Aldyen Donnelly: Use product standards, not tariffs

(Aug. 31, 2010) Implementing tariffs to discriminate against environmentally subsidized imports is a horrible—and very 1950s—idea.

When we decided that it was unhealthy to sell toys in Canada that were covered with leaded paint, did we: (1) prohibit the manufacture of leaded paint in Canada and (2) put a tariff on leaded paint and leaded painted toy imports? Certainly not. Everyone involved agreed that would have been a stupid idea. So why are we seriously contemplating such a stupid idea to address the damage of GHGs and other pollutants?

When we wanted to get the lead out of gasoline and paint, PCBs out of electricity components, DDT out of pesticides, sulphur levels down in diesel, or CFCs out of refrigerants, we did not regulate domestic manufacturers and put tariffs on imports, as proposed in Jeff Rubin’s article.

In EVERY case of successful environmental management outcomes we did the same thing.

We first regulated the pollution factor and/or content for pollution precursor products, at the point of sale—not the point of manufacture or import. To the extent that we prohibited the manufacture of polluting products or pollution precursors in Canada, we only did so after North American product standards created significant demand for more environmentally benign versions of those products.

Efficient and effective regulation will not involve any tariffs. Effective regulations will say that every distributor of petroleum products in Canada has to report global supply chain fossil carbon consumption and comply with fossil carbon content limits (on a Canadian sales portfolio basis) that decline over time.

We only have to put supply chain carbon/GHG reporting and content limits in place for nine basic commodities to cover 85% of North America’s global supply chain emissions. 80% of the least cost measures industry will apply to comply with the reduction obligation will also result in local air pollution reductions.

Why are we talking tariffs—which will be the start of trade wars—when we clearly know how to get this right and also know that tariffs are inefficient? Regulate products sold, and not manufacturing techniques. Leave it to the market to come up with the manufacturing techniques required to comply with the product standards.

Product standards treat all products sold equally, regardless where the products are manufactured.

Learning from past experience

I should note that every time we have regulated products to achieve environmental protection goals, (1) Canada has regulated domestic production as well, but (2) the US has exempted exports. Consistent with this history, the US Congress has even included an exemption from proposed US GHG caps for all GHG sources that are producing exported products in every climate change bill that has passed 2nd reading on the House or Senate since January 2006.

We can afford to regulate what is manufactured here only if/after our product standard regulations have created a large enough demand for environmentally superior products, and only if the US removes the export exemption from its existing and proposed regulations.

Every time Canada has regulated both sales and production, the US has subsidized US producers of the regulated products by allowing them to continue to produce and dump polluted/polluting products on developing world markets. A system of tariffs just makes the return on dumping worse.

The ultra low sulphur diesel case

For example, in 2006 it became illegal to sell diesel fuel that was greater than 15 parts per million (ppm) sulphur through the retail distribution networks in both Canada and the US. In Canada, it became illegal to manufacture high sulphur diesel in the same year. But the US did not completely prohibit the production of high sulphur diesel.

Up until 2006, the US was a net importer of diesel fuel. After 2006 the US became a net exporter of diesel fuel. 100% of the US’s incremental diesel exports are high sulphur diesel, and most of these exports are going to developing nations in South America or to developed nation refineries where the high sulphur diesel is blended with their low sulphur production before the finished blend is exported to developing nations.

The US refinery dumping of high sulphur diesel on the developing world market mirrors the US dumping of leaded gasoline starting in 1990, after the completion of the US domestic leaded gasoline phase out.

Most of the gasoline export increase you see pictured below was in the form of leaded fuel from 1980 through roughly 1995. Congress eventually approved regulations prohibiting the manufacture of leaded gasoline in the US in 1996. Having established new export market share with leaded fuel exports, the US refineries maintained and continued to grow those export market shares by substituting unleaded for leaded fuel.

Western Climate Initiative

Note, as well, that the California GHG standard for electricity and Low Carbon Fuel Standard—the critical measures the states/provinces participating in the Western Climate Initiative have agreed to—effectively exempt product that is manufactured in California/the WCI states/provinces, but is exported, from the GHG limits.

Canada unity at risk

Please also note that if/when Canada/the provinces agree to a domestic “cap and trade” set of rules (where “cap and trade” regulates GHGs at the point of production, not the point of sale) and levels the playing field with tariffs on imports, if Canada replicates the US historical and proposed GHG bill models, all Canadian production destined for export markets will be exempt from Canada’s GHG caps.

