SPEECH – An Expanded Commitment: DuPont and Sustainable Growth

Posted on October 1, 2006 by energyprbe

Chad Holliday, Chairman and CEO, DuPont

October 1, 2006

It’s a pleasure to be here today to discuss the imperative for an expanded commitment to sustainability and sustainable growth – for DuPont, for industry in general, and for all sectors of society.

Let me start with a perspective on DuPont. We are in our 204th year as an enterprise and have grown and moved in directions that our predecessors would find surprising. But what wouldn’t surprise them is the innovation and creativity – rooted in a foundation of values – that has taken us in those directions.

A Heritage of Innovation

We began as an explosives company. Our first patent in 1804 was signed by Thomas Jefferson and endorsed by James Madison. It was a machine for granulating gunpowder. Today we are on the leading edge of biotechnology and nanotechnology. When the U.S. government issued U.S. Patent 7,000,000 earlier this year, it was for a very different DuPont invention – a bio-based synthetic fiber derived from renewable resources.

In between, DuPont has been awarded patents for more than 34,000 inventions, many of which gave the modern age its look and feel and many of its most useful materials. The majority of those discoveries came in the second half of our history, with the pace rapidly accelerating the closer you get to the present. But you could say our patents represent, on average, a new innovation every other day for the past two centuries.

Today our innovation capability can best be described as dynamic science – science that is constantly anticipating and addressing market needs. For DuPont in the 21st century, dynamic science means using biology as well as chemistry and other scientific disciplines to develop sustainable products that address some of the world’s most pressing challenges.

To deliver those innovations to market, we have transformed our company several times in our history, constantly challenging ourselves with this question: Are we doing the right things to build a stronger company, help solve the world’s toughest challenges, and build a brighter future for people and our planet?

Examples of how we answered that question can be traced throughout our history as a company. In the DuPont archives there is a handwritten document from 1811 with our first safety rules. You also can read our first statement of environmental responsibility which was created in 1938. We answered the question again at the start of our most recent transformation to a science company when we said our mission is sustainable growth – putting our science to work to develop sustainable, global solutions, not only for our customers but for people everywhere.

There’s also something else that comes with 200 years of history – humility. As a company we have been through many experiences that remind us that we don’t have all the answers. When you have been making thousands of different products for more than two centuries, there are bound to be legacy issues. DuPont has them. We accept that society expects transparency and responsiveness on such issues, and we are committed to both in order to earn and keep the public’s trust.

Sustainability – An Evolving Idea

In order to do that, we have to keep pace with the evolving idea of sustainability. In the 1970s and 1980s our focus was on internal safety and meeting environmental regulations. In the late 1980s and 1990s we added voluntary footprint reductions, going beyond regulatory requirements. We looked to increase shareholder value with a goal of zero safety and environmental incidents as we decreased raw material and energy inputs into our products and reduced emissions at our manufacturing sites.
Now we see ourselves in a third phase of sustainable growth, characterized by a holistic approach that is fully integrated into our business models. In this phase, sustainability is broadened to include human safety as well as environmental protection, and it becomes our market-driven business priority throughout the value chain. The transition to products that meet the definition of “sustainable” will take place over time, for DuPont as well as for other companies such as General Electric and Wal-Mart. But the pace will quicken as the synergistic effects of market demand, societal expectations and product innovation create collaborations up and down the value chain. Sustainability will increasingly become central to the total value proposition. This will impact not only our business, but every customer and – through their products – every consumer we touch.

How to accomplish that is changing in this new century of sustainability. The view of scientists locked away in a laboratory inventing something new and wonderful to spring on the world has given way to a market-back approach. For innovation to be successfully introduced into the marketplace and accepted by society, it must be based on many forms of partnership and continuous dialogue with stakeholders, including governments, NGOs and academia. Science and innovation that does not address pressing human needs will not advance sustainability. Likewise a vision of sustainability detached from science and technology will not succeed. We need both the commitment to sustainability and the accomplishments of science.
But we never forget that we are a business, and our first job is to create value for our shareholders.

Sustainable growth means creating value for our shareholders and for society by developing products that the market demands – and which also are good for the environment and for the health, safety and well-being of people everywhere. Many companies say that what’s good for the environment can also be good for business. We have the view that what’s good for business must be good for the environment and for people worldwide or you are not moving toward sustainable growth.

Goals to Track Our Progress

To help keep us on that track, we have found it useful to create goals so everyone in the company knows what we’re aiming for and everyone outside the company can hold us to it.

We take such commitments very seriously.

For example, in 1994, we set a goal to reduce greenhouse gas emissions by 40 percent by the year 2000. We achieved that goal on schedule. Then we challenged ourselves to reduce our greenhouse emissions by 65 percent by 2010. We made that goal as well. In fact, we achieved a 72 percent reduction by 2004, six years ahead of schedule, and avoided costs of over $3 billion by holding our energy use six percent below 1990 levels.

We’ve been recognized for our efforts. An independent panel of experts assembled by BusinessWeek, for example, named DuPont the top green company of the past decade for our greenhouse gas reductions and our leadership in environmental management. But we don’t see recognition as a victory. We see it as confirmation that we’re moving in the right direction and as encouragement to continue.

2015 Sustainability Goals

Now we’ve created a new set of 2015 Sustainability Goals that renew and expand our commitment to sustainability. Our 2015 Sustainability Goals span every sector of our operations – from R&D to manufacturing to marketing.

They go beyond traditional footprint reductions to include goals that tie our business growth even more directly to the development of safer and environmentally improved products for the many global markets we serve – transportation, communications, construction and agriculture, to name a few. They also make sense from a business performance perspective because revenues from our current safety and environmental offerings are increasing at double our average revenue growth rate.

Market-Facing Goals

First and most important among this newest set of goals are what we call our market-facing goals. These build on markets and opportunities where we believe our integrated science capabilities in chemistry, biology and materials science can make a difference for our shareholders and society. F
or example, not only will we work to develop alternative fuels, but we also will create products that help make the use of those fuels more efficient. We have four market-facing goals:

By 2015, DuPont will double our investment in R&D programs with direct, quantifiable environmental benefits for our customers and consumers along our value chains.

By 2015, DuPont will grow our annual revenues by at least $2 billion from products that create energy efficiency and/or significant greenhouse gas emissions reductions for our customers. We estimate these products will contribute at least 40 million tonnes of additional CO2 equivalent reductions by our customers and consumers.

By 2015, DuPont will nearly double our revenues from non-depletable resources to at least $8 billion.

DuPont will enhance our focus on protecting people. We will increase the amount of R&D spent on developing and bringing to market new products that will protect people from harm or threats. Between now and 2015, we will introduce at least 1,000 new products or services that help make people safer globally.

Footprint Goals

To intensify our ongoing efforts to minimize the environmental impact of our operations around the world, we have updated and expanded what we call our footprint goals:

Since 1990, DuPont has reduced our global greenhouse gas emissions measured as CO2 equivalents by 72%. By 2015, we will further reduce our greenhouse gas emissions at least 15% from a base year of 2004.

DuPont commits to reducing water consumption by at least 30% over the next ten years at our global sites that are located where the renewable freshwater supply is either scarce or stressed as determined by the United Nations analysis of river basins globally. For all other sites, DuPont will hold water consumption flat on an absolute basis through the year 2015, offsetting any increased demand from production volume growth through conservation, reuse and recycle practices.

DuPont will introduce fleet vehicles that represent the leading technologies for fuel efficiency and fossil fuel alternatives. By 2015, we will ensure that 100% of our off-site fleet of cars and light trucks meet these criteria. We will continue to ensure these vehicles are safe as well as fuel efficient, and we will track and report on our fuel efficiency improvements.

Since 1990, DuPont has reduced our global air carcinogen emissions by 92%, well beyond legal requirements. By 2015, we will further reduce our air carcinogen emissions at least 50% from a base year of 2004. This will bring our total reductions since 1990 to 96%.

By 2015, DuPont will ensure that 100% of our global manufacturing sites have successfully completed an independent third-party verification of the effectiveness of their environmental management goals and systems. We will make this information publicly available and communicate it to our local communities.

To achieve these goals, we’re relying on the power of One DuPont – the creativity and commitment of our 60,000 employees around the world. But it’s also going to take partners who share our commitment and have the influence and ability to take actions that will make a difference in achieving a safe and sustainable world. Because of the nature of DuPont’s products and services, we sell into virtually every major industry in the world. As an ingredient supplier in countless value chains, we have a broad and deep impact on global industries and therefore on global society.

In some of those value chains, we already see opportunities for sustainable growth unfolding. Let me describe some of the exciting developments in three areas of current activity – biotechnology, bio-based materials and safety.

Biotechnology

Biotechnology holds great promise to enhance our lives and the planet. In the 20th century, DuPont used chemistry to transform natural processes and materials into manmade materials based largely on petroleum feedstocks. In the 21st century, we are using nature’s own processes to produce materials that are based on renewable feedstocks that can be produced and used in a sustainable manner. With a world population expected to reach nearly 9 billion by 2050, biotechnology offers the potential for sustainable living, healthy eating and battling diseases while reducing environmental impact on the planet.

We believe the broad field of biotechnology presents important opportunities that should be explored and developed to identify those safe and commercially viable applications that bring benefits to society. These opportunities span food, materials, energy generation, sensors and electronics. Benefits include lower cost, higher quality products and reduced reliance on fossil fuels, among other environmental benefits.

We are committed to improving our understanding of how to grow more nutritious food, particularly in areas that, because of soil composition or drought, pose an agricultural challenge. For example, our Pioneer Hi-Bred International subsidiary uses advanced plant genetics to develop field crops that are more productive, of higher quality, more nutritious and better suited for specific uses.

Pioneer® brand low linolenic soybeans are used to produce soybean oil that eliminates the need for hydrogenation, a process that creates trans fats, which have been linked to heart disease and other health concerns.

Bio-Based Materials

A direct product of our biotechnology is our work in bio-based materials. A few months ago, we announced a partnership with BP to create a new generation of biofuels that can be produced from locally grown crops containing sugar – like corn in North America, sugar beets in Europe, and sugar cane in Brazil.

These biofuels will help reduce the world’s dependence on oil while also providing economic opportunity to local farmers. We expect to commercialize products in the U.K. next year. Separately, we are developing seeds to increase the production of alternative fuels.

Our intent is for DuPont to become a major player in bringing biofuels to market in a way that promotes sustainable agriculture. Sustainable agriculture is a goal that demands partnerships across multiple sectors, and we currently are in discussions in the United States and Brazil to identify NGOs with whom we can partner in pursuit of this objective. We want to make sure that the development of biofuels is accomplished in a way that does not take food out of some peoples’ mouths to put gasoline into other peoples’ cars.

We also are tapping into a multi-year research and development partnership with MIT focusing on bio-based materials and technologies, including fine chemicals, monomers, biopolymers and biomodified polymers.

Our joint venture with Tate & Lyle of the U.K. is developing a bio-based process for creating a major ingredient for our Sorona® polymers, our newest polymer platform. The bio-route to this polymer uses 40 percent less energy and will save the equivalent of 10 million gallons of gas annually – enough to power 22,000 cars a year. The first manufacturing facility for what we call Bio-PDOTM will start up later this year in Loudon, Tennessee, with commercial product available early next year.

