An Open Letter to the Minister of Finance o Charities Act includes better quality reproductions of relevant images and screenshots – this blog presents the main text of the letter. These are our opinions.

Oct. 12, 2018

The Honorable Bill Morneau

Member of Parliament for Toronto Centre & Canada’s Minister of Finance



Minister Morneau,

RE: Comments on proposed changes to the Charities Act in the 30-day consultation period

We address your request for comments in the following pages and in an open letter we posted to our blog as we believe these matters to be in the public interest.

Part of the proposals to revise the Charities Act concern the removal of limitations on political activity.

We submit that many Canadian Charities are already far too politicized, and several charities are clearly acting on behalf of offshore or corporate interests, to the detriment of Canadians.  Detailed examples are listed in the Appendix.

Implementing Recommendation no. 3 of the Report of the Consultation Panel on the Political Activities of Charities to allow charities to pursue their charitable purposes by engaging in non-partisan political activities and in the development of public policy is a slippery slope.  The definition of “non-partisan” political activity is far from clear.  Shouldn’t supporting Minister McKenna’s Global Warming policies to the detriment of Canadian industries be deemed partisan?  Also one could argue that opposing the same policies would be deemed partisan to the opposing parties.

As a group consisting of tax paying Canadians we request that if anything, the charities involved in receipt of foreign funds, which have agitated for ever more stringent environmental and climate policies, should be delisted as charities.

Canadian taxpayers should not be further humiliated by being forced to support foreign funded ‘charities’ that are making them jobless.  There is no justice in that – eco or otherwise.




Appendix of Eight Examples

  1. West Coast Environmental Law

In an excerpt of the offshore funder, the Oak Foundation’s grant database[1] the grant says that West Coast Environmental Law (WCEL) of Canada was funded for $97,131.00 USD in 2010.  The purpose was: “To constrain development of Alberta’s tar sands through a legislative ban on crude oil tankers on British Columbia’s north coast. This would necessitate the cancellation of the Enbridge Northern Gateway Pipeline proposal to transport tar sands oil and bitumen to Asian markets. …”

This came to pass. We would like to ask, what is the net public benefit of this multi-billion-dollar loss to the Canadian economy, thanks to the work of the advocacy arm of a Canadian ‘charity’ funded by offshore interests?[2]

It would appear that some charities in Canada already operate with extremely broad political influence and that this level of influence appears to be acceptable to the Charities Directorate.  Is it acceptable to Canadian investors and industry?  Is this acceptable to the thousands of out of work oil and gas workers who have been forced to subsidize (through tax receipts) the anti-industry operations of this offshore funded ‘charity’? This tanker ban ruling has done immense harm to the Canadian economy – particularly to the group of First Nations investors and potential First Nations earners who looked forward to job creation through the Northern Gateway project – people who are looking to raise themselves out of on-reserve poverty. [3]  It is a tragic and true irony that one of the foundation principles of charities is the alleviation of poverty.  In this case, a federally registered charity ensured on-going poverty for thousands of First Nations people.


  1. Scope of Foreign Influence

Researcher Vivian Krause[4] has documented in some detail the millions of dollars of foreign funds flowing to Canadian federally registered environmental charities and related non-governmental organizations.

The global scope of such influence is clarified in the ClimateWorks Wikileaks document: ClimateWorks Foundation – WikiLeaks

The 2007 “Design to Win” document has been online for years.[5]

The content of this document is supported by other peer-reviewed work by Matthew Nisbet. [6] Other commentators, such as Counterpunch are more specific about the objectives and parties involved.[7]

None of this appears to represent charitable work.  The foundations involved appear to have vested interests in global cap and trade and renewables.


  1. Proxy for Corporate Interests – David Suzuki Fund

We note that Mr. Peter Robinson, CEO of the David Suzuki Fund, was one of the members of the advisory panel on changing the charities act.

In reviewing the Power Corporation’s Carbon Disclosure Project (CDP Worldwide) reports, posted on line, we found that Power Corporation states that it has been funding David Suzuki Foundation since 2007.[8]  David Suzuki Foundation has also been funded by offshore interests according to Vivian Krause, and also operates a US Charitable Foundation.

