ISO 14000: Are environmental standards relevant to the oil and gas industry?

By David Vilder.

In a rapidly evolving political landscape of interdependence and lowering of traditional frontiers, new tools for environmental governance keep emerging with both successes and failures. Governments struggle to enact new regulations. They often face strong opposition from the business sector, or the political climate simply isn’t favorable [1]. Government regulation is also very costly, both in terms of political capital and finances. Since the 1980s, New Environmental Policy Instruments (NEPI) have emerged as a results of growing dissatisfaction toward traditional command and control policies [2].

Gulf of Mexico (May 6, 2010) -- Dark clouds of smoke and fire emerge as oil burns during a controlled fire in the Gulf of Mexico. The U.S. Coast Guard working in partnership with BP PLC, local residents, and other federal agencies conducted the "in situ burn" to aid in preventing the spread of oil following the April 20 explosion on Mobile Offshore Drilling Unit Deepwater Horizon. (Source: WikiCommons/U.S. Navy photo by Mass Communication Specialist 2nd Class Justin Stumberg/Released)

Gulf of Mexico (May 6, 2010) — Dark clouds of smoke and fire emerge as oil burns during a controlled fire in the Gulf of Mexico. The U.S. Coast Guard working in partnership with BP PLC, local residents, and other federal agencies conducted the “in situ burn” to aid in preventing the spread of oil following the April 20 explosion on Mobile Offshore Drilling Unit Deepwater Horizon. (Source: WikiCommons/U.S. Navy photo by Mass Communication Specialist 2nd Class Justin Stumberg/Released)

Eco-labels, in particular, have proliferated in the past 20 years. One of the most prominent is the ISO 14 000 family of environmental standards. In brief, ISO 14000 requires a company to assess all aspects of their production and their respective environmental impacts. It also requires an Environmental Management System (EMS), which must include an Emergency Preparedness and Response Plan (EPRP) [3]. Thousands of companies have been certified since the launch of the new standard in 1996, yet one sector remained slow to catch on: the oil and gas industry.

The trend is changing. All major oil and gas companies are moving toward an ISO 14000 certification or have already implemented it (Shell and Total amongst others) [4].   The issue – or the benefits – around eco-labels and such type of NEPI that are market-based is that they are voluntary standards motivated by the market (hence the name market-based!). In other words, there must be a perceived economic advantage for a company to move forward with the often costly certification. Economic advantage, in turn, is the results of both consumer awareness and uptake [2]. When these two elements are combined, an eco-label scheme can become quite successful at protecting the environment while benefiting the company (like the Forest Stewardship Council -FSC- for pulp and paper industry or ISO 14000 in some sectors) [2].

In the oil and gas sector, however, the potential benefits are often hard to grasp. Nobody thinks twice about which gas they put in their cars (except from reward schemes such as Air Miles). The logic behind ‘green’ gas is not the same as for organic tomatoes, yet there is one element of ISO 14000 that can be very beneficial for a company like Enbridge: an EPRP. EPRP can influence directly a company’s long-term operational risk, thereby reassuring investors and potential stakeholders [5]. Other players in the industry have made the move.

Cleaning work after the oil spill of the Exxon Valdez (source: Exxon Valdez Oil Spill Trustee Council)

How many more spills will be required before oil companies implement comprehensive and transparent EPRPs. On image: Cleaning work after the oil spill of the Exxon Valdez (source: Exxon Valdez Oil Spill Trustee Council)

References:

[1] GABRIEL, T., WINES, M., & DAVENPORT, C. (2014, 01 18). Chemical Spill Muddies Picture in a State Waryof Regulations. Retrieved 02 23, 2014, from The New York Times: http://nyti.ms/1eUSePM

[2] Kalfagianni, A., & Pattberg, P. (2013). Fishing in muddy waters: Exploring the conditions for effective governance of fisheries and aquaculture. Marine Policy, 38(1), 124–132.

[3] Willaert, T. (2014, 03 02). Major revision of ISO 14001 coming up: what is new in ISO 14001:2015? Retrieved 03 02, 2014, from DQS-UL CFS GmbH: http://dqs-cfs.com/2014/01/major-revision-of-iso-14001-coming-up-what-is-new-in-iso-140012015/

[4] Spence, D. B. (2011). Corporate Social Responsibility in the Oil and Gas Industry: The Importance of Reputational Risk. Chicago-Kent Law Review, 86(1), 59-85.

[5] The Great Lakes and St. Lawrence Cities Initiative. (2013). Final Oral Arguments Presented to the National Energy Board of Canada. Chicago, IL: The Great Lakes and St. Lawrence Cities Initiative.

The push for renewable energy: a role for impact assessment?

Depending on which day you’re looking at the news, or which sources you’re following, or even which sections you choose to delve into, it can be unclear where we stand in terms of renewable and clean energy. New coalfields are being developed in Australia, Ecuador’s rain forests continue to be transformed into oil fields, and fracking is becoming commonplace news. At the same time, investments in renewable energy seem to be growing and governments continue to proclaim their commitment to green technologies and sustainable energy policies. So the question remains: why are we not further along in our push for ‘green growth?’

United States President Barack Obama discussing his commitments to changing the US’s energy policy at a June 2013 speech at Georgetown.