Our plan is to brand our product line of high-performance materials made with renewable resources, so that our customers can easily identify and select DuPont Renewable Materials. This will include Sorona® as well as engineering polymers, coatings and elastomers based on renewable materials.

Progress Throughout DuPont

We also are aiming to make further progress in improving the environmental profile of our traditional product lines. For example, our R&D pipeline is delivering next-generation refrigerants with lower greenhouse warming potential; new automotive finishes with lower VOC content; and enhanced solutions to improve solar module lifecycle and efficiency, building on our experience with eight DuPont prod
ucts currently used in photovoltaic solar panels.

Safety

Because of our unique tradition of safety at DuPont, the third area where I believe DuPont will make a sustainable growth difference is in safety. At DuPont, sustainability is not just about being an environmentally smarter company. It’s also about protecting people and keeping them safe.

We have many current product offerings that protect people, with many more in development. We are confident that the power of DuPont science will put us on a path to meet our 2015 goal of 1,000 new products or services that help make people safer.

You know Kevlar® as a 40-year-old product that is used in protective vests where it has saved the lives of 3,000 police and security officers. What you may not know is that Kevlar® – a lightweight aramid fiber that is five times as strong as steel – also is used to reinforce high-performance automobile tires sold by Goodyear. And it is being used to protect people from tornadoes and hurricanes through the DuPont TM StormRoomTM with Kevlar® that can stop a 2×4 traveling at over 200 miles per hour.

We recently announced a $100 million global investment in our Nomex® business. You probably know Nomex® as a flame-resistant aramid fiber that protects firefighters and emergency workers around the world. It’s also widely used in aircraft interiors, train upholstery, as electrical insulation, and is now seeing growing use in providing safe and reliable wind power in countries like China.

Because of products like Kevlar® and Nomex®, we’ve seen the market for personal protection products continue to grow around the world. We’re building on that strong base with innovations that address the increasing threats facing people and property from weather, attack and accidents.

The threat of avian flu poses a significant and serious challenge to countries around the world. As part of our safety offering, we will be marketing personal BioSecurity kits that include DuPont disinfectants and wipes. Our Virkon® S disinfectant has been independently tested by the Harbin Veterinary Research Institute in China, and was proven to be effective against the H5N1 avian flu virus.

In fact, the United Nations Food and Agricultural Organization has asked us to provide initial supplies of Virkon® S to meet the short-term needs in 69 nations, where it is needed most to help governments and farmers prevent avian flu from spreading.

Safety is paramount in the early development of products and technologies. We will not be sustainable if the technologies we are developing and their applications throughout the value chain are not introduced to the market in a safe manner.

Partnerships are critical to achieving this objective. An example of this is the work we are doing with Environmental Defense to understand potential risks of the emerging field of nanotechnology as it gains broader application. We are developing a framework for responsible development, production, use and disposal of nano-scale materials critical to “next-generation” communications devices and other products.

Also, our longstanding partnership with Public Citizen on automotive safety has been instrumental in the development of products and processes that help keep people safe while on the road.

These are just a few examples that show how sustainable growth is not a distant goal, but an immediate reality. For DuPont, 2015 begins today. Sustainable growth is about products and services we are working on right now. Our 2015 Sustainability Goals are our investment in the future of our business, the future of our customers, and the future of families around the world. They are also about the future of our planet – the one we live on today and the better, safer and healthier planet we aspire to leave for tomorrow.

Posted in The Deniers | Leave a comment

Small-scale plants run rings around nuclear

Posted on September 29, 2006 by energyprbe

Lawrence Solomon
National Post
September 29, 2006

“If we don’t go nuclear, what type of energy will meet our future energy needs,” I’m often asked. “Do you think fringe fuels such as solar energy can take the place of nuclear? Or windmills? Bio fuels? Small dams? Tidal power? Burning garbage?”

My answer is “all of the above.” It rarely satisfies my questioner, who thinks I’m evading the question; neither does the question, which reflects a historical one-size fits-all bias, sit well with me.

For the last century, in most of the developed world, the only providers of power have been government-backed monopolies, both public and private. Being monopolies, they didn’t need to worry unduly about pleasing either their customers or their suppliers. Their primary concern was pleasing themselves.

Convenience ruled. When Ontario Hydro tired of managing its small hydro dams around the province, it dynamited or otherwise decommissioned hundreds of them. The far-flung dams were a hassle to run from afar, and also administratively expensive to manage from its Toronto head office. Hydro favoured big, centralized coal plants then, just as it would later favour big, centralized nuclear plants.

Likewise, other utilities in other parts of the continent closed down the windmills that once were common, and squelched independent power producers small and large who wanted to bring power to market. Among the larger concerns that they squelched was Fiat, the automotive giant, which in the 1980s manufactured home power plants able to run on any liquid or gaseous fuel.

The central planners at the state monopolies favoured a few large central generating plants over countless small ones, for administrative ease. Yet electricity production is inherently decentralized; different regions have different fuels at the ready, different industries have different power wants and, often, power-producing abilities of their own. The monopolies have had great success in suppressing decentralized power systems. But despite the restraints, small-scale power plants remained so attractive that they not only survived, they thrived, gaining market share against their heavily subsidized nuclear competitor.

Add up all the output from the world’s small-scale power plants and you find that they now total more than the world’s output from nuclear reactors. You also find that they are growing faster than nuclear plants – in 2004, they added about three times as much output, and six times as much generating capacity, as nuclear power added to the world’s electricity systems.

The gap will only increase in future. According to estimates from official bodies such as the International Energy Agency and World Nuclear Association, compiled by Amory Lovins at the Rocky Mountain Institute, within five years new nuclear additions will be dwarfed by any number of small-scale power technologies, including solar photovoltaics (the same technology that powers calculators). Small-scale cogeneration and wind power, which are becoming large players in the world electricity market, will each provide 20 to 30 times as much new capacity as nuclear plants.

In many countries, small-scale power plants have already made their presence felt big time. They now provide half of the electricity generated in Denmark, almost 40% of the generation in the Netherlands and Finland, 30% of Russia’s and between 15% and 20% of the electricity generated in Germany, Japan, Poland and China. Most remarkably, these large market shares came about despite resistance from the power monopolies: Some of them are token projects, built by the monopoly to preempt private competitors who were seeking permission to enter the electricity business, or in response to public pressure; some are public-private partnerships that had to surmount monopoly opposition; and some of them aren’t utility projects at all, but free-market power plants developed by businesses capitalizing on cost-saving opportunities to provide power for their own needs.

While many of the monopoly-built plants required subsidies, many more were economical yet rejected by the monopoly. Without the monopoly utility deciding who can produce power and who can’t, small-scale private producers would dominate the marketplace. Large buildings and shopping centres would routinely be generating their own power, just as they now produce their own heat. Just about the only technology that wouldn’t have a future in a de-monopolized, de-subsidized power system would be nuclear power.

Lawrence Solomon, author of the forthcoming book Toronto Sprawls, is executive director of Urban Renaissance Institute and Consumer Policy Institute, divisions of Energy Probe Research Foundation.;

 

Posted in Energy Probe News, Reforming Ontario's Local Electrical Distribution Sector, Renewables | Leave a comment

Call Iran’s bluff

Posted on September 28, 2006 by energyprbe

Lawrence Solomon
National Post
September 28, 2006

If the United States imposes meaningful economic sanctions on Iran, let alone tries a military strike against its nuclear facilities, Iran threatens to play its oil card. Many fear Iran will make good on its vow to “halt oil supply to the last drop” through the Strait of Hormuz, conduit for 40% of the world’s oil exports; others fear Iran will cut back its own oil production. Either way, they believe, Iran would be demonstrating its determination to deliver “$200-a-barrel oil,” in the process buffeting the West’s economies and exposing its vulnerability to oil disruptions.

In truth, it is not the West but Iran that is wholly hostage to oil.

Should the day come that the United States, with or without Israel and other allies, feels impelled to bombard Iran’s nuclear facilities, Washington would likely precede its attack by taking out Iran’s air defences and missile launchers, to limit Iran’s ability to respond militarily, and it would likely also take out Iran’s energy infrastructure, to limit its ability to fund a later retaliation. Iran, following these events, would lose its outsized economic and military influence, much as happened to Iraq after the first Gulf War, but without any need for an American ground invasion or post-war occupation.

Some 80% to 90% of Iran’s export earnings, and 40% to 50% of its budget, come from sales of energy. With the U.S. military destroying Iran’s oil and gas pipelines and blockading its oil tankers, Iran would face bankruptcy – the same situation as in the late 1990s when oil prices plummeted. Even with today’s high energy prices, Iran is struggling economically with double-digit inflation, double-digit unemployment, and a per-capita GDP that is 25% below the Iran of the 1970s.

An American attack on Iranian infrastructure would also expose Iran’s surprising vulnerability to energy shortages of its own: The Islamic Republic imports one-third of its gasoline, keeping a mere 45-day supply, and is a net importer of natural gas. The loss of oil revenues would not only force upon Iran draconian domestic rationing, it would squeeze its own military – already deprived of funds for spare parts – and limit Iran’s ability to finance its proxy armies in Iraq (al-Sadr’s Mahdi Army) and in Lebanon (Hezbollah), immediately strengthening the prospects for democracy in those countries. With Islamic terrorists losing their largest funding source by far, the level of terror could well subside. Candidates for making up the terrorists’ shortfalls, such as Syria, would think twice before inviting Iran’s fate.

Many argue that the United States does not have a credible military option in Iran, claiming that without a ground invasion the best that the U.S. military could do would be to set back Iran’s nuclear program by several years. But several years could suffice to cause the Iranian public to reassess the wisdom of the mullahs’ rule. With Iran having lost its status as regional superpower, and the mullahs seen to have brought not glory but disgrace to Iran, reformers would be validated. (In Lebanon, the public began to turn against Hezbollah immediately after its war with Israel ended.)

While regime change may not follow an attack on Iran’s infrastructure, debilitating the Islamic Republic of Iran – America’s chief enemy since the end of the Cold War – would be accomplishment enough. A militarily and economically humbled Iran can be contained, albeit imperfectly, as was Iraq between the two Gulf Wars. The alternative – risking Iran’s acquisition of nuclear weaponry – carries risks too grave to countenance.

Yes, military action by the U.S. may cause Iran to unleash thousands of suicide bombers against the coalition forces in Iraq, and the West, as it has boasted it could do. Yes, Iran could also unleash the Mahdi Army against coalition forces in Iraq and rain down missiles on Israel. Yes, it could severely disrupt oil exports if its military is not quickly neutralized in any attack. But the mere presence of these clubs in Iran’s arsenal are evidence enough of the threats that America and its allies will need to contend with sooner or later. Better to deal with this gathering storm before it reaches whirlwind intensity, and at a time of America’s choosing, than to pray it will dissipate with time.

Others argue that the Western economies would take a grievous hit from the hyperexpensive oil that would follow a major disruption of exports from the Middle East. This alarm is overblown. We already pay a large oil surcharge for living with the fear of disruption – some believe the risk premium exceeds $20 a barrel – and any closure of the Strait of Hormuz, the U.S. Defense Intelligence Agency testified last year, would be short-lived. Iran’s own exports of 2.5-million barrels a day, meanwhile, could be offset by the world’s strategic petroleum reserves. America’s reserves, by far the world’s largest, amounts to 600 days worth of Iranian oil exports.