Power Corporation owns a number of subsidiaries, some of them in the renewable wind and solar industries.  David Suzuki Foundation has been agitating to phase out coal and incorporate wind and solar, especially in Alberta.  David Suzuki Foundation made a submission to the Alberta government’s Climate Leadership Panel that was solely dedicated toward the implementation of wind power in Alberta.  The Alberta Climate Leadership Panel moved forward to implement some 5,000 MW of wind and solar in Alberta and to phase out coal.  A Power Corporation subsidiary is now building a wind farm in Jenner, Alberta.

These seem unlikely coincidences.

David Suzuki Foundation has engaged in anti-pipeline and anti-oil rhetoric for years and has agitated against pipelines to the coast in British Columbia.  One of the major shareholders of Kinder Morgan Canada, the company owning the Trans Mountain pipeline and the expansion project, is Caisse de Depot et Placement du Quebec – which is also reportedly an investor in Power Corporation or Power Financial Corporation, and thus may receive a direct or indirect benefit from the Canadian government’s purchase of the Trans Mountain Expansion project.  As noted, Power Corporation reports it has funded David Suzuki Foundation since 2007.

Thus, it would appear that this charity has taken partisan political positions on a nationally-approved public work – the Trans Mountain Pipeline Expansion, approved by the NEB and federal cabinet – resulting in immense public harm and cost to the public in the form of forced purchase, by the Canadian government, of the moribund project, loss of revenue to federal, provincial, municipal and First Nations coffers due to underpricing existing exports and lack of access to regional and international markets, and the consequent widespread job loss.

It is our understanding that charitable activities are defined as such because they are to provide a net public benefit. Indeed, charities were never established to act in political capacities, according to correspondence we received from the CRA. The following are the foundational reasons for the approval of a charity and its related activities:

If following this mandate, charitable activities would be local, would provide a specific, tangible and measurable benefit, serving a local need.  There would be a net benefit to society.

Clearly, in the example of the food bank, these needs would be better served by local people and a local organization, rather than establishing a top-down government body from Ottawa to administer a local food bank.

This is not the case with a large national/international charity like the David Suzuki Foundation which has been blocking pipelines.  Excerpt of the Canada Revenue Agency (CRA) Charities ‘net benefit’ guideline:

It is difficult to believe that a partially foreign-funded ‘charity’ has more professional and technical insight and expertise about a pipeline’s performance and value to the nations, than the National Energy Board, which has been successfully approving energy and infrastructure projects for about the past 50 years.Some out-of-work oil field people have committed suicide.  It is hard to believe that pipeline blockades can be considered to be a ‘net public benefit’ when the country is losing some $50 million a day in revenues, and when global demand for oil is up, but Canadian access to markets is blocked by foreign-funded ‘charities.’

May we note that all communications we have seen on these matters from the David Suzuki Foundation have been partisan in nature.

  1. Ecojustice

The anti-pipeline, partisan nature of Ecojustice has caused significant damage to the Canadian economy.

Ecojustice has run a campaign to push for changes to Canada’s environmental laws, which industry and economics experts say have now made Canada a ‘hostile’ place to invest or try to do business.

Since 2016, Ecojustice has been agitating against the NEB and Trans Mountain Pipeline Expansion as clearly outlined by their Executive Director in this email to their subscribers.

Ecojustice: Devon Page, Executive Director

To: <>

May 19, 2016 at 10:07 a.m.

Feds have no choice but to tell Kinder Morgan no.

Dear Friend,

The National Energy Board (NEB) is set to release its recommendation on Kinder Morgan’s controversial application for the Trans Mountain Pipeline Expansion Project later today, and like many others awaiting the Board’s final report, we expect the outcome will leave us disappointed.

Our cynicism does not come without experience. In recent years, Ecojustice lawyers have represented environmental interests during most of the major pipeline project reviews in Canada, and have been disappointed time and time again.

We have been involved in the reviews for Enbridge’s Northern Gateway pipeline, Enbridge’s Line 9 reversal and Kinder Morgan’s Trans Mountain pipeline expansion, and we plan to participate in the review for TransCanada’s Energy East pipeline. We know pipelines, and we know how their review processes stack up. Generally speaking, they have gone from bad to worse — but that’s a tale for another day.

