In the fall of 2023, the New Brunswick Anti-Shale Gas Alliance responded to a call for comments on a draft of the Federal Government’s Clean Electricity Regulations. The following is our submission:
The New Brunswick Anti-Shale Gas Alliance is a consortium of civil society, environmental, and health and science groups from Anglophone and Francophone communities across New Brunswick, who work closely with Indigenous allies. Our mandates are to keep unconventional fossil fuels out of our province, and to promote a clean energy economy to address the looming climate crises. We’ve helped secure a provincial moratorium on fracking, and intervened on the side of the federal government at provincial Courts and the Supreme Court of Canada on the issue of carbon pricing. Currently we, and the Ecology Action Centre, are in court in Nova Scotia, challenging an EIA for the proposed Goldboro LNG plant. We have both a general and specific interest in CER. Our province is contemplating an energy future involving exotic nuclear processes in the form of Small Nuclear Reactors (SMR’s), a conversion of our only coal generating plant to biomass, and the introduction of gas generators, supplied by a new provincial fracking industry.
Below are our recommendations with supporting comments, and citations numbered in brackets. A list of recommendations and citations are provided at the end of the document.
As the fossil fuel industry will attempt to eliminate or weaken CER, it is vital to have some bedrock principles and standards, which cannot be negotiated away or compromised. These CER principles should remain intact:
- There should be no allowance of emissions trading or offsets. Offsets have been found to be, in almost every case, ineffective, unverifiable or even fraudulent. Electricity producing units must be evaluated solely by their individual performance.
- The emissions standard of 30t/GWh by 2035 should not be weakened.
- Exceptions for ‘peaker’ units must not be weakened. The maximum of 450 hours of operation per year OR a limit of 150 kt/yr of emissions must remain as is. Otherwise, this will become an area of constant attempts to get exceptions, each of which will weaken the CER’s intent.
Other Recommendations
As the International Energy Agency noted on Oct.24th, in its World Energy Outlook [1], governments aren’t moving with enough urgency to phase out fossil fuels. Despite gains in clean energy, the continued burning of fossil fuels is undermining renewable energy progress. As summed up in a press release from Oil Change International, “We can’t solve the climate crisis by adding renewable energy on top of new fossil fuels—we need to rapidly replace and phase out all fossil fuels, including gas.” A recent study in Nature Communications [2], comparing all of the IPCC climate scenarios, found that global coal, oil and gas supply must decline by an average of 95%, 62% and 42%, respectively, from 2020 to 2050 to limit warming to 1.5 °C.
When carbon capture and storage (CCS) and carbon dioxide removal are limited to levels judged plausible by experts, then gas supply must fall twice as quickly – by 84% rather than 42%. Canada is far from meeting its goals in reducing greenhouse gas emissions. We can’t afford any concessions to the idea of increased burning of any fossil fuels. Virtually all scientific analyses note that no new fossil fuel plants should have been built since 2020.
Therefore:
- For plants commissioned AFTER Jan. 1, 2025, the “End of Prescribed Life” principle should NOT apply.
The transition may require, older, existing fossil fuel plants to continue, even if they do not meet CER regulations. However, there is no scientific basis supporting the construction of new plants that cannot meet CER standards. Doing so guts the intention of the CER concept, and enables dirty energy projects to be built that will still be in existence in 2035. Their ‘fact-of-life’ presence will argue for their continued existence after that date, compliant or not, and require many years beyond 2035 to fully decommission, just as it has taken decades to decommission coal burning plants.
New Brunswick is already proposing to “move the construction date for new natural gas-fired generation units from 2025 to 2030, which would allow the units to continue operating until 2050, in line with the ultimate goal of zero net consumption by 2050.” It is likely that new plants elsewhere will also be fuelled by natural gas. Studies over the years have indicated that methane leakage into the atmosphere is as bad or worse for the climate as burning coal. A 2023 study in Environmental Research Letters [3] made a stronger case that even minor leakages of methane are worse than coal. “We estimate that a gas system leakage rate as low as 0.2% is on par with coal, when considering climate effects over a 20 year timeframe. Recent aerial measurement surveys of US oil and gas production basins find wide-ranging natural gas leak rates 0.65% to 66.2%, with similar leakage rates detected worldwide.”