Diplomacy is unlikely to prevent the need for an attack on Iran. But, to give diplomacy a chance, the logic of an attack on Iran must be brought home to Iran’s chief backers, Russia and China, both of whom have large investments in Iran. They need to understand that their investments in Iranian oil infrastructure will be best protected by bringing the mullahs to heel.

Russia – a much larger oil exporter than Iran and likewise dependent on oil wealth for its stability – would in any case be conflicted at the prospect of an American-Iranian War: Moscow stands to gain more than lose in the near term from the higher energy prices that would accompany a halt to Iranian oil exports. And it doesn’t want a nuclear Iran on its southern flank, where separatists and terrorists already provide threat enough.

But Russia – which has played good cop to America’s bad cop in efforts to pacify Iran’s nuclear program – has no incentive to push Iran hard if it believes that the U.S. will not act militarily. Diplomacy cannot succeed without a military threat looming large. Whether the end game is diplomacy or war, America must brandish its oil card.

Lawrence Solomon, author of the forthcoming book Toronto Sprawls, is executive director of Urban Renaissance Institute and Consumer Policy Institute, divisions of Energy Probe Research Foundation.; www.urban-renaissance.org

A reader responds

Mr. Solomon’s argument that the West should call Iran’s bluff. May I suggest, however, a different way of calling it? Instead of spending billions on another war, the West should induce emigration of the best and brightest Iranian scientists, engineers and entrepreneurs, and imbue them with an appreciation for free and open societies. With Iran’s economy already on the verge of collapse, a downward spiral would begin. Iran would pump more oil to compensate. Falling oil prices would hasten its decline and boost the global economy. With its economy in tatters, funding for Hamas, Hezbollah and the Iraqi insurgency would dry up.

Another front in the Middle East war might work, but the time has come to explore alternatives.

Steven Salamon, Toronto

 

Posted in Coal, Energy Probe News | Leave a comment

Radiation, ecology and the invalid LNT Model: The evolutionary imperative

Posted on September 27, 2006 by energyprbe

(Sep. 27, 2006) Metabolic and energetic efficiency, and hence fitness of organisms to survive, should be maximal in their habitats. This tenet of evolutionary biology invalidates the linear-nothreshold (LNT) model for the risk consequences of environmental agents. Continue reading →

Posted in Hormesis, LNT | Leave a comment

Radiation, Ecology and the Invalid LNT Model: The Evolutionary Imperative

Posted on September 27, 2006 by energyprbe

Peter A. Parsons
Dose Response
September 27, 2006

Abstract
Metabolic and energetic efficiency, and hence fitness of organisms to survive, should be maximal in their habitats. This tenet of evolutionary biology invalidates the linear-nothreshold (LNT) model for the risk consequences of environmental agents. Hormesis in response to selection for maximum metabolic and energetic efficiency, or minimum metabolic imbalance, to adapt to a stressed world dominated by oxidative stress should therefore be universal. Radiation hormetic zones extending substantially beyond common background levels, can be explained by metabolic interactions among multiple abiotic stresses. Demographic and experimental data are mainly in accord with this expectation. Therefore, non-linearity becomes the primary model for assessing risks from low-dose ionizing radiation. This is the evolutionary imperative upon which risk assessment for radiation should be based.
Keywords: adaptation, background radiation, Chernobyl, ecology, environmental stress, evolutionary expectation, hormesis, LNT model, metabolic efficiency, oxidative stress, radiation

BACKGROUND RADIATION VARIATIONS
Exposure to ionizing radiation has always been part of the environment on Earth. Life apparently evolved spontaneously from basic chemicals formed by reactions largely initiated by ionizing radiation from the sun. When life commenced on Earth around three and a half billion years ago, the natural level of radiation was up to five times higher than today.
Everyone is exposed to background ionizing radiation in the environment from outer space, the sun, terrestrial rocks, the soil, buildings, the air that we breathe, the food we eat, and from human and animal bodies. Using a standard measure of the effects of radiation in terms of milliSieverts (mSv) per year, these exposures from natural sources total around 2.15 mSv each year at around sea level. Smaller components from man-made sources principally from medical procedures (around 0.30 mSv per year), and a minor component (around 0.05 mSv per year) from other sources including consumer products and fall-out, bring the total to around 2.5mSv per year. Doses from man-made sources therefore amount to substantially less than 20% of natural exposures. In summary, the average dose rates due to natural and man-made background ionizing radiation in industrial countries in mSv per year are:
Background radiations of natural origin

Naturally occurring radioelements in the soil, rocks etc.    0.40
Radon, thoron, and their short lived decay products    1.20
Cosmic radiation at sea level    0.25
Radionuclides inside the human body, mainly potassium-40    0.30
Man-made sources
Medical procedures, mainly X-rays    0.30
Other man-made sources (consumer products, air travel, fall-out etc.)    0.05

giving a total of around 2.5 mSv per yer at sea level (Lowenthal and Airey, 2001)
Background radiation of natural origin can be substantially higher than those around sea level. The two major sources of variation upwards are height above sea level and diverse geological backgrounds. Background radiation can shift upwards by a factor of three or more in populations with increasing altitude as found in the Rocky Mountains regions of USA. Populations numbering several millions are exposed to background radiation in the range of 3 to 8 mSv per year and much higher for some smaller groups, when exposed to geological structures rich in uranium, thorium and their decay products.
Some areas of the world, called high background radiation areas (HBRAs), have extremely high levels of background radiation. A field of medical geology has emerged defined by the International Commission of Geological Sciences for Environment Planning as the science dealing with the influence of ordinary environmental factors on the geographical distribution of health problems in humans and animals.
Dissanayake (2005) has published many research papers in medical geology. In a recent essay in the American journal Science, he writes:

Extreme HBRAs are found in Guarapari (Brazil), southwest France, Ramsar (Iran), parts of China, and the Kerala coast (India). In certain beaches in Brazil, monazite sand deposits are abundant. The external radiation levels on these black beach sands range up to nearly 400 times the normal background level in the United States. The Brazilian coastal sands have several radioactive minerals, among them monazite, zircon, thorianite, and niobate-tanalate.
In India, along the 570-km-long coastline of Kerala, there are major deposits of monazite-rich mineral sands with very high natural radiation. The monazite deposits are larger than those in Brazil, and the dose from external radiation is, on average, similar to those reported in Brazil.
Ramsar, a city in northern Iran, has one of the highest natural-radiation levels in the world. In some locations at Ramsar, the radiation level is 55 to 200 times higher than the background level.
The most interesting feature in all these cases is that the people living in these HBRAs do not appear to suffer any adverse health effects as a result of their high exposures to radiation. On the contrary, in some cases the individuals living in these HBRAs appear to be even healthier and to live longer than those living in control areas that are not classified as HBRAs. These phenomena pose many intriguing questions for medical geologists.


THE RADIATION-EXPOSURE PARADOX
Although more critical data are needed, the apparent health-promoting consequences of HBRAs are paradoxical and are frequently disputed. Definitive studies of outlier populations such as HBRAs require enormous sample sizes to differentiate between populations exposed to differing radiation levels. Even when negative correlations occur between dose and cancer incidence in these demographic studies, there is always the problem of whether correlation implies causation. For example, Cohen (1995) found a highly significant negative association between mean radon exposure and lung mortality across US counties. Cohen and his colleagues explored many possible explanations including variations in smoking prevalence, errors in the radon data, coincidental properties of data sets, and confounding by socioeconomic factors, but none of these led to substantial reductions in the effect. In spite of extensive efforts, the negative correlation between radiation exposure and lung cancer rate therefore remained. Consequently “there is no evidence in this analysis that low-level radiation causes cancer, and there is at least some evidence that it may protect against cancer.”
On the other hand, the commonly assumed model for radiation protection is the linear- no-threshold (LNT) model, which assumes a direct linear extrapolation from the deleterious health effects of radiation at high doses to the very small doses in our background. The contrasting model of negative associations between low exposures and health consequences giving non-linearity (i.e. a U shaped curve) is referred to as hormesis. Non-linearity is typically manifested by reduced cancer incidence and increased longevity at low radiation exposures. This is to be expected since organisms evolve over time to be fittest in the environments in which they live, that is exposed to background radiation. This fundamental tenet of evolutionary biology shows that the LNT model is a biological impossibility (Parsons, 1990, 2000, 2003). In accord with this reality, radiation hormesis has been demonstrated on numerous times in controlled experiments in organisms ranging from microorganisms to mice (eg Luckey, 1991; Calabrese and Baldwin, 2000).
Furthermore, the multiplicity of environmental agents to which we are exposed on Earth interact metabolically, so that the LNT model breaks down to include the exposures of geological outliers including HBRAs as explained in detail in the next section. Therefore the hormetic zone apparently extends to exposures substantially in excess of those at sea-level (Parsons, 2003, 2005).
Some French scientists recently carried out a comprehensive assessment of the evidence for and against the LNT model. In an excellent report “Dose-Effect Relationships and Estimation of the Carcinogenic Effects of Low Doses of Ionizing Radiation,” published by the French Academies of Medicine and Science, Tubiana et al. (2005) concluded that the LNT model for human data defaults at doses less than 100 mSv, and even more so at extremely low doses less than 10 mSv. Positive health consequences of low exposures to ionizing radiation are implied compared with the LNT model. Such positive health or fitness deviations from the LNT model are a manifestation of radiation hormesis.
In preparing the French report, the authors note the very real difficulties in obtaining accurate estimates from demographic data. They emphasize that hundreds of thousands of subjects need to be included and monitored for a sufficiently long time, but that “below 20 mSv generally encountered within the context of radioprotection, epidemiology can neither confirm nor refute the existence of an increased incidence of cancer.”
The French report is based upon an analysis of a range of populations including the survivors of the Hiroshima and Nagasaki bombs, people involved in the clean up following the Chernobyl accident, nuclear industry workers, and radiologists and radiology technicians. Even airline flight crews are included where the French report concludes:

Airline flight crews receiving exposures of 1.5 to 6 mSv per year have been studied. No increase in the total number of cancers or of cancers in the most radiosensitive organs has been detected in 44,000 members of flight crews or in 2,749 Canadian pilots. An excess of melanomas was observed in these populations, and this can be explained by their more frequent exposure to the sun.

A potentially safe exposure range substantially above those recommended by the International Commission of Radiation Protection (ICRP) emerges from the French report. The lack of deleterious consequences from background exposures in HBRAs, plus the evidence for hormesis, appears consistent with a limit to the safe range in the region of 50 – 100 mSv per year for the general population. Therefore, the limit of 1 mSv per year recommended by the ICRP appears absurd in view of these estimates. From this descent into fantasy based upon the demonstrably invalid LNT model, spurious estimates of risks follow.
A consequence of these spuriously inflated risk estimates is media hysteria based upon radiophobia (Parsons, 1999) for the Chernobyl accident and exposure to depleted uranium. In the case of Chernobyl, a recent report of the Chernobyl Forum (2005) made up of eight UN specialized agencies, has shown that the Chernobyl incident was not catastrophic and not nearly as substantial as had at first been feared. Even so, one prediction of the Forum is that eventually an extra 4,000 may eventually die from cancer. This speculative upper limit is based upon the LNT assumption. In any case, such a predicted number cannot be verified, and equally, it is difficult to falsify. Most importantly, any hormetic model would necessarily imply substantial reductions below the estimated 4,000 deaths, almost certainly closer to zero than to 4,000.

