Input to the Government on the Development of 'BC Clean' Energy Standards

February 12, 2008

Edward Higginbottom
Electricity Policy Branch
Ministry of Energy, Mines and Petroleum Resources
Victoria, BC
(by email: ed.higginbottom@gov.bc.ca)

Dear Mr. Higginbottom,

Re: Draft Revisions to BC’s Clean or Renewable Electricity Guidelines

Thank you for providing this opportunity for comment on the draft revisions to BC’s Clean or Renewable Electricity Guidelines. The BCSEA is a non-profit society dedicated to promoting sustainable energy in British Columbia and in fostering a fundamental shift in energy use toward generally sustainable practices. We are especially concerned with greenhouse gas emissions and the need to move away from the widespread use of fossil fuels. Formed in 2004, the BCSEA has some 700 members and eight chapters around the province.

The BCSEA commends the Ministry of Energy, Mines and Petroleum Resources for undertaking to define and distinguish clean and renewable energies. This is a key requirement if the province is to enact policies to promote sustainable versus unsustainable energies. In general, the draft revisions successfully identify energy forms that would not emit greenhouse gases. Naming and listing the clean or renewable resources aids in clarity and transparency.

“Dedicated energy crops”

“Dedicated energy crops,” as defined in the draft guidelines and Environment Canada’s Environmental Choice Program Certification Criteria Document, should not be accepted as “clean or renewable.” Recent national and international media discuss the harmful effects of developing and clearing land for the production of crops to be used for energy (e.g. the Los Angeles Times report on studies in Science by Joe Fargione, University of Minnesota and Timothy Searchinger, Princeton University (http://www.latimes.com/news/science/la-scibiofuel8feb08,0,4389870.story)). Land development can release very large quantities of carbon dioxide, negating or postponing for many years any net reduction in greenhouse gas emissions from the substitution of biofuel for fossil fuels. The European Union is currently reconsidering biofuel requirements use because of this.

There is also the danger of competition between food crops and energy crops. For example, the US demand for corn as feedstock to produce ethanol fuel has driven up price of corn in Mexico, causing hardship for people who eat corn. This problem can be expected to occur in many countries, where low-income people are unable to ensure their access to land to grow food crops in competition with powerful political and economic interests. BC should avoid any action that might exacerbate this problem, as it is a significant humanitarian and moral issue.

The guidelines should simply exclude “dedicated” or purpose-grown energy crops. Failing that, the guidelines should consider the fuel on a lifecycle basis. The MEMPR is currently preparing a Renewable Fuel Standard and a Low Carbon Fuel Standard, including the assessment of lifecycle factors. It would make sense to harmonize these two standards, provided both are rigorous in accounting the greenhouse gas and other environmental impacts. There should also be a test to verify that fuel crops would not cause human hardship through the reduction of food crops. The BCSEA is skeptical that it would be practical for a significant fuel crop industry to address these issues appropriately, or that it would be practical to enact a reliable system to assess and verify appropriate standards, especially for jurisdictions outside BC.

“Clean organically sourced material”

For clarity, this should specify that fossil fuel derivatives like plastics are excluded.

Hydrocarbon energy

The technical barriers to the capture and storage of greenhouse gas emissions from the combustion of hydrocarbon fuels are great. Any such fuel that is considered for the designation “clean or renewable” should not only be “subject to long-term sequestration,” but there should also be (a) reliable analysis to show that the storage would be effective in the long term, and (b) reliable commitments, including economic, to ensure that such sequestration would in fact take place.

Municipal solid waste (MSW)

The BCSEA opposes the designation of MSW as “clean or renewable.” These wastes contain a large component of plastics, which would emit greenhouse gases and highly toxic combustion products. We recognize the serious problems faced by municipalities in trying to dispose of their waste. Designating incineration as “clean or renewable” would simply mischaracterize the solution. Municipalities should be encouraged to minimize the production of waste, putting pressure in turn on consumers, manufacturers and distributors to minimize the production of waste.

Tidal energy

This category should include energy from tidal currents, which is not only in estuaries or bays and not necessarily directly reliant on the rise and fall of water levels.

Please do not hesitate to contact us if you have any questions about these submissions.

Regards,
Thomas Hackney,
Vice-President for Policy
cc: Shelley Murphy