This has major implications, including but not restricted to:

  • many of the larger GHG sources in western Canada will be exempt from the national GHG cap and trade regulations, but
  • most of the cost of import tariffs will be paid by consumers living in Ontario and Quebec.

I do not believe that any such outcome will prove acceptable to the residents of Ontario and Quebec.



Aldyen Donnelly, August 31 2010

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Looking at NB Power numbers

(Aug. 28) Norm Rubin with the Toronto-based energy watchdog group Energy Probe  says he is concerned that NB Power might be forced to go too far in cost-cutting efforts in order to freeze the power rate, postponing such things as required maintenance, writes W.E. (Bill) Belliveau in the Times and Transcript. Continue reading

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Looking at NB Power numbers

(Aug. 28, 2010) As Prime Minister Harper rattles around the Arctic pumping the need for fighter planes and Arctic sovereignty and warning of Russian bomber threats that justify the recently announced $9 billion dollar purchase of U.S. manufactured fighter planes, NORAD, the North American Aerospace Defense Command says that at no time did Russian bombers enter Canadian airspace this week. Continue reading

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Looking at NB Power numbers

W.E. (Bill) Belliveau
Times and Transcript
August 28, 2010

As Prime Minister Harper rattles around the Arctic pumping the need for fighter planes and Arctic sovereignty and warning of Russian bomber threats that justify the recently announced $9 billion dollar purchase of U.S. manufactured fighter planes, NORAD, the North American Aerospace Defense Command says that at no time did Russian bombers enter Canadian airspace this week.

Coincidently, a few miles away in Nunavut a huge chunk of ice broke off Ellesmere Island. Scientists estimate the size of the ice chunk at roughly the size of Bermuda. Could this be another piece of the global warming threat and is anybody paying attention?

On another matter, notes to the 2009 (year ending March 31, 2009) Financial Statements of NB Power relating to refurbishment of the Point Lepreau Generating Station say that “costs of replacement power will be recovered from customers over the station’s operating life and reflected in . . . charges, rates and tolls to customers.” Meanwhile, it will defer costs and capitalize interest payments – a method of creating paper profits. It does not reduce the need for cash. In an early 2010 election undertaking, Progressive Conservative Leader David Alward has promised voters a three-year freeze on power rates if his party wins the Sept. 27 election.

With the greatest respect for Mr. Alward, one has to wonder about the feasibility of his promise. Cost over-runs and power replacement costs for the Lepreau refurbishment could be $2- to $3-billion before it’s finished, if it is ever finished.

Let’s be optimistic and assume the nuclear generator will be up and running by January 2012 and total costs of over-runs and power replacement costs prove to be as little as $3 billion. Based on notes to the financial statements referred to above and assuming a plant life of 25 years, the charge to ratepayers for capital recovery would be $120 million a year (not including interest costs). With five per cent interest rates the annual cost of interest would be another $150 million, more than double the reported profit of NB Power in 2009 ($70 million). How does a rate freeze fit into that scenario?

NB Power has already warned that it needs future rate increases to pay for the financial setbacks of the $1.4-billion refurbishment at Point Lepreau. Interest and capital recovery alone would require a rate increase of at least seven per cent ($40 million per point) and that could be on top of revenue-losses over three years – the result of a rate freeze – short-term gain for long-term pain.

Norm Rubin with the Toronto-based energy watchdog group Energy Probe
says he is concerned that NB Power might be forced to go too far in cost-cutting efforts in order to freeze the power rate, postponing such things as required maintenance. “You have to be careful that you don’t put too much financial pressure on a utility, especially one that’s always been Crown-owned and hasn’t been pressed before,” he said.

Rubin says freezing rates without knowing when Atomic Energy of Canada Ltd. will complete the refurbishment of the Point Lepreau nuclear power plant (2.5 years behind schedule) is “a recipe for disaster.”

To be clear, Energy Probe has an agenda. Founded in 1969, the organization believes that nuclear power is uneconomic. It claims to have been successful in stopping the construction of all nuclear plants in Canada proposed since that date.

Even though the province’s 90-year-old power utility is saddled with a debt of $4.75 billion, Alward says his idea is feasible based on an analysis done by a former NB Power vice-president and two consultants.

Mr. Alward is also promising to appoint an energy commission to map the province’s energy strategy for the next decade if he wins the Sept. 27 election. His party’s “discussion paper”, including the recommended three-year rate freeze, relies on analysis by Darrell Bishop, a former vice-president at NB Power. Bishop told a news conference that “lower fuel prices, combined with a recent three per cent rate increase” has put NB Power in a position where it can operate profitably despite the rate freeze.