Christina Figuere’s, executive secretary of the United Nations Framework Convention on Climate Change (UNFCCC), stated in early January that investment in clean technology needs to grow to $1 trillion a year within the next 10 to 15 years, signifying a tripling over current investments ($300 billion/yr). In mid-January, in line with this imperative, Ceres Investor Network organized a meeting of the world’s chief financial interests to discuss the needed increase in renewable investments [1]. This is a prime example of how more and more we are putting our environmental future at the mercy of business; placing faith in their ability to see that our current trajectory is unsustainable and not viable economically. It is increasingly common to frame decisions regarding unsustainable energy in terms of investor motivations rather than social and environmental imperatives [2].

All this leads me to question what role government can have in promoting renewable energy. As much as our world has opened up and globalization has entrenched the role of the private sector and economic interests, the role of the state should not be discounted. For one, it is governments that meet at international organizations to enter into agreements about policies for energy and climate. In 2011 the Intergovernmental Panel on Climate Change published a report stating that almost 80% of the world’s energy could be supplied through renewable sources (bioenergy, solar, geothermal, hydropower, ocean, and wind energy) by 2050, pushing us towards stabilizing the climate, pending “consistent climate and energy policy support” [3]. The main hiccup towards moving in this regard is not an issue of resource availability but rather the proper economic and political policies supporting their development.

Annual installations of new power sources, in gigawatts, through 2030. The model for these predictions takes into account a 3-fold increase in yearly investments in renewable energy by the year 2030. (Source: http://www.motherjones.com/blue-marble/2013/04/charts-renewable-energy-fossil-fuels, provided by BNEF)

Annual installations of new power sources, in gigawatts, through 2030. The model for these predictions takes into account a 3-fold increase in yearly investments in renewable energy by the year 2030.
(Source: http://www.motherjones.com/blue-marble/2013/04/charts-renewable-energy-fossil-fuels, provided by BNEF)

Increased emphasis on natural gas and oil in the form of fracking, oil sands, and heavy-crude are proof to many that we are moving into what Hampshire College Professor Michael T. Klare [4] names “The Third Carbon Age: The Age of Unconventional Oil and Gas.” Klare bases a number of his findings on a November 2012 report by the International Energy Agency (IEA) that states that our energy demands led to government subsidies for fossil fuels totalling $523 billion in 2011 [5]. Coal alone has met the need of almost half of the rising energy demands in the past 10 years. Similarly to the IPPC report, the IEA report states that actually realizing energy efficiency is not related to unprecedented technological discoveries, but rather on “taking actions to remove the barriers obstructing the implementation of energy efficiency measures that are economically viable” [5]. The key is to change the incentives in decision-making processes. As a student of Environmental Impact Assessment (EIA), I believe that impact assessment can play a pivotal role in the process towards shaping energy policy decisions. The incorporation of energy efficiency priorities and overall sustainability into impact assessment is absolutely integral to our ability to move towards sustainable energy.

World’s total energy use projected through 2013 – more and more energy will be accounted for by renewable energy sources.
(Source: http://www.motherjones.com/blue-marble/2013/04/charts-renewable-energy-fossil-fuels, provided by BNEF)

The pressure to include sustainability thought processes within EIA has been the subject of much research. Pope, et al. [6] discuss the importance of performing an ‘assessment for sustainability,’ in order to actually determine whether a plan is sustainable. Its purpose is simple: to unambiguously answer the closed-question of whether or not a policy or plan is sustainable. The guidelines for a sustainability assessment should be created in a top-down manner: determining what it means to be sustainable, and then identifying principles that represent this objective. The authors find that when sustainability assessment is incorporated within EIA, it tends to be through bringing in the thinking of economics, environment and society, and then attempting to reduce negative effects to all three. This results in an inherent competition and the acceptance that that trade-offs are necessary. However, since this is at a project level, the overall goal of sustainability at the level of society is never addressed. At this point a project has already been decided on and you are dealing with tweaking the details of a potentially inherently unsustainable project.

Strategic Environmental Assessments (SEAs) are used to assess the impacts of plans and policies in order to guide decision-making processes. If countries are serious about making changes to their environmental policies and promoting the development of sustainable energy, an SEA is an important tool that could be used to give an all-encompassing picture of the status of energy resources nationally. This information would in turn be used to inform project choice and implementation, as well as the EIA process of projects. As Hugé et al state [7], “the appeal of impact assessments lies in their systematic, stepwise approach and in their contribution to generate ‘order out of chaos,’” (p. 6247). I particularly like this notion of EIA, and think that it encompasses the principle that we must lay everything out on the table in order to make clear guidelines on environmental policy. While it is true that investment from the private sector is immensely important in the move towards sustainable development, SEA is an important tool to help countries put in place policies that will act as a catalyst for this change.

———————-

References

[1] Goldenberg, S. 2013, Jan 14. “Why We Need to Triple Clean Energy Investment.” Mother Jones. Web. 21 Jan 2013. Retrieved from: http://www.motherjones.com/environment/2014/01/un-climate-chief-christiana-figueres-triple-clean-energy-investment

[2] McDonnell, T. 2013, Apr. 22. “Charts: The Smart Money Is on Renewable Energy.” Mother Jones. Web. 21 Jan. 2013. Retrieved from: http://www.motherjones.com/blue-marble/2013/04/charts-renewable-energy-fossil-fuels

[3] IPCC. 2011. PRESS RELEASE: Potential of Renewable Energy Outlined in Report by the Intergovernmental Panel on Climate Change. Retrieved from: http://srren.ipcc-wg3.de/press/content/srren-press-release-updated-version.pdf

[4] Klare, M. T. 2013, Aug. 8. “The Third Carbon Age.” The Nation. Web. 21 Jan. 2013. Retrieved from: http://www.thenation.com/article/175659/third-carbon-age#.