WHY IS THE LNT MODEL INVALID BEYOND BACKGROUND EXPOSURES?
On evolutionary grounds, organisms tend to become increasingly adapted to their habitats. While fitness is characteristically assessed at the organismic level for a range of traits such as fecundity, survival and longevity, energy provides a more fundamental foundation for fitness (eg Van Valen, 1976; Watt, 1986; Parsons, 2005). A tendency towards increased energetic efficiency of organisms in their habitats therefore represents an adaptive process which translates into increased fitness, however measured. That is, a basic measure of fitness in a stressed world is energetic efficiency in the face of multiple environmental hazards, including ionizing radiation.
In this context, stress is an energy drain and can be expressed by a loss of fitness. Consequently, stress is an environmental change or probe that targets energy carriers so that energetic efficiency is reduced. Any increase in stress will disturb the energy balance between input and output that organisms build up in their habitats. More generally, the second law of thermodynamics requires that any process underway in a system universally degrades the energy in that system. Stress therefore reduces energy flow until a critical threshold is reached where cells and hence organisms can no longer survive. Based upon this reductionist approach, the availability of energy and its interaction with stress underlie fitness, and hence can determine limits to adaptation in populations of the past and present (Parsons, 2005).
Variation in the severity of an environmental stress gives a non-linear fitness continuum. Considering temperature, fitness should be maximal at intermediate temperatures between the extremes of heat and cold. Physiologically, this expectation is manifested by low metabolic rates at intermediate temperatures. For example in fasting rats, minimum heat production and maximum survival occur around the intermediate temperatures of 28–29°C (Kleiber, 1961; Blaxter, 1989). This and other examples show that biological systems are the most stable and energy dissipation is low in the thermal neutral zone, which is a region of high energetic efficiency and hence high fitness (Zotin, 1990).
Since fitness in relation to stress level is non-linear, the LNT model often assumed between the level of an environmental agent and its biological and health consequences is invalid, since all environmental agents have energetic costs (Parsons, 2003, 2005). The term hormesis can be used to describe the maxima especially for agents that are exceedingly toxic at high exposures. Radiation hormesis becomes merely a case study of a general ecological and evolutionary expectation for all environmental agents.
An array of mild stresses including cold, heat, physical activity, irradiation and caloric restriction can induce longevity extensions (Calabrese and Baldwin, 2000; Rattan, 2004). One metabolic consequence of such hormetic exposures to mild stress is the production of “heat shock” or “stress” proteins, hsps. However, this adaptive process can incur a cost, since Hercus et al. (2003) increased life span of Drosophila melanogaster by repeated exposure to mild heat stress but fecundity fell. Sørensen et al. (2003) argue that the expressed hsps level in each species and population is a balance between benefits (resistance to stresses) and costs (negative effects on growth, development rate, fecundity etc.). Fitness maxima of hormetic zones therefore should reflect tradeoffs among various metabolic components all directed towards the maximization of energetic efficiency.
Radiation hormesis is commonly observed in experimental organisms and in man at exposures substantially exceeding background radiation levels. Assume that energetic and metabolic reserves such as hsps are built up to counter the wide array of stresses, especially climatic, to which all organisms are exposed in natural habitats. Such adaptive responses could provide protection from low-level to moderate stresses such as ionizing radiation at non-catastrophic levels but at higher levels than common background (Parsons, 2003). That is, the hormetic response becomes part of a general stress response involving hsps and other metabolic adaptations across stress levels and environmental agents (Hercus et al., 2003). Fitness interactions for combinations of stresses should therefore ameliorate the effects of individual stresses in isolation. Therefore the hormetic model can be extended to multiple environmental agents. Cross-protection among various environmental agents could then occur, so that hormesis depends upon the energetic consequences of the totality of interacting environmental stresses of natural habitats. Hormesis therefore is an expression of high energetic and metabolic efficiency and hence high fitness that evolve in response to single and multiple environmental agents where energetic costs are not excessive. This generalization is consistent with the lack of deleterious consequences of life in HBRAs, and to negative associations between radiation exposure and cancer incidence, which only change to positive when exposures become extreme.

OXIDATIVE STRESS, METABOLIC BALANCE AND ADAPTATION
Recent attention given to oxidative stress in natural populations will now be considered in the light of the above energetic and metabolic efficiency arguments.
The free radical theory of aging, based on the premise that a single common process is responsible for aging and death of all living beings, is a convenient starting point. Life apparently evolved spontaneously from basic chemicals formed by free radical reactions largely initiated by ionizing radiation from the sun. Under the free radical theory, the process of aging is determined by the sum of the deleterious free radicals occurring continuously throughout the cells and tissues of organisms. Free radicals, however incited, are proposed to underlie the progressive deterioration of biological systems over time due to their innate ability to produce change. In particular, oxygen is combined with enzymatically degraded food products to produce energy during tissue respiration at the mitochondria. A number of reactive oxygen species, ROS, are generated during this process. A wide range of cellular molecules including membrane lipids, proteins and DNA, can be attacked and seriously damaged by ROS. These free radicals therefore generate oxidative stress so reducing fitness and accelerating aging (see Arking, 1998).
Genetically-determined resistance to a variety of stresses in many species, including yeast, nematodes and Drosophila, is strongly correlated with longevity. Multiple-stress screening including oxidative stress, is an effective procedure for identifying longevity genes (Wang et al., 2004). Similar patterns of gene expression characterize aging and oxidative stress in D. melanogaster, suggesting that the primary or operative feature is oxidative-stress resistance (Arking, 1998). Individuals with the potential for a long life should therefore carry genes for resistance to ROS, which are an inevitable consequence of life in a world rich in oxygen (Hekimi and Guarente, 2003).
In D. melanogaster, the stresses tested include temperature extremes, desiccation, anoxia and ionizing radiation. Recently, three ecological stresses (aridity, high temperature, solar radiation) which differentiate the north and south facing slopes of Evolution Canyon in Israel have been reduced to oxidative stress responses in field collected yeast, Saccharomyces cerevisiae (Miyazaki et al., 2003), as anticipated from temperature-stress experiments in D. melanogaster (Nevo et al., 1998).
Physical stresses in natural populations therefore appear reducible to oxidative stress responses, deriving from the universality of ROS. Oxidative stress responses are therefore critical in the adaptation of natural populations, so that survival becomes a function of the efficiency of handling such stress over time. For example, oxidative stress is lower in healthy centenarians than in other aged subjects (Paolisso et al., 1998).
One of the most radioresistant organisms on Earth is the red-pigmented bacterium, Deinococcus radiodurans, which is resistant to other physical stresses including ultraviolet radiation, hydrogen peroxide, heat, desiccation and a variety of toxins. Genes protective against radiation stress are therefore protective against other stresses. For example, antioxidants can protect against both X-irradiation and oxygen poisoning in mice (Lane, 2002).
Damage from increased oxidative stress can be related to an imbalance between free-radical production and antioxidant protection. While this imbalance strengthens as radiation exposure increases, it should be minimal where fitness is highest in hormetic zones in accord with evolutionary expectations. A range of physical stresses should increase this imbalance, but metabolic interactions among stresses should adaptively ameliorate the consequences of individual stresses so providing metabolic protection. A significant consequence is radiation hormesis for exposures substantially in excess of common background exposures.
Radiation hormesis therefore becomes a manifestation of minimum metabolic imbalance. Analogously considering nutrition, excessive diets elevate the production of ROS implying increased metabolic imbalance, so giving a non-linear relationship and hence nutritional hormesis. In any case in the hormetic zone of caloric restriction, metabolic rate is less and stress resistance is higher than under excessive diets, implying a region of high metabolic balance (Nesse and Williams, 1994; Lane, 2002).
Radiation hormesis can be viewed as the summation of interdependent and complex adaptations involving ROS, antioxidants, heat shock proteins, DNA repair processes, and so on. More generally, complex metabolic processes at the molecular, genetic, chromosomal, cellular, physiological and immunological levels are interdependent, and have been considered in the hormetic context by increasing numbers of authors (eg. Pollycove and Feinendegen, 2001; Feinendegen 2005; Feinendegen and Neumann, 2005; Tubiana et al., 2005). Hormetic deviations from the LNT model follow, manifested by high fitness at the whole organism level typically measured by longevity and survival, and in demographic data by reduced cancer incidence. The biosystem therefore responds to ionizing radiation so efficiently in the hormetic zone that the risk of mortality from cancer should fall and life span should increase due to protective metabolic processes, apparently reducible to the evolutionary consequences of oxidative stress.

CONCLUSION: THE EVOLUTIONARY EXPECTATION INVALIDATES THE LNT MODEL
The invalid LNT premise has been documented in over 5,000 examples of physical/chemical agents (Calabrese and Baldwin, 2003). Scattered observations back to the early part of last century are even suggestive of hormesis in bacteria for uranium salts, and in the last decade a low-dose hormetic response to depleted uranium in grass has been reported (Buchanan and Fulmer, 1930; Meyer et al., 1998). More information would assist, but uranium is a constituent of most rocks and the sea, giving an evolutionary expectation of uranium hormesis. It is not surprising that Gerber et al. (1999) concluded: “We suggest that hormesis may be almost universal for substances normally present throughout geological time.”
Habitats provide the ecological theatre for assessing the LNT model. Adaptation towards high energetic and metabolic efficiency, that is fitness, to counter the metabolic consequences of the stresses from single and multiple environmental agents should occur over time. This evolutionary process is expected to lead to non-linear continua for fitness for all agents including ionizing radiation. In the specific example of radiation, hormesis extends to exposures substantially in excess of background due to interactions between the metabolic effects of an array of abiotic stresses to which organisms are exposed in their habitats.
Non-linearity should therefore be the primary hypothesis against which any data set is tested. Indeed, Calabrese has said “I actually think that there should be a paradigm shift and that the hormetic model should be the default model.” This quote comes from Hadley (2003), one of the few commentators who has considered the need to emphasize evolutionary inputs in attempting to understand hormetic zones. She emphasizes the underlying evolutionary process of selection for metabolic efficiency to adapt to a stressed world, which immediately predicts the universality of hormesis for all environmental agents. This is a present-day version of the often repeated Dobzhanky (1973) dictum that “Nothing makes sense in biology except in the sense of evolution.” In conclusion, non-linearity is the fundamental model for assessing the risks from lowdose radiation.