This questions the logic of the End of Prescribed Life for plants commissioned before 2025, as well as for new ones. If the goal of CER is clean electricity by 2035, why allow any non-compliant plants to operate until 2045? Investments in these plants will also encourage the exploitation of new fossil resources, and divert financing from clean energy.
Therefore:
- For plants commissioned BEFORE 2025, the End Of Prescribed Life should be the earlier of 20 years from commission OR 2035.
Carbon Capture and Storage
In CER (and energy planning generally) danger lies in policies being based on hope and hype. One specific example is the promotion of carbon capture and storage (CCS) as a means of reducing CO2 emissions. It is discussed as if it is currently a working and affordable technology, when, in fact, after a decade of trying, no attempt has gotten anywhere near the 90% plus efficiency both required and promised. All CCS projects would be failures if not for continued government subsidies.
A report just released from the industry oriented International CCUS Knowledge Centre [4], says that CER compliance using CCS cannot be achieved without major extensions of time limits and reduced performance requirements.
A report last year from the Institute for Energy Economics and Financial Analysis (IEEFA) [5], explains why. Industry has hyped the technology without evidence, and faced no consequences for that hype, until now, when it has to account for its miserable performance.
To meet CER standards natural gas-fired power plants would need to achieve a nearly 95 per cent CO2 capture rate using CCUS. No CCS facility anywhere has come close to achieving that level of performance. SaskPower’s Boundary Dam — Canada’s only large-scale carbon capture facility currently on a power plant — has a capture rate of 65 to 70 per cent, been plagued by technical issues and equipment failures, and in 2017, the government admitted that ratepayers were paying an “implicit” carbon tax of nearly $60 per tonne to support the plant.
The IEEFA analysis found that 10 of the world’s 13 “flagship” CCS projects, accounting for 55% of global carbon capture capacity, had under-performed, failed outright, or been mothballed. “The wider CCS industry has been defending these claims of 90%, 95% capture for years with no evidence that it’s going to be achieved”. “This… should lead governments to raise greater doubts about whether these targets will be achieved. The only way carbon capture and storage will be financially viable is with permanent and very high subsidies, at a time when renewable energy costs are falling.”
“The fact is that there are still no natural gas-fired power plants using CCS anywhere in the world, and we know there are always unexpected issues that come up with first-of-a-kind projects.” CER standards become useless if fossil plants are allowed to operate out of compliance after 2035, because the hoped for technology of CCS couldn’t deliver. Weakening regulatory standards or extending timelines may work help industry to eventually comply, but the climate isn’t waiting for industry.
Evidence to date indicates that CCS is simply a ploy to extend the life of the fossil fuel industry, particularly as almost all existing CCS projects use the CO2 to produce new fossil fuels. It may have a role in niche applications involving industries that are hard to decarbonize, but it is not a tool that currently works for large scale electricity generation. Without major progress in the technology soon, other options should be pursued.
Therefore:
- If CCS cannot be quickly shown to be capable of meeting necessary efficiencies standards, at reasonable costs, there must be a process to ascertain that – many years before the 2035 deadlines – to allow time for a switch to direct investments in proven clean energy alternatives at the necessary scale.
Biomass is not an answer.
As forests are carbon sinks and are threatened everywhere, backers of biomass say they only use waste from the forest industry. Yet a review of the European Renewable Energy Directive appearing in Nature Communications [6] stated that, “Contrary to repeated claims, almost 90% of these wood pellets come from the main stems of trees, mostly of pulpwood quality, or from sawdust otherwise used for wood products.” The study points out that net savings on GHG emissions are few and take many, many years before benefits are realized. “Wood that reaches a power plant can displace fossil emissions, but per kWh of electricity it typically emits 1.5x the CO2 of coal and 3x the CO2 of natural gas because of wood’s carbon bonds, water content and lower burning temperature.”
“Allowing trees to regrow can reabsorb the carbon, but for some years a regrowing forest typically absorbs less carbon than if the forest were left unharvested, increasing the carbon debt. Eventually, the regrowing forest grows faster and the additional carbon it then absorbs plus the reduction in fossil fuels can together pay back the carbon debt on the first stand harvested. But even then, carbon debt remains on the additional stands harvested in succeeding years, and it takes more years for more stands to regrow before there is just carbon parity between use of wood and fossil fuels. It then takes many more years of forest regrowth to achieve substantial GHG reductions.”