[5] IEA. 2012. World Energy Outlook 2012: Executive Summary. Retrieved from: http://www.iea.org/publications/freepublications/publication/English.pdf

[6] Pope, J., Annandale, D., Morrison-Saunders, A. 2004. Conceptualising sustainability Assessment. EIA Review. 24: 595-616.

[7] Hugé, J., Waas, T., Eggermont, G., Verbruggen, A. 2011. Impact assessment for a sustainable energy future—Reflections and practical experiences. Energy Policy. 39: 6243-6253.

EIA and Sustainable Development: Recommendations from the Entropy Law, and Life-Cycle Assessment (LCA)

Defining Sustainability…

The management of the Earth’s resources in a way that does not threaten the ability of future generations to use the same resources

-The Brundtland Commission Report

The problem of achieving sustainability lies in the challenge of today’s societies figuring out how to “provide for the well-being of future generations given [Earth’s] ecological constraints” [2].

Earth as a Closed System

Consumers may not think of the creation, use, and destruction of a product as a cyclical process when they pick it off a Wal-Mart shelf.

The fact is they should! And so should EIA practitioners with a project.

When one “throws something out”, where do they think they are throwing it out to? The Earth is a closed system, and the reality is that they are throwing it out into the environment. It may be temporarily contained by an impermeable landfill, or incinerated into gases which are released and diluted into the atmosphere… but is this truly eliminating the product? No.

Over long periods of time the landfills may leach, and the atmosphere will become even more saturated with incinerated chemicals. The solution to “disposal” of products or projects is to not think of is as “disposal” at all. It must be considered as a cyclical process with the natural environment as both source and sink.

We are responsible for keeping our sink clean.

Earth

Figure 1: Hierarchy of physical and economic systems, adapted from [2]

Thermodynamics: The Entropy Law

Our production levels far exceed the levels of the Earth to assimilate our used outputs [2], and this is a problem for sustainability.

The second law of thermodynamics, the Entropy Law, takes into account the irreversibility of using inputs from the natural environment [2].

All physical process convert low-entropy energy and materials into high-entropy wastes.

- McMahon and Mrozek, 1997, 504

The directionality of the entropy law states that over time, the world becomes more disordered, and entropy increases. McMahon and Mrozek (1997) argue that the entropy law will be the eventual constraint to economic growth, and thus to sustainability, under our current neoclassical economic theory.*

Limited resources

Once a product is disposed of and forgotten, consumers often concede that it is no longer their problem. This mentality has pocketed the Earth with massive waste piles. Societies are digging massive holes to pump unused, high-entropy refuse into. We are hoping to never have our waste cross our minds again.

That is, until we collectively realized that mineral resources are becoming scarcer. After all, “resources may appear abundant until shortly before they are exhausted” [2].

The big question: Which processes and tools could help achieve sustainability?

EIA

EIA practitioners are instructed to use EIA as a tool for improved planning and decision-making for activities which involve the natural and human environments. CEAA ensures Canadians that EIA regulatory mechanisms are in the business of sustainable development because they are used to assess impacts and to mitigate accordingly, always with the future in mind [1].

Life-Cycle Analysis

Just as its very name implies, Life-Cycle Analysis (LCA) “is a tool designed to evaluate the impacts of the production, use and waste management of goods”, or in other words, to evaluate goods from “cradle-to-grave” [5].

Thus, it is suggested that the EIA process should not only be about project development but also about acknowledging Life-Cycle Assessment of inputs and outputs required to operationalize and decommission these development projects.

LCA is flexible in that choices on how to proceed in LCA (i.e. specific methodologies) can be determined based on “the goal of an LCA study” as well as “on the scientific perspectives of the researcher or practitioners” [3].

So why could it not be used to assess large-scale projects and not just the “cradle-to-grave” of one product?

Bringing EIA, Entropy and LCA Together…

What EIA practitioners must do is ensure that the development of projects does not continue to proceed in a linear fashion. LCA can offer the tools to ensure this. By examining life-cycles of large scale projects and minimizing inputs and outputs, a minimum of entropy is created where the planet is no longer a wasteworld of our damaging practices.

As societies become more aware of the importance of EIA and its role in sustainable development, EA practitioners could help consumers become aware of the importance of LCA.

LCA is a strategy to further reduce environmental impacts, increase societal awareness of resource use (and disuse). It also adds to proponent accountability for environmentally sound project development.


*Under neoclassical economic theory, sustainability lies in technological capabilities and societal innovations; but over time, substitutability will be less possible as entropy increases and low-entropy inputs become scarcer [2].


Sources

[1] Canadian Environmental Assessment Agency. (2013a). Overview: Canadian Environmental Assessment Act, 2012. Retrieved November 17, 2013 from Canadian Environmental Assessment Agency: http://www.ceaa-acee.gc.ca/

(Note: At the time of retrieval the word “sustainability” was used on this webpage. It has since been modified (January 21, 2014) and the word omitted. This gives clear indication that EIA practitioners should be armed with knowledge and tools such as LCA to address sustainable development in EIA in the future.)

[2] McMahon, G. F., & Mrozek, J. R. (1997). Economics, entropy and sustainability. Hydrological Sciences Journal, 42(4), 501-512. doi: 10.1080/02626669709492050

[3] Rebitzer, G., et al. (2004). Life cycle assessment: Part 1: Framework, goal and scope definition, inventory analysis, and applications. Environment International, 30(5), 701-720.