REFERENCES

* Arking R. Biology of Aging: Observations and Principles. 2d edn. Sunderland, Massachusetts: Sinauer Associates; 1998.
* Blaxter K. Energy Metabolism in Animals. New York: Cambridge University Press; 1989.
* Buchanan RE, Fulmer EI. Volume II-Effect of Environment upon Microorganisms. Baltimore: Williams and Wilkins; 1930. Physiology and Biochemistry of Bacteria.
* Calabrese EJ, Baldwin LA. The effects of gamma rays on longevity. Biogerontology. 2000;1:309–319. [PubMed]
* Calabrese EJ, Baldwin LA. Toxicology rethinks its central belief. Nature. 2003;321:691–692. [PubMed]
* Chernobyl Forum. Chernobyl’s Legacy: Health, Environmental and Socio-Economic Impacts. 3 volumes. Vienna: International Atomic Energy Agency; 2005.
* Cohen BL. Test of the linear-no threshold theory of radiation carcinogenesis for inhaled radon decay products. Health Physics. 1995;68:157–174. [PubMed]
* Dissanayake C. Of stones and health: medical geology in Sri Lanka. Science. 2005;309:883–885. [PubMed]
* Dobzhansky Th. Nothing in biology makes sense except in the light of evolution. Am Biol Teach. 1973;March:125–129.
* Feinendegen LE. Evidence for beneficial low level radiation effects and hormesis. Brit J Radiol. 2005;78:3–7. [PubMed]
* Feinendegen LE, Newmann RD. The issue of risk in complex adaptive systems: the case of low-dose radiation induced cancer. BELLE Newsletter. 2005;13:11–18.
* Gerber LM, Williams GC, Gray SJ. The nutrient-toxin dosage continuum in human evolution and modern health. Quart Rev Biol. 1999;74:273–289. [PubMed]
* Hadley C. What doesn’t kill you makes you stronger. EMBO reports. 2003;4:924–927. [PubMed]
* Hekimi S, Guarente L. Genetics and the specificity of the aging process. Science. 2003;299:1351–1354. [PubMed]
* Hercus MJ, Loeschcke V, Rattan SIS. Lifespan extension in Drosophila melanogaster through hormesis by repeated mild heat stress. Biogerontology. 2003;4:149–156. [PubMed]
* Kleiber M. The Fire of Life: an Introduction to Animal Energetics. New York: Wiley; 1961.
* Lane N. Oxygen: the Molecule that made the World. Oxford: Oxford University Press; 2002.
* Lowenthal GC, Airey PL. Practical Applications of Radioactivity and Nuclear Reactions. Cambridge: Cambridge University Press; 2001.
* Luckey TD. Radiation Hormesis. Boca Raton: CRC Press; 1991.
* Meyer MC, McLendon T, Price D. Evidence of depleted uranium-induced hormesis and differential plant responses in three grasses. J Plant Nutrition. 1998;21:2475–2484.
* Miyazaki S, Nevo E, Grishkan I, Idleman U, Weinberg D, Bohnert HJ. Oxidative stress responses in yeast strains, Saccharomyces cerevisae, from Evolution Canyon, Israel. Monatschefte für Chemie. 2003;134:1465–1480.
* Nesse RM, Williams GC. Evolution and Healing. London: Weidenfeld & Nicolson; 1994.
* Nevo E, Rashkovetsky E, Pavlicek T, Korol A. A complex adaptive syndrome in Drosophila caused by microclimatic contrasts. Heredity. 1998;80:9–16. [PubMed]
* Paolisso G, Tagliamonte MR, Rizzo MR, Manzella D, Gambardella A, Varricchio M. Oxidative stress, advancing age: results in healthy centenarians. J Am Geriatric Soc. 1998;46:833–838.
* Parsons PA. Radiation hormesis: an evolutionary expectation and the evidence. Appl Radiol Isot. 1990;40:857–860.
* Parsons PA. Low level exposure to ionizing radiation : do ecological and evolutionary considerations imply phantom risks? Persp Biol Med. 1999;43:57–68.
* Parsons PA. Hormesis: an adaptive expectation with emphasis on ionizing radiation. J Appl Toxicol. 2000;20:103–112. [PubMed]
* Parsons PA. Energy, stress and the invalid linear no-threshold premise: a generalization illustrated by ionizing radiation. Biogerontology. 2003;4:227–231. [PubMed]
* Parsons PA. Environments and evolution: interactions between stress, resource inadequacy and energetic efficiency. Biol Rev. 2005;80:589–610. [PubMed]
* Pollycove M, Feinendegen LE. Biological responses to low doses of ionizing radiation: detriment versus hormesis Part 2. Dose responses of organisms. J. Nuclear Medicine. 2001;42:26N–37N.
* Rattan SIS. Aging, anti-aging, and hormesis Mech Ageing Dev. 2004;125:285–289.
* Sørensen JG, Kristensen TN, Loeschcke V. The evolutionary and ecological role of heat shock proteins. Ecology Letters. 2003;6:1025–1037.
* Tubiana M, Aurengo A, Averbeck D, Bonnin A, Le Guen B, Masse R, Monier R, Valleron AJ, de Vathaire F. Dose-effect relationships and estimation of the carcinogenic effect of low doses of ionizing radiation. Paris: Académie des Sciences-Académie National de Médicine; 2005.
* Van Valen L. Energy and evolution. Evolutionary Theory. 1976;1:179–229.
* Wang H-D, Kazemi-Esfarjani P, Benzer S. Multiple-stress analysis for isolation of Drosophila longevity genes. Proc Natl Acad Sci USA. 2004;11:12610–12615. [PubMed]
* Watt WB. Power and efficiency as fitness indices in metabolic organization. American Naturalist. 1986;127:629–653.
* Zotin AI. Thermodynamic Bases of Biological Processes: Physiological Reactions and Interactions. New York: Walter de Gruyter; 1990.

Posted in Hormesis, LNT | 1 Comment

EP’s response to OPG’s proposed environmental assessment guidelines for new nuclear waste site

Posted on September 22, 2006 by energyprbe

Energy Probe

September 22, 2006

Canadian Nuclear Safety Commission
Attn: Michael Rinker, Environmental Assessment Specialist
P.O. Box 1046, Station B
Ottawa, ON K1P 5S9
Phone: 1-800-668-5284
Fax: (613) 995-5086
E-mail: ceaainfo@cnsc-ccsn.gc.ca

Re: Comment on the Proposed Scoping Document (Environmental Assessment Guidelines) for Ontario Power Generation’s Proposal for a Deep Geologic Repository for disposal of low and intermediate level radioactive wastes in Kincardine.

Dear Mr. Rinker,

Energy Probe, a national environmental and consumer energy research organization, is responding to the CNSC’s above-noted notice that it will hold a one-day public hearing on October 23 on the Scoping Document (Environmental Assessment Guidelines) regarding Ontario Power Generation Inc.’s (OPG) proposal to construct and operate a Deep Geological Repository within the Bruce Nuclear Site in Kincardine, Ontario.

Energy Probe wishes to register the following comments:

Energy Probe believes that there is a significant public concern with the proposal presented by OPG.

The proposal being presented by OPG is very significant. Deep underground disposal of nuclear wastes from reactor operations is not currently approved in Canada and represents a major change in current practice. OPG is proposing to construct a radioactive disposal site approximately 1 kilometre from shore of Lake Huron, a very significant natural resource for both Canadian and American citizens. The inventory of waste to be interned in the proposed facility will include transuranic isotopes and other long-lived and biologically active isotopes such as long-lived iodine isotopes. It is likely but not certain that the site will be used as a repository for large amounts of refurbishment and decommissioning waste. There is substantial uncertainty as to the composition and quantity of waste that will ultimately be interned in the site.

Energy Probe therefore recommends that the proposal should be subject to the most thorough review procedures afforded by prevailing Canadian law. The highest standard of review available is a panel review under the Canadian Environmental Assessment Act (CEAA). Under CEAA, a panel review allows for the highest standard of testing of environmentally significant project proposals, and also allows some opportunity for concerned parties and individuals to participate fairly in the review process.

Environmental assessment without a panel review, as proposed by the Canadian Nuclear Safety Commission, will be inadequate for assessing the proposed underground disposal facility for low- and intermediate-level radioactive waste.

Given its scope and implications, OPG’s proposal should be subject to pubic hearings with presentation of evidence, the appearance of witnesses for the proponent to speak to the evidence under oath, and the examination of this evidence by concerned parties and individuals, including through cross-examination.

Consistent with the significance of OPG’s proposal, Energy Probe suggests that a written interrogatory process should be built into the review process. In its July 17th submission, Greenpeace asked the CNSC to establish an obligatory interrogatory process that allows questions to be directed to all parties under established rules. Greenpeace further suggested that an initial deadline for response to interrogatories should be set at an agreed time after receipt of the initial draft environmental assessment report from OPG. Energy Probe supports the suggestions of Greenpeace.

Energy Probe is concerned that the scope of the review proposed by the CNSC excludes consideration of the approach that, with available or foreseeable technology, is likely to have the lowest overall environmental impact. The waste management review should include a comparison of OPG’s proposal for centralized, transportation-dependent, and probably non-retrievable deep underground disposal with the option of on-surface or near-surface monitored and retrievable storage at the reactor sites where the radioactive waste is produced. Energy Probe is concerned that CNSC staff has stated that storage at existing facilities would not be assessed (Canadian Nuclear Safety Commission, Disposition of Comments from First Nations, the Public and Stakeholders on Scoping Document [sic] for OPG’s Proposed DGR, August 2006 (CNSC CMD 06-H22), p. 2). Energy Probe is also concerned that a complete analysis of the impacts of transportation implications of OPG’s proposal would not be reviewed under the proposed CNSC approach and that the communities along the transportation corridors will not be specifically consulted. CNSC staff has stated that “Transportation of waste from power generating stations to the WWMF will not be assessed because this is a currently approved activity. Nor will a specific consultation plan be considered along the transportation route in the context of this EA.”

Sincerely,
Tom Adams
Executive Director
Energy Probe

 

Posted in Nuclear Safety | Leave a comment

EP’s response to OPG’s proposed environmental assessment guidelines for new nuclear waste site

Posted on September 22, 2006 by energyprbe

Energy Probe

September 22, 2006

Canadian Nuclear Safety Commission
Attn: Michael Rinker, Environmental Assessment Specialist
P.O. Box 1046, Station B
Ottawa, ON K1P 5S9
Phone: 1-800-668-5284
Fax: (613) 995-5086
E-mail: ceaainfo@cnsc-ccsn.gc.ca

Re: Comment on the Proposed Scoping Document (Environmental Assessment Guidelines) for Ontario Power Generation’s Proposal for a Deep Geologic Repository for disposal of low and intermediate level radioactive wastes in Kincardine.

Dear Mr. Rinker,

Energy Probe, a national environmental and consumer energy research organization, is responding to the CNSC’s above-noted notice that it will hold a one-day public hearing on October 23 on the Scoping Document (Environmental Assessment Guidelines) regarding Ontario Power Generation Inc.’s (OPG) proposal to construct and operate a Deep Geological Repository within the Bruce Nuclear Site in Kincardine, Ontario.

Energy Probe wishes to register the following comments:

Energy Probe believes that there is a significant public concern with the proposal presented by OPG.

The proposal being presented by OPG is very significant. Deep underground disposal of nuclear wastes from reactor operations is not currently approved in Canada and represents a major change in current practice. OPG is proposing to construct a radioactive disposal site approximately 1 kilometre from shore of Lake Huron, a very significant natural resource for both Canadian and American citizens. The inventory of waste to be interned in the proposed facility will include transuranic isotopes and other long-lived and biologically active isotopes such as long-lived iodine isotopes. It is likely but not certain that the site will be used as a repository for large amounts of refurbishment and decommissioning waste. There is substantial uncertainty as to the composition and quantity of waste that will ultimately be interned in the site.

