Newfoundland and Labrador’s “Climate Action Plan” is All Bark and No Bite

You could almost mistake its 55 glossy pages of picturesque coastal landscapes for a tourism brochure, save a strange word map of climate policy-related buzzwords. In reality, it is Newfoundland and Labrador’s brand new climate change action plan; or, to stay on brand, The Way Forward: On Climate Change in Newfoundland and Labrador. A five-year plan to guide provincial action and support implementation of the federal government’s Pan Canadian Framework on Clean Growth and Climate Change.

Does this beautiful PDF detail how to decarbonize the provincial economy and to help avoid the catastrophic impacts of global climate change?

It has some strengths, and many weaknesses.

Let’s start with the good news.

First and foremost: kudos to the provincial government for recognizing the urgency of climate change. Annual average temperatures in Newfoundland and Labrador have already increased 0.8 degrees Celsius above historical norms, and the report does not shy away from highlighting some of the most frightening scientific evidence on climate-change induced impacts in the region.

By mid-century, winter temperatures in northern Labrador are expected to rise by seven degrees Celsius. This rate of temperature growth could shorten the winter season by four to five weeks, severely impacting northern transportation routes and Indigenous people’s abilities to travel the land and ice.

The frequency of tropical storms and hurricanes in the province has doubled compared to the last century. And in some areas of the province, sea levels are expected to rise by half a meter.

So credit where it’s due. Acknowledging these impacts head-on is no small feat for any level of government.

Second: while it’s never wise to laud failure, there is a refreshing honesty in their assessment of the province’s recent decarbonization efforts.

In 2007, the provincial government adopted an emissions reduction target of 10 per cent below 1990 levels by 2020. As of 2016, the province emitted 10.8 megatonnes (MT) of greenhouse gases (GHG) annually, an increase of 16% over 1990 levels. The new climate plan boldly admits “the Provincial Government is not on track to meet its 2020 target, even with the Muskrat Falls development and the forthcoming closure of the Holyrood Generating Station.” (p. 8).

While the province should be congratulated for its honesty, this failure does not inspire confidence in the 2019 plan’s new emissions reduction targets: “the province will strive to reduce provincial GHG emissions by 30 per cent below its 2005 GHG emissions level” by 2030.

“We will strive”—not good enough. Another round of non-legislated emissions-reduction targets means that in 2029 we will once again be admitting climate defeat with zero penalty for policymakers.

Now for the bad news.

There is a concerted effort in the province’s new climate plan to ignore the impact of Newfoundland and Labrador’s offshore oil sector on the provincial emissions profile.  

In 2016, oil and gas production accounted for 25% of provincial emissions, behind only transportation (36%), and far ahead of the third largest contributor—electricity generation (11%). This is concealed in the province’s climate action plan—burying the category of ‘oil and gas production’ beneath ‘large industry’ to avoid criticism of these tremendous impacts.

What’s more troubling is that in February of 2018, over a year prior to publishing their new climate action plan, the province released Advance 2030: A Plan for Growth in the Newfoundland and Labrador Oil and Gas Industry. This report paints a clearer picture of where provincial priorities lay. Advance 2030 details plans to double offshore oil production, from current levels of 280,000 barrels per day (bbl/day) to over 650,000 bbl/day by the end of the next decade.

In 2016, the production of 77 million barrels of offshore crude oil was responsible for 1.6MT of GHG emissions. Assuming the province’s stated goal of increasing offshore oil production to 237 million barrels annually, we can extrapolate our numbers to suggest emissions from the sector will account for a staggering 4.9MT annually by 2030. The province’s new annual emissions target for 2030 is 6.9MT, meaning offshore oil production alone will account for 71 per cent of provincial emissions, assuming targets are met.

We cannot have meaningful climate action in Newfoundland and Labrador without curtailing the production of oil and gas.

The provincial climate plan includes eight focus areas, with a total of 33 action items in order to mitigate emissions, adapt to the realities of climate change, and further educate the population of Newfoundland and Labrador. This tri-fold approach (mitigate, adapt, educate) should be applauded, but the climate plan is missing a major component.

