Tell the Harper gov't to fix its limp, ineffective coal regulations!

Dear Friend,

On August 27th the Harper government introduced regulations for coal-fired electricity stations that add up to a shell game, a loose set of "rules" that will not protect your family or the environment from coal pollution.

But it's not too late! Today, we are taking action en masse to overwhelm Environment Canada with our letters during its formal public comment period (which ends October 26, 2011).

Today is a great day to tell the Harper government to fix its limp, ineffective coal regulations!

Sierra Club Canada has done the math: It is not possible to address climate change and air pollution without a compete phase-out of coal. It's that simple. By writing to Environment Canada today, you will be adding your voice to Sierra Club Canada's call to:

• Eliminate five ridiculously broad, industry-biased exemptions;
• Add incentives so industry can embrace the new rules;
• Include independent multi-stakeholder oversight; and
• Require companies to make their data public (so we can know if they’re complying!).

Just a few minutes of your time will deliver your unmistakable message to government. You can use the draft letter we have prepared, or even better, write your concerns in your own words.

We already won the coal fight in Ontario where it is set to disappear as a source of electricity in the next few years! Now it's time for the federal government to do the responsible thing, too.

We know how much you care about the devastating health and environmental impacts of coal pollution. So please send your letter today.

John Bennett, Executive Director
Sierra Club Canada
jb@sierraclub.ca

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Backgrounder: Five Industry-Biased Exemptions Outlined in the Regulations

Existing Unit Exemption

The regulations include no incentives for utilities to reduce CO2 emissions from existing units so it will be business as usual as new ‘performance standards’ won’t apply to existing coal plants that have not reached the end of their “useful life”. The yet-to-be-built Maxim mega-coal plant in Alberta also qualifies as an existing unit grandfathered under this ridiculous exemption. There should be no exceptions – dirty plants should be shut down and new ones should not be built.

Substitution Exemption

The effect of this exemption is to allow old CO2 emissions-intensive plants to continue to burn coal when it should be shut down or retrofitted to meet the newly proposed performance standard (375 tonnes of CO2 per GWh). This exemption authorizes a utility to avoid the application of the performance standard to an existing unit that is reaching the end of its useful life by applying (“substituting”) the performance standard instead to another existing unit. It’s a shell game and Canadians deserve better.

Carbon Capture and Storage Exemption

This exemption is based on the promise of a utility to construct a carbon capture and storage (CCS) system for a plant. To qualify for the exemption, the plant operator of the unit must submit a feasibility assessment. However, the public isn’t guaranteed access to the feasibility assessment to evaluate the likelihood that the CCS system will actually be constructed. No sunlight – no accountability.

Eighteen-month Exemption

This exemption allows dirty old CO2-intensive coal plants – clearly identified as having to be shut down or retrofitted under the proposed regulations - to continue to burn coal for 18 months (or longer). All the plant operator has to do is establish that another of its units is capturing 30% of its emissions using CCS. This exemption is also extendable by the Minister of Environment for further 18-month periods. This is regulation-based on politics and not sound policy.

Emergency Circumstances Exemption

Where there is a so-called extraordinary, unforeseen, or irresistible event that results in a power disruption - or a significant risk of a power disruption - a coal plant may apply to the Environment Minister for a 90-day exemption from the performance standard, which may be extended. There are many things wrong with this approach: 1) “Extraordinary, unforeseen and irresistible events” will become increasingly common as a result of climate change; 2) “Significant risk” of a power disruption is not a difficult test to meet - the exemption should be limited to situations where there are actual brownouts or blackouts; and 3) The utility will decide when there is a “significant risk” and NOT the provincial government or regulatory agency - obviously a conflict of interest. The fox must not be allowed to guard the henhouse.