As we rapidly approach tipping points and our 1.5 °C limit, rapid reductions in CO2 are what is necessary, not potential reductions sometime in the distant future.
What we do get in the present from burning biomass is increased air pollution. A nationwide US study in Environmental Research Letters [7] found that health impacts of biomass and wood combustion are higher than combustion of coal and gas individually, and indicated that biomass and wood are the leading sources of stationary source air pollution health impacts in 24 states. A great deal of pollution is also released where wood pellets are produced, as revealed in a recent BBC investigation [8] of an Alberta company that supplies the UK’s largest biomass burner.
Environment and Climate Change Canada is now investigating the plant, which did not submit a required 2022 report relating to permitted levels of hazardous compounds (VOCs) and particulate matter, which can harm human health. Tom Harrison, electricity transition analyst at global think tank Ember, said: “The possibility then that there are also serious pollution and emission problems of particulate matter, or whatever it may be, further down early in the supply chain of wood pellet sourcing production only adds to this really risky nature of biomass as a fuel source.” The investigation also alleged that some of the wood comes from primary forests cut down by the company in Canada. It is not possible to run a biomass industry simply on waste wood. As the European review [6], noted, “nearly all such wastes have long been used,” and “because meeting a small quantity of Europe’s energy use requires a large quantity of wood, and because of the example it sets for the world, it profoundly threatens the world’s forests.”
Biomass threatens forests, provides few timely GHG benefits, is highly polluting, during processing and burning, and is difficult to regulate where it is sourced. Furthermore, much ‘waste’ wood, taken from forest floors could have serious environmental effects on forest soil, water and diversity. Burning biomass for electricity makes little sense, except, perhaps, in very limited niche applications, but it is not suited to large scale electricity production.
Therefore:
- Biomass should have no place in CER alternatives, as it brings no GHG advantages, but lots of accompanying problems.
No Time for SMR’s
SMR’s in our view are an expensive and unnecessary distraction from actions necessary right now. New, exotic technologies have a track record of taking years longer than forecast and costing a whole lot more. See our discussion above on CCS. The various SMR technologies seem to be ‘learn as you go’ endeavours, which gives pause, knowing the existing and potential dangers involving radioactive materials
Thus, the care that must be taken, plus all the unknowns that arise in all novel technology, means that the technology is likely to lag its planned timeline and overrun its cost estimates, just as all nuclear projects have. What do we do come 2035 if SMR’s are not ready to deployed en masse? Just as in the case of failed CCS, we will have to burn more unabated fossil fuels. The Point Lepreau CANDU reactor is allegedly a well-known quantity, yet it is constantly plagued by problems and outages. With new technology, however, every new problem discovered and ‘solved’ will require reiterative testing of the whole system – a long, expensive process.
We need to bet on sure things and proven technologies that can be implemented now, especially as they are much less expensive than SMR’s and carbon capture, and they don’t carry the baggage of new problems to be solved, such as disposal of exotic types of nuclear waste.
Therefore:
- Plans built around SMR’s aren’t really plans at all – they are hopes. They shouldn’t be part of the CER planning or divert government funding from available, proven clean electricity options.
Finally, hydrogen.
Hydrogen has been heralded as the next great energy champion for 40 years, yet its very properties have prevented the achievement of its potential. Like CCS, it may have a role in niche applications involving specific industries that are hard to decarbonize. But it is not well suited for use as a fuel to burn to produce electricity or to ship across distances. At this point, any hydrogen used to achieve any clean electricity goal should be ‘green’, made from water and renewable energy. Hydrogen coming from fossil fuels just extends fossil fuels and continues pumping CO2 and methane into our atmosphere. It also is worth noting that hydrogen has climate altering characteristics itself that have not been studied enough.
Therefore:
- Hydrogen remains a holy grail, but we cannot depend on it in the short run to help with climate change via electricity generation.
***
As we prepared these remarks, a study in Nature Climate Change [9] re-evaluated the climate budget of GHG emissions that we can emit and not exceed our 1.5 °C target. New data and refined models show that, “for a 50% chance of keeping warming to 1.5 °C is around 250 GtCO2 as of January 2023, equal to around six years of current CO2 emissions.”