Any well-designed government policy, plan, program, or project includes not only action items, but meaningful ways to measure progress on those action items in order to ensure the initiative is meeting its goals. Of the 33 action items outlined in the plan, expected emissions reductions are only included for a single initiative. The provincial carbon pricing program is projected to reduce cumulative GHG emissions by over 650,000 tonnes (0.65MT) between 2019-2030, or approximately 59,000 tonnes per year. This equates to a 0.6% emissions reduction annually from the carbon pricing program.

With current annual emissions of 10.8MT, an addition of 3.3MT from expanded offshore oil production, and minor projected decreases of 1MT from shuttering Holyrood and 0.65MT from carbon pricing, it’s not hard to imagine Newfoundland and Labrador in 2030 emitting 13MT of GHG emissions, or nearly double the target of 6.9MT.

The plan identifies $225.4 million in funding from various sources to address its 33 action items. Using provincial wind energy development as an emissions reduction-proxy: this amount of funding could build 113 megawatts of wind energy, which would be theoretically capable of displacing .63MT of GHG emissions annually at Holyrood. The $12.7-billion-dollar Muskrat Falls project will displace only 1MT of provincial emissions annually, giving an idea of the magnitude of investment required to decarbonize.

$225.4 million is a woefully inadequate amount to achieve meaningful reductions of greenhouse gas emissions.

In general, the climate action plan contains a lot of bark, but little bite. Terrific action items, but very little explanation of how these actions items will be implemented to achieve emissions reductions. The toothless nature of the climate action plan is demonstrated most vividly in action items related to electricity generation.

For example:

Action Item 4.2.6: Seek opportunities to develop renewable and low-carbon energy for local and export markets (e.g. hydro, wind, tidal, hydrogen and smart grid technology).

The hypocrisy here is astonishing: renewable energy development by private sector proponents, community groups, municipalities, educational institutions, Indigenous governments, is prohibitively—and deliberately—difficult in Newfoundland and Labrador.

Bill 61, passed in 2012 in preparation for the Lower Churchill Project, provides Newfoundland and Labrador Hydro “the exclusive right to supply, distribute, and sell electrical power or energy” to retail or industrial customers for use by their operations on the island portion of the province. In addition, the bill requires that “a retailer or an industrial customer buy electrical power or energy from Newfoundland and Labrador Hydro.”

In practice, this means that NL Hydro is the only company permitted to own, supply, distribute, transmit, think about, dream about, or do anything related to renewable energy development in the province.

What are you proposing to do here? Abolish Bill 61? Pursue innovative renewable energy policy tools such as expanding net-metering, a feed-in-tariff, renewable portfolio standards, or tax incentives?

All platitudes and no actual mechanism to achieve tangible policy outcomes like a reduction in greenhouse gas emissions.

Here’s another:

Action Item: 4.2.7: Work with stakeholders, including Indigenous governments and organizations and Newfoundland and Labrador Hydro, to identify opportunities to reduce diesel electricity generation in the province’s isolated diesel-powered communities.

Combined, 21 isolated diesel communities in Newfoundland and Labrador consume approximately 18 million litres of fuel per year—resulting in 50,000 tonnes of C02 emissions, as well as public health challenges, the risks of fuel spills and leaks, and other detrimental impacts.

On its face, this is another excellent action item. But as you might expect, the devil is hidden in the details. The provincial carbon pricing scheme, for instance, entirely exempts off-grid diesel generation. While this is a tremendous benefit for ratepayers in isolated communities who are struggling with the current cost of electricity, it sends a price signal to the existing utility that pollution from diesel-generation is entirely acceptable. Once again we are left asking—what is your plan? How are you going to reduce diesel consumption? But we are left with more questions than answers.

This has been typical of many Way Forward plans: glossy pages, stunning photography, stylish production, but very little substance hidden behind the design. On Climate Change in Newfoundland and Labrador adds a new innovation: stating the problems frankly, but then continuing to ignore them anyway.

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