Interim response to the provincial government’s “climate strategy”

On Monday (Dec 4, 2017), Environment Minister Dustin Duncan announced the Saskatchewan government’s much-awaited climate strategy, entitled “Prairie Resilience”.  We find it something of an anticlimax – a remix of old ideas with no truly new initiatives.  There are some positive elements within it, but for the most part it demonstrates a distressing lack of commitment to addressing the climate crisis.

General comments

1. All climate policy should recognise:

  • that there is a carbon budget within which the global community must stay in order to avoid unmanageable resilience-proof climate change;
  • that, in order to stay within that budget, all jurisdictions have a responsibility to reduce emissions so as to reach net zero in a matter of decades; but that the onus is particularly on wealthy industrialised high-emitting societies such as Saskatchewan;
  • that carbon budgets have shrunk so far that it is unlikely that we could meet them without transformative change; and this is particularly true of those jurisdictions which have done little or nothing to address the climate crisis during the three decades that we have had sufficient scientific certainty to act.

The official government document, and Mr. Duncan’s statements, at no point show any understanding of the scientifically-determined carbon budget, of the challenge which it sets us, or of the importance of international equity both morally and practically.

2. The document is extremely vague. It is full of language such as “investigating the feasibility”, “explore additional… products and services”, “determine the viability”, “policies will be explored”, etc.  Even where there is a definite commitment to “introduce regulations” or “implement standards”, there is no indication as to what those regulations or standards might be.  This lack of detail – a full year since publication of the federal Pan-Canadian Framework on Clean Growth and Climate Change, nearly two years since signing the Vancouver Declaration, and over ten years since the current administration first came into office – is deeply concerning.

3. The government frames its “strategy” in terms of “resilience”, and uses this framing to downplay mitigation measures (i.e. reducing our contribution to climate change) in favour of adaptation (i.e. coping better with its impacts). While adaptation is also vitally important, the use of this framing amounts to misdirection, given the lack of substance in both categories but especially in the mitigation portfolio.  Furthermore, it puts lives and livelihoods at risk in its failure to recognise that, at the global average temperatures to which we will be heading if all jurisdictions approach mitigation in a similar way, there will be no realistic chance of successful adaptation.  (A related concern:  Combine this emphasis on adaptation with Premier Wall’s well-publicised call a year ago for federal funds to be redirected away from support for adaptation in climate change impacted low-income countries, and we see at the very least a serious case of cognitive dissonance.)

4. A major sign of government negligence is the lack of any firm emissions targets – let alone any indications as to how to achieve them. Targets are an essential element in developing a pathway to a zero-net-carbon society.  Further evidence of negligence is the lack of benchmarking, whether against acknowledged standards or against other jurisdictions’ best practice – and, associated with this, the lack of quantitative data or evidence to back up claims.  The government has not shown how each of the measures it advocates would result in emissions reductions, nor by how much.  The few numbers provided in the report are undocumented, and are mostly difficult to take seriously.

5. It is somewhat ironic that the document (rightly) states that “the conversation about climate change must be broader than carbon pricing”, when the bulk of the premier’s climate messaging over the last year – unlike that of environmental and climate-focussed groups or even of the federal government – has been about federal carbon tax proposals (and mostly in highly simplistic terms).

6. It is also worth noting that the provincial government’s refusal to cooperate with the rest of Canada in the Pan-Canadian Framework will most likely render the province ineligible for federal funding on some projects which could both reduce our carbon footprint and create jobs. We should, for example, be seeking federal support for enhancing the electrical interconnection between Saskatchewan and Manitoba, and for developing a strong network of fast charge stations for electric vehicles.

7. A serious climate plan would seek to take advantage of the massive employment potential and investment possibilities in green energy options – surely an important element in the resilience of our communities. This is a matter of vital social and economic importance, and yet is not mentioned in the report.

Some Specifics

1. Both because of the shrinking carbon budget and because of the health impacts of a number of non-carbon emissions, it is important that we plan a rapid but orderly exit from coal-fired power. Instead of acknowledging this, the government remains firmly attached to carbon capture and storage – a technology which has proved both unreliable and (as SaskPower management have recently come close to acknowledging publicly) unacceptably expensive.  CCS would be inadequate as an emissions reduction technique even if it were not being used to increase emissions elsewhere through enhanced oil recovery.  We should instead be planning a rapid but orderly shift to a 100% renewables-based electricity grid, learning from state-of-the-art international research and from the experience so far of countries such as Scotland, Denmark and Germany.

