Open Letter to Canadian Securities Administrators on Climate-risk Reporting and the Impossibility of Net Zero Targets

June 19, 2024

To Whom it May Concern:

RE: Comments and Scientific/Policy Insights Related to the Canadian Sustainability Standards Board – Drafts on Climate-risk reporting

PDF of the letter

“International Organization of Securities Commissions (IOSCO) articulated its vision and expectations of the IFRS Foundation’s work towards a global baseline of investor‑focused sustainability reporting standards to improve the global consistency, comparability and reliability of sustainability reporting. …  IOSCO noted the need for enhanced transparency and comparability to inform investment decision‑making and protect investors from ‘greenwashing.’” – The jurisdictional journey towards implementing IFRS S1 and IFRS S2 — Adoption Guide Overview July 2023 

As a group of earth, atmospheric, solar scientists, Professional Engineers, economists and business people, our organization has been tracking the climate science and economic implications of climate policy since the Kyoto Accords.  Friends of Science Society was formed in 2002; we have deep knowledge of the area of climate science, economics, and policy developments over the past 22 years.  We are independent. We do not represent any industry.  We advocate for open, civil debate on climate and energy policies and full-cost benefit analysis prior to adopting new policies.  We advocate for a stable, flourishing economy and human condition, in a rules-based context that does not create exceptions for proponents of Net Zero solutions.

We are deeply concerned that present efforts to embed climate risk reporting in corporate operations will embed greenwashing and fraudulent misrepresentation of climate risks across the board, resulting in skewed markets and capital misallocation, the very thing the standards intend to avoid. There will be a huge waste of corporate financial and human resources spent on counting carbon molecules at a time when Canada’s focus needs to be on upping productivity.  This onerous reporting will result in further departure of investment capital from Canada and lack of competitiveness with our largest trading partners, the USA and Mexico.

We understand that your organizations will determine whether or not these standards remain voluntary or become mandatory.  They should not become mandatory.

We have written a number of letters on climate-risk reporting to the Office of the Superintendent for Financial Institutions (OSFI), the Bank of Canada, our president has written a personal letter to the Canadian Senate Committee on Banking (re: Bill S-243, climate aligned finance), and we have done a video explainer – “Molecule Madness” for the general public.[1] We have made a submission to FRACanada/CSSB.[2]

The principal issues are these:

1. Climate risk for a corporation cannot be determined by running computer models or climate risk scenarios which are fundamentally flawed. They are flawed in these ways:
2. According to the Task Force on Climate Risk Disclosure, corporate climate forecasting is based is on downscaled Global Circulation Models. These are not fit for purpose. Downscaling cannot capture local conditions and leads to much hotter outcomes and mistaken forward impressions.  The past is the key to our future; the historical record is the more valuable source of information for assessing climate and extreme weather/wildfire risks. See our critique of Prof. Katherine Hayhoe’s report on Alberta’s Climate Future, “Facts vs Fortune-Telling.”[3]  Note that extreme weather events and wildfire are integral to weather and are not signs of human-induced climate change, according to the Intergovernmental Panel on Climate Change science report.  
3. Scenarios known as Representative Concentration Pathways 8.5 and 6.0 (and SSP iterations of them) are implausible. This is quite well-known in the climate science community but is ignored by the financial community, perhaps because the RCP 8.5 scenario makes the case for Net Zero. This is fraud.  In short, RCP 8.5 is NOT a ‘business-as-usual’ case, even though it is often as presented as such by “Risky Business” and by various climate institutes in Canada (i.e. Climate Atlas).
4. The terms “climate emergency” and “climate crisis,” while ubiquitous in the media and from the mouths of climate activists and even people like Mark Carney, only appear once, each, in the 4000-page Intergovernmental Panel on Climate Change (IPCC) report of the AR6 Working Group I Physical Sciences – in reference to media coverage. It is well-known that the IPCC Summary for Policy Makers (SPM) (a 40-page version of the 4,000-pg. report) and the commonly cited IPCC Synthesis Reports are highly compromised by government delegations which approve the SPM line by line.  As investigative journalist and author, Donna Laframboise revealed in her 2012 presentation in Calgary,[4] IPCC reports are tampered with by “Greenpeace and WWF legends.”  Grant documents show that ClimateWorks Foundation member, the Oak Foundation of Switzerland,[5] has liberally funded these two and many dozens of other environmental groups to further an agenda to institute global cap and trade systems and a global price on carbon.
5. Since COP-26 in Glasgow, the United Nations Framework Convention on Climate Change (UNFCCC) has abandoned the use of RPC 8.5 and 6.0 and now focusses on RCP 4.5, reporting that global emissions are under that projected scenario – which once would have been considered a climate success! Without RCP 8.5 and 6.0, the ‘climate emergency’ is over.  Thus, there is no Net Zero urgency and no need for such detailed reporting. (UNFCCC is the political arm of the UN climate movement, vs the IPCC’s mandate to assess human-influence on climate).   Current iterations of climate models are acknowledged by NASA climate scientists Gavin Schmidt as running ‘too hot.’  Statements like “Code Red for humanity” by UN Sec. Gen. Guterres are not supported by the IPCC science report.[6]
6. What kind of ‘standard’ is being established if there is no consistency in the use of IPCC RCP scenarios? The CSDS-2 document states that it “…references the TCFD scenario documents and recommends an “ensemble” approach to scenario analysis and is generally agnostic about the IPCC RCP that is used – effectively leaving the selected RCP up to the discretion of the scenario writer.” (pg. 5)

