Blog Posts | Pembina Institute

A provincial approach to regulating coal doesn’t mean the Feds are off the hook

Blog - Jan. 12, 2012 - By P.J. Partington

The federal government has repeatedly touted its forthcoming regulations for coal-fired electricity as proof that it’s serious about climate change. While the numerous loopholes in the draft regulations tell a different story, the new rules were nonetheless a modest step in the right direction. It was therefore concerning to see reports from the Globe and Mail last week that suggest the government might “backtrack” on their coal regulations even before the final version has seen the light of day.

The Globe article explained that Nova Scotia, Saskatchewan and Alberta might be given equivalency agreements that would allow the federal regulations to stand down in favour of provincial regulations when the latter is shown to be at least as stringent.

Smoke stacksThat said, allowing provincial governments to take the lead with their own policy solutions isn’t necessarily a step backwards and it could actually be a good thing if the equivalency agreements are credible. More flexible approaches can typically achieve similar environmental outcomes at lower cost (or even stronger outcomes for the same cost); however, equivalency agreements that aren’t credible and/or enforceable are a giant step backwards.

Under the current draft federal regulations, any coal-burning unit starting operation after June 2015 can’t emit any more greenhouse gas pollution than roughly what would be produced by a highly efficient combined-cycle natural gas plant generating the same amount of electricity. This performance standard would also apply to existing coal-burning units after they have been in operation for their “full economic life,” defined in the draft regulations as 45 years.

In other words, the federal regulations lay out a 45-year schedule from 2015 that dictate when each individual unit must meet this standard or shut down. Some flexibility allows for end-of-life dates to be traded within a province and company for units of a similar size but, otherwise, the standard applies to every unit operating in Canada for any one particular year. This level of specificity has prompted some provinces to cry foul and demand the ability to pursue their own approach.

What would a credible equivalency agreement look like?

First and foremost, any agreement should be based on implemented provincial regulations that will reduce global warming pollution from coal-fired electricity generation at least as much as the reductions projected under the federal regulations. They should also be backstopped by federal regulation in the case that the provincial rules are weakened or don’t perform as expected. We described these ideas in more detail in our submission to the federal government.

Nova Scotia and Ontario are the only two provinces that could currently make a credible claim for equivalency. That said, Ontario doesn’t really need to make a claim because they’re in the process of phasing out the last of their coal-fired generators and will have dismantled all coal-fired capacity before the federal regulations come into force. Neither is it planning to build any new coal plants, so it doesn’t have to worry about trying to muck around with ‘clean’ coal.

Nova Scotia has placed a hard cap on emissions from the electricity sector and plans to cut coal consumption significantly while increasing renewable power to at least 40 per cent of supply by 2020. That’s significant given coal-fired generation made up almost 75 per cent of the province’s supply in 2010! Nova Scotia’s cap requires an emissions reduction of roughly 20 per cent this decade, which appears very likely to match or exceed the emissions reductions from coal that would be produced by the federal regulations alone.

Alberta and Saskatchewan, on the other hand, have much more work to do if they want to make a credible case for equivalency. Apart from financial support for carbon capture and storage at SaskPower’s Boundary Dam 3 unit, Saskatchewan doesn’t currently have any climate change policies that will reduce global warming pollution from their coal plants. Until that changes, any claim of equivalency is hollow. 

While there is nothing inherently wrong with equivalency agreements, the lack of equivalent climate policy in Alberta and Saskatchewan is cause for concern.Alberta is a bit more complicated. The province currently requires its major emitters — including all coal-fired units — to reduce emissions intensity by 12 per cent below baseline, with the target being phased in for newer facilities. In addition to reducing their emissions intensity, coal-fired plants could also comply with the policy by purchasing credits from firms that have exceeded their targets, purchasing offsets from Alberta-based projects or paying into a technology fund at a rate of $15 per tonne of carbon dioxide.

As Alberta’s current policy is structured, it does not provide as strong an incentive to reduce global warming pollution from coal-fired generation as the draft federal regulations would. According to analysis by the International Institute for Sustainable Development, the cost of complying with the federal coal regulations between 2011 and 2020 will be about $50 per tonne of pollution reduced, which is significantly more than the maximum $15 per tonne that coal-fired plants would pay under Alberta’s current policy.

So while there is nothing inherently wrong with equivalency agreements, the lack of equivalent climate policy in Alberta and Saskatchewan is cause for concern. The Ontario environment minister raised a similar concern in a letter sent the federal environment minister following the story in the Globe and Mail. As a province that has already done most of the heavy lifting to phase out coal, it’s entirely reasonable that they’re expecting comparable actions from other parts of the country.

If the federal government is going to hand off responsibility for reducing global warming pollution from coal to the provinces, these concerns need to be addressed in advance.

Rob Vann — Mar 19, 2012 - 04:33 PM MT

By the comments, it appears the paid industry shills are out in force here. You have to wonder if they get paid by the word or paragraph to write such utter nonsense.

Looking forward to seeing Pembina's report on Nova Scotia's alternative plan to reduce greenhouse gas emissions.

Rob Vann — Mar 19, 2012 - 04:31 PM MT

By the comments, it appears the paid industry shills are out in force here. You have to wonder if they get paid by the word or paragraph to write such utter nonsense.

