The BC Sustainable Energy Association commends the Government of BC for CleanBC, its latest update to BC’s climate action plan.
- CleanBC provides a solid foundation for starting to make significant sector-specific greenhouse gas (GHG) emissions reductions and for ramping up emissions reductions over time to meet the long term targets.
- CleanBC makes a good start at engaging all levels of society.
- Transportation measures include mandated zero emissions vehicle (ZEV) sales and increasing the renewable fuel standard to 20%. Deferred to the next 18 - 24 months are freight and community planning.
- Buildings measures retain the 2032 target date for new construction to achieve a net-zero standard. There are significant new incentives for energy retrofits for existing buildings. CleanBC commits to helping communities develop renewable energy projects. CleanBC relies heavily on a 15% renewable natural gas (RNG) standard for BC’s natural gas system.
- Waste measures include a 95% organic waste diversion commitment and a 75% landfill gas capture commitment.
- CleanBC commits to identifying job requirements in a sustainable energy economy and to implementing new categories of professional certification categories.
- CleanBC increases provisions for democratic accountability for the implementation of climate action measures.
- BCSEA recommends that the government implement parallel accounting of imported and exported embedded GHG emissions, along with the regular accounting of conventional emissions.
CleanBC offers British Columbians a sound foundation for a move toward energy sustainability and for BC to contribute its fair share to reducing GHG emissions. At the same time, it addresses vital social needs such as employment and economic well-being.
CleanBC is evolutionary, building on past actions and avoiding harmful disruption from rapid change. For example, freight transport is not radically curtailed while awaiting practical ways to eliminate the use of diesel fuel. Instead, a range of interim measures are proposed, and there is a commitment to develop a fuller plan in the next 18 to 24 months. Likewise, CleanBC seeks to maintain economic prosperity and growth.
BCSEA believes that the growing urgency of climate change demands faster and deeper cuts in emissions than are given in the plan. However, we also recognize the need for political acceptability. To the extent that British Columbians embrace CleanBC, it can be ramped up and accelerated to achieve a faster transition to sustainability. BCSEA strongly recommends this course.
Broad Engagement with BC Society; Addresses the Main Sectors of Energy Use
BCSEA commends the government for its work to engage different levels of society more broadly than previous plans. The government invited public feedback and resourced a broad-based consultative group – the Climate Solutions and Clean Growth Advisory Committee – to provide detailed and technical advice. The government obtained endorsements from a range of groups, including labour, academia, the environmental sector and business. The government signed a Memorandum of Understanding with the Business Council of British Columbia to collaborate on growing industry while shrinking emissions. And there is a commitment to continue engagement going forward.
The plan addresses emissions and energy use in the main sectors of society, with generally credible sector-specific reduction targets and measures to achieve them.
For transportation, the most striking measure is the zero emissions mandate for new vehicles, which rises to 100% of vehicles sold by 2040. This is supplemented by incentives for people to purchase zero emissions vehicles (ZEVs) and fuelling/charging infrastructure. However, recognizing the delay caused by stock turnover cycles, the CleanBC plan relies on an increase in the low carbon fuel standard to 20% to achieve the majority of the greenhouse gas (GHG) emissions reductions to 2030. Additional measures address: ferries (LNG capability for coastal ferries and a commitment to electrify inland ferries); increasing BC’s production of low carbon fuels; investments in transit service and electrification; and some support for cycling.
These measures would cut transportation emissions by some 25% by 2030, and there is obvious scope for that to improve beyond 2030, in the form of a general electrification of the vehicle fleet. The aim should be to electrify the whole ferry fleet, not just the inland fleet. Electrification is or may soon be practical on all the shorter routes.
Not addressed in the transportation measures, but bookmarked for the next 18 to 24 months are freight transportation, community planning and active transportation. Measures being considered for freight include electrification and other technological solutions, but also planning. The community planning and active transportation measures are not discussed in detail, but it is encouraging that they are recognized as significant issues for transportation energy and emissions.
Missing from the discussion on transportation is the importance of reducing spending on urban highways, interchanges and other infrastructure designed to increase traffic flows. Building increased traffic lanes is a strong driver of increased GHGs. BC must find better ways to move goods and people and stimulate the economy.
For buildings, the CleanBC plan maintains the 2032 “net-zero ready” deadline for new construction that was established in the 2016 Climate Leadership Plan. This is disappointingly slow, since European standards are going to net zero now. Also, the target for “net-zero ready” appears to have been weakened. In the initial BC Step Code, 15 kWh per square meter per year was the Thermal Energy Demand Intensity (TEDI) target for 2032. In the latest revision however, effective since December 10, 2018, a home with a TEDI as high as 60 can reach the target in the coldest climate of the province. The changes are made to balance out the effort it takes to reach higher steps across all BC climate zones; nonetheless, the Energy Step Code Level 5 — the 2032 target — may no longer mean true “net-zero ready” homes in the colder regions of BC.