Using ‘any’ RCP scenario will result in wildly varying, inaccurate outcomes with no standard of consistency whatsoever.

1. RCP Scenarios were developed for research purposes only; should not be used for policy making. Explicitly stated in the original van Vuuren et al (2011) paper:[7]

“The RCPs should not be interpreted as forecasts or absolute bounds, or be seen as policy prescriptive. The RCPs describe a set of possible developments in emissions and land use, based on consistent scenarios representative of current literature (see Section 2). The RCPs should clearly not be interpreted as boundaries for possible developments with respect to emissions and land use. Similarly, while the RCPs may be used to identify the range of climate impacts associated with different anthropogenic forcing levels, they are not meant to be policy prescriptive, (i.e. no likelihood or preference is attached to any of the individual scenarios of the set). At the same time, the use of the RCPs in climate research may provide important information for decision-making.”  (bold emphasis added)

2. Net Zero is unattainable with existing technology unless degrowth and deindustrialization are the preferred outcomes for industry and society. See our overview analysis of two Canada Energy Regulator reports and a bluntly realistic report by the Canadian Centre for Policy Alternatives.[8]  A video explainer is also available.[9]
3. The materials supply chain for mined minerals requirements for Net Zero ‘solutions’ does not exist as shown by Prof. Simon Michaux.[10] [11] CSDS reporting requirements are literally asking corporations to forecast “The Pursuit of the Impossible.”[12] Thus corporations are being forced into making Net Zero transition plans and promises that they cannot keep.
4. CSDS reporting will open the door to shareholder liability, ENGO lawfare, corporate demarketing by competitors or competitor nations, corporate/competitor/supplier extortion by manipulating access or supply of critical energy or resources. There was a time when corporations kept insider information tightly held close to the chest and warded off corporate espionage.  Today, standards organizations are demanding disclosures, and in this case, predictive disclosures, which open corporations to everything from shareholder liability to ENGO lawfare (already very common based on current reporting), and corporate demarketing. 

A good example of this is the CDP “In the Pipeline” report of 2016.  Canadian oil sands corporations were demarketed[13] because they were focussed on their core business (formerly a sign of competency and a worthy investment opportunity) while those oil/gas corporations which were branching out into renewables were given the highest scores. Ironically, the top-three-placed “Total SA” had just signed an HoA (i.e., Heads of Agreement- a non-binding document that outlines the basic terms of a tentative partnership agreement) for $5 billion with Iran and China in Nov. 2016.[14] Neither Iran nor China are places that honor human rights, DEI, ESG, or any environmental concerns. 

The Carbon Disclosure Project (CDP Worldwide) began as a Rockefeller charitable operation, however the corporate and city intelligence that it has gathered over the years can be used against any reporting entity; in fact, the aggregated reports the groups like Accenture or PwC (Pricewaterhouse Coopers) have done over the years for the CDP from their collected ‘voluntary’ reports do create a ‘black and white’ lists for investors (which are typically the signatories to the UN Principles for Responsible Investment).  How can this naked exposure be in the interest of the Canadian economy or that of entrepreneurs and investors?