[4] The World Commission on Environment and Development. 1987. Our common future. New York: Oxford University Press.

[5] Tukker, A. (2000). Life cycle assessment as a tool in environmental impact assessment. Environmental Impact Assessment Review, 20(4), 435-456.

Australia’s New Coalition Government Threatens EIA Standards

Prime Minister Tony Abbott of Australia assumed office September 18, 2013 (Source: http://www.smh.com.au/federal-politics/political-news/tony-abbott-names-his-new-ministry-20130916-2tujb.html)

Prime Minister Tony Abbott of Australia assumed office September 18, 2013
(Source: http://www.smh.com.au/federal-politics/political-news/tony-abbott-names-his-new-ministry-20130916-2tujb.html)

The new Liberal prime minister of Australia as of last month, Tony Abbott, is not exactly what one might call a steward to the environment.  Glancing through the Liberty Party of Australia’s website, amid the over 50 policies the coalition has developed, we see no “Policy for the Environment,” but rather many documents displaying the Party’s commitment to jobs, development, and trade at the cost of all else. Abbott would like to do away with essentially all of the current environmental programs in place and enact his Direct Action Plan, which would remove the Carbon Tax and devolve the power of environmental decision-making to the state level in order to do away with “unnecessary ‘Green Tape [1].’” These plans are worrisome for the country of Australia, especially from an Environmental Impact Assessment (EIA) perspective.

Currently, EIAs are dealt with at both the state and Commonwealth level. States have their own EIA regulations and projects that fall into one of eight categories are dealt with by the Commonwealth under the Environment Protection and Biodiversity Conservation Act (EPBC) of 1999. This applies to projects that impact endangered species, water resources, and World Heritage sites, among other things. These two processes run simultaneously, with bilateral agreements in place to streamline processes. In these cases the Commonwealth accredits state assessments if they are in accordance with Commonwealth standards [2, 3].

The Coalition’s new policy would allow state governments to opt into a deal of “one-stop-shop for environmental approvals,”[1] essentially ‘accrediting’ all state processes and making them the only approval necessary for projects to go through.  It is noted in the plan that this is “as the Business Council of Australia has recommended [1].” If the direct reference to business and development interests isn’t enough of a red flag, delving into the EIA practices at the state level, and recent squabbles over them, we see how problematic this policy is for Australia’s EIA standards.

In 2011, largely in a response to the proposal of 9 new mega-mines and 18 new coal ports along the coast of Queensland (Qld) abutting the Great Barrier Reef (GBR) (Figure 1), the state government amended EIA guidelines to “reduce ‘green tape’ burden [4].” Public funding of the Qld Environmental Defenders’ Office (a department that aided citizens in environmental cases) was slashed and approval processes that distinguished different kinds of activities, such as mining and petroleum exploration, were removed along with EIA requirements for a number of ‘environmentally relevant activities’ [4, 5].

Figure 1. Greenpeace map of proposed coal ports along the Great Barrier Reef Marine Park (Source:http://www.greenpeace.org/australia/Global/australia/images/2012/Climate/GBR_infographic_large.jpg)

Figure 1. Greenpeace map of proposed coal ports along the Great Barrier Reef Marine Park
(Source:http://www.greenpeace.org/australia/Global/australia/images/2012/Climate/GBR_infographic_large.jpg)

When the first coal project (the Alpha Coal Mine) was approved, UNESCO demanded a complete halt to development around the GBR pending an assessment of its over-all health [6]. Environmental indicators appeared down along the GBR and Gladstone Fishing Research Fund had found algal blooms and acidity variations in the water, as well as increased prevalence of disease in marine species [7]. The EIA performed by Queensland was broadly criticized for being deficient and “shambolic,” [8] in the words of Federal Environment Minister Tony Burke, merely pushing for the process to be approved in order for development to continue. The Federal government threatened to suspend bilateral agreements on EIA approvals and place the Commonwealth solely in charge of projects within their jurisdiction [8]. This resulted in a standoff between Burke (since replaced by Abbott) and Qld Premier Campbell Newman over EIA standards and processes [9]. Below is Australia’s Network Ten reporting on the public battle that ensued between Newman and Burke.

If the power of EIA is delegated purely to the state level, when state level processes are not up to international or national environmental standards, then there is a real danger of significant demise to the environment, and more specifically immediate threat to the Great Barrier Reef.  Abbott and Newman are proponents of coalmine projects, seeing the economic profit that they bring, and believe the coal companies are capable of providing adequate protection to the environment.  While it is not untrue that industry is capable of following environmental protection standards, their view begs the question of what industry’s incentives would be, or even where they would get their base knowledge of the environment from, if EIAs are brushed aside merely as an impediment to development. EIAs are fundamentally about proper consideration of the environment in planning and decision-making, with the overarching goal of working towards environmental sustainability [10]. The identification of potential impacts and subsequent mitigation of negative effects is inherently impossible of the EIA process is stunted in this manner.

These recent developments in Australia are disheartening for the consolidation of high EIA standards worldwide. It can be compared to Canada’s recent setbacks in EIA just last year, and a warning of how development over energy resources can significantly change the character of a nation. Australia and the world must really take note of these developments, and question whether they are in line with the environmental protection we should be providing to the world.

Author: Maya Kelty

————

[1] Liberal Party of Australia. The Coalition’s Policy for Resources and Energy. September 2013.