The climate crisis is with us now, globally and in Canada. ‘It’s Like Our Country Exploded’: Canada’s Year of Fire.” [10]
What time and opportunity we had to consider compromises, exotic technologies, and slow phase-outs of fossil fuels has passed. Fossil fuel use must be cut significantly starting now. Our electricity investments must be in renewable energies and immediate, vast grid improvement. It is in the context of a true emergency, that we make these recommendations.
Summary of Recommendations
- There should be no allowance of emissions trading or offsets.
- The emissions standard of 30t/GWh by 2035 should not be weakened.
- Exceptions for ‘peaker’ units must not be weakened. The maximum of 450 hours of operation per year OR a limit of 150 kt/yr of emissions must remain as is.
- For plants commissioned AFTER Jan. 1, 2025, the End of Prescribed Life principle should NOT apply.
- For plants commissioned BEFORE 2025, the End of Prescribed Life should be the earlier of 20 years from commission, OR 2035.
- If CCS cannot be quickly shown to be capable of meeting necessary efficiencies standards, at reasonable costs, there must be a process to ascertain that – many years before the 2035 deadlines – to allow time for a switch to direct investments in proven clean energy alternatives at the necessary scale.
- Biomass should have no place in CER alternatives, as it brings no GHG advantages, but lots of accompanying problems.
- Plans built around SMR’s aren’t really plans at all – they are hope. They shouldn’t be part of the CER planning or divert government funding from available, proven clean electricity options.
- Hydrogen remains a holy grail, but we cannot depend on it in the short run to help with climate change via electricity generation.
Sincerely, James D. Emberger
Spokesperson
New Brunswick Anti-Shale Gas Alliance
Citations
- World Energy Outlook 2023,International Energy Agency
https://www.iea.org/reports/world-energy-outlook-2023/executive-summary - Global fossil fuel reduction pathways under different climate mitigation strategies and ambitions,Ploy Achakulwisut, Peter Erickson, Céline Guivarch, Roberto Schaeffer, Elina Brutschin & Steve Pye, Nature Communications, Sept.13, 2023
https://doi.org/10.1038/s41467-023-41105-z - Evaluating net life-cycle greenhouse gas emissions intensities from gas and coal at varying methane leakage rates, Deborah Gordon, Frances Reuland, Daniel J Jacob, John R Worden, Drew Shindell and Mark Dyson, Environmental Research Letters, Volume 18, Number 8. 17 July 2023
https://doi.org/10.1088/1748-9326/ace3db - CCS critical to decarbonizing Canada’s electricity grid, International CCUS Knowledge Centre. Oct 19, 2023
https://ccsknowledge.com/pub/CCUS%20&%20Clean%20Electricity%20Regulations%20Review.pdf - The carbon capture crux: Lessons learned, Bruce Robertson and Milad Mousavian, Institute for Energy Economics and Financial Analysis. September 01, 2022
https://ieefa.org/resources/carbon-capture-crux-lessons-learned - Europe’s renewable energy directive poised to harm global forests, Timothy D. Searchinger, Tim Beringer, Bjart Holtsmark, Daniel M. Kammen, Eric F. Lambin, Wolfgang Lucht, Peter Raven & Jean-Pascal van Ypersele, Nature Communications, 12 September 2018
https://doi.org/10.1038/s41467-018-06175-4 - A decade of the U.S. energy mix transitioning away from coal: historical reconstruction of the reductions in the public health burden of energy, Jonathan J Buonocore, Parichehr Salimifard, Drew R Michanowicz and Joseph G Allen, Environmental Research Letters, Volume 16, Number 5. 5 May 2021
https://doi.org/10.1088/1748-9326/abe74c - Drax faces penalty after Canadian biomass plant fails to submit pollution report, Independent UK edition, Rebecca Speare-Cole. 21 October 2023 https://www.independent.co.uk/climate-change/news/alberta-ofgem-britain-tom-harrison-uk-government-b2433624.html
- Assessing the size and uncertainty of remaining carbon budgetsRobin D. Lamboll, Zebedee R. J. Nicholls, Christopher J. Smith, Jarmo S. Kikstra, Edward Byers & Joeri Rogelj, Nature Climate Change, 30 October 2023
https://www.nature.com/articles/s41558-023-01848-5 - It’s Like Our Country Exploded’: Canada’s Year of Fire, New York Times Magazine. Oct. 24, 2023
https://www.nytimes.com/2023/10/24/magazine/canada-wildfires.html