5. There is a Lack of Safe Harbour Protection in the CSDS draft – necessary to protect corporations from any of the aforementioned legal liabilities. This must be established if such reporting is to go forward in any way.
6. The transition risks are based on an invented set of ‘planetary boundaries.’ Jessica Weinkle is a climate policy analyst who focusses on the many serious Conflicts of Interest in the world of climate science and policy.  A recent analysis by her shows that the Transition Risks, used by the Network for Greening the Financial Sector and recommended for corporate climate risk reporting (i.e. Disorderly, Orderly, Too Little-Too Late, Hothouse Earth), are derived from a “Hothouse Earth” paper, issued some years ago, and that these stem from a highly conflicted research group.[15]  Our Communications Manager wrote a rebuttal at the time showing that this paper was primarily a ‘science advertorial’.[16]  Indeed, the million member geosciences organisation, International Union of Geological Sciences  recently decisively rejected a bid to have them define us stratigraphically as living in the “Anthropocene.”[17]
7. Undue influence of ENGO proxies, associated with foreign actors. Indeed, a new report from the US House Judiciary Committee indicates there is Climate Cartel Collusion to decarbonize America.[18] Such climate risk disclosure simply provides these parties with ammunition for lawfare and activist shareholder attacks.

Climate activist ENGOs have been exploiting the information required of corporations for public reporting and regulatory filings to conduct lawfare, blockades, and to institute policies that benefit competitor nations and limit Canada’s economic potential and market access. The best recent example is that of the Trottier Family Foundation’s funding of ENGOs and pushing cap-and-trade legislation, which was issued as a surprise announcement to Alberta at COP28.  Please read of their wide circle of influence and funding in the words of their CEO.^[19] As noted in the article, Trottier Family Foundation claims that: “… we collaborated with other funders and networks like Bloomberg, the Open Society Foundation, C40 Cities, ClimateWorks, WINGS and the Canadian Philanthropy Commitment on Climate Change. The global philanthropic community is stepping up and playing its role in advancing climate solutions.”

This is a subversion of the democratic process, to have unelected, unaccountable, tax subsized charitable foundations skewing public policy, nationally and internationally.

Professor Matthew Nisbet has been tracking ClimateWorks for over a decade and notes that they are using their influence to try and institute global cap and trade markets.[20]  This is not in the public interest. As we have noted, there is no urgent need for climate solutions as there is no climate emergency when the implausible RCP 8.5 and 6.0 scenarios are removed from the equation.

Our report “Manufacturing a Climate Crisis” compiles important information on how foreign-funded ENGOs have affected Canadian climate and energy policies.[21]

8. Canadian courts have never tested climate science. Climate activists and members of the media often quote certain statements from Supreme Court judges, taken from Greenhouse Gas Pollution Act filings, that ‘climate change is an existential threat.’ However, this is a misrepresentation of what was on trial.  These cases were about constitutional jurisdiction, not climate change science.  The preamble to the case included such statements, but these were never argued in court as the case was about the constitution, not climate change.  The provinces did not argue the climate change claims as this would have required a separate trial; their concern was constitutional jurisdiction.  Thus, what the judge said is only part of the ‘obiter dicta’ – general commentary.  It is not part of the ‘ratio decedendi’ – the reasons for the decision.  Professor William van Wijngaarden was an expert climate science witness in the so-called Youth Climate trial in Ontario, wherein several youth claimed their future charter rights were being damaged by the Ontario government’s position and changes to climate law (related to cap and trade).  The document “Impact of Changing Greenhouse Gas Concentrations on Ontario’s Climate” reflects Prof. Wijngaarden’s expert opinion on climate change and we understand it is similar to content submitted to the court.[22] Wijngaarden’s work is scientific but written in a highly readable manner that ordinary people can easily understand.  For instance, this is a table he prepared for one of our presentations where you can see Canada’s and Alberta’s contribution to global warming over the past century. 

Excerpt of Prof. Wijngaarden’s document:

For the case of a clear sky, one can compute the amount of heat radiated by the Earth as is shown in Fig. 3 [19]. This shows the heat radiated per unit area by the Earth and its atmosphere to outer space at the various infrared colours or frequencies. This calculation considered the 5 most important naturally occurring greenhouse gases: water vapour (H2O), carbon dioxide (CO2), ozone (O3), nitrous oxide (N2O) and methane (CH4). The effects of water vapour are very noticeable at frequencies less than 550 cm−1 and in the range of 1200 to 2800 cm−1 . The two noticeable dips in the black and red curves are due to absorption by carbon dioxide at 660 cm−1 and ozone at 1050 cm−1 . The effects of methane and nitrous oxide are barely noticeably because their atmospheric concentrations are over 1000 times smaller than water vapour and more than 100 times smaller than carbon dioxide. One can barely distinguish between the black and red curves which correspond to carbon dioxide concentrations of 400 and 800 ppm, respectively. An important check of this work is to compare modelled results to data observed by satellites that measure the intensity of infrared light radiated by the Earth and its atmosphere as shown in Fig. 4 [19]. (bold emphasis added)

Due to the reporting requirements proposed for Scope 1, 2, 3, and the advice to use downscaled Global Circulation Models, the following sections of Prof. Wijngaarden’s paper are critically important for your consideration as to whether or not CSDS reporting is necessary or relevant. We recommend reading his entire paper to fully grasp the context:

1.6 Global Warming due to Other Greenhouse Gases such as CH4 and N2O

All five of the Earth’s naturally occurring greenhouse gases, H2O, CO2, O3, N2O and CH4 are very strongly saturated [19]. This means that doubling any of their concentrations produces a global warming that is greater than a subsequent similar absolute increase. N2O and CH4 are much less abundant than H2O and CO2 in the Earth’s atmosphere and therefore somewhat less saturated. An analogy to explain saturation is a farmer painting a barn. One notices a big difference between the first and second coat but negligible effect between the 10th and 11th coat. For the case of methane, we recomputed Fig. 3 for ambient and doubled methane concentrations of 1.8 and 3.6 ppm, respectively. One additional methane molecule is 30 times more effective for global warming than one additional CO2 molecule. However, 300 times more carbon dioxide is added to the atmosphere each year than CH4. Hence, the overall effect of the increasing methane concentration to global warming is less than 1/10 that of carbon dioxide [19]. For the case of nitrous oxide, one additional N2O molecule is 230 times more effective for global warming than one additional CO2 molecule, But the rate of increase of CO2 molecules is 3000 times larger than that of N2O. So the contribution of nitrous oxide to global warming is about 230/300 or about 1/13 that of carbon dioxide [20]. (bold emphasis added)

1.7 Global Climate Models

Efforts to construct a realistic mathematical computer model of the Earth’s climate is an enormous task that has been ongoing for over half a century [25]. The Earth’s surface area of 515 million km2 is divided into area segments and the atmosphere into vertical slices. For an area element of 100 km2 and a vertical step size of 100 m, one needs over 2.5 billion points. At each point, one must calculate: temperature, pressure, water vapor concentration, greenhouse gas and aerosol concentrations, wind speed and direction etc. At the surface, one must determine the fraction of sunlight reflected. Evaporation must be taken into account which is very different for an ocean as opposed to a land surface. For the latter case, the vegetation type may be important. Ocean currents such as the Gulf Stream that transport enormous amounts of heat from the tropics to polar latitudes must also be modelled using an additional array of points. Ocean circulation is not well understood and cycling times of deep ocean water are estimated to take up to hundreds of years. Finally, the entire system is time dependent, as the Earth orbits annually about the sun and daily rotates about its axis. ⁷

…It is very challenging to determine the global warming or cooling effects of clouds, which at any time cover about two thirds of the Earth. Cooling occurs when clouds block the midday sun on a summer day while in winter, cloudy nights are warmer than clear nights. The huge uncertainty due to clouds is the elephant in the room in Climate Science. (bold emphasis added)

Prof. van Wijngaarden discusses the issues of Urban Heat Island Effect.  This issue is perhaps best illustrated by the work of Roger A. Pielke, Sr. on land use. [23] The following illustration from Pielke, Sr.’s work shows a shocking spike of 6 °Celsius inner-city temperature above that in the open country in the Urban Heat Island context of London, England.  Will reporting corporations be blamed in lawfare for Urban Heat Island artifacts caused by other emitters?  How much will these court cases cost society?

Wijngaarden notes that urban flooding in Ontario is not due to an increase in precipitation, but rather to urban environments having paved over wetlands and open fields that once absorbed much of the rainfall.  Regarding wildfires, Wijngaarden reports that there is no trend in increasing wildfires in Canada (though last year’s wildfire season was extraordinary, scientifically speaking this is known as an ‘anomaly’ and does not show a trend).

Likewise, three eminent scientists submitted this document to the Court of Appeal in The Hague.[24]

“In our opinion, the District Court of The Hague findings that “dangerous” climate change and extreme weather are caused by CO2 emissions from fossil fuels are contradicted by the scientific method and only supported by the unscientific methods of government opinions, consensus, peer review, and cherry-picked or falsified data. Science demonstrates fossil fuels and CO2 will not cause dangerous climate change. Rather, there will be disastrous consequences for people worldwide if fossil fuels and CO2 emissions are reduced to “net zero,” including mass starvation.” (bold emphasis added)

