Thank you very much, Madam Chair and honourable MPs, for inviting me to join you today. My name is John Smol and I'm a professor at Queen's University, where I also hold the Canada research chair in environmental change.
While I am not an expert on the Canadian Environmental Protection Act, I am someone who has been involved in environmental monitoring and environmental issues in this country for over three decades. I also acknowledge that I seem to be offering more problems than solutions, but recognizing problems is an important first step, I think, to finding solutions to them.
The world has changed a lot since CEPA's inception in 1999 and especially on the environmental front. We have many new challenges, but also new understandings of how ecosystems are being affected by human impacts.
First, I think we have to realize that we have opened a perpetual Pandora's box of new stressors, as we release new problems for the environment to cope with on a daily basis. Many of the new and emerging problems are chemical in nature, which is a major focus of CEPA, but they are also compounded by biological issues, such as exotic species, and physical changes to our environment, such as habitat disturbance and climate change. Many of the effects of these stressors are interactive and additive, or even multiplicative, often resulting in unpredictable interactions leading to even more complex problems. In simple terms, our world is getting more difficult to predict.
I am reminded of the Red Queen's race in Lewis Carroll's Through the Looking-Glass, where the Red Queen and Alice are constantly running but remain in the same spot. In some respects, given the complexity of new environmental issues, standing in the same place might be the most optimistic viewpoint we might have, unfortunately. I feel we are constantly falling behind, despite our efforts. How do we evaluate whether we are falling behind or improving when it comes to the overall environment?
This brings me to my first recommendation. Improve the generally poor state of environmental monitoring in this country. The only way we can know what our baseline conditions are, how our ecosystems are changing, and whether our environmental policies, laws, and regulations are in fact working is to know what is happening in the environment, and that requires effective, evidence-based monitoring.
The situation is complicated when proponents or polluters are authorized to carry out their projects and development on the condition that they self-monitor the effects of their own actions. In my experience, self-monitoring by proponents can often fall well short of the mark because it is typically not subject to peer review, which is the underpinning of legitimacy of all science.
Proponents can turn in thousands of pages of documents without independent and scientific checks, or most importantly, follow-ups to ascertain whether the proponent-based monitoring is effective. In many cases I think it may not be. Of course, I believe in the principle that the polluter pays and that proponents should be paying for the monitoring, but it is the job of independent scientific bodies, like our government, to oversee and scientifically assess these efforts.
I had first-hand experience in investigating one such monitoring program in the oil sands, when I was asked to be part of the six-person oil sands advisory panel back in December of 2010. Yes, monitoring was ongoing and the consultants doing the monitoring were, by and large, doing exactly what they were tasked with, but the scientific underpinnings of what should have been the backbone of the monitoring program had disappeared. A scientific monitoring program needs scientific oversight. The federal government has outstanding scientists who are well prepared for this oversight, perhaps with assistance from universities or other institutes.
Financial considerations are often a quick and easy excuse to cut environmental programs. However, it is well established that it is best, and certainly cheaper, to recognize these environmental problems early. Looking to the past at acid rain, something I was involved in when I was younger, as an example, and since we always worry about how much things cost, it is legitimate to ask whether the acid rain monitoring program was worth it to identify and deal with this problem.
Researchers did such an analysis in 2005 in the United States. They calculated that the cost of monitoring was about one-half a percentage point of compliance costs and less than one-tenth of a percentage point of the estimated health and ecosystem costs. Similarly, the U.S. EPA concluded that the estimated costs of cleaning up industrial groundwater contamination is often 30 to 40 times, and sometimes up to 200 times, greater than the costs associated with simply preventing the contamination from happening in the first place.
It sounds as if monitoring is a bargain. Surely, we can learn from history and realize we should be increasing our environmental monitoring and research. This, however, is not happening.
My second overall point, as I said at the start of this presentation, is that we keep opening new Pandora's boxes, continually developing new stressors and releasing them into the environment before their environmental impacts are sufficiently understood.
CEPA is very chemical-focused and often seeks to control chemicals individually, based on assessing the impacts of individual chemicals in isolation with little regard to their cumulative, interactive, or long-term impacts. Assessing individual chemicals in isolation from other compounds and natural stressors, as well as anthropogenic stressors such as climate change and habitat degradation, is overly simplistic and may create unacceptable environmental risks.
In Europe, the idea of trying to assess and regulate chemicals by considering the environmental mixture and how a new chemical might contribute added toxicity to the chemical soup is emerging as part of their evolving regulatory framework. This might fit well in an updated CEPA.
My third point is that there are certainly more opportunities to improve chemical-based monitoring by bringing in biology, so-called biomonitoring. Biological organisms are excellent indicators of environmental conditions and provide the ability to track not only chemical stressors but the cumulative impacts that have ecological and economic relevance.
It may seem naive for me to recommend increases in the breadth and resources to support enhanced environmental monitoring. But we spend a lot of time talking about how much a new science initiative costs and very little into considering how much inaction costs in the long term if we choose not to avoid or mitigate environmental harm before it occurs.
Universities are not appropriate places to undertake long-term monitoring programs. It is not consistent with our primary research mandates, nor is the tri-council funding structure amenable to supporting long-term monitoring programs. Clearly, monitoring is the domain of our government programs and scientists who can work under national mandates and have access to national networks of environmental laboratories and opportunities to collaborate across departments. In my opinion there are some successful templates of such programs already, perhaps the northern contaminants program, which is celebrating 25 years of activity in 2017.
My fourth point addresses the issue of institutional silos in government. We often hear phrases like “ecosystem management”, which sounds good and makes good press but is not being achieved because it relies on different departments working together, despite having different priorities, different mandates, different legislation, and different programs and budgets.
I want to emphasize that over my career, many of the finest, most dedicated, and hard-working scientists have been in the federal government. This brings me to the last point I have time for; Canada must invest in and support the highly skilled scientists who can actually do the job. To do so effectively will involve continuing with important research programs to fill in gaps in understanding. This new knowledge will allow you legislators to integrate the results of relevant science into the decisions you collectively make in drafting new legislation or amendments or the rigorous science-based decision-making, which is a central premise of this current government.
Canada could and should be leading in both fundamental and applied research. Historically Canada has punched far above its weight in areas such as freshwater and marine science. Not allowing and encouraging government scientists to continue to engage and collaborate in world-class research programs is a waste we cannot afford.
Research gives us options and when it comes to the growing number and importance of major environmental issues we are now facing, we are going to need all the options we can get. In the end, we have to remember the environment does not negotiate. Nature is slow to pardon our mistakes. We need the air, soil, and water. The air, soil, and water does not need us.
Thank you very much.