Energy Probe therefore recommends that the proposal should be subject to the most thorough review procedures afforded by prevailing Canadian law. The highest standard of review available is a panel review under the Canadian Environmental Assessment Act (CEAA). Under CEAA, a panel review allows for the highest standard of testing of environmentally significant project proposals, and also allows some opportunity for concerned parties and individuals to participate fairly in the review process.

Environmental assessment without a panel review, as proposed by the Canadian Nuclear Safety Commission, will be inadequate for assessing the proposed underground disposal facility for low- and intermediate-level radioactive waste.

Given its scope and implications, OPG’s proposal should be subject to pubic hearings with presentation of evidence, the appearance of witnesses for the proponent to speak to the evidence under oath, and the examination of this evidence by concerned parties and individuals, including through cross-examination.

Consistent with the significance of OPG’s proposal, Energy Probe suggests that a written interrogatory process should be built into the review process. In its July 17th submission, Greenpeace asked the CNSC to establish an obligatory interrogatory process that allows questions to be directed to all parties under established rules. Greenpeace further suggested that an initial deadline for response to interrogatories should be set at an agreed time after receipt of the initial draft environmental assessment report from OPG. Energy Probe supports the suggestions of Greenpeace.

Energy Probe is concerned that the scope of the review proposed by the CNSC excludes consideration of the approach that, with available or foreseeable technology, is likely to have the lowest overall environmental impact. The waste management review should include a comparison of OPG’s proposal for centralized, transportation-dependent, and probably non-retrievable deep underground disposal with the option of on-surface or near-surface monitored and retrievable storage at the reactor sites where the radioactive waste is produced. Energy Probe is concerned that CNSC staff has stated that storage at existing facilities would not be assessed (Canadian Nuclear Safety Commission, Disposition of Comments from First Nations, the Public and Stakeholders on Scoping Document [sic] for OPG’s Proposed DGR, August 2006 (CNSC CMD 06-H22), p. 2). Energy Probe is also concerned that a complete analysis of the impacts of transportation implications of OPG’s proposal would not be reviewed under the proposed CNSC approach and that the communities along the transportation corridors will not be specifically consulted. CNSC staff has stated that “Transportation of waste from power generating stations to the WWMF will not be assessed because this is a currently approved activity. Nor will a specific consultation plan be considered along the transportation route in the context of this EA.”

Sincerely,
Tom Adams
Executive Director
Energy Probe

 

Posted in Energy Probe News, Nuclear Safety | Leave a comment

If we want to help the Third World, let’s promote nuclear power?

Posted on September 13, 2006 by energyprbe

Paul Driessen, response by Tom Adams
Free Lance-Star
September 13, 2006

Re: “If we want to help the Third World, let’s promote nuclear power” (Published by the Free Lance-Star, Fredericksburg, Va, on Sept. 13, 2006 – original article appears below)

Nuclear power will light Africa’s darkness, says your author Paul Driessen, but his advice would make a bad situation worse.

Reactor designs similar to the “revolutionary” reactor announced in the article have been tried several times before in the developed world and several of those attempts were spectacular failures, including Fort Saint Vrain in Colorado. The fuel for the reactor your author promotes would require enriching uranium, the production of which could lead to weapons proliferation problems as we see now in Iran. On the subject of safety, pebble bed reactors contain a large inventory of graphite and other flammable materials.

Would giving the poor of Africa electricity solve their problems? That approach has been tried without success across Africa from Egypt to Ghana. Nuclear technologies, particularly untested ones, are not suited to meet the needs of Africa’s poor.

Tom Adams, Energy Probe
Toronto, Canada

If we want to help the Third World, let’s promote nuclear power

Nuclear to the rescue: Electricity is the key to a healthier, more prosperous Third World.

by Paul Driessen, the Free Lance-Star, September 13, 2006

“The only good thing about the good old days is that they’re gone.” My grandmother’s wisdom came from experience. As a teenager in late 19th-century Wisconsin, she had cleared tons of rocks from fields and hauled countless buckets of water on the family farm. If she had to select just one modern technology, she said, she’d choose running water. But electricity was a close second.

No wonder. Without electricity, modern life reverts to her childhood: no lights, refrigeration, heating, air conditioning, radio, television, computers, safe running water, or mechanized equipment for homes, schools, shops, hospitals, offices, and factories.

Incredibly, this is what life is still like every day for 2 billion people in developing countries. Viewed at night from outer space, Africa really is the Dark Continent: Only 10 percent of its 700 million people regularly have electricity.

While 75 percent of South Africa is now fully electrified, only 5 percent of Malawi, Mozambique, and other countries are so fortunate. Much of poor and rural Asia and Latin America faces a similar predicament.

Instead of rolling blackouts, neighborhoods have rolling power. “In the western part of my country, families get electricity maybe three hours every two weeks,” says Pastor Abdul Sesay, a Sierra Leone native who now resides in Maryland. “Eastern communities get it maybe once a month!”

Instead of turning on a light or stove, millions of women and children spend their days gathering wood, grass, and dung to burn in primitive hearths for cooking and heating. Instead of turning a faucet, they spend hours carrying water from distant lakes and rivers that are often contaminated with bacteria.

Pollution from their fires causes 4 million deaths a year from lung infections. Tainted water and spoiled food cause intestinal diseases that kill another 2 million annually.

The dearth of electricity also means minimal medical facilities, manufacturing and commerce – and impoverished countries forever dependent on foreign aid.

Abundant, reliable, affordable electricity is thus a critical priority for developing nations. Hydroelectric projects offer one solution, coal-fired power plants another. They aren’t perfect ecologically, but neither are wind turbines, which require extensive acreage, kill birds, and provide inadequate amounts of intermittent, expensive electricity that cannot possibly sustain modern societies.

Now a revolutionary nuclear energy technology is being designed and built in South Africa, but with suppliers and partners in many other nations. The 165-megawatt Pebble Bed Modular Reactors are small and inexpensive enough to provide electrical power for emerging economies, individual cities or large industrial complexes. However, multiple units can be connected and operated from one control room, to meet the needs of large or growing communities.

Process heat from PBMRs can also be used directly to desalinate sea water, produce hydrogen from water, turn coal, oil shale, and tar sands into liquid petroleum, and power refineries, chemical plants and tertiary recovery operations at mature oil fields.

The fuel comes in the form of baseball-sized graphite balls, each containing sugar-grain-sized particles of uranium encapsulated in high-temperature graphite and ceramic. This makes them easier and safer to handle than conventional fuel rods, says Pretoria-based nuclear physicist Dr. Kelvin Kemm.

It also reduces waste disposal problems and the danger of nuclear weapons proliferation. Conventional fuel-rod assemblies are removed long before complete burn-up to avoid damage to their housings, but PBMR fuel balls are burnt to depletion.

Because they are cooled by helium, the modules can be situated anywhere, not just near bodies of water, and reactors cannot suffer meltdowns. If the chain reaction must be shut down in an emergency, the fuel’s residual decay heat dissipates slowly and naturally.

Since PBMRs can be built where needed, long, expensive power lines are unnecessary. Moreover, the simple design permits rapid construction (in about 24 months), and the plants don’t emit carbon dioxide.

PBMR technology could soon generate millions of jobs in research, design and construction industries – and millions in industries that will prosper from having plentiful low-cost heat and electricity. It will help save habitats that are now being chopped into firewood – and improve health and living standards for countless families.

“I met a guy living in the bush who got electricity and promptly started making wooden chairs,” Dr. Kemm told me. “Not garden stuff, but perfect Louis XIV chairs, because he could now use electric saws, drills, routers, and lathes.” His story will be repeated all over, as people gain access to electricity.

Not surprisingly, dozens of companies and countries are keenly interested in PBMR technology, and the first pilot plant will go online in 2011. But assorted special interest groups have lined up against it.

George Soros’ Open Society Foundation supports anti-nuclear organizations that oppose PBMR. Danish interests see it as undesirable competition for their wind-turbine businesses. Others assert that electricity “destroys” traditional cultures. “If there is going to be electricity,” says activist Gar Smith, it should be “decentralized, small and solar-powered.”

Poor people everywhere hope these patronizing attitudes will soon be replaced by a recognition that they have an inalienable right to take their place among the Earth’s healthy and prosperous people.

Paul Driessen is senior policy advisor for the Congress of Racial Equality and Committee For A Constructive Tomorrow, and author of “Eco-Imperialism: Green power/Black death.”

 

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Canada and the ethanol factory: A blend too good to be true?

Posted on September 5, 2006 by energyprbe

Richard Blackwell

September 5, 2006

Sarnia, Ontario: It smells like a brewery, looks like a small petrochemical plant, and what comes out the back end is at the centre of a debate over Canada’s energy future.

The spanking new ethanol plant built by Suncor Energy Inc. on the outskirts of Sarnia, Ont., opened officially last week – it’s been operating since early summer – and is now Canada’s largest ethanol factory. It will generate about 200 million litres a year, enough to replace all of the imported ethanol Suncor has been buying to blend with gasoline it sells at gas stations across Ontario.

Suncor puts just under 10-per-cent ethanol in all the gas at its 300 Sunoco retail outlets in the province. The clean-burning fuel helps reduce engine emissions with a negligible reduction in gas mileage, the company says.

Still, ethanol has plenty of critics, even among environmentalists. Producing it takes an enormous amount of energy, they say, and without government incentives it would be entirely uneconomical.

The debate over ethanol has even spilled over into entertainment. An episode of NBC’s The West Wing early in 2005 dealt with ethanol subsidies as an issue in the fictional presidential election fight between Arnold Vinick and Matthew Santos.

That said, real-life governments have signed on in a big way and are boosting the industry with tax breaks, the promise of guaranteed markets – by setting minimum levels of ethanol in gasoline – and direct subsidies.

The new Sarnia plant, like most other ethanol factories across the country, wouldn’t exist if Ottawa hadn’t picked up some of the costs. The federal government’s ethanol expansion program, which has put more than $100-million into projects across the country, contributed $22-million of the $120-million price tag for Suncor’s new plant.

Ontario will help out with another $36-million in funding over the next three years.

On the surface, Suncor’s new ethanol plant is a model of efficiency. Every day as many as 40 trucks filled with corn kernels rumble up to unload their contents through a huge grate in the floor of the receiving shed. The corn is mostly from Ontario farmers within a 120-kilometre radius of the plant, although some is trucked in from Michigan.

The corn is then ground to expose the starch hidden under the fibre, and this is dissolved in water and cooked for 45 hours in huge tanks, along with enzymes and yeast that break down the starch into sugar, and then ferment it into alcohol. Essentially it’s a big distillery, although the end product is not whisky but a brew of 14-per-cent ethanol. The ethanol is stored on site and then shipped by truck or train to one of Suncor’s gasoline blending facilities in Ontario.

But that’s not the end of the chain. The dried remnants of the corn, which look like ground cereal, are loaded into trucks and eventually find their way by ship to Europe as animal feed. And the carbon dioxide released by the fermenting process, while it is now released into the air, will eventually be collected at a Praxair Inc. plant being built next door and sold as dry ice.

All this with a total contingent of about 40 employees.

