British Columbia releases long-awaited Climate Leadership Plan

On August 19, 2016, the BC government released its long-awaited Climate Leadership Plan, which updates the province’s earlier Climate Action Plan (2008). The plan follows the release of the government-appointed Climate Leadership Team’s (CLT) recommendations in November 2015 and sets out 21 actions to reduce emissions across five areas: (1) natural gas, (2) transportation, (3) forestry and agriculture, (4) communities and built environment, and (5) public sector.

The CLT had made 32 recommendations including, among others, the establishment of a mid-term 2030 greenhouse gas emissions reduction target and a reduction in the provincial sales tax from 7% to 6%, which would be offset by an increase in the carbon tax by $10 per year commencing in July 2018.  While the Climate Leadership Plan has been informed by some of the recommendations made by CLT and feedback received from the public and stakeholders, the plan focuses on actions that will enable BC to achieve its legislated target of reducing emissions 80% below 2007 levels by 2050. In so doing, the Climate Leadership Plan bypasses BC’s 2020 target of achieving a reduction in GHG emissions of 33% below 2007 levels. The BC government has declined to set a mid-term target and will keep the province’s revenue neutral carbon tax at $30 per tonne until the federal government’s approach to carbon pricing is revealed.

The key actions in the Climate Leadership Plan include the following:

Communities & Built Environment

  • Working together with local governments to refresh the Climate Action Charter, with a particular focus on: (i) growth near major transit corridors for large urban communities; (ii) increasing the use of decision support tools that provide the information needed to create more resilient green infrastructure; and (iii) strengthening the ability of communities to adapt to the impacts of climate change.
  • Amending regulations to promote more energy efficient buildings.
  • Creating a waste-to-resource strategy to reduce waste sent to landfill and establishing a food waste prevention target of 30% and increasing organics diverted from landfills to 90%.

Public Sector

  • Promoting the use of low carbon and renewable materials in public sector buildings.
  • Mandating the creation of 10-year emission reduction and adaptation plans for provincial public sector operations.

Transportation

  • Increasing the requirements for BC’s Low Carbon Fuel Standard to 15% by 2030 (it currently requires a reduction in the carbon intensity of transportation fuels by 10% by 2020 (relative to 2010)).
  • Amending regulations to encourage emission reductions in transportation by allowing utilities to double the total pool of incentives available to convert commercial fleets to natural gas, when the new incentives go towards vehicles using 100% natural gas.
  • Expanding support for zero emission vehicle charging stations in buildings through the Clean Energy Vehicle program.

Forestry & Agriculture

  • Rehabilitating under-productive forests, recovering more wood fibre, and avoiding emissions from burning slash; these actions will be taken through the new Forest Carbon Initiative, which will seek to increase the rate of replanting and fiber recovery by 20,000 hectares per year.

Industry & Utilities

  • Developing new energy efficiency standards for gas-fired boilers.
  • Facilitating projects that will help fuel marine vessels and commercial vehicles with natural gas.

Natural Gas

  • Developing a strategy to reduce upstream methane emissions, including targets for reducing fugitive and vented emissions from extraction and processing infrastructure (built before January 1, 2015) by 45% by 2025.
  • Investing in infrastructure to develop upstream electrification of several projects, including the Peace Region Electricity Supply Project, North Montney Power Supply Project and others.

The BC government has said that the Climate Leadership Plan is a living document that will be further updated over the coming year. The plan will likely be updated to reflect federal climate change policy developments once the working groups that were established at the First Ministers’ meeting in March 2016 report back in October 2016 (working groups were established to study (a) clean technology, innovation and jobs, (b) carbon pricing mechanisms, (c) mitigation opportunities, and (d) adaptation and climate resilience).