Nobody in the world can guarantee future energy prices. Any cost assumptions based on future energy prices are guesstimates at best and wishful thinking at worst. David Alward’s counterpoint: “NB Power is in good shape and is able to allow rate freezes going forward over the next three years and still pay down the debt (because) it is still a profitable company.”

Energy Minister Jack Keir says he is astonished at Bishop’s participation on the Tory panel considering that just a year ago, when he was NB Power’s vice-president of generation, he was requesting rate increases for the utility. Bishop is not a financial analyst or a cost accountant; he is an engineer with some high-level experience in customer service and marketing.

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N.B. Tories promise energy rate freeze, but expert questions wisdom behind plan

(Aug. 24, 2010) FREDERICTON – New Brunswick’s Conservative leader is promising to freeze power rates for 2 1/2 years if he’s elected next month, but one expert questioned the wisdom of that proposal as the province’s utility grapples with a massive debt. Continue reading
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Lawrence Solomon: Global warming has not increased damages from weather disasters: American Meteorological Society study

Energy Probe

“Climate change is often seen as the culprit of increasing economic losses from weather disasters. The scientific literature, however, shows that there are other causes up to now.”

So reads the capsule summary of a peer-reviewed study that will soon be published in the Bulletin of the American Meteorological Society. The study, by Laurens M. Bouwer of the Institute for Environmental Studies at Vrije Universiteit in The Netherlands, wondered why insurance claims from extreme weather events had been increasing. To find out, Bouwer looked at 22 studies and found that none justified the claim that global warming was the culprit. Instead, the answer lies in the habits of people: We have more valuable possessions than we had in the past, there are more of us than in the past, and we love living in vulnerable places, such as flood plains and the coastal regions that experience the most weather damage.

Why did scientists get this wrong? One reason, according to Bouwer, a former IPCC lead author, was that they were too quick to come to conclusions based on flimsy evidence. For example, while weather-related damages have increased, damages from earthquakes and other non-weather causes have stayed fairly stable, leading some to conclude that global warming was the culprit.

Had these scientists dug deeper or thought longer about this, as Laurens did, they would have realized that lands susceptible to earthquakes are distributed widely around the globe, occurring without favor in high and low population areas alike. In contrast, many weather related events such as hurricanes and floods tend to occur along the shorelines where humans tend to congregate.  After Laurens corrected for such demographic factors, and for other wrongly held assumptions in previously published studies, the evidence implicating global warming in insurance damage withered away.

Laurens quite accessible study, in pre-publication form, is available here.

Lawrence Solomon is executive director of Energy Probe and the author of The Deniers.

Lawrence Solomon, Financial Post, August 24, 2010

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N.B. Tories promise energy rate freeze, but expert questions wisdom behind plan

Kevin Bissett, The Canadian Press
Winnipeg Free Press
August 24, 2010

FREDERICTON – New Brunswick’s Conservative leader is promising to freeze power rates for 2 1/2 years if he’s elected next month, but one expert questioned the wisdom of that proposal as the province’s utility grapples with a massive debt.

In his first major policy announcement ahead of the Sept. 27 vote, David Alward said Tuesday energy bills for residential and industrial customers would hold until March 2013 if he were elected premier.

Alward said New Brunswickers need price certainty and that the freeze would give him time to develop an energy plan.

Even though the province’s 90-year-old public power utility is saddled with a debt of $4.75 billion, Alward said his idea was feasible based on an analysis done by a former NB Power vice-president and two consultants.

“This is something that people with a bunch of experience and expertise have put a tremendous amount of work into and we feel very confident with the work that they’ve done,” Alward said in an interview after making the announcement in Saint John, N.B.

“Not only can New Brunswickers receive a rate freeze but also NB Power will still be profitable and we will be able to pay down debt as well.”

Alward said the analysis would be made public Wednesday.

Norm Rubin with Toronto-based energy watchdog group Energy Probe said he was concerned NB Power might be forced to go too far in efforts to cut costs in order to freeze the power rate, postponing such things as maintenance.

“You have to be careful that you don’t put too much financial pressure on a utility, especially one that’s always been Crown-owned and hasn’t been pressed before,” he said.

Rubin said freezing rates without knowing when Atomic Energy of Canada Ltd. will complete the refurbishment of the Point Lepreau nuclear power plant, which is 2 1/2 years behind schedule, is “a recipe for disaster.”