9. The CSDS draft document emphasizes the need for working closely with First Nations, Metis and Inuit and references the United Nations Declaration of the Rights of Indigenous Peoples (UNDRIP). It should be noted by Canadian Securities Administrators that for many months prior, six provinces were asking for clarifications of the text or requesting revisions to UNDRIP.^[25] When the Kamloops First Nation (Tk’emlúps te Secwépemc) announced on May 27, 2021, that Ground Penetrating Radar (GPR) had discovered a mass grave of 215 children’s bodies on the ground of the former Indian Residential School,[26] those questions were pushed aside.  This astonishing, ghastly news went round the world; Canada’s flag flew at half mast for half a year. UNDRIP legislation was passed about one month (June 21, 2021) after the Kamloops mass grave claim made world news, with little question and no evidence of graves.  China accused Canada of genocide the day after UNDRIP was passed, citing the Kamloops discovery as proof.[27]  This year, the Kamloops band changed their memorial announcement to state that they had found “anomalies.”[28]  A review of previous land use in the area reveals a field of abandoned septic system trenches in the same area claimed to be gravesites.[29]  The RCMP have been removed from the investigation and the site is under jurisdiction of the Kamloops First Nation.  This is unheard of in criminal investigations, that an alleged victim has custody of the site where the alleged crime was committed. Numerous scholars have rejected the claims regarding allegations of genocide in Canada.[30] None-the-less, on July 6, 2021 the Assembly of First Nations passed a resolution accusing Canada of crimes against humanity, stating that a group of lawyers had filed documents with the International Criminal Court (June 6, 2021);[31] [32]the AFN resolution cites UNDRIP articles in support of its statements.[33]  These are serious charges which may result in international actions such as those applied against South Africa during apartheid.  Thus, it presents a legal risk of great uncertainty to require corporations to apply UNDRIP to their reporting activities.

Retired lawyer Andrew Roman wrote a three-part series in 2020 on how UNDRIP was being misconstrued by many people.^[34] 

Excerpts:

1. Contrary to popular misconception, UNDRIP does not give Canadian indigenous peoples a veto over government approval of pipeline or other resource projects;
2. The BC government’s claim to be the first province to have enshrined UNDRIP into BC law is premature, as it has not done that; and

III. UNDRIP should not be enshrined into Canadian federal or provincial law because that would do more harm than good to First Nations (FNs) and to Canadians generally.    

With recent revelations of foreign interference in Canadian politics, clearly China, an aggressive competitor nation, plans to exploit the situation with UNDRIP to its advantage. With regard to British Columbia, retired lawyer Geoffrey Moyse has written numerous articles on the unconstitutionality of UNDRIP and related property rights issues.[35]  Thus, requiring corporations to comply with UNDRIP without regard for these uncertainties may also open companies to legal action by shareholders, climate and Indigenous activists, or other members of society or international organizations outside of Canada.

10. Emissions from immigration and housing build-out will defeat all corporate efforts to reduce emissions. Canada has enacted the Century Initiative,[36] attempting to up our population, by the immigration of ~63 million people to Canada by 2100. Excerpts of a recent article[37] outline the carbon footprint problem:

People who come here from warmer places not only bring their own personal carbon footprint with them, but they also increase their carbon footprint to the Canadian average. 

Immigrants typically come from countries with a carbon footprint per person ranging from between 0.2 to 12 tonnes of carbon dioxide equivalent per year (tCO2-eq/yr). The average annual emissions per person of Canada’s 2022 immigrants was 4.7 tCO2-eq based on the top 10 countries.

By contrast, Canada’s greenhouse gas emissions per capita in 2021 were 17.5 tCO2-eq. The annual increase of emissions of the 2022 immigrants would have increased by 5.5 to 17.3 tCO2-eq per capita as they adopt Canada’s cold climate and lifestyles.

Last year, “Over 437,000 new permanent residents, along with over 604,000 temporary workers, were admitted.” …

In fact, adding 63 million people to Canada, based on a per capita emissions rate of 17.5 tCO2-eq would equate to Canada increasing its annual greenhouse gas emissions by 1.1 billion tCO2-eq. …

Canada’s Housing Plan is to build 3.9 million homes in seven years when Canada, on average, builds 250,000 homes per year. …

Even if embodied emissions [of housing construction] are cut in half, such as in the COP26 test home the carbon footprint of a 3.9 million home build out would be huge. The COP26 test home folks say they could drop the normal 78 tonnes of CO2 embodied emissions (the emissions which are part and parcel of the construction materials and process), down to 32 tonnes using smart design strategies. That’s still 32 tCO2 x 3.9 million homes =124,800,000 tonnes of CO2e emissions. This doesn’t include infrastructure!

Thus, what is the purpose of standardized CSDS/CSSB reporting when activities associated with emissions reduction by a corporation will be meaningless in the broad scope of things?  As discussed with Dr. Benny Peiser of the Global Warming Policy Foundation,[38] Net Zero targets (and the wasteful efforts to count every molecule in Scope 1, 2, 3) simply hand the competitive advantage to competitor nations like China, India, Brazil and other ‘rising giants.’[39]

Emissions have been flat in Western countries for years.  Degrowth is not a positive goal.