BC’s New GHG Reporting Framework came into force on January 1, 2016

In January 2010 British Columbia’s first mandatory GHG reporting regulation came into force. The Reporting Regulation specified that operations located in British Columbia and emitting 10,000 tonnes or more of carbon dioxide equivalent emissions (CO2e) per year (excluding emissions from biomass listed in Schedule C of the regulation) are required to report greenhouse gas (GHG) emissions (while reporting operations emitting 25,000 tonnes or more of CO2e per year have also been subject to a third party verification requirement).
As part of efforts to re-orient BC’s GHG regime and establish a framework for the developing liquefied natural gas (LNG) industry, the BC government passed the Greenhouse Gas Industrial Reporting and Control Act (the Act), which came into force on January 1, 2016. The Act introduces as part of the reporting performance standards that are set for industrial facilities or sectors by listing them within a Schedule to the Act. Currently, the Schedule sets GHG emissions benchmark for LNG facilities and includes an emissions benchmark for coal-based electricity generation operations. It is anticipated that other industrial facilities and sectors will be added later. The Act also streamlines several aspects of existing GHG legislation and regulation into a single legislative and regulatory system, including the GHG reporting framework established under the Greenhouse Gas Reduction (Cap and Trade) Act. Notably, three regulations necessary to implement the Act also came into effect on January 1, 2016:

  1.  Greenhouse Gas Emission Reporting Regulation – this regulation replaces the existing industrial Reporting Regulation and adds compliance reporting requirements.
  2. Greenhouse Gas Emission Administrative Penalties and Appeals Regulation – this regulation establishes the process for when, how much, and under what conditions administrative penalties may be levied for non-compliance with the act or regulations.
  3. Greenhouse Gas Emission Control Regulation – this regulation establishes the BC Carbon Registry and sets criteria for developing emission offsets issued by the BC government. The regulation also establishes a price of $25 for funded units issued under the Act that would go towards a technology fund to support the development of clean technologies. Regulated operations will need to purchase offsets from the market or funded units from government in order to meet their compliance obligations.

Under the new Greenhouse Gas Emission Reporting Regulation, industrial operations will continue to report GHG emissions as they have since 2010.

BC Climate Leadership Team Issues 32 Recommendations to BC Government

In May 2015, BC Premier Christy Clark appointed a Climate Leadership Team (consisting of leaders from B.C. businesses, communities, First Nations, academia and the environmental sector) to provide advice and recommendations to government for its new Climate Leadership Plan.
Following stakeholder consultations, the Climate Leadership Team prepared a report that was released by the BC government on November 27, 2015, in advance of the COP 21 meeting in Paris. The team’s report consists of 32 recommendations addressing a number of areas including GHG reduction targets, carbon tax design, transportation, buildings, communities, offsets, and First Nations.

Some of the key recommendations from the Climate Leadership Team include:

  • setting a legislated target for 2030 of 40% GHG reduction from 2007 levels, and reaffirming B.C.’s commitment to the 2050 target of an 80% GHG reduction from 2007 levels;
  • establishing the following sector-specific GHG reduction goals (below 2015) for 2030: (a) 30 per cent for the transportation sector totalling 6.3 MT of CO2; (b) 30 per cent for the industrial sector totalling 8.4 MT of CO2; and (c) 50 per cent for the built environment totalling 3.4 MT of CO2;
  • lowering the provincial sales tax (PST) from 7 per cent to 6 per cent, supported by incremental carbon tax;
  • increasing the carbon tax by $10 per year commencing in July 2018 while (a) maintaining the current tax reductions achieved through the existing carbon tax that are broad based, provide support to vulnerable populations, or promote GHG reductions; (b) adjust the current low income and rural and northern tax credits; and (c) establish targeted and transparent mechanisms for emission-intensive, trade-exposed sectors until such time that carbon pricing and regulatory policy equivalency with other jurisdictions is achieved;
  • expanding the coverage of the current carbon tax to apply to all GHG emission sources in BC after five years, starting with measurable GHG emissions covered by the current reporting regulation;
  • using incremental revenues generated from the increase in the carbon tax to (a) eliminate PST on all electricity rates; (b) establish mechanisms to facilitate investments in technology and innovation that reduce GHG emissions; and (c) establish mechanisms to provide local governments with funding for projects that will result in demonstrable GHG emission reductions;
  • amending the Clean Energy Act to increase the target for clean energy on the integrated grid from 93 per cent to 100 per cent by 2025;
  • establishing a strategy and funding to phase out diesel generation in remote communities and replace it with low-GHG electricity service by 2025;
  • developing a low-carbon transportation strategy to enable the transportation sector to emit 30 per cent fewer GHG emissions by 2030 which include Zero Emission Vehicle targets, increases to the scope and coverage of the Low Carbon Fuel Standard, and the establishment of a revenue neutral PST for all vehicles based on grams of Co2 per kilometre;
  • undertaking a review and update of the Climate Action Charter to align provincial and community goals;
  • creating a waste-to-resource strategy that reduces GHG emissions associated with food waste, organic waste, and landfills;
  • working with First Nation communities to transition communities that are currently dependent on diesel generation to low-GHG electricity service; and
  • undertaking a review of the current offset policy in BC.