He said rising energy costs have to be paid at some point.

“Eventually the rising costs have to be met with rising rates.”

Liberal Energy Minister Jack Keir said it’s irresponsible to promise a rate freeze without knowing what oil prices will be in six months or when Point Lepreau will be back in service.

“Without knowing any of the unknowns in the electricity sector he’s determining right now that NB Power doesn’t need an increase,” said Keir. “I’m bewildered and don’t understand what he’s doing other than electioneering.”

Keir said the government has made efforts to control power rates by putting the various divisions of NB Power back together as one company and giving the energy and utilities board more teeth to regulate the utility.

He said the government is also continuing to press Ottawa to pay for cost overruns arising from the refurbishment of Point Lepreau.

The government attempted to sell NB Power to Hydro-Quebec last year in an effort to stablize energy rates. But the deal was scrapped earlier this year after the government faced fierce public outcry over the proposal.

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Bank’s investment in Lepreau 2 ‘extremely remote at this point’

(Aug. 23, 2010) Sector: Experts agree: David Hay’s comment regarding CIBC’s investment in nuclear project purely speculative Continue reading

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Bank’s investment in Lepreau 2 ‘extremely remote at this point’

Christine Dobby
Telegraph-Journal
August 23, 2010

Sector: Experts agree: David Hay’s comment regarding CIBC’s investment in nuclear project purely speculative

Is this the dawn of a new era of nuclear investment in Canada?

The former head of NB Power, soon to be installed as vice-chairman with CIBC’s investment banking team in Toronto, said in a recent interview that the bank might consider investing in a project such as the second New Brunswick reactor Areva Inc. is floating.

“These are enormous capital requirement projects, so I would hope that we’d be able to provide some capital to a project like that, you know, as it gets nearer to fruition,” said David Hay, who will join the Canadian Imperial Bank of Commerce (TSX:CM, NYSE:CM) on Sept. 7.

But energy analyst Tom Adams said in an interview these comments are likely “extremely speculative.”

When it comes to the utility sector, Adams said, “The banks are very active in marketing securities and offering loans – this is a big area of business for them and Mr. Hay, because of his background, has a special insight into the utility sector, what its borrowing needs are going to be, and how to manage them.”

But in terms of direct investment in nuclear projects, he said, “I don’t take these comments from him about potential investments in what is, at this stage, a speculative Areva reactor, to be particularly material.”

Adams said the prospect of investment by a large bank into a merchant nuclear plant, “a plant that’s created on a stand-alone basis and is selling its power into the market,” is “extremely remote at this point.”

Canadian banks have long been involved with the nuclear industry in Canada, according to Adams. However, he said they have gone into those projects “shielded from the consequences” by loan guarantees and other protections from governments, which have almost always been involved in Canadian nuclear projects.

“The repayment record is outstanding for those investments because they’re all taxpayer guaranteed,” Adams said.

Bruce Power in Ontario, Canada’s first privately owned nuclear generator, is owned by a handful of private investors.

Norm Rubin, the director of nuclear research at Energy Probe, said it’s conceivable that banks were involved as “lenders or facilitators,” in that project but said he does not think any were involved as direct investors.

As for the prospect of CIBC investing in a reactor project with Areva in New Brunswick, Rubin too is unconvinced.

“Maybe CIBC will join the list of gutsy nuclear cowboys that used to have money – I hope not, you know, we need banks in Canada,” he said.

Rubin said that nuclear projects have a track record of disappointing investors.

“This is a technology whose capacity to break your heart is almost unlimited and I think most investors know that.”

Toby Couture, an energy analyst now based out of London, England, said in an email that he takes Hay’s comments to mean CIBC would do its due diligence, examine the business case and consider whether investment makes sense.

“As I see it, no bank is going to invest in nuclear projects in North America without corresponding guarantees similar to those being offered in the U.S. – loan guarantees, guarantees on the power purchase agreement and so on,” Couture said.

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Hydro prices ‘going up like a rocket’

Don Butler
The Ottawa Citizen
August 23, 2010

Electricity prices in Ontario are “going up like a rocket,” fuelled in part by the Ontario government’s Green Energy Act, says a longtime observer of the province’s energy scene.

“You are going to get screwed, and it’s going to be painful,” said Tom Adams, a Toronto-based consultant and a former executive director of Energy Probe.

“We’re talking about hundreds of dollars a year out of your pocketbook that didn’t need to happen. I’m livid about it. People should be outraged.”

