Last March I penned an open letter to Prime Minister Harper asking him to recognize that the global atmosphere was at least as essential to our national security as pipelines and highways. We didn’t receive any response from the Prime Minister’s office, so in July, Ashley Thomas (one of our great summer students) and I filed an environmental petition with the Commissioner for Environment and Sustainable Development asking Public Safety Canada whether it agreed that the global atmosphere fell within its definition of critical infrastructure.
In brief, we learned that Public Safety Canada recognizes that climate change can have a huge impact on Canada’s security, but that – other than preparing for climate-related risks to “critical infrastructure” – addressing climate change is not its responsibility. But since the agency that is responsible – Environment Canada – says that it had no answers to our questions, we’re left with the impression that the Canadian government as a whole, at least to date, has not appreciated the security implications of climate change.
The Environmental Petition
We sent an environment petition directed at Public Safety Canada because most of the federal departments are required to reply to environmental petitions within 120 days; Canada’s Commissioner of Environment and Sustainable Development monitors to make certain that you get a reply. It’s a cool process that we’d like to see more people using.
Our environmental petition picked up where my open letter left off, pointing out that the U.S. government recognizes climate change as a security risk, and asking whether Public Safety Canada recognizes that the global atmosphere is “critical infrastructure”, on par with pipelines, electrical transmission lines and highway, amongst other sectors. Our petition explained:
In 2010 the National Strategy for Critical Infrastructure, (“National Strategy”), which set out general policy related to critical infrastructure, gave the following definition of the term:
Critical infrastructure refers to processes, systems, facilities, technologies, networks, assets and services essential to the health, safety, security or economic well-being of Canadians and the effective functioning of government. Critical infrastructure can be stand-alone or interconnected and interdependent within and across provinces, territories and national borders. Disruptions of critical infrastructure could result in catastrophic loss of life, adverse economic effects, and significant harm to public confidence. …
The atmosphere plays a critical role in sustaining life on the planet (including in Canada), and in moderating the temperature of the globe and determining weather patterns. Interfering with the atmosphere affects the health, safety, security and economic well-being of Canadians as discussed above. The atmosphere is interconnected across provincial, territorial and national borders and is a matter of national security. Disruption of the atmosphere is already resulting in the loss of life, adverse economic impacts and significant harm to public confidence, and if left unchecked, atmospheric disruption poses further, significant risks to future generations. It is therefore significant that the atmosphere has been omitted from the National Strategy’s list of critical infrastructure sectors.
We set out a number of questions asking Public Safety why the global atmosphere did, or did not, fall within the definition of critical infrastructure.
Public Works Canada’s response: the global atmosphere is a resource, not critical infrastructure
As I understand it, Public Safety Canada argued that the list of “10 critical infrastructure sectors” was developed first, and then the definition was created to describe what those 10 infrastructure sectors had in common. It was not intended that other sectors/systems that met the definition would be added to Canada’s National Strategy on Critical Infrastructure. Public Safety wrote:
The description of critical infrastructure in the Strategy is not intended to be an exclusionary definition that can be used to determine whether an asset or system is considered critical infrastructure. Rather, it is a description of characteristics common to critical infrastructure as organized into the ten sectors.[…] These ten sectors were identified based on extensive consultation with the private sector, non-governmental organizations, as well as provinces and territories. In addition, these ten sectors were recognized as part of the Strategy, which was approved in 2010 by all Federal, Provincial and Territorial Ministers responsible for emergency management.
A possibly ironic point here: this was a government that failed to work with the provinces on climate change, but was able to work closely with those provinces to finalize a national strategy on “critical infrastructure.”
But in fairness to Public Safety, I’m guessing that the global atmosphere and climate change really weren’t raised frequently, if at all, in the consultations that they’re talking about, and that’s because Canadians have not internalized the threat we face from climate change.
That being said, Public Safety did recognize that the global atmosphere “plays a critical role in sustaining life and is therefore essential to the health, safety, security and economic well-being of Canadians...”, and is (along with other “important resources”), “essential for the continuity of all ten critical infrastructure sectors...”
However, Public Safety’s role is apparently limited to:
continu[ing] to work with lead federal departments and agencies to encourage critical infrastructure owners/operators to take into account the effects of climate change in carrying out their risk management activities.
The Department’s reply said that “matters relating to the atmosphere are not explicitly within Public Safety Canada's mandate,” and referred us to Environment Canada. On one level, of course, that is not a surprise, as Environment Canada does clearly have a lead role on climate change. That being said, our point was that an issue as critical to the health and safety of Canadians, and our national security, does not fit neatly within one Department’s mandate. However, that does bring us neatly to …
Environment Canada’s response: we have no response
We did also receive a reply from Environment Canada. Given that Public Safety Canada referred us to them as the lead agency, we read their very brief response with interest.
As the issues raised in your petition fall outside of Environment Canada's mandate, the Ministers of Agriculture and Agri-Food, National Defence, Finance, Industry, Natural Resources, Health, Public Safety and Emergency Preparedness, and Transport will be responding to your questions.
This we found remarkable. Granted the questions in the environment petition were about the atmosphere’s status (or non-status) as critical infrastructure, but surely Environment Canada does have a perspective about whether we should treat climate change as if it was about national security, and our global atmosphere as if it were critical infrastructure.
Other Ministry responses: we’re adaptable
As the Environment Canada response suggests, we did receive replies from several other government agencies, although in some cases the Ministry just said that they had nothing to say (Finance Canada referred us back to Public Safety and Environment Canada). Those that did provide a substantive comment were generally replying to our question #9:
9. In what ways do the sector forums recognize and evaluate the threats to critical infrastructure posed by harm to the atmosphere? What specific plans have been prepared to address the impacts of harm to the atmosphere on each sector?
In general the replies sought to reassure us that climate change was being considered in planning for critical infrastructure, often as part of a more general consideration of risks to the industry. Although not always. In relation to the manufacturing sector, for example, Industry Canada wrote simply:
Currently, there is no active consideration being given to atmospheric effects by the manufacturing sector network.
For those interested, here are the replies which included substantive comments, from Industry Canada, Transport Canada, and National Defence Canada.
Not answered: “perhaps the biggest threat to confront the future of humanity today?”
Public Safety Canada did, to its credit, answer most of the questions we put to it. All but one.
Our question 10 asked:
How does the Department reconcile the failure of the National Strategy for Critical Infrastructure to recognize the atmosphere as critical infrastructure with the Prime Minister’s statement that climate change is “perhaps the biggest threat to confront the future of humanity today?” Does the Department agree with that statement, and what steps does it intend to take to address this security issue?
The response from Public Safety Canada reiterates some of its efforts to ensure that Canada’s critical infrastructure is resilient, but entirely fails to indicate whether it agrees with former Prime Minister Harper’s stated assessment of the security risk associated with climate change, or what steps it intends to take to address that issue (beyond promoting resilience for critical infrastructure).
A challenge to the new Canadian government
It’s probably a huge understatement to say that tackling climate change is not easy. It’s probably more challenging than most international security issues.
But until now we haven’t been treating it as a security issue going to our health, safety and economic wellbeing – just as an environmental issue.
There are signs that the incoming Canadian government is treating climate change more seriously than was the case under the previous administration, and that’s welcome. However, it does require the seriousness that we would give a national security issue … because it is.
By Andrew Gage, Staff Counsel