efficiencies improve. To the extent industry cannot meet its energy needs through local renewable generation, it must be given a scheduled mandate to require energy demand be met with steadily greater use of renewable fuels available on the market. An industry-wide mandate would provide the level playing field required, and also establish a transparent standard that would be appreciated by industry clients.

The Problem of Positive Feedback Loops and Escalating Rates of Fossil Fuel Combustion

As emissions are added to the atmosphere, climate impacts increase in frequency and severity. Responses to date have usually meant even greater fossil fuel consumption and thus yet more emissions. The impact events themselves can also directly increase GHG emissions. We note the following recent examples from the NWT:

a) Community resupply issues associated with low water levels, deteriorating ice roads, forest fires restricting access often results in airlifts of freight, with higher emissions;
b) Unprecedented NWT Forest fires cause extreme GHG emissions, both directly and indirectly through the necessary actions of fighting fires, community evacuations, establishing community buffer zones and infrastructure rebuilds – all which are done using fossil fuels.
c) Challenges of the rehabilitation efforts at the Taltson River hydroelectric station have left the entire South Slave region dependent on diesel generation for over a year, and counting.
d) Repeated yet futile efforts to stabilize the shoreline at Tuktoyaktuk, with increasing requirements to move the community away from its current site.
e) Community evacuations and rebuilds due to flooding.
f) Extreme droughts that cause low water levels, preventing normal hydroelectricity generation and thus increasing the need for diesel generation on the North Slave Grid. Droughts seem to be becoming more frequent, longer and more severe with emission ramifications for the long term if so.
g) Continual extraordinary repair of highways, airstrips and building foundations.
h) The use of LNG is now confirmed as having GHG emissions as bad as, or worse than coal. GNWT’s shift to transport and increase the use of LNG in the Mackenzie Delta has increased methane emissions which are known to have much worse warming effect than carbon dioxide.
i) Industry is putting ever more effort into building ice roads, and into stabilizing structures during operation and closure in response to the need to meet long-term impacts of climate change given ongoing and widespread lack of government response to prevent extreme warming.
j) Number of vehicles has more than doubled in the NWT from 1989 to 2022; in particular vehicles with large fuel demand have increased much more rapidly – Number Of Registered Vehicles By Type – Dept. of Statistics.

Noticeably, it’s the positive feedback loops characteristic of climate change that underlay many of these impacts, and that hold the greatest threat. The only way that might be possible to stop this apparent trend is through all-out efforts to rapidly and substantially reduce anthropogenic GHG emissions.
Critically, it also requires a strategy to ensure efforts that seek low-emitting actions in response to climate impacts. A brief review of the above points reveals how we are currently doing the opposite, and thus exacerbating the problem. Yet we see no acknowledgement of this dilemma, or attempt to deal with it in the plan.

The Desperate Need and Significant Rewards of Becoming a Climate Leader

The globe is in desperate need of exemplary leadership on the biggest issue of our times – the changing climate. The naïve portrayal in Goals 2 and 3, climate research and adaptation, in the plan – that we have the time for long-term studies or that we can adapt to the degree of changes to be realized — reflect a lack of appreciation for the severity of impacts and the time available to us to substantially reduce climate change before we lose any hope of control. Yes, we do need to understand climate impacts and we do need to adapt to the extent possible, but we will fight a losing battle if we do not simultaneously prioritize acting on the knowledge we already have and focus first and foremost on mitigation. If the current cost of impact mitigation is already leading to ravaged government budgets and increasing debt, with now annually discernible rising impacts to deal with, what does the future hold for us?

The Northwest Territories has the opportunity to be a climate leader and provide an example of a responsible and progressive government approach to climate change on behalf of our residents and our young people’s future. Should we choose to do so, we would be met by unimagined cooperators and federal supports recognizing such actions. Now that would be ‘doing our part.’

Specific Recommendations

1. You’ve asked about ambition before. The plan should follow the science, which we believe calls
   for about 60% reduction from 2005 by 2030.
2. Revise the plan to focus on how GNWT will act to achieve rapid and more ambitious reduction in GHG emissions (Goal 1), stipulating targets and deadlines for each action.
3. GNWT acknowledges that most emissions come from industry (page 6 of Energy Strategy). Bring that focus to the plan, showing where, how and by when industrial emissions will be reduced over the next five years.
4. For actions involving residents and businesses, clearly identify the new and effective policies and actions planned, focusing on those that with implementation will provide systemic opportunities and supports to engage the public and make it easy for them to participate in energy switching. All actions should be accompanied by identification of clear targets, responsible party, and completion date. Take the lead to implement cost-effective actions (lowest $/tonne) in NWT communities:

5. Given the record of highly fossil fuel-consuming responses that are occurring in the NWT as climate impact events and severity accelerate, there is a need to identify and prepare responses that minimize fossil fuel consumption to avoid worsening positive feedback loops.
6. The many significant opportunities for increasing energy efficiency and reducing demand do not seem to be pursued with any vigour. One member of Alternatives North has identified a simple and highly cost-effective way to reduce electricity demand in Yellowknife by about 1 MW/year simply through effective use of timers for block heaters on vehicles. Such pursuits are the most cost-effective and emissions-effective, yet receive short shrift in the plan.
7. The excessive detail in listing the many studies and plans the government does, intends to do, facilitates or hopes for; the omission (by relegation to the Energy Strategy) of mitigation from the plan; the inattention to mitigation and lack of urgency all contribute to opaqueness and inefficiency, reflect divided and ineffective government leadership on climate change, and cause a lack of focus and effective planning. We recommend a stand alone Climate Mitigation Plan focused on Goal 1 that gathers all mitigation actions under one plan and one authority. For actions in Goal 2 (study it) and Goal 3 (Adapt), include them in an Adaptation Plan but remove all of the basic government business actions that muddle the document and place them in an appendix.

8. Transportation – It is worth noting here that much of industrial emissions are from transportation of fuel, and that efforts to derive renewable energy at the mine sites (for heating, local transportation or whatever) will also reduce transportation emissions.

• On industry transportation, we note growing interest in testing airships, such as in the recent
  plan in Australia using Canadian technology. Would this be worth considering for NWT?

• Alternatives North has previously identified the opportunity for immediate emission reductions
  through the adoption of subsidized Renewable Diesel (RD) to meet many of our fuel needs. A new RD plant is being constructed in Strathcona Alberta. IsGNWT working to ensure that production includes arctic grade RD, and that the NWT has access to a guaranteed supply?

9. Health and Well Being – a significant deterrent to health and well being is the direct impact of inhaling some of the many carcinogenic components of exhaust from the combustion of fossil fuels. The considerable health benefits to be gained by reducing consumption of fossil fuels in communities seems to be ignored in this section.