[2] “EPBC Act.” What Is Protected under the EPBC Act? Australian Government: Department of Energy, 16 Aug. 2013. Web. 4 Oct. 2013.

[3] “EPBC Act.” About Bilateral Agreements and How They Work. Australian Government: Department of Energy, 30 July 2013. Web. 4 Oct. 2013.

[4] “Client Update: Queensland Reforms Reduce ‘green Tape’ Burden.” Allens, 28 Oct. 2011. Web. 4 Oct. 2013.

[5] AAP. “Government Takes Razor to Environmental Defender’s Office.” Brisbane Times, 5 July 2012. Web. 4 Oct. 2013.

[6] Milman, Oliver. “Australian ‘mega Mine’ Plan Threatens Global Emissions Target.” The Guardian, 18 Sept. 2012. Web. 4 Oct. 2013.

[7] Neubauer, Ian L. “Massive Port Projects Threaten Integrity of Australias Famed Great Barrier Reef Comments.” Time World, 23 Sept. 2013. Web. 4 Oct. 2013.

[8] Cullen, Simon. “Burke Slams ‘shambolic’ Reef Mine Approval.” ABC News Australia, 6 June 2012. Web. 4 Oct. 2013.

[9] Alberici, Emma. “Qld Wanted to Lower Environmental Standards.” Lateline Australia. Australian Broadcasting Corporation, 27 Aug. 2012. Web. 4 Oct. 2013.

[10] Noble, Bram., 2008. Introduction to Environmental Impact Assessment: A Guide to Principles and Practice, Second Edition. Toronto: Oxford University Press.

Enbridge and the lack of risk management

Suncor refinery in East-Montreal. (credit: David Vilder)

Suncor refinery in East-Montreal. (credit: David Vilder)

Enbridge 9B. This name should ring a bell as it is everywhere in the media these days.

Enbridge, based in Alberta, is seeking approval from the National Energy Board (NEB) to reverse the flow and increase capacity of the pipeline from 240 000 to 300 000 barrels a day. The 9B section in question goes from Hamilton to Montreal and is part of a broader line that links Alberta to the Atlantic. According to Enbridge this project is a “critical step in ensuring Quebec’s future in refining and petrochemical industries”; it will safeguard over a thousand permanent jobs and generate substantial taxes revenues for municipalities (Enbridge, 2012).

The project has received strong support from Suncor, who operates the Montreal-East refinery as well as from the government of Quebec (Shields, 2013). Both Enbridge and Ultramar (operating the refinery in Levis) registered lobbyists in Quebec to improve social acceptability (Shields, 2013).  Both Premier Marois and the Minister of Sustainable Development, Environment, Wildlife and Parks (MDDEFP) Yves-François Blanchet have been promising ‘consultations’ for months, yet now a few months before the first barrels are supposed to flow nothing has been done (Nadeau, 2013).

Enbridge's 9B pipeline

Enbridge’s 9B pipeline

Facing the government’s inaction, municipalities in Quebec have voiced their concern and on April 22nd 2013 the City of Montreal formally asked for an Environmental Impact Assessment (EIA) and a public hearing to be conducted by the MDDEFP (City of Montreal, 2013). That demand has yet to be answered (Côté & Croteau, 2013).

In Canada, pipelines fall under federal competence through the NEB. Critics argue that recent amendments to the National Energy Board Act through omnibus Bill C-38 gave the NEB power to screen potential participants from public hearings (Ruby, 2013). Ottawa’s support to Enbridge is the most heard open secret, especially after the Keystone XL and Northern Gateway pipelines (Shields, 2013).

However, there is still room for leverage from the provinces. Unless deemed frivolous, article 31.3 of Quebec’s Law on the Quality of the Environment (Loi sur la qualite de l’environnement) requires the government of Quebec to hold public hearings if formally asked by a municipality, person or group. In Ontario, where line 9B also faces strong opposition, the 2006 Clean Water Act could be used to require an independent EIA. Last August, Premier Kathleen Wynne strongly came against Enbridge and threatened to do a separate EIA if the project still showed environmental concerns (CBC, 2013).

One might argue why conduct another EIA when the NEB has already done one? A brief look at the actual report gives some hints. Three issues have been voluntarily left out of the scope. First, the impact of the 12% increase of production is left unaccounted for. The same goes for the increase of CO2 emissions in Quebec that will result from the extra supply. Third, and perhaps most importantly, effects from potential spills are completely ignored (Stantec, 2013).

Whistle-blower John Bolenbaugh wades through thick mud in the Kalamazoo River looking for leftover traces of oil from the July 2010 Enbridge tar sands pipeline spill.      John W. Poole/NPR     John Bolenbaugh stands in a forested stretch of the Kalamazoo River that borders a mobile home community in Battle Creek, Mich.     John Bolenbaugh stands in a forested stretch of the Kalamazoo River that borders a mobile home community in Battle Creek, Mich.     John W. Poole/NPR     Oil rings on trees only 50 feet from the nearest home show the height of the oil and water, and its proximity to the Baker Estates Mobile Home Park in Battle Creek.     Oil rings on trees only 50 feet from the nearest home show the height of the oil and water, and its proximity to the Baker Estates Mobile Home Park in Battle Creek.     John W. Poole/NPR     Michelle BarlondSmith and her husband lived in a riverfront trailer park. BarlondSmith says the sickening fumes from the oil lasted for months.     Michelle BarlondSmith and her husband lived in a riverfront trailer park. BarlondSmith says the sickening fumes from the oil lasted for months.     John W. Poole/NPR     One of dozens of houses along the Kalamazoo River sits empty since the spill. Enbridge offered to buy up most of the property along the river immediately after the spill, and most residents sold at deflated prices to escape the area.     One of dozens of houses along the Kalamazoo River sits empty since the spill. Enbridge offered to buy up most of the property along the river immediately after the spill, and most residents sold at deflated prices to escape the area.     John W. Poole/NPR     Children fish at a newly opened recreational area built by Enbridge on the Kalamazoo River. Posted signs warn that most of the fish is not safe to eat. These children were not aware of the oil spill and were not area residents.     Children fish at a newly opened recreational area built by Enbridge on the Kalamazoo River. Posted signs warn that most of the fish is not safe to eat. These children were not aware of the oil spill and were not area residents. (John W. Poole/NPR)

