To: Minister of Environment and Climate Change


Dear Minister Guilbeault,

I am writing pursuant to s. 76(3) of the Canadian Environmental Assessment Act, 1999, to formally request you to add thermal coal to the Priority Substances List, and as soon thereafter as possible, to the Toxic Substances List. This will enable you to regulate the mining, use, export and import of thermal coal in Canada.
I commend your government for playing a leading role under previous minister Catherine McKenna in establishing the international Powering Past Coal Coalition. I am grateful for your recent decision to deny the Province of New Brunswick an extension to continue burning coal past 2030. I thank your government for the recent election commitment to ban the export of thermal coal from Canada by 2030. However, given the vanishing carbon budget and the imminent risk of going past 1.5 degrees C global average temperature increase, our Paris goal, we believe it is essential that the export ban be put into effect as soon as possible.

The reasons for my request are as follows:
1) Burning thermal coal is the single largest contributor to climate change and a major source of toxic pollution that harms human health.
(See: Environment and Climate Change Canada News Release dated June 11, 2021):

2) The physical effects of climate change pose serious risks for Canada, including:
a) a reduced ice cover and degrading permafrost in the North affecting community infrastructure and traditional ways of life;
b) ecosystem changes and shifts in species distribution affect Canada's species at risk and food supply;
c) increased frequency of drought brought on by climate change affects forests and agriculture, posing a risk to productivity and livelihoods;
d) more frequent heat waves and vector-borne diseases affect health and health systems;
e) increased wildfires put lives at risk and pose risks to wildlife;
f) rising sea levels and increased erosion affect coastal infrastructure; and
g) more intense rainfall increases inland flood risk, landslides, destruction of railway lines, bridges and highways resulting in disruption of supply chains, damage to urban infrastructure and housing as well as to farmland and food production.

3. Canada’s greenhouse gas emissions have increased since the Paris Agreement was signed, making it the worst performing of all G7 nations since the 2015 Conference of the Parties in Paris, France. In 2021, the government announced its new target of a 40% to 45% reduction below 2005 levels by 2030, and a new target of net-zero emissions by 2050. The government now must revisit its plans, policies, and actions needed to achieve these new targets, focusing on meeting the targets, and not just making plans. Adding thermal coal to the Priority Substances List and the Toxic Substances List, then fast-tracking regulations to ban the import, export, burning and mining of thermal coal would give the government a jumpstart toward meeting the new targets.

I look forward to hearing how you intend to deal with my request, and your reasons for dealing with it in that manner.


Why is this important?

Thermal coal is one of the worst contributors of GHGs that promote climate change. Banning the mining, export, import and burning of thermal coal in Canada would be a significant step in reducing climate change. The Canadian Environmental Protection Act provides a mechanism for the public to use to accomplish this. After last summer's wildfires and the catastrophic flooding last fall, Canadians realize that climate change is here now, and feel compelled to do something to stop or reduce it before their communities are destroyed.