Hydro Ottawa customers have already been hit with a double-digit increase this year, thanks to rate hikes approved May 1 by the Ontario Energy Board (OEB) and the imposition of the harmonized sales tax July 1.

A typical consumer in Ottawa who uses 800 kilowatt hours of electricity now pays $116.82 a month, including tax, according to the OEB.

That’s 17.7 per cent more than the $99.35 a month the same residential customer was paying in April. Half the increase is due to higher rates and half because of the HST.

Adams warned that Ontarians should expect to pay at least $110 more a year by the end of 2011 for electricity. That translates into an additional nine-per-cent increase.

After that, rates will move steadily up for four or five years, he predicted.

The OEB has already received several applications for more hefty rate increases.

Hydro One, which operates most of the province’s long-distance transmission lines, has asked for a hike of 15.7 per cent in 2011 and 9.8 per cent in 2012. If approved, the increases would apply to the transmission portion of electricity bills.

Ontario Power Generation, which produces about 70 per cent of Ontario’s power, has asked for a 6.2-per-cent price increase effective next March. It scaled that back from 9.6 per cent after pressure from Energy Minister Brad Duguid.

Traditionally, Ontarians have paid less for power than Americans. But now, said Adams, “we are leaving them in our dust.”

He calculated that Ontario electricity rates passed the average U.S. price for the first time early this year, and are now nearly 15 per cent higher.

Adams assigned much of the blame for the rise in electricity rates to Ontario’s Green Energy Act, which promotes the use of solar, wind and other alternative power sources.

The Feed-in Tariff (FIT) program, which locks in generous payments for 20 years for large green energy projects, is “just outrageous,” Adams said.

The program’s rates are far in excess of current electricity prices. The FIT program, for example, offers producers between 44.3 cents and 71.3 cents per kilowatt hour for solar power, and between 13.5 and 19 cents for wind power.

By contrast, the average weighted price for electricity so far this year is 4.02 cents per kilowatt hour.

Four FIT projects are already operating commercially, as are more than 700 small-scale projects under the companion microFIT program, which offers even richer incentives.

Adams said FIT projects will drive up electricity bills as they generate more and more of Ontario’s power.

Because 20-year contracts have already been offered for FIT projects totalling more than 2,600 megawatts of power, Adams said, “it’s now too late to avoid hundreds of dollars per year of increases.”

But Tom Carpenter, a research associate at Queen’s University’s Institute for Energy and the Environment, said claims that green energy will drive up the price of electricity are “simply false.”

Over the next two or three years, Carpenter said, the impact of FIT projects on electricity rates will be negligible, because the high-priced renewable energy will only represent a tiny fraction of the province’s generating capacity.

As the program expands, he said, economies of scale will kick in and prices will come down sharply.

Another impending shift that could raise costs for residential customers is the advent of time-of-use pricing.

Unless they’ve signed electricity contracts, Ottawa residents now pay the Ontario Energy Board’s regulated price for hydro. For the first 600 hours of consumption in summer — and the first 1,000 hours in winter — they pay 6.5 cents per kilowatt hour, and then 7.5 cents for each kilowatt hour beyond that.

But smart meters, now installed at virtually all Ottawa residences, make it possible to bill customers at three variable rates, depending on when they use electricity.

The current time-of-use rates are:

n 5.3 cents per kilowatt hour between 9 p.m. and 7 a.m.,

n 8 cents from 7 a.m. to 11 a.m. and from 5 p.m. to 9 p.m., and

n 9.9 cents from 11 a.m. to 5 p.m.

Hydro Ottawa plans to shift 4,750 customers to time-of-use billing in November, a further 30,000 early next year and the balance by June 2011. Those who’ve signed contracts with electricity suppliers won’t be affected.

While time-of-use pricing should be cost-neutral overall, Adams said, some people will pay more and some will pay less, depending on their consumption patterns.

Pilot projects in Toronto found many small businesses saved money while residential customers, on average, paid about eight per cent more for their electricity.

Adams said “substantial increases” are also on the horizon for electrical transmission and distribution.

One driver is an OEB decision last December that allowed local utilities to increase their allowed rate of profit. The decision bumped Hydro Ottawa’s allowed return on equity to 9.85 per cent from 8.57 per cent.

There’s some public benefit to that because the City of Ottawa is Hydro Ottawa’s sole owner, but “that is going to drive the distribution and transmission components of the bill up by more than 10 per cent just in and of itself,” Adams said.

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