Whistle-blower John Bolenbaugh wades through thick mud in the Kalamazoo River looking for leftover traces of oil from the July 2010 Enbridge tar sands pipeline spill. (credit: John W. Poole/NPR)

From an EIA perspective, a pipeline is the perfect example of the need for scenario analysis. One of the main functions of this is risk management, and Enbridge’s performance with the latter is less than mediocre. In 2010 a rupture in the company’s line 6B spilled over 3.3 million litres of oil in the Kalamazoo River in what would be the largest onland spill in the history of the Unites States (Paris, 2013). Three years after the cleanup is still not complete. What’s more, between 1999 and 2010 over 800 spills occurred on Enbridge’s pipelines and almost all of the company’s pumping stations were recently deemed non-compliant by the NEB itself (Gignac & Schepper, 2013).

One wonders why the NEB insists on leaving potential spills out of the scope when Enbridge has such a history.

Whatch this video from the Off Island Gazette where The mayor of Ste-Justine-de-Newton, Patricia Domingos, explains how Enbridge has offered communities living near its pipeline donations to improve their emergency responder services.

Bibliography:

CBC. (2013, August 29). Pipeline   d’Enbridge : l’Ontario hausse le ton. Retrieved October 05, 2013, from CBC:   http://www.radio-canada.ca/regions/ontario/2013/08/28/016-enbridge-pipeline-wynne.shtml

City of Montreal. (2013, Avril 22). Déclaration.   Retrieved October 05, 2013, from   http://www.google.ca/url?sa=t&rct=j&q=&esrc=s&source=web&cd=3&cad=rja&ved=0CEMQFjAC&url=http%3A%2F%2Ffiles.newswire.ca%2F643%2FEtude_Enbridge.pdf&ei=qLhQUr6FNsni4AOAkYGADw&usg=AFQjCNGNV-nADLmC818YOeXa4vkhI1oVqQ&bvm=bv.53537100,d.dmg

Côté, C., &   Croteau, M. (2013, Octobre 02). Oléoduc 9 d’Enbridge: le débat s’enflamme.   Retrieved October 05, 2013, from La   Presse:   http://www.lapresse.ca/environnement/pollution/201310/02/01-4695449-oleoduc-9-denbridge-le-debat-senflamme.php

Enbridge. (2012). Enbridge’s Line 9 Pipeline:   Open House. Calgary: Enbridge.

Gignac, R., & Schepper, B. (2013). Projet d’oléoduc   de sables bitumineux « Ligne 9B » : le Québec à l’heure des choix. Montreal:   Institut de recherche et d’informations socio-économiques (IRIS).

Nadeau, J. (2013,   Octobre 04). Ligne 9B d’Enbridge – Il y aura consultation, assure le   ministre. Le Devoir.

Paris, M. (2013, September 2013). Enbridge’s   Kalamazoo cleanup dredges up 3-year-old oil spill. Retrieved October 06,   2013, from CBC: http://www.cbc.ca/news/politics/enbridge-s-kalamazoo-cleanup-dredges-up-3-year-old-oil-spill-1.1327268

Ruby, C. (2013, August 18). Harper government   unfairly limits public input on Enbridge pipeline. Retrieved October 05,   2013, from The Star: http://www.thestar.com/opinion/commentary/2013/08/18/harper_government_unfairly_limits_public_input_on_enbridge_pipeline.print.html

Shields, A.   (2013, September 11). Inversion du pipeline – Enbridge se félicite de   l’ouverture du Québec. Le Devoir.

Stantec. (2013). Line 9B Reversal and Line 9   Capacity Expansion Project – Environmental and Socio-Economic Impact   Assessment – Addendum. Calgary: Enbridge.

Should economic development trump environmental assessment – the example of the Port-Daniel-Gascons Cement Plant

On September 3rd 2013 the Premier of Quebec, Pauline Marois, announced that the Port-Daniel-Gascons cement plant would not have to be submitted to an environmental review by the Bureau d’audiences publiques sur l’environnement (BAPE), allowing construction of the near billion dollar project to begin by the end of the year (Haroun, 2013).  The PQ government and the proponent of the plant, McInnis Cement, state that the project will meet all environmental regulations and “be a model of environmental performance” (McInnis Cement, 2013).  More importantly its construction and operation will create 400 to 600 direct and indirect jobs over the next 2 years in a chronically depressed area of the province.  Local ecologists are dismayed at the decision to exclude this project from the BAPE as it will be responsible for more than 2 million tons of Green House Gas emissions per year once in operation (Haroun, 2013), increasing Quebec’s GHG emissions from industry by 10% alone.