US EIA forecast of world energy consumption between 2018 and 2050.

Though the stated goal of COP28 was to triple renewables worldwide,[40] this can only be accomplished with an equivalent tripling or quadrupling of fossil fuel production, as mining draws 10% of the world’s energy,[41] and wind/solar devices are vast consumers of oil, natural gas, coal and their byproducts for production, transportation, installation, maintenance and operation.[42]

Canada is a mining and energy extraction nation; the prospects for Canada reaching Net Zero are zero. (Unless an artificial shell-game of carbon credit trading is invoked, as famously described by Mark Schapiro as trading in the “lack of delivery of an invisible substance to no one.”)[43]

This, imposing mandatory reporting standards, or requiring corporations to use any of the flawed tools noted above, would embed a form of fraud within corporate reporting and would open companies and securities administration organizations to legal liabilities and ENGOs lawfare.

11. The Canadian Sustainability Standard Board’s whole premise on Climate-risk reporting appears to focus entirely on “Global Warming”. A company that truly wants to understand the climate risk needs to understand that Climate Change means just that. The climate has been, is and will be changing in the future, warming and cooling for a variety of reasons (which includes CO2) on a variety of time scales. Those changes occur on multi-decadal, centennial and millennial time scales, with the average human life span representing less than 3 climate related data points. The entire Modern Temperature Record (MTR, 1850 to the present) is less than 6 climate related data points. Understanding climate change requires more than calibrating a climate model to the loosely correlated CO2 and Temperature data since 1850. That same temperature data can be modeled (and more accurately) using just the sun’s Total Solar Irradiance (TSI) and no CO2 contribution. That option was laid out by a group of 37 very qualified scientists in their 2023 paper, “The Detection and Attribution of Northern Hemisphere Land Surface Warming (1850–2018) in Terms of Human and Natural Factors: Challenges of Inadequate Data”.[44]

Which one of those interpretations is correct? The answer is neither, because the answer lies somewhere in between. The figure below shows the CO2 and temperature profiles over the last 12500+ years. Note, the CO2 concentrations have been plotted on a scale that represents the premise that the 1.07 °C of warming since the pre-industrial era (based on the IPCC’s August 2021 AR6 – SPM report) has been primarily due to human emissions (i.e.: a CO2 increase of 135 ppm). Prior to the MTR, CO2 concentrations were essentially flat, yet temperatures fluctuated significantly. CO2 was not driving climate (temperature or otherwise) over the pre-MTR Holocene. Those fluctuations are all natural (primarily related solar activity directly or indirectly (ocean cycles, Cosmic Ray Flux (CRF), cloud albedo, electromagnetic field strength, etc.). Those natural forcings were still active during the MTR and will continue to be active in the future.

Solar cycles manifest themselves most prominently in the Greenland temperature data where the warm and cold periods stand out. The Northern and Southern Hemispheres experience the solar cycles differently but regardless of which temperature data set you use; the Little Ice Age (LIA) is visible. You might also note that temperatures began rising centuries before CO2 began its rise and most (86%+) of humanity’s emissions occurred post-1950. The recent 1.07  °C MTR temperature rise could just as easily be due to the natural forcings as CO2. The well documented Dansgaard-Oeschger events (the sharp warmings) and subsequent Heinrich events (the rapid then extended cold periods) could be playing out on the 1100 – 1200-year time scale visible in the Greenland data. Even if the cold is limited to the Northern Hemisphere that has huge implications on humanity (independent of our activity). The Milankovitch Cycles use the solar insolation at 65° N (which passes through Greenland) to model the deep ice age and interglacial warm periods. Solar insolation can obviously cause deep ice ages with minor changes in TSI. The more recent small changes in TSI, when used as a proxy, model the Holocene significantly better than CO2 and may be representing a significant portion of the smaller Holocene solar insolation changes that have obviously initiated the very visible Holocene temperature fluctuations.

The one place those natural forcings will not be active is in the CMIP6 climate models. Climate change in the models is limited by programming to changes in anthropogenic causes (primarily CO2 emissions). Those models are incapable of history matching the well-established temperature profiles over the Holocene. How can they be trusted to model our climate future when they ignore the very obvious natural forcings that were active pre-1850? The climate models have been self-acknowledged (by the modellers themselves) to “run way too hot”. And as mentioned earlier, there are some very real concerns with the use of unrealistically high emission scenarios. On top of that, the models use a wide range of CO2 climate sensitivities. Their Equilibrium Climate Sensitivity (ECS) ranges from 1.8 to 5.6 °C. Only the Russian models come close to history matching the Lower Troposphere temperatures by using the low end 1.8 °C ECS. That is not a settled range, and the differences would have a significant impact on any potential climate risk analysis. Broader estimates that factor in solar activity and Urban Heat Island Effects (UHIE) suggest that the ECS is closer to 1.0 °C and very likely less around 0.8 °C.