With the number of gaps and deficiencies in its application, Kinder Morgan’s pipeline plan should never have seen the light of day, let alone be considered for final approval by a federal government that has promised to combat climate change and improve environmental assessments. Proving the old adage that it is quality, not quantity that matters, the company’s 15,000-page application failed to provide information that sufficiently evaluates the project’s many risks, including its effects on endangered Southern Resident Killer Whales, threats to people and communities in the region, and the potential impacts of a major oil spill in the Fraser River or the Salish Sea.  We’ll know soon the extent to which these deficiencies are captured in the Board’s final report, but it is a certainty that climate change, the proverbial elephant in the room during these pipeline reviews, will barely register.

And how could it? Climate change was entirely excluded from the Board’s scope of review, and appeared to be excluded from the approval process altogether until the newly-formed federal government tacked on some degree of climate consideration with the introduction of its interim environmental assessment measures in January 2016.

While the measures are a welcome start, the prescribed ‘climate test’ misses half the picture. Only upstream greenhouse gas emissions will be assessed; downstream emissions will not be considered — despite the fact they account for the majority of this project’s climate impact. And even the analysis of upstream emissions is flawed. Based on the first draft climate assessment for another pipeline (Enbridge Line 3) the test fails to consider projects in the context of Canada’s national commitments and underestimates projects’ climate effects. We will have to wait until late May, after the NEB’s recommendation, to see the results of Kinder Morgan’s climate assessment.

While details of the interim measures continue to emerge slowly, it remains unclear whether or how the climate assessment, done outside the NEB’s review by Environment Canada, will factor into Cabinet’s final decision. The best case is that this climate assessment will lead to a decision to not approve the pipeline expansion; the worst case is that it is meaningless and amounts to window dressing before a final approval. Time will tell.

These half measures and unanswered questions are particularly disturbing when you consider that Prime Minister Justin Trudeau and his ministers swept into office with bold promises to take action on climate change and restore faith in Canada’s battered environmental assessment process. To his credit, Trudeau has since committed to, and signed, the Paris Agreement, which aims to limit global warming to 1.5 degrees above pre-industrial levels. However, the inadequacy of his government’s interim measures suggest that Trudeau’s pledges might be just that: All talk, and no action.

We’re bracing for disappointment later today, but let’s not forget that the NEB’s recommendation on Kinder Morgan’s pipeline is not the final word on the matter.  When the Harper government gutted Canada’s environmental laws in 2012, it stripped the NEB of its role as the final decision-maker on projects like the Kinder Morgan pipeline and endowed the federal cabinet with that power instead.

In other words, this is a golden opportunity for the federal government to demonstrate the bold leadership it has promised Canadians. If they are to truly deliver on their commitment to evidence-based decision-making and meeting the climate targets set in Paris, Trudeau and his ministers have no choice but to reject the Kinder Morgan project outright.

It’s pretty simple.  All they have to do is say, “No.”


Devon Page, Executive Director

Ecojustice is Canada’s only national environmental law charity. Help us build the case for a better earth.


None of the materials we have seen have been non-partisan in nature. Many focussed on ‘climate change’ which was never part of the NEB’s mandate to begin with, introducing a false and misleading factor suggesting (to the public and legislative authorities) that there was negligence by the NEB, which was not the case.

As described by former public servant and former diplomat, Robert Lyman, in this post:

“The Federal Court of Appeal’s decision rests on two highly dubious claims of fact: first, that the National Energy Board did not examine the marine tanker consequences of the Trans Mountain Expansion Project, when it clearly did; and second, that the modest increase in tanker traffic places the Orcas at a much higher risk of collision with shipping. Common sense, however, does not necessarily trump law.” [9]

As reported by Vivian Krause, Ecojustice has been funded by offshore ClimateWorks partners via Canadian charity TIDES.

It should be noted that Ecojustice client “Living Oceans” is a recipient of ClimateWorks partner funding via the Oak Foundation.

The following is part of an anti-NEB campaign that Ecojustice ran for several months prior to the subsequent court case wherein they represented various parties. This is not impartial. This was part of a point and click email campaign to Members of Parliament, which raises questions about the fairness of the ruling by the Federal Court of Appeals.  Judges, no matter how impartial on the bench, are part of society and may have been exposed to this false and misleading material.

We challenged these claims as false and misleading in this piece:

Did the Trans Mountain Expansion project get a fair trial?  Normally it is not the convention that a plaintiff has the right to publicly denigrate a defendant for weeks or months.[10]

How is this to the public benefit?  How is it non-partisan?