The new Suncor plant, built on a former corn farmer’s field, will be doubled in size if the market demands warrants and the government subsidies keep on coming, said plant manager André Boucher.

But what would it take to make ethanol self-sufficient? Tom Ryley, executive vice-president of Suncor Energy Products, says ethanol could be economic “without a huge amount of government support” if corn prices were sustained at or below the current level of about $2.50 a bushel, and oil prices stayed above $70 (U.S.) a barrel. But with the price levels of those two commodities fluctuating, there is still a need for government support.

In fact, Mr. Ryley said, it was the government’s excise-tax break on ethanol that prompted Suncor to start blending it with its gasoline back in the mid-1990s. That government support for the ethanol component made it cheaper to produce the blended product.

Since then, with environmental concerns more front and centre in consumers’ minds, Suncor has also seen ethanol as a means to improve the company’s environmental performance.

But environmentalists aren’t as keen on ethanol as one might expect. Tom Adams, executive director of Toronto-based energy watchdog Energy Probe, concedes that ethanol is “a good fuel in a lot of respects” because it burns cleanly, but he still considers himself an “ethanol skeptic.”

One problem is “ethanol cannot make it on its own horsepower,” he said. “It’s highly dependent on government protection,” both from direct subsidies and the coming regulations that will force minimum levels in gasoline sold to consumers.

 

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Scouring scum and tar from the bottom of the pit

Posted on July 1, 2006 by energyprbe

Peter Cizek
Canadian Dimension Magazine
July 1, 2006

Faced with the undeniable reality of “Hubbard’s Peak” in global conventional oil supplies, the world’s largest multinational energy corporations are now hell-bent on squeezing oil out of tar in northern Alberta, like junkies desperately conniving for one last giant fix in a futile attempt to quench America’s insatiable “addiction to oil” (described so eloquently by President George Bush II). Along the Athabasca River near Fort McMurray, a sub-arctic town almost 1,000 kilometres north of the U.S. border, tar literally seeps out of the riverbanks where Aboriginal peoples once used it to patch their birch-bark canoes. But most of the tar sands lie hidden below northern Alberta’s boreal forest, in an area larger than the state of Florida.

The first serious effort to dig huge tar pits along the Athabasca River to steam out the oil began in 1963 with the Great Canadian Oil Sands Company developed by Sun Oil Ltd., later to become Sunoco, and eventually Suncor.

By 1967, the company’s scion, J. Howard Pew, self-proclaimed “champion of free enterprise and enemy of godless communism,” had sunk $240 million (over $1 billion in today’s currency) into this project in an effort to wean Americans from dependence on foreign oil – Canada being considered an American territory. However, this Pew family project was less than successful, since separating the tar from the sand and then turning it into crude oil requires huge amounts of energy, steam and water. Even after the tar is melted down into bitumen, it still has to be “upgraded” into synthetic crude oil by adding hydrogen, usually made from natural gas.

Starting in the 1970s, the federal and Alberta governments paid out billions of dollars in tax breaks and research subsidies, invested in a joint-venture corporation called Syncrude, and even significantly lowered the royalty rate in the tar sands in 1997. In the mid-1980s, new “in situ” technologies like “Steam-Assisted Gravity Drainage” (SAGD) were developed, which steamed the tar from deposits around Cold Lake and Peace River – deposits too far below the surface to strip-mine. By the turn of the millennium, dozens of multinationals had invested over $24 billion into the tar sands, which finally began to yield huge profits with the explosive increase in the price of oil.

Between 1995 and 2004, tar-sands production doubled to more than 1.1 million barrels per day, 16 years ahead of schedule. It was a banner year in 2003, when the United States Energy Information Administration recognized that 175 billion of the total 1.7 trillion barrels of oil in the tar sands were “economically recoverable,” placing Alberta second only to Saudi Arabia in the world’s pecking order of oil reserves.

The Tar Sands’ Appalling Impact

“Oil Sands Fever,” a report released in November, 2005, by the Pembina Institute, a Calgary-based energy think tank, barrages the readers with an onslaught of horrifying facts and images that make the appalling environmental impacts of the tar sands assume gargantuan proportions:

About half of Canada’s oil production currently comes from the tar sands. Tar-sands oil production has been predicted to quintuple from one million barrels per day in 2003 to five million barrels per day in 2030, representing over three-quarters of Canada’s oil production, 70 per cent of which is destined for export to the United States.

Around Fort McMurray over 430 square kilometres of boreal forest has been eradicated. There is an approved disturbance of 950 square kilometres and a planned disturbance of 2,000 square kilometres. Not including the loss and fragmentation of boreal forest from “in situ” operations in Cold Lake and Peace River, this will be twice the combined urban footprint of Calgary and Edmonton (1,000 square kilometers). No land has yet been certified as reclaimed.

To produce one barrel of oil, four tonnes of material is mined, between two and five barrels of water are used to extract the bitumen, and enough gas to heat 1.5 homes for a day is required. Oil-sands producers move enough overburden and oil sands every two days to fill Toronto’s Skydome or New York’s Yankee Stadium.

The tar-sands industry now consumes 0.6 billion cubic feet of natural gas per day, enough natural gas to heat 3.2 million Canadian homes for one day. By 2012, this industry will consume two billion cubic feet of natural gas per day, enough to heat all Canadian homes for a day. By 2030, the tar sands are forecast to consume over five billion cubic feet per day of natural gas, representing more than the combined output of the planned Mackenzie Valley and Alaska gas pipelines, which will induce exploration and development of thousands of natural-gas wells and feeder pipelines spanning the Northwest Territories, Yukon and Alaska.

The greenhouse-gas intensity of tar-sands production is almost triple that of conventional oil, largely due to the vast amounts of natural gas consumed. Even before the actual produced oil is burned, carbon emissions from the tar sands are forecast to increase from 23.3 million tonnes per year to between 83 and 175 million tonnes per year. This might represent almost two-thirds of Canada’s 2005 “Kyoto gap” of 270 million tonnes. Canada’s “Kyoto gap” has increased from 138 million tonnes in 1997 to 270 million tonnes in 2005, due in large part to the impact of the Alberta tar sands.

Approved oil-sands mining operations are already licensed to divert 349 million cubic metres of water per year from the Athabasca River. This is approximately three times the volume of water required to meet the municipal needs of Calgary, a city of almost one million people, for one year. Planned projects will increase water diversions to almost 500 million cubic metres of water per year, representing 10 per cent of the river’s winter low flow.

Syncrude and Suncor are the top two air polluters in Alberta, which have already degraded the once-pristine air quality in Fort McMurray, a small northern city of 70,000, to the level of metropolitan centres like Edmonton and Calgary. Air-quality modeling for approved projects predicts that national, provincial and international guidelines for sulfur dioxide and nitrogen oxide will all be exceeded.

A Modern Gold Rush

Very recent developments reinforce and amplify all these facts. Multinational corporations, including majority players such as ExxonMobil, ConocoPhillips and Shell, who also happen to be the promoters of the Mackenzie Valley and/or Alaska arctic natural-gas pipelines, have confirmed a grand-total planned investment of $100 billion into the tar sands in the next decade. This makes it the largest mega-project complex in the world, growing to an astounding total of at least $160 billion when all the required arctic natural-gas supplies from the Mackenzie Valley and Alaska pipelines are added – which requires coining a whole new word: “gigaproject.”

Brokers like Raymond James Ltd. and the Canadian Imperial Bank of Commerce are advising investors about the realities of “peak oil” and counseling them to invest in the tar sands, which they describe as the planet’s last new significant oil-supply addition with total production forecasts whose total output will rival Saudi Arabia by 2030. When interviewed by CBS’s 60 Minutes in January, 2006, about the confirmed tar-sands reserves of 175 billion barrels, Clive Mather, CEO of Shell Canada, baldly stated, “We know there’s much, much more there. The total estimates could be two trillion or even higher” – eight times the reserves of Saudi Arabia.

Early this year, frenzied speculation hit new heights in a bidding war for new tar-sands leases, where energy corporations spent almost twice as much cash in one month than they had ever spent in a whole year. During the month of January, 2006, the Alberta government raised $850 million for selling 4,000 square kilometres of new tar-sands leases, adding this block to the grand total of 24,000 square kilometres of boreal forest available for extracting oil from tar, a combined area almost as big as Vancouver Island. Finally, the Alberta government is steamrolling towards a March 31, 2006 deadline to complete public consultations about its “Mineable Oil Sands Strategy” (MOSS). The plan is to effectively re-zone the entire Fort McMurray region as a permanent industrial landscape – or what Ronald Reagan once called a “national sacrifice area” – finally abandoning the fantasy of “multiple use” through “integrated resource management,” which balances resource extraction with wildlife and other ecological values.

The option of nuclear power to supply steam and hydrogen to the tar sands has been promoted for at least a decade by Atomic Energy of Canada Limited, desperate to rejuvenate the dwindling market for its white elephant CANDU reactors. In the fall of 2005, French energy conglomerate Total SA began to muse publicly about using nuclear power in its new tar-sands projects. More pragmatically, TransCanada Pipelines just announced serious discussions to revive the dormant 1,800-million-watt Slave River hydroelectric project at the massive rapids near Fort Smith at the Northwest Territories’ border, host to the northernmost rookery of the once-endangered white pelican.

Our Meek Environmentalists

Despite Pembina’s exhaustive documentation of this unfolding ecological holocaust, its policy prescriptions are shockingly timid and meek. On December 1, 2005, led by the Pembina Institute, eleven major environmental organizations, including World Wildlife Fund Canada, the Canadian Parks and Wilderness Society and the Sierra Club of Canada, issued a declaration called “Managing Oil Sands Development for the Long Term.” It calls for elimination of subsidies, a network of protected areas and corridors, a binding, integrated regional resource-management plan and, most curiously, “carbon neutral (zero net greenhouse gas emissions) by 2020 through a combination of on-site emission reductions and genuine emissions offsets.”

The possibility of slowing down, much less stopping, further expansion of the tar sands is not even mentioned.

Moreover, the declaration goes on to assure its intended audience that, “These conditions can be implemented without significant macroeconomic impacts through innovation and strong leadership. Only through the satisfaction of these conditions do we believe that Canada will be in a position to develop this energy resource in a responsible manner that will create a positive legacy for current and future generations.” Are these environmental organizations so terrified of upsetting this “foundational economic driver for Canada” – as described in a 2004 agreement between Alberta and the federal government – that allows speedy work permits for foreign “guest-workers” to relieve labour shortages in Fort McMurray? Or are there deeper forces yanking at these environmentalists’ chains?

Pembina just happens to make money selling “carbon offsets” to the guilt-ridden rich and progressive corporations by subsidizing TransAlta Utilities, a major Alberta coal producer, to construct windmills that produce electricity without emitting carbon. Without legislated “caps” on maximum carbon emissions, the purchase of carbon offsets is a feel-good illusion, as this does not actually result in the reduction of overall carbon emissions. A major purchaser of these credits is Suncor, which most recently offset 144,000 tonnes of carbon out of its total 10 million tonnes per year of steadily growing carbon emissions for a whopping 1.4 per cent. Pembina also offers franchise opportunities to other non-profit groups in this moneymaking scheme. With Conservative prime minister Stephen Harper’s announcement that Canada cannot meet its Kyoto commitments, Pembina’s climate-change specialist Matthew Bramley conceded with a capitulation: “We do need to buy international credits as part of our package of measures to meet our Kyoto target.”