The BC government is now reviewing the Climate Leadership Team’s recommendations. It will commence the public consultation process in January 2016, with a view to releasing a final Climate Leadership Plan in March 2016.

British Columbia joins Sub-National “Under 2 MOU” Climate Change Initiative

On May 19, 2015, British Columbia (BC) joined a new sub-national climate change initiative known as Under 2 MOU. The Under 2 MOU brings together states and regions willing to commit to reducing their greenhouse gas (GHG) emissions and will galvanize action at the Conference of the Parties (COP 21) in Paris this December. The founding signatories, who were present at the May 19 signing ceremony in Sacramento, California, include the following:
• Acre, Brazil
• Baden-Württemberg, Germany
• Baja California, Mexico
• British Columbia, Canada
• California, USA
• Catalonia, Spain
• Jalisco, Mexico
• Ontario, Canada
• Oregon, USA
• Vermont, USA
• Wales, UK
• Washington, USA
The Subnational Global Climate Leadership MOU is nicknamed “Under 2 MOU” in reference to (i) the goal of limiting warming to below 2°c, and (ii) the MOU’s shared goal of limiting greenhouse gas emissions to 2 tons per capita, or 80-95% below 1990 level by 2050. By joining the Under 2 MOU initiative, signatories also commit to establishing midterm targets, increasing energy efficiency and renewable energy, coordinating on a number of issues from transportation to short-lived climate pollutants, and working towards consistent monitoring, reporting, and verification of their emissions. All signatories will submit an appendix to the MOU that will outline their unique set of actions and plans to reach their goals.
The Under 2 MOU originated from a partnership between California and Baden-Württemberg out of the desire to bring together ambitious states and regions willing to make a number of key commitments towards emissions reduction and to help galvanize action at COP 21. Jurisdictions are invited to sign the MOU up to COP 21 in December. Interested jurisdictions are asked to submit a letter expressing their intent to sign on to the MOU and to complete an appendix that outlines the unique set of actions that are in place or planned to reach their emissions reduction targets.
According to the United Nations Development Program (UNDP), 50 to 80% of the mitigation and adaptation actions necessary to tackle climate change will be implemented at the subnational or local levels of governance. Subnational governments are particularly well placed to address climate change for a number of reasons, including:
• They are often responsible for the development and implementation of policies that have the most impact on climate change, including in the following areas: air quality; transportation; energy and energy efficiency; the built environment; natural lands; technology innovation, development, and transfer; and others that have direct implications for greenhouse gas emissions levels.
• Sub-national governments often serve as the laboratories for policy innovations which are then adopted at the national and even international level.
• Sub-national governments provide the critical link in the vertical integration of climate policies between national and local governments.