2. The transport strategy is helpful at the margins. However, three important policy options capable of reducing emissions are neglected:

  • public transit conceived as a public service,
  • developing a strong infrastructure network for electric vehicles – especially a province-wide network of charging stations – either through support of the private sector or through direct public sector investment, and
  • using SGI rates to provide incentives for fuel-efficient options and disincentives for gas-guzzling.

3. Requiring compliance with building codes is a good start – if overdue. The document is correct to recognise the early work done in Saskatchewan on energy-efficient building design.  However, things have moved on internationally since then, and advances in northern Europe are now making their way back to Saskatchewan, with the construction this year of houses in Saskatoon compliant with the much tougher Passivhaus standard.  This shows that there is definite potential for moving rapidly to more rigorous building energy codes in future.  Preparations should be put in place to do so.

4. Large industrial emitters account for about one-tenth of emissions, once electricity generation and upstream oil and gas are excluded (as appears to be the government’s intention). While the output-based performance standards proposed by government for this sector are a useful tool, much more is needed to actually reduce emissions.  That this is possible is shown by success in reducing emissions from diverse industrial subsectors in a number of European countries through a combination of subsector-specific regulation and carbon pricing.

5. There is no indication of any government intention to require any particular energy efficiency or emissions standards for new industrial development. Regulations to ensure best climate practice in plant design would prevent inefficient practices from being locked into the system for decades.

6. For the oil and gas sector – the largest source of emissions in Saskatchewan – nothing solid is proposed beyond a vague commitment to “develop regulations”. Furthermore, there is no commitment to statutory monitoring of fugitive emissions (venting, flaring, leaks, etc) – which account for over half of the oil and gas sector’s upstream climate impact.  On this subject, it would also be helpful to know whether the Saskatchewan government is willing to cooperate federally – and how its proposal might compare with the existing relatively stringent regulations in North Dakota.

7. The Saskatchewan government has summarily dismissed the whole idea of carbon pricing. We are, by contrast, confident that it is possible to design a system which works for Saskatchewan’s economy while also reducing emissions.  This requires a willingness to think carefully through options, to listen to expert advice, and to consult more widely than has so far been done.  In several sectors, carbon pricing could drive efficiency improvements and hence competitiveness.  More generally, it would be wise to build, in tandem, a plan for economic diversification, encouraging the growth of low-emissions sectors.  Carbon pricing is just one tool in the box, but it is a tool which can leverage change in most sectors, and will be particularly effective if combined with the removal of logistical and administrative barriers to low-carbon and zero-carbon options (and, in some cases, with government-supported arrangements for low-interest financing of emissions reduction strategies).

8. While it is important to develop and encourage carbon sequestration in soils and forests, policy in this area should be based on full-system analysis which accounts for all sources and sinks of greenhouse gases. The government’s current position systematically fails to do so.  Pulse crops do indeed fix nitrogen in the soil, and so could offer a benefit.  This benefit, however, is only realised if it results in reduced use of artificial fertilisers and hence in reduced nitrous oxide emissions from soil (and also in reduced fossil gas combustion at the fertiliser factories).  The reality is that artificial fertiliser use has actually increased over the last two decades despite the expansion of pulse crop planting.  As regards soil and forestry, the figures which matter are the net increase in annual carbon sequestration, not the absolute size of the annual sink.  Using the wrong parameters constitutes misleading the public.  In any case, NRCan data shows that forest fires and insect impacts have led to our managed forests being a net source of carbon over 7 of the past 10 years – a trend liable to intensify as climate change progresses.  And if government is really serious about soil carbon sinks it should be reconsidering its decision to sell off community pastures.

What is needed now

We therefore do not believe that Mr. Duncan’s “made-in-Saskatchewan climate change strategy” can achieve its declared goal of “prairie resilience”, nor significantly reduce the province’s disproportionately high emissions footprint.  The province of Saskatchewan is capable of making a much more effective climate strategy than this – and we know that there are people willing to do so.  Design of such a strategy needs to start from an understanding of the urgency to which the science is pointing, set firm targets and establish ambitious and precisely articulated multi-decade plans.

CJS is therefore interested in working together with others who are committed to evidence-based policy and to principles of fairness (including both full recognition of Indigenous rights and creation of good clean jobs in a just transition), to build viable alternative plans.

Over the next few months we will be putting forward both positive proposals and more detailed comments on government policy as it develops.

Thanks to Hayley Carlson and Justin Fisher for some of the points included in this posting

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