Twisting Science

One need look no further than the list of “partners and clients” in Pembina’s annual report to find a veritable who’s who from the oil patch, including major players in the tar sands/arctic natural-gas pipeline “gigaproject” like ConocoPhillips, Encana, Husky Oil, PetroCanada, Shell Canada and even Suncor, whose vice-president of sustainability makes valuable use of his surfeit of uncritical face time in Pembina’s tar-sands video to proselytize about the company line.

In November, 2005, Pembina also produced a report called Counting Canada’s Natural Capital: Assessing the Value of Canada’s Boreal Ecosystems, wherein they proclaim that the Canadian boreal forest absorbs 173 million tonnes of carbon worth $1.85 billion each year, which could presumably be used to “offset” carbon emissions from the tar sands. Yet, deep within the body of the text, Pembina acknowledges recent scientific literature, which concludes that the boreal forest actually became a net source of 44 million tonnes of carbon emissions per year in the 1970s, largely due to increases in forest fires and pest outbreaks, all related to global warming.

In an amazing twist of logic, Pembina then uses a study from 1995 that explored possible intensive-management scenarios, like tree-planting, fire suppression and pest control to reverse future carbon emissions from the boreal forest, as a way to rationalize its deceptive conclusion that the boreal forest is now absorbing carbon and not actually producing it. The primary author of all these boreal carbon studies is Dr. Werner Kurz, (*) formerly of Natural Resources Canada but now with Ducks Unlimited, who, despite Pembina’s distortion of his studies, is surprisingly also listed as an advisor, reviewer and contributor to the report.

Follow the Money

The sponsor of Pembina’s Counting Canada’s Natural Capital report is the Canadian Boreal Initiative (CBI), self-described as “an independent organization working with conservationists, First Nations, industry and others to link science, policy and conservation activities in Canada’s boreal region.” This “organization” does not have a board of directors, is not registered as a non-profit corporation under any federal or provincial laws, and does not have a charitable number. Yet, this “organization” employs a staff of eleven and has sponsored at least five major research reports about the boreal forest in the past three years. Cathy Wilkinson, the CBI’s “director,” appeared on the Report on Business T.V. show Squeezeplay on December 13, 2005, to publicize the findings of the Counting Canada’s Natural Capital report:

Kevin O’Leary: :I like to understand where people’s interest lies and I always do that by finding out where their money came from because I believe that money and interests are always aligned. Who funds your organization?”

Cathy Wilkinson: “We’re funded by charitable organizations both in the United States and in Canada who are interested in the value of the world’s largest and intact forests. So this is really an international effort in the same way that our trade moves across the border.”

Not quite. As noted on CBI’s own website, its sole funder is actually the Philadelphia-based Pew Charitable Trusts – the same Pew family who originally developed the tar sands, created Suncor (worth $5.9 billion, when they sold their shares in 1995) and who continue to own Sunoco, a major refiner of synthetic crude oil from the tar sands.

So, if it is neither a legal entity nor a registered charity in Canada, how does CBI actually channel money “across the border”? The Pew first transfers money to the North American headquarters of Ducks Unlimited in Nashville, Tennessee, which is funneled to its Canadian branch-plant headquarters in Winnipeg. Ducks Unlimited, which proudly lists Suncor and Syncrude as its “corporate partners,” then recycles “boreal” money not only back to the CBI, but also to other Canadian environmental organizations, like World Wildlife Fund Canada (WWF) and the Canadian Parks and Wilderness Society (CPAWS).

Buying the Environmental Movement

WWF and CPAWS got their first snort of this nose candy from the Pew in 1999 with a grant of $1.8 million over two years to “protect at least 20 million acres of boreal forest wilderness in the Yukon and Northwest Territories of Canada.” Even though they never came even close to this lofty objective, the Pew kept cranking the dose of crackerjack cash higher and higher, from $2.1 million per year in 2000 to $4.5 million per year in 2002-03, topping out with a mind-blowing speedball injection of $12 million – the Pew’s single biggest grant in 2004.

Just like they do not oppose the tar sands in Alberta, WWF and CPAWS also do not oppose the Mackenzie Valley Pipeline in the Northwest Territories.

After all, the new president and CEO of WWF, Mike Russill, is a former senior executive of Suncor. WWF and CPAWS are only lobbying to establish a network of protected areas before the start of construction. Last year, WWF, CPAWS and Ducks Unlimited squeezed out an additional $9 million from the federal government to conduct more studies to identify such a network under the government-approved Northwest Territories Protected Areas Strategy.

In 1996, WWF threatened to sue the federal government for approving Canada’s first diamond mine due to the absence of any protected areas in the central arctic region. WWF then withdrew its lawsuit in exchange for the government’s commitment to develop a Northwest Territories Protected Areas Strategy. Since this strategy was approved in 1999, WWF has not formally identified, much less established, any protected areas in the central arctic, while only two areas have received temporary protection elsewhere in the Northwest Territories under this strategy.

In Alberta, the once-feisty Edmonton branch of CPAWS is pursuing a similar approach around the tar sands, where it is promoting four protected areas, all of which have low oil potential and no leases. This pattern of environmental organizations adopting a docile “low-hanging fruit” strategy soon after being bankrolled by the Pew has been thoroughly documented by American activists and investigative reporters, including Jeffrey St. Clair, Alexander Cockburn, Mark Dowie and Felice Pace.

Setting Up Fronts

Until the early 1980s, the Pew religiously followed J. Howard Pew’s founding mission “to acquaint Americans with the evils of bureaucracy, the paralyzing effects of government controls on the lives and activities of people, and the values of the free market” by funding right-wing extremists like the John Birch Society and the Heritage Foundation. Since then, the Pew has adopted a much more sophisticated strategy of setting up dozens of socially progressive “front groups” across North America like the CBI, an innovative right-wing twist on classic Marxist-Leninist organizing tactics.

In 2003, the CBI established the “Boreal Leadership Council,” composed of WWF, CPA WS, Ducks Unlimited, Suncor, Tembec, Alpac, Domtar and several First Nations. Its goal is to implement the “Boreal Conservation Framework” by protecting at least half of Canada’s boreal forest, with the remainder available for “leading-edge sustainable practices.”

Concerned that this arbitrary benchmark of protecting half the boreal forest has never been scientifically justified, the David Suzuki Foundation did not endorse the framework. As pointed out by the free-market environmentalist Larry Solomon of Energy Probe, the “Boreal Conservation Framework” actually amounts to a massive resource giveaway requiring government subsidies, as industrial development in the far northern boreal forest is currently uneconomic under market conditions.

Lacking any accountable governance structures and directed by carefully chosen Pew operatives, front groups like the CBI not only fund but also insist on entering into partnerships with established advocacy organizations. Thus, the front group can serve as a “drag anchor” on any activities that are excessively disruptive to the status quo. According to an employee of CPAWS, the CBI is now reviewing and vetting their draft press releases. A project officer of a major Canadian foundation recounts tales of environmental organizations pleading with him for grants, desperate to break their dependence on the Pew/CBI as their sole funding source.

The Sierra Club of Canada originally took a hard-line position against the Mackenzie Valley Pipeline and the tar sands. In a wacky turn of events, shortly after receiving funding from the CBI/Pew, Sierra Club endorsed the Pembina-orchestrated “oil sands declaration” and threw its support behind the Alaska Pipeline as the “lesser of two evils” on the entirely false assumption that none of the Alaska gas would go to the tar sands. Sierra’s flip-flopping continues with its most recent announcement that it now wants a moratorium on further oil-sands development.

The only bright light in this deep, dark pit of depravity is a report entitled Fuelling Fortress America, released in March, 2006, by the Parkland Institute, the Canadian Centre for Policy Alternatives and the Polaris Institute. This report clearly advocates a moratorium on further tar-sands development, a national energy policy and exemption like Mexico from the “proportional sharing” clause of the NAFTA free-trade agreement, which only allows Canada to reduce energy exports to the United States in proportion to reductions of our own consumption.

“Canadian Oil Is Ours”

While allegedly supporting boreal conservation in Canada, the Pew is also busy addressing American foreign policy regarding the tar sands. With its partner, the $6-billion Hewlett Foundation, which also funneled $1.85 million through the Pew to the CBI in 2004, the Pew established the “National Energy Commission,” a bipartisan group of twenty energy experts.

This group includes James Woolsey, a former director of the CIA and a member of the “Project for a New American Century,” which advocated pre-emptive war and the invasion of Iraq as early as 1998. In its 2004 report, “Ending the Energy Stalemate,” the Commission advocated, “a $300 million increase in federal funding over ten years to improve the environmental performance of technologies and practices used to produce unconventional oil resources” in Alberta’s tar sands and Venezuela’s Corinoco heavy oil belt. Overall, the Commission advocates $36 billion in government subsidies to the energy sector to be financed though the sale of carbon credits.

Canada’s tar sands and arctic natural gas have been on America’s foreign-policy radar screen at least since 2001, when Dick Cheney’s “National Energy Policy” report stated that the continued development of the tar sands “can be a pillar of sustained North American energy and economic security.” Last year, American politicians were outraged by a relatively small Chinese investment of $225 million in the tar sands, which prompted energy analyst Irving Mintzer to blurt out the widely held but publicly unspeakable opinion of Beltway insiders: “The problem with the Chinese is that they don’t know that the Canadian oil is ours. And neither do the Canadians.” Mintzer is also a co-author of the report, U.S. Energy Scenarios for the 21st Century, commissioned by the Pew Center on Global Climate Change.

In 2005, Dick Cheney’s “National Energy Policy” was transmuted into legislation called the “National Energy Policy Act,” with the support of the “Set America Free Coalition,” a front group of the “Institute for the Analysis of Global Security.” A member and advisor to both organizations, James Woolsey proudly proclaims that, “We’ve got a coalition of tree-huggers, do-gooders, sodbusters, hawks and evangelicals,” including the Natural Resources Defense Council, a regular recipient of millions in Pew and Hewlett funding, which has also become involved in a boreal-forest campaign in northern Manitoba.

In addition to providing $13.6 billion in subsidies to the energy sector, the National Energy Policy Act has a “Set America Free” sub-section, which establishes “a United States commission to make recommendations for a coordinated and comprehensive North American energy policy that will achieve energy self-sufficiency by 2025 within the three contiguous North American nation area of Canada, Mexico, and the United States.” Since the United States currently imports 60 per cent of its oil supply, this continental self-sufficiency will require much additional Canadian and Mexican oil. Furthermore, the Act establishes a Task Force to initiate “a partnership with the Province of Alberta, Canada, for purposes of sharing information relating to the development and production of oil from tar sands.” Finally, the Act requires the Secretary of Energy to update his/her assessment of domestic heavy-oil resources to include “all of North America and cover all unconventional oil, including heavy oil, tar sands (oil sands), and oil shale.” However, this legislation merely formalizes the continent-wide “deep integration” that has been well underway with the establishment of the “Security and Prosperity Partnership,” which released its “Oil Sands Experts Working Group” workshop report in March, 2006.

 

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