There are incentives for building retrofits – notably the EfficiencyBC incentive program and $400 million to improve the energy efficiency of public housing – and there is a commitment to implement new standards for building upgrades. Most welcome is a strong commitment to support the use of electric heat pumps in new and existing buildings, including for water heating. This is an established and very efficient technology. Unfortunately, the plan is only “exploring” energy performance labeling for buildings rather than implementing it right away. It is overdue for buyers and renters of homes and other buildings to have good, transparent information on energy performance.
CleanBC also provides additional support and funding for communities, including First Nations and remote communities, to develop renewable energy and distributed energy systems.
The measures for buildings and community energy systems would reduce GHGs by some 30% by 2030. However, fully three-quarters of this improvement is attributed to mandating a 15% renewable natural gas (RNG) standard for BC’s natural gas system. It is not clear how a 15% low carbon content in natural gas could achieve a roughly 24% reduction in GHGs for buildings generally. As well, CleanBC may rely on RNG sources that have not been technologically or economically proven. BCSEA is seeking clarification on this from the government.
For industry, CleanBC proposes the electrification of operations – particularly oil and gas production – that would otherwise be powered by natural gas or other fossil fuels. The plan also relies on incentives funded by the carbon tax to achieve unspecified GHG reductions in pulp mills and mines. Several other measures are proposed, including: a 45% reduction in methane emissions from upstream oil and gas operations; more carbon capture and storage, including direct air capture; and the above-noted 15% RNG standard for the natural gas system.
In addition, CleanBC is fostering a range of technologies and practices for industry that are currently being piloted or developed, and the plan calls for ongoing engagement with industry and the Business Council of BC.
Measures for industry would cut emissions by 8.4 MT, or 37% of total emissions for that sector. This is a promising start. BCSEA strongly supports low carbon electrification as a way to reduce GHGs. We note that this will also increase the market for cost-effective renewable energy generation, making opportunities for BC renewable power producers.
CleanBC proposes a dramatic vision for waste:
“Imagine living in a world without waste, where by-products of all kinds are reused, recycled and reconstituted as raw materials. Where no other option exists, they are used a source of energy. That approach, known as a “circular economy” is what we are adopting in British Columbia, recognizing its potential for creating jobs, promoting innovation, and protecting the environment by harnessing the full value of resources.” [CleanBC, page 60]
CleanBC commits to diverting 95% of organic materials from BC’s waste streams, and it commits to capturing 75% of the methane leaked from landfills. These measures will necessarily engage BC’s communities, as well as industry and the agricultural sector. Organic waste diversion will support RNG production with feedstock, and this will also provide employment in technology development.
Job Requirements, Training, Certification
Another feature of CleanBC is its commitment to identify job requirements in a sustainable economy and to support job skills development, including through professional certification for new job categories. The government is developing a CleanBC Labour Readiness Plan, with public engagement to take place in 2019.
Accountability & Reporting
Accountability is improved with commitments to table in the legislature annual reports of climate action spending and results and forecasts of emissions, based on modelling. BCSEA hopes that a more systematic and detailed discussion of climate action in the legislature will lead to better media coverage and greater public engagement on the issue.
Need to Address Low Carbon Electrification
While CleanBC makes commendable steps to switch BC from fossil fuels to electricity, and it has measures to increase the supply of renewable natural gas, it gives little attention to the need to increase the supply of clean, renewable electricity in BC. BCSEA recognizes a role for renewable natural gas, but we believe that low carbon electrification and energy conservation are the most practical ways to decarbonize BC’s energy use. BCSEA understands that low carbon electrification may be addressed in Phase 2 of the government’s Comprehensive Review of BC Hydro and/or in BC Hydro’s upcoming 2020 Integrated Resource Plan.
In any case, BCSEA recommends that the government assess low carbon electrification from the perspective of electrifying much of BC’s current energy use. This should include consideration of how electricity can most efficiently be delivered to load centres. Distributed generation -- smaller generation close to load centres -- offers important efficiencies. Net metering can be especially useful in enabling citizens to be a part of the energy revolution by producing local clean power. The government (and BC Hydro) should consider how distributed generation and net metering can support climate action targets while meeting BC’s energy needs efficiently.
Need to Address Embedded GHG Emissions
Finally, while CleanBC generally addresses only the GHG emissions caused within BC’s borders, the plan also acknowledges in principle the need to consider “consumption based” emissions:
“Our strategy for waste will focus on prevention, which has the greatest potential for reducing GHG emissions, including those emissions that occur beyond our borders where many of the products we use are manufactured.” [CleanBC, page 60]
BCSEA supports applying this principle to the GHGs embedded in BC’s exports – especially fossil fuels – as well as to imports. These emissions are not formally part of BC’s responsibilities under international accounting protocols, but they are real, and BC has some practical responsibility for them.
BCSEA recommends that the government (a) implement transparent accounting of the embedded GHG emissions of BC’s imports and exports that can be presented in parallel with the current GHG accounting under international protocols; and (b) develop for public discussion draft policies and standards to address the embodied GHG emissions of trade items.
BCSEA looks forward to further engagement on the CleanBC plan, as it evolves toward fully meeting BC’s sustainability goals.