The technical discussion provided here is not designed to adjudicate climate change. But the discussion is extremely important when applied to the climate risk evaluations that are being pushed on corporate entities. Climate Science is nowhere near settled. The IPCC (supposedly the authoritative voice on climate change) does not know CO2’s Equilibrium Climate Sensitivity value. A rather important parameter considering they believe CO2 is responsible for all the recent Climate Change and into the future. The IPCC has backed away from their unrealistically high emission scenarios, but they have made no attempt to correct those in academia, politics or media that still routinely use those unrealistically high emission scenarios. The IPCC’s AR6 detailed scientific reports correctly acknowledge that there is no definitive anthropogenic signature in the extreme weather event trends. So, again why have they made no attempt to correct the academic, political and media individuals/groups that constantly promote that “climate change” has led to or will lead to more extreme and more frequent extreme weather events. The empirical data shows that extreme weather events have been statistically flat or more commonly are trending down on climate time scales.

By what process will a “climate expert” be qualified to provide a definitive opinion on “climate change” globally, yet alone locally? Climate is extremely complicated and as laid out by the IPCC, “The climate system is a coupled non-linear chaotic system, and therefore the long-term prediction of future climate states is not possible.”[45] How many non-ideological climate experts are available to sit on corporate boards or supply a non-biased estimate of the potential climate risk to a specific company in a specific geographical location? The measured temperatures in Calgary have been declining by 1.76 °C /century since 1973. The homogenized “official” temperatures have been increasing by 1.35 °C/century. How does a “climate expert” rationalize those two very different temperature data sets. Since we experience measured temperatures, the more prudent choice would be measured temperature trend but that does not fit the “official” interpretation. Counting CO2 molecules is a scientifically unjustified, expensive, unnecessary imposition on society.

In Summary – Wait 4055 Years for 1 °C Warming Caused by Canada
The relationship between emissions and temperature is uncertain and controversial. Here’s what the government relies on:  Intergovernmental Panel on Climate Change (“IPCC”) AR6, “CLIMATE CHANGE 2023: Synthesis Report” Page 19, Section B.5.2 which states that: “For every 1000 GtCO2 emitted by human activity, global surface temperature rises by 0.45°C (best estimate, with a likely range from 0.27°C to 0.63°C).”

Using this, determining Canada’s impact on climate is a matter of simple arithmetic:

(0.45°C / 1,000,000,000,000 tonnes) x 548,000,000 tonnes / yr = 0.0002466°C / yr, or 1°C per 4055 years.

We hope this information is useful. Feel free to contact us for additional insights or details.

Sincerely,

Addendum:

Some of our previous recent correspondence to OSFI and Bank of Canada:

• https://blog.friendsofscience.org/2023/07/31/open-letter-to-office-of-the-superintendent-of-financial-institutes/
• https://blog.friendsofscience.org/2023/11/21/you-must-ensure-energy-security-for-all-canadians-osfi/
• https://blog.friendsofscience.org/2024/01/21/osfi-boc-discrepancy-between-unfccc-cop-scenario-baseline-and-that-of-the-standardized-climate-scenario-exercise-scse/
• https://blog.friendsofscience.org/2023/12/22/collapse-catastrophe-responding-to-osfi-on-scse-climate-scenarios-exercise/

Footnotes:

[1] https://youtu.be/_01XZ_v9T18

[2] https://blog.friendsofscience.org/2024/06/10/open-letter-comments-about-canadian-sustainability-disclosure-standard/

[3] https://friendsofscience.org/assets/documents/Alberta%20Climate%20Future%20rebuttal.pdf

[4] https://friendsofscience.org/library/events/ffriends-of-science-ninth-annual-luncheon,-with-donna-laframboise.html

[5]https://blog.friendsofscience.org/wp-content/uploads/2023/07/grants-env-oak-pdf-75-page.pdf

[6] https://www.prweb.com/releases/-code-red-overstates-actual-findings-of-ipcc-climate-report-and-trends-in-extreme-weather-events-819828074.html