If the foregoing illustrates how federally registered charities operate when the Canada Revenue Agency Act forbids partisan political activities that cause harm to the public; what will be the ramifications when or if the restrictions are lifted, as recommended by the panel [11]  (one panel member being part of the David Suzuki Foundation, a charity criticized herein for their political and proxy activity)?


  1. Tides Canada

As noted above, the CRA requirement for the charity’s objective was that it should be local in nature, to the public good and with no fiduciary benefit to others, however we have noticed on TIDES Canada pages calls for action that appear to be related to investments and to international activity.

Correspondence from the CRA to us states: “The Objective must limit the scope of the organization’s activities…”

The TIDES main page website as it was, seems to contravene all of the above, offering ‘investment’, ‘international’ opportunities, ‘pooling’ of gifts, to ‘make the world a better place’ – none of this appears to meet the above parameters at all, especially the offer of ‘international’ giving – what place or who is that (ie. Vis a vis a ‘soup kitchen in Halifax’)?

The operation of ‘charities’ in Canada has opened the door to all kinds of foreign and proxy influence to the detriment of Canadians and the Canadian economy.  We are not able to ascribe intent or legality of any of the issues listed herein – but we question how the outcomes have in any way provided net public benefit – the fundamental purpose of a charity.

The ENGO market is proud of putting people out of work and costing our nation dearly. Why do we put up with this? What are the CRA charitable guidelines for if not to be enforced for the betterment of Canada?

In the case of the International Funders of Indigenous People, in their 2010 report, there is a clear statement that ENGOs and various indigenous groups planned to engage in pipeline blockades with the intent of shutting down the Alberta oil sands (tar sands).  People at the event also advised they were willing to spend millions of dollars in legal fees (compensated in part by employing dozens of law students) in order to force certain constitutional issues.  In the case noted below, they spent $15 million dollars and spent 15 years.  How many First Nations students could have attended school, travelled or been provided with a better lot in life in that time and with that money?  How much did it cost the taxpayer to defend the case on behalf of the federal government?

While there are certain very real wrongs that must be addressed in court – there are also limitations on the taxpayers’ purse and practical needs of the parties involved – where mediation and common goals might make more sense.

But as we find in many of the pipeline blockade cases, or the demand for more stringent environmental management – nothing is good enough for these foreign funded ENGOs.  So, one can conclude that the Tar Sands Strategy is truly stating the objective. The objective is to drive up costs of production, hamper development with court challenges, denigrate and smear the product and workers as ‘dirty,’ drive off investors, and ultimately shut the project down (or of course, make it open season for vulture investors – another possibility.)

Excerpts of the International Funders of Indigenous People’s 2010 report:[12]



  1. Other Uncharitable Acts

ENGOs have tremendous public and political power at the moment:

  • they are registered as provincial and federal lobbyists
  • they have mobbed the mic at hearings and reviews; they can activate their large followings via social media within seconds
  • they have initiated EC complaints and appeals
  • they have interfered with international relations, initiating NAFTA CECE complaints
  • they have coordinated with foreign ENGOs to demean Canadian resource activities in Washington DC.

(linked examples are: Pembina Institute’s testimony to US Senate in 2012 calling for a $150 ton carbon tax on the oil sands[13]; “Wildlands League” part of CPAWS (106865272 RR0001) in a 2001 intervention on softwood lumber to US; Joint NRDC, Alberta Wilderness (118781251 RR0001), and West Coast Environmental Law Association (advocacy arm of the West Coast Environmental Law Research Foundation # 119292415 RR0001) (and others) submission in 2003 to the US Dept of Commerce on softwood lumber.)

It should be noted that many of these large US ENGO groups – like NRDC and WRI – have received funding from Al Gore’s climate alliance and are listed as ‘collaborators’ for his clients in Generation Management.

These forces have significantly interfered in domestic Canadian natural resource development and resource utilization (primarily energy) policies.

While the “Forces of No” have every right to undertake activism in a democracy, but they have no right to expect their activities is be afforded the implied respect and financial privilege, on the taxpayer’s dime, or the – social license – afforded to charitable, non-profits that are actually  engaged in ‘good works’ for the common Canadian – millions of people who are in need of bread, work, dignity, or health support.

