On November 24, 2022, the federal government (Environment and Climate Change Canada) released the final draft version of the Strategy for a final 90 day comment period. The Strategy discusses the federal government’s role and approach to preparing for climate change hazards and outlines specific investments aimed at addressing the impacts. Information about the Strategy is available at this link.
In part because the government announced that $489M have been invested in the Disaster Mitigation and Adaptation Fund, as well as $59.5M of new funding to accelerate the use of climate-informed codes, standards and guidelines for resilient infrastructures, CDA has submitted formal comments on the Strategy. You will find the CDA submission below.
February 24, 2023
The Honourable Steven Guilbeault, P.C., M.P.
Minister of Environment and Climate Change
House of Commons
Ottawa, Ontario K1A 0A6
Subject: Final Review and Consultation - Canada’s National (Climate) Adaptation Strategy
Dear Minister Guilbeault,
The Canadian Dam Association (CDA) acknowledges the leadership of the federal government and your office in developing a National Adaptation Strategy, given the significant impact that climate change presents to Canada, as well as the need for government, private sector, stakeholders, communities and the public to collaborate on best approaches to adapting to climate change.
Please be in receipt of this submission in support of the final round of consultation on the Strategy, as well as a request for further engagement by Environment and Climate Change Canada (ECCC) with the CDA in support of implementation of the Strategy.
1. The CDA
The CDA is the pre-eminent organization in Canada of dam owners, operators, regulators, consultants, suppliers and academics interested in dams and reservoirs. CDA provides a national forum for the exchange of ideas and experience related to dams. We believe that dams play important roles related to public safety, protection of the environment and the broader Canadian economy. The CDA envisions a future in which all dams are safe, well managed and benefit society.
CDA’s mission is to encourage cooperation, advance technical knowledge and build competency related to dams in Canada. To achieve our vision and mission, our objectives include:
As ECCC may be aware, technical guidance documents produced by CDA represent the backbone of regulatory requirements used by federal, provincial and territorial regulatory departments and agencies across Canada and these guidance documents are broadly used by Canadian dam owners as a key part of their commitment to the safe construction, maintenance and operation of their dams.
CDA is committed to promoting excellence in dam engineering, construction and operation. Additional information about CDA and its activities is available at https://www.cda.ca/
2. Dams and Climate Change
Dams represent critical infrastructure and they play important roles in Canada including helping to maintain and protect water supplies, managing water levels and mitigating flood events, irrigation, hydroelectric power generation, mine waste management and remediation, enabling navigation and supporting water based recreation and tourism.
Like all other kinds of infrastructure, dams and their supporting works (e.g. flow-control systems, access roads, bridges, etc.) are vulnerable to the effects of climate change including precipitation, flood events, range of ambient temperature, permafrost thawing and land cover changes. It is broadly recognized in the dam industry that responses to climate change need to be both anticipatory (adaptation and resilience planning), as well as reactive (emergency management planning and response). Adaptation actions can help build resilience to the impacts of climate change and extreme weather events.
While CDA has prepared and maintained a series of state of the practice technical guidance documents for dam construction, operation and maintenance, it is recognized within the industry that more work is required to supplement these documents to better address climate change considerations and adaptation.
CDA of course is not alone in recognizing the need for such action. While the Strategy very correctly recognizes the need for improved technical guidance for infrastructure in the face of climate change, the Canadian Standards Association (CSA) recently commissioned a report on Climate Adaptation for Dams and is now preparing to consider further development of climate change related guidance for dams in Canada. In addition to any efforts and initiatives that CDA may undertake, the CDA and its members will be playing a key role in the oversight and technical support of CSA’s work in this regard.
As just one example on the provincial front, the Ontario Auditor General recently recommended that the Province better consider the impact on dams of climate change and increased precipitation and flooding in its November 2022 Management of Hazards and Emergencies in the Environment - Value for Money Audit.
3. CDA Comments
CDA is in broad support of both the need for and key components of the Strategy.
While the CDA supports the inclusion of all five key “systems” identified in the Strategy, the CDA has particular and well respected technical expertise that would allow it to make significant contributions towards achieving the objectives and key action items associated with two of the five systems: disaster resilience and infrastructure systems.
We strongly support the disaster resilience Guiding Principle #3 of the Strategy that recognizes that proactive, risk-based measures are required to reduce climate impacts before they occur. While CDA has issued technical guidance on emergency preparedness and response planning for dams, this material could be supplemented with climate related vulnerability assessment guidance.
Specific to the Strategy’s recognition of the importance of infrastructure systems, the CDA supports the Strategy’s call for increased investment to make infrastructure generally more robust in the face of climate change impacts and to consider the complex interdependences across the five systems.
CDA is impressed with and believes that it can make significant contributions towards the achievement of three key Strategy objectives related to infrastructure systems:
While many other forms of critical infrastructure are referenced in the Strategy, we encourage ECCC to add specific reference to dams in the final version of the Strategy, both in terms of the importance of dams to Canada’s economy, but also in relation to the Strategy’s recognition that flooding is the most significant potential impact associated with climate change.
4. Next Steps
CDA would like to meet with ECCC staff associated with implementation of the Strategy to discuss program development and funding opportunities where CDA technical expertise and its broad representation of the dam community could help support key action items in the Strategy.
Given the breadth of CDA’s membership across the dam community including fresh water and mining related dams, CDA can play an important role in helping to align and improve climate adaptation standards, actions and processes across Canada. CDA technical guidance is extensively relied upon by dam owners, the engineering profession and regulatory agencies across Canada to inform decisions on dam construction, maintenance and repair, and operations.
CDA is particularly interested in funding opportunities that could be used to supplement existing CDA technical guidance with more comprehensive consideration of climate change adaptation, resiliency and emergency management. ECCC may also wish to better understand the important role that CDA plays in professional development, communications and knowledge transfer within the Canadian dam community, as well as its outreach to international organizations that look to the CDA for its technical expertise.
We kindly request that your office direct that ECCC staff follow up with Lyne Trahan, CDA Executive Director (ltrahan@cda.ca) at the earliest opportunity to initiate dialogue between ECCC and CDA on collaborative efforts to support implementation of the Strategy.
Yours truly,
Michael Cyr P. Eng., PMP
President
Canadian Dam Association
c.c.
Adaptation@ec.gc.ca
Lyne Trahan, CDA Executive Director
Jarrod Malenchak, CDA Dam Safety Committee Chair