Looking forward to seeing Pembina's report on Nova Scotia's alternative plan to reduce greenhouse gas emissions.

coal industry — Mar 15, 2012 - 05:13 AM MT

Coal Terminals and additional infrastructure are required in the coal supply chain. Coal industry and coal prices show developing economies are more likely to increase their investment into & their use of thermal coal & metallurgical coal in coming years because of its affordability and to meet increasing demands for electricity and steel.

coal industry — Mar 07, 2012 - 05:46 AM MT

coal publications would suggest the commodity isn't going anywhere. Coal reports show if we have to live with it, we may as well reduce the impact of coal and CCS seems to be the best solution found to date. Cherry While for some an ideal world would see no reliance on coal industry to produce electricity,

FREE — Jan 13, 2012 - 03:58 PM MT

I think these people at pembina need to spend time in jail for the fraud they continue to present to the world.

Try googling climategate 1 and 2

Bart R — Jan 15, 2012 - 12:24 PM MT


Out of climategate 1, no less than seven full inquiries, several at the initiation of verifiably hostile authorities, have pursued illegality and wrongdoing connected to the contents and the rumourmongering associated with this hack.

The upshot?

One person was found to not be competent to the duties of administering FOI (and had his duties reduced) and dozens of recommendations -- most of which have since been adopted -- to improve communication and administration.

Climategate 2's cynical and obvious agenda makes clear we're witnessing a hacker interested in malice, not a whistleblower intent on revealing to us all everything he knows about a wrongdoing.

So, really, I can't feel anything but disdain for your claims.

Roger Gagne — Jan 13, 2012 - 07:04 PM MT

Hi Free,

American Meteorological Society reaffirms it’s support for climate change.
“Impact of CRU hacking on the AMS Statement on Climate Change”

Who else responded to Climategate?

The Associated Press wrote that the hacked emails
"… don't undercut the vast body of evidence showing the world is warming because of man-made greenhouse gas emissions."
"Hacked e-mails show climate scientists in a bad light but don't change scientific consensus on global warming." checked out Sen. James Inhofe's claim that climate science "has been pretty well debunked", and gave it an unequivocal "False" on it's Truth-O-Meter.

American Association for the Advancement of Science reviewed the evidence and said "…global climate change caused by humans is now underway, and is a growing threat to society."

Joining them are The Geological Society of America, National Academies of Science, The National Research Council, and the journal Nature.

Roger Gagne — Jan 12, 2012 - 10:23 PM MT

And watch Nova Scotia and Ontario reap the benefits of distributed power via renewables, as is being well understood and appreciated in Gainseville, Fla., the first municipality in North America to implement a Feed In Tariff.

"A report released earlier this year found that the grid benefits and social benefits of solar power far outweigh the typical valuation of solar power by utilities. These benefits include reduced stress on the utility distribution system and reduced transmission losses."

Roger Gagne — Jan 12, 2012 - 10:18 PM MT

Hi Skip,

Myths and junk science... and your proof is...?

Please name any scientific organization or national association on the planet that disagrees with the theory of anthropogenic global warming.


skip — Jan 12, 2012 - 09:59 PM MT

Still believing in the global warming myth I see.

Still believing in junk science and fraudulent economics.

Canadians have seen through this watermelon scam and are moving on.

You are pissing in the wind.

Coal fired plants will be continue to be built. They will have state of the art particulate, NOx, SOx removal but nobody cares about a harmless trace gas that is essential to life.

Bart R — Jan 15, 2012 - 12:17 PM MT


I find your remarks interesting.

If I may, I'd like to mainly skip over your use of the perjoratives 'myth', 'junk', 'fraudulent', 'watermelon' and 'pissing' instead to discuss the words 'state of the art', 'harmless', 'trace' and 'essential'.

True, we know to a scientific certainty without rational dispute that CO2 participates in the warming of our biosphere, in turn allowing liquid water essential to life.

Absolutely, concentrations of CO2 above 130 ppmv are essential. Below that level, plants suffer CO2 starvation.

Ice cores going back 800,000 years with great precision and geological evidence allowing us to extrapolate the ice core record for hundreds of millions of years to a lesser degree of accuracy tell us that all life on Earth has for between 10 and 20 million years acclimated to a level of CO2 at 230 ppmv +/- 50 mmpv, with local variation due geophysical and biological activity varying for seasonal terms.

Essential? You have that right. Up to 180 ppmv. Past that, CO2 is of diminishing value and increasing risk of harm.

Trace? Trace is another term easy to spin to a sophist's ends, as naive scientific dictionaries seldom so tightly define technical terms as to dissuade abuse. Normally, "trace" implies such small concentrations or absolute amounts as to be difficult to measure and of a degree so small as to take no measurable or important part in a reaction.

Obviously we can measure CO2 in the air we breath.

We know CO2 takes important, measurable parts in diverse ways in our life.

Calling CO2 trace because N2 and O2 (btw, no O2 would exist in the atmosphere if not for CO2) have such relatively high concentrations pushes usage beyond credibility, even if your own 'essential' were not proof enough that 'trace' isn't correct.

CO2 concentration is the variable of interest in much of science. Ergo, it is not trace.

'Harmless' is a word that brings to mind the old saw, "the dose makes the poison."

Above some level, CO2 certainly harms every category of living thing, in ways ranging from minor behavioural changes to lethality. These ranges differ between micro and macroscopic forms, for different plants with different CO2 pathways, and for different animals depending on physiology, size and metabolism. Each of these CO2 levels is a ceiling of harm.

Harms drive life to migrate, and we know migrations attributable directly and indirectly to CO2 concentration by diverse living things from traditional ranges have been happening for decades.

Harmless cannot be applied to CO2, except in the range 180 ppmv to 280 ppmv. We know we've passed several harm ceilings, and are headed to more, more serious, limits of harm.

Clearly, rational Canadians do care.

"State of the art" is a myth that ought provide no comfort nor have any persuasive weight.

However state of the art the technology, they're always making better idiots, skip.

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