Yet again the role of the environmental assessment process has been misunderstood by Quebec politicians and the business community for short-lived regional economic development and short-term political gain.  While it is true that this project was submitted to the government for approval before June 22, 1995, when the environmental rules governing such developments were strengthened (Haroun, 2013), the magnitude of the impacts of this project should have played a more important role in the decision making process.

Environmental assessment is a crucial part of the decision making process for the carrying out of a project.  It is a process that is supposed to identify and predict the impacts of a project, find ways to minimize or avoid negative impacts, enhance and create positive impacts, and ensure that the environmental consequences of development decisions are fully understood (Noble, 2008).  It is a tool for a sustainable future, not a hindrance to development.  In Quebec, for over 30 years the BAPE has been tasked with conducting public reviews of projects that have significant impact on the environment (BAPE, 2009).  The BAPE procedures for public consultation are regarded as some of the best in the world – both impartial, and fair to all parties involved.

One may ask why the Port-Daniel-Gascons cement plant should be reviewed by the BAPE, as it appears to have met all legal requirements for its approval and construction.  First, it will be the largest cement plant in Quebec and one of the largest in the world.  Second, it will use fuels that will lead to a significant increase in CO2 emissions for the whole province – contrary to Quebec’s policy on GHG emission reduction (Ministère du Développement durable, de l’Environnement, de la Faune et des Parcs, 2013), and in the future they may use alternate fuels, such as tires, that will have more environmental impacts.  While the project proponent states that it meets all requirements for emissions they omit the fact that those limits are voluntary (CCME, 1998).

592414-site-cimenterie-port-daniel-investissement

La Presse, 2012

Cement kilns, the heart of any cement plant, need a large supply of high energy content fuel to maintain the very high temperatures required for the conversion of limestone into the intermediate product that becomes the primary component of Portland cement (Chen et al, 2010; Van Oss & Padovani, 2002).  Every ton of cement produced needs approximately 1.25  tons of limestone, 1/3 ton of clay, 200 litres of water, and 450 kg of petroleum coke (the proposed fuel) (Chen et al, 2010).   The process produces significant emissions of particulates (dust and smoke) and gases with CO2 having the largest impact (Van Oss & Padovani, 2002).  In the case of the Port-Daniel-Gascons plant, the source fuel that McInnis has chosen, petroleum coke has a significant environmental impact of its own.  Petroleum Coke, or Petcoke, is a by-product of the refining process of petroleum (IUPAC, 1997).  It is high in carbon content making it a suitable fuel for the high temperatures (1450 to 1500 degrees Celsius) needed inside a cement kiln.  Alternative fuels for cement plants include: coal, oil, natural gas, and various waste products such as tires.  The same high temperatures allow for the destruction of hazardous waste – both biological (medical and animal processing), and chemical (Van Oss & Padovani, 2002).

The impacts of the GHG emissions alone should have warranted a review of the project, the economic and social impacts should not be overlooked.  The Port-Daniel-Gascons cement plant proposal is not new – it was first proposed in 1990, and had an abortive start to construction in the late 1990’s.  Despite the best efforts of successive provincial governments the project has not been started as the economic situation in the United States has been the main driver of the project (McInnis Cements, 2013).  Such a large cement plant cannot function economically within the Quebec economy – exporting to the world market is the only option for a viable operation.  With the current global financial and trade situation reliance on exports is a path fraught with uncertainties that offers no guarantees for the long term operation of the plant.  Might it become another Gaspésia fiasco?  For the sake of the Gaspe region one hopes not, but it is one aspect that a full BAPE review would put to rest.  Who will take responsibility for the environmental, economic, and social impacts after the political gains have long since disappeared?  Let’s hope the government sees the error of its ways and sends this project to a full review to the BAPE so that it can build a solid environmental legacy when other levels of government are failing to do that.

 

References:

Bureau d’audiences publiques sur l’environnement (BAPE). (2009). Plan stratégique 2008-2013, Québec, Bureau d’audiences publiques sur l’environnement.  Retrieved from: http://www.bape.gouv.qc.ca/sections/documentation/plan_strat_2008-2013.pdf

CCME (Canadian Council of Ministers of the Environment)(1998). National Emission Guideline for Cement Kilns. PN 1284. Winnipeg, Manitoba :CCME

Chen, C., Habert, G., Bouzidi, Y., & Jullien, A. (2010). Environmental impact of cement production: detail of the different processes and cement plant variability evaluation. Journal of Cleaner Production, 18(5), 478-485.

Haroun, T. (2013, September 3).  Port-Daniel-Gascons – Un projet de cimenterie d’un milliard échappe au BAPE. Ledevoir.com. Retrieved from : http://www.ledevoir.com/environnement/actualites-sur-l-environnement/386525/un-projet-de-cimenterie-d-un-milliard-echappe-au-bape

IUPAC ( 1997). Compendium of Chemical Terminology, 2nd ed. (the “Gold Book”). Compiled by A. D. McNaught and A. Wilkinson. Blackwell Scientific Publications, Oxford.

McInnis Ciment (2013). Retrieved from http://cimentmcinnis.com/projet-cimenterie-ciment-mcinnis

Ministère du Développement durable, de l’Environnement, de la Faune et des Parcs (2013), Inventaire québécois des émissions de gaz à effet de serre en 2010 et leur évolution depuis 1990, Québec, ministère du Développement durable, de l’Environnement, de la Faune et des Parcs, Direction des politiques de la qualité de l’atmosphère, 20 p.

Noble, Bram. (2008). Introduction to Environmental Impact Assessment: A Guide to Principles and Practice, Second Edition. Toronto: Oxford University Press

Van Oss, H., & Padovani, A. C. (2002). Cement manufacture and the environment. Journal of Industrial Ecology, 6(1), 89-106.

 

Applause to Cenovus Marketing and its Implications on Public Participation

Applause to Cenovus Marketing and its Implications on Public Participation

by Derek Davies

The below YouTube is of the Cenovus’ Future In Situ Drilling plans for the Alberta Oil Sands.

http://www.youtube.com/watch?v=j0vYTFve7tA

The video is certainly a work of art. Combining sources of Canadian identity, innovation, determination, persistence, and resiliency, with imagery of Canada’s beautiful and vast wilderness, the rocky mountains, sunlit forests – and the oil sands. Wait, what? Pardon? Is this a skit from The Onion?[i]

Almost had me Cenovus, I see what you did there. I will admit Cenovus is using innovative technologies such as Steam-assisted gravity drainage (SAGD) and their trademark SkyStrat drilling rig for in situ drilling that will potentially save the Albertan landscape by using drilling instead of open pit extraction.  However, while the aesthetics of in situ drilling are quite compelling, that does not mean they still will not affect the landscape and the environment; the oil still needs to be pumped back to a refinery and energy must still be supplied to the rig, creating large areas of fragmented forests (Pembina, 2010). As well as the fact that Cenovus will be, by the year 2021, the largest oil company in the Alberta Oil Sands market, producing over 500,000 barrels/day (Cenovus Energy, 2013). With the only method of in situ drilling, which creates almost triple the GHG and Sulphur Dioxide emissions, but uses half the amount of water as open mining, it is still considered to be a very unclean energy – and this is only drilling, this does not even take into account the process of refining bitumen into crude oil (Pembina, 2010).

Personally, I can see through this marketing scheme to the hilarity in which it really is – Greenwashing. In terms of Greenwashing, this commercial is Oscar worthy. The commercial, which is played before every movie across the country has you almost cheering for Cenovus for their innovation – no sorry, ‘our’ innovation as Canadians. Our innovation to find a way to drill 400 meters below the ground to be able to suck out bitumen in order to perpetuate our countries addiction to fossil fuels.  What about those others that cannot easily spot or see through this deception?

With respect to pubic participation in Environmental Assessment this will end up having drastic effects to public hearings and participation. Cenovus’ marketing strategy is clear, they want to stop negative backlash from the public. One way to achieve this is to target an early generation of people that do not know enough information to form an educated opinion on the oil sands.  This is an example of a classic theory of mass communication known as the theory of agenda-setting. By using mass media, a corporation can transfer core salience or prominent important issues of their agenda onto the public in hopes to shift public perception (Carroll & McCombs, 2003).

There are two major problems this strategy of agenda-setting that will affect public participation.

First, awareness of oil sand issues has been a driving force that makes Canadians doubt this enormous industry. Without outside sources coming from all over Canada and the world, the oil sands will become a localized problem. Issues concerning tailing ponds and water quality for communities along the Athabasca River are local problems people suffer with everyday. The oil sands are an incredibly obvious environmental scar on the province of Alberta; so large you can see it from space or on Google Earth. Yet, Cenovus applies a ‘green’ cosmetic in their commercials to hide the large disfigurement that is the oil sands. Without the globalized upheaval of this problem, less and less people will participle in EA hearings, comments, or they may not even bother to even pay attention to the oil sands at all. By shifting the agenda and the most the prominent issues away from Cenovus, it puts the company out of the media, where they are happy to be.

Second, the commercial discourse sends a message to Canadians that everything is ‘okay’. This marketing strategy desensitizes the general population. It “Greenwashes” or uses agenda setting effects in changing the publics opinion into believing that oil sands production is environmentally sound. Why would you ever need to protest, participate or question something that looks so beautiful and is so patriotic to our country? You probably wouldn’t protest, question, participate, and worst of all – you wouldn’t even be aware.

Painting a perfect picture deters people from asking questions. Should it not be the other way around? If something is too good to be true, it usually is.

Works Cited

Carroll, Craig E and Maxwell McCombs. “Agenda-setting effects of business news on the public’s image and opinion about major corporations.” Corporate Reputation Review 6.1 (2003): 36-46.

Cenovus Energy. “Cenovus – Canadian Ideas at Work.” Online Commercial.  YouTube. http://www.youtube.com/watch?v=j0vYTFve7tA. Youtube, 8 March. 2012. Retrieved: Sun. 6 Oct. 2013.

Cenovus Energy Inc. “Cenovus Energy: First Quarter 2013 Report.” Quarterly Report. Cenovus Energy, 2013.

Cenovus Energy. Operations: Technology: SkyStrat drilling rig. 22 10 2013 <http://www.cenovus.com/operations/technology/skystrat.html&gt;.

—. Operations: Technology: Steam-assisted gravity drainage (SAGD). 22 10 2013 <http://www.cenovus.com/operations/technology/sagd.html&gt;.

Dyer, Simon and Marc Huot. “Mining Vs. In Situ: What is the Highest Environmental Impact?” Fact Sheet. Pembina Institute, 2010.

Footnotes


[i] The Onion is an American news satire organization. It is an entertainment newspaper and a website featuring satirical articles reporting on international, national, and local news.