BC Restructures GHG Emissions Regulatory Framework in Light of LNG Projects

 
On October 20, 2014, Environment Minister Mary Polak announced the first part of a restructuring of BC’s GHG emissions regulatory framework with the release of Bill 2, also known as the Greenhouse Gas Industrial Reporting and Control Act. This piece of legislation will replace the Greenhouse Gas Reduction (Cap and Trade) Act that came into force on May 29, 2008. The restructuring will continue with the release of the relevant Regulations under the new Act once it is given Royal Assent and comes into force. These regulations will include a new GHG Reporting Regulation and a new Emission Offset Regulation. It is expected that the reporting thresholds in the new GHG Reporting Regulation and the resulting obligations thereunder will remain the same. Tim Lesiuk, Executive Director and Chief Negotiator at Climate Action Secretariat, emphasized in a technical briefing the importance and responsibility of companies assuming to be below the lowest reporting threshold of 10,000 t CO2e annually (called non-reporting entities), to also monitor and document their GHG emissions in order to mitigate the risk of regulatory non-compliance and provide proof of their status as a non-reporting entity in case of an inspection.
A new Emission Offset Regulation is expected to offer an independent offset certification process from the BC Government’s Carbon Neutral purchase program. This will be achieved through a new certification and registry system. The BC Government’s existing Carbon Neutral purchase program conducted by the Climate Investment Branch will continue, but they will source their offsets from the new certification and registry system. Existing offset purchase contracts are expected to be grandfathered into the new system.
The functional new aspect in Bill 2 is the introduction of a new carbon intensity performance requirement. This carbon intensity performance target, called Regulated Operations’ Emission Limits in the Act is an additional requirement beyond the reporting obligation that only applies to industries that are listed in the Schedule of Regulated Operations and Emission Limits in the Act.
The only two listed industries so far are coal-based electricity generation operation with a limit of 0 tonnes carbon dioxide equivalent emissions and liquefied natural gas operations with a limit of 0.16 carbon dioxide equivalent tonnes for each tonne of liquefied natural gas produced. However, additional industries may be added and the BC Government has indicated that it will be announcing climate change measures in other sectors going forward.
The emission target carbon intensity performance quantification is limited to the facility level and therefore does not include any upstream or downstream emissions outside of the facility boundary. In order to meet their obligations, regulated entities with prescribed emission limits will have several compliance mechanisms available to them. In particular, they can:
• improve energy efficiency or increase the use of clean electricity through facility design;
• acquire emissions offsets by investing in BC-based emission reduction projects at market prices; or
• contribute to a technology fund at a rate of $25 per tonne of CO2e.

Besides setting up a new technology fund, Bill 2 also requires the establishment of a registry for the purposes of the Act. This registry will be the only place where offset units and earned credits, resulting from performance below the emissions limit, are tracked. This is also the only place where transactions under the Act can be executed for compliance purposes.
If you have any questions about Bill 2 and the proposed changes to the BC emission offset regime or their potential impacts on your operations or offset project, please contact GHG Accounting Services.
 

BC signs Climate Action Plan with California, Oregon and Washington

 
On October 28, 2013 the leaders of British Columbia, California, Oregon and Washington signed the Pacific Coast Action Plan on Climate and Energy committing their governments to a comprehensive and strategic alignment to combat climate change and promote clean energy. The region covered by the Action Plan has a combined population of 53 million people and a GDP of $2.8 trillion, which represents the world’s fifth largest economy.

Through the Action Plan, all four jurisdictions will account for the costs of carbon pollution and where feasible, link programs to create consistency and predictability across the region.  In addition, the Action Plan provides for the following actions:

  • harmonizing 2050 targets for greenhouse gas (GHG) reductions and developing mid-term targets needed to support long-term reduction goals;
  • cooperating with national and sub-national governments around the work to press for an international climate change agreement in 2015;
  • enlisting support for research on ocean acidification and taking action to combat it;
  • adopting and maintaining low carbon fuel standards in each jurisdiction;
  • taking action to expand the use of zero-emission vehicles, aiming for 10% of new vehicle purchases by 2016;
  • continue deployment of high-speed rail across the region;
  • supporting emerging markets and innovation for alternative fuels in commercial trucks, buses, rail, ports and marine transportation;
  • harmonizing standards to support energy efficiency on the way to “net zero” buildings;
  • supporting federal policy on regulating GHG emissions from power plants;
  • sponsoring pilot projects with local governments, state agencies and the West Coast Infrastructure Exchange to make infrastructure climate smart;
  • streamlining approval of renewable energy projects; and
  • supporting integration of the region’s electricity grids.