[7] https://link.springer.com/article/10.1007/s10584-011-0148-z

[8] https://blog.friendsofscience.org/2024/03/15/getting-to-net-zero-in-canada/

[9] https://youtu.be/BCTSWChezX8

[10] https://tupa.gtk.fi/raportti/arkisto/42_2021.pdf

[11] https://youtu.be/MBVmnKuBocc?t=106

[12] Robert Lyman offers a short overview of Prof. Michaux’s 1,000 page report https://blog.friendsofscience.org/2022/11/28/the-pursuit-of-the-impossiblematerials-constraints-and-realities-for-the-net-zero-utopia/

[13] https://calgaryherald.com/business/energy/foreign-exodus-has-followed-investment-frenzy

[14] https://totalenergies.com/media/news/press-releases/iran-total-and-nioc-sign-contract-development-phase-11-giant-south-pars-gas-field

[15] https://open.substack.com/pub/thebreakthroughjournal/p/how-planetary-boundaries-captured?r=f96qu&utm_campaign=post&utm_medium=email

[16] https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3243151

[17] https://www.iugs.org/_files/ugd/f1fc07_40d1a7ed58de458c9f8f24de5e739663.pdf?index=true

[18] https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/2024-06-11%20Climate%20Control%20-%20Exposing%20the%20Decarbonization%20Collusion%20in%20Environmental%2C%20Social%2C%20and%20Governance%20(ESG)%20Investing.pdf?utm_source=substack&utm_medium=email

[19] https://pfc.ca/good-cop-bad-cop-the-role-of-philanthropy-at-cop28/

[20] https://web.northeastern.edu/matthewnisbet/wp-content/uploads/2018/05/Nisbet2018_ClimatePhilanthropy_WIREsClimateChange_Final.pdf

[21] https://blog.friendsofscience.org/wp-content/uploads/2019/02/Manufacturing-A-Climate-Crisis-2A-FINAL.pdf

[22] https://friendsofscience.org/pdf-render.html?page=2963

[23] https://pubs.aip.org/physicstoday/article/69/11/40/415367/Land-s-complex-role-in-climate-changeTo-mitigate

[24] https://friendsofscience.org/pdf-render.html?page=2954

[25] https://www.cbc.ca/news/politics/liberal-government-undrip-bill-opposition-second-reading-1.5984689

[26] https://x.com/CFJC_Today/status/1398051802419920903

[27] https://www.cbc.ca/news/politics/china-canada-un-calls-investigation-crimes-indigenous-uyghurs-1.6075025

[28] https://nationalpost.com/opinion/tkemlups-te-secwepemc-first-nation-graves-kamloops

[29] Kamloops – Indian Residential School Records

[30] https://www.amazon.ca/Grave-Error-Misled-Residential-Schools/dp/B0CP465ZPP

[31] https://edmonton.ctvnews.ca/canadian-lawyers-request-icc-investigate-residential-school-system-as-crime-against-humanity-1.5458806

[32] https://www.fosterllp.ca/blog/coalition-of-canadian-lawyers-demand-international-criminal-court-to-investigate-discovery-of-215-dead-indigenous-children-in-kamloops-bc

[33] https://www.afn.ca/wp-content/uploads/2021/07/AFN-AGA-2021-Resolutions-English.pdf

[34] https://andrewromanviews.blog/2020/10/04/undrip-the-united-nations-declaration-on-the-rights-of-indigenous-peoples-part-1-of-3/

[35] See the PDF version of the letter.

[36] https://www.centuryinitiative.ca/

[37] https://www.westernstandard.news/opinion/stirling-trudeaus-housing-plan-cancels-out-your-carbon-tax-sacrifice/54041?utm_source=newsletter&utm_medium=email&utm_term=2024-04-24&utm_campaign=Western+Standard+s+Daily+Newsletter

[38] https://youtu.be/E7Oa1bvIOlc

[39] https://blog.friendsofscience.org/2021/03/01/when-giants-arise-the-real-world-of-ghg-emissions-and-growth/

[40] https://www.irena.org/Publications/2024/Mar/Tracking-COP28-outcomes-Tripling-renewable-power-capacity-by-2030

[41] https://www.theworldcounts.com/challenges/mining/energy-use-in-the-mining-industry

[42] https://spectrum.ieee.org/to-get-wind-power-you-need-oil

[43] https://climatechange101.ca/wp-content/uploads/2021/03/Conning-the-Climate.pdf

[44] “The Detection and Attribution of Northern Hemisphere Land Surface Warming (1850–2018) in Terms of Human and Natural Factors: Challenges of Inadequate Data” https://www.mdpi.com/2225-1154/11/9/179

[45] “The climate system is a coupled non-linear chaotic system, and therefore the long-term prediction of future climate states is not possible.” https://www.ipcc.ch/site/assets/uploads/2018/03/TAR-14.pdf