To give them such privilege without restriction, besmirches real charity done to advance a public good for Canadians. Continuing to make this mistake in policy and law threatens the integrity of the charitable and volunteer sector as well as the economic and political stability of the country.

  1. Not Grassroots – Recipients of More Tax Funds

Members of the public might be very surprised to learn that some charities have millions of dollars in assets.  The David Suzuki Foundation has some $19 million in assets (Source: CRA) and operates an endowment fund that earns them some $600,000 a year.

World Wide Fund (World Wild Fund – WWF)[14] reports $20,946,149 in revenues with Government funding $305,804 (1%).

In the year of the Paris COP-21 conference, WWF received $293,309.00 from Environment Canada.

It is concerning that investigative journalist, Donna Laframboise, has reported in her book about the Intergovernmental on Panel on Climate Change (IPCC), the body that reviews scientific evidence to allegedly provide impartial reports for governments on climate change, has been infiltrated at the highest levels of authorship by Greenpeace and WWF ‘legends’ – activists who are not scientists.[15]

As reported in the foreign billionaires’ ClimateWorks project, pushing global cap and trade, they have reportedly seconded and directed people to act on their behalf at events like the Paris COP-21 events.

Ms. Morgan of WRI[16] appeared at COP-21 as a representative of Greenpeace.

Since at least one of the ClimateWorks partners (Oak Fund) is also a funder of Greenpeace, it is difficult to understand these relationships.  Greenpeace is not a registered charity in Canada, but has frequently collaborated with other charitable ENGOs, like in the push for the disastrous Ontario Green Energy Act. (Pembina Institute is the non-profit advocacy arm of the Pembina Foundation: Registration number: 875787913RR0001)

Here are two examples of Oak Foundation grants to Greenpeace Canada, intended to ‘phase-out’ the oil sands and drive off investors. Source: Oak Fund on-line grant database.


  1. Climate Change is the Green Cloak

On the particular issue of climate science, since 2003[17] and 2005[18], the science community has recognized that carbon dioxide is not the main driver of human influence on climate.  The IPCC itself cannot provide us with any peer-reviewed material showing that wind and solar are effective or adequate replacements for coal or other conventional power, despite the IPCC touting them as such in their Summary for Policy Makers.[19]  Yet all these ENGO charities claim there is a ‘clean energy revolution’ in progress and that we ‘must decarbonize.’ Author and Prof. Em. Vaclav Smil, energy expert, disagrees.[20]

Clearly the ClimateWorks billionaires and their global cap and trade project has had a tremendously negative impact on Canada’s economy due to their funding of diverse ENGOs – most of which are federally registered charities which employ dozens of Ottawa lobbyists.  It is impossible for us to know whether these ENGOs knowingly acted as agents for an external purpose – but the result is that our environmental legislation has been turned upside down by foreign-funded ENGO charity activists, and dozens of ENGO lobbyists in Ottawa have acted against the interests of hard-working Canadians.

Meanwhile, global demand for oil, gas and coal grows while Canadian products are virtually landlocked.[21] But Canada is now seen as a place that is ‘hostile’ to investment.[22]

  1. Climate change hysteria not founded on fact.

The climate is much less sensitive to greenhouse gases than the IPCC claims, that extreme weather is not getting worse, that crop yields are dramatically increasing, that the planet is greening by both CO2 fertilization and by warming, that the rate of sea level rise is little different from 80 years ago, that the area of tropical islands are increasing, that beach area is increasing, that warming reduces heating costs by many times greater than it increases cooling costs, that warming net benefits health and reduces deaths.

Our evidence is outlined in this brief that we previously prepared for the Prime Minister.


  1. In Closing
  • Canadians jobs and the economy are being damaged by the current scope of operations and cooperative campaigns of the many federally registered environmental charities in Canada. We believe it would pose a danger to free society to provide them with any further freedom to engage in political activity, particularly as they are subsidized by all taxpayers through their charitable status, but their views do not represent those of all taxpayers.


[1] set “Select a programme of interest” to Environment and “Quick Search” to “canada west coast”







[8] (pg 17)




[12]    IFIP is a US registered charity; a number of Canadian ENGOs appear to have participated in this event.


[14]  119304954 RR0001