The Action Plan provides a much needed boost to regional and national efforts climate change policy efforts.

The Pacific Coast Collaborative was established in 2008 to address the unique and shared circumstances of the Pacific coastal areas and jurisdictions in North America by providing a formal framework for co-operative action, a forum for leadership and the sharing of information on best practices, and a common voice on issues facing coastal and Pacific jurisdictions.
 

California Holds Successful First Auction of Carbon Allowances

 
The California Air Resources Board (CARB) held its first auction on November 14, 2012 for the purchase and sale of carbon allowances for its planned cap-and-trade regime. Mary Nichols, chairman of CARB, declared the auction a success:

“The auction was a success and an important milestone for California as a leader in the global clean tech market. By putting a price on carbon, we can break our unhealthy dependence on fossil fuels and move at full speed toward a clean energy future.  That means new jobs, cleaner water and air – and a working model for other states, and the nation, to use as we gear up to fight climate change and make our economy more competitive and resilient.”

The auction results were released to the public on November 19th (available online) .  A tonne of carbon for the 2013 vintage year sold for $10.09, which is slightly above the $10.00 price floor set by CARB. The highest bid was a whopping $91.13.  Also, there was three times the number of bidders at the auction than actual buyers, indicating a healthy and competitive market. Furthermore, 97% of allowances were purchased by regulated entities indicating that prices were not influenced by speculative buyers. Instead, it seems to indicate that regulated entities are looking to retire allowances for compliance purposes.  Perhaps most importantly, the auction sold out with all 23,126,110 2013 vintage year allowances being purchased, raising approximately US$233 million. This auction kicks off the largest carbon market in North America and the second largest in the world, behind the European Union Emissions Trading Scheme.

California’s partners in the Western Climate Initiative (WCI) – including British Columbia, Manitoba, Ontario, and Québec – are no doubt paying close attention.  Apart from Québec, which will launch its emissions trading system on January 1, 2013 with California, the success of California’s cap-and-trade program may spur the other WCI partners into action to implement a similar scheme.

 


BC Announces New Funding for Public Sector Carbon Neutral Commitments

 
On April 5, 2011, Environment Minister Terry Lake announced a new $5 million capital program that will be available to school districts for energy-efficiency projects to lower their carbon emissions. The provincial government indicated that this funding reaffirms its commitment to being the first carbon-neutral government in North America.

Starting in 2012/13, the new K-12 energy-efficiency capital program will be available to boards of education through the Ministry of Education. The amount of available funding has been set to be equal to or greater than the total paid by school boards each year for purchases of carbon offsets from the Pacific Carbon Trust (PCT).

In addition to the new funding, the following program enhancements for all public sector organizations were announced:

  • SMARTTool administration costs will no longer be charged to public sector organizations, resulting in $850,000 of cost savings that will be absorbed by the PCT.
  • To ensure the PCT’s offset portfolio meets the needs of stakeholders, the PCT will create an advisory panel. The panel will play an ongoing role in reviewing the structure and diversity of the carbon offset portfolio and provide suggestions regarding future offset opportunities. The panel will include representatives from the private and public sectors that purchase offsets from PCT, as well as select carbon-industry experts.
  • To streamline the current system, a link will be established that will feed energy data directly into the SMARTTool to reduce administrative costs associated with measuring emissions.

Under BC’s Carbon Neutral Regulation of the Greenhouse Gas Reduction Targets Act, certain public sector organizations were required to be carbon neutral by 2010. In June 2011, it was announced that BC had become the first major jurisdiction in North America to achieve carbon neutral operations as of 2010. This means that BC’s public sector including schools, post-secondary institutions, government offices, Crown corporations and hospitals have all achieved net-zero greenhouse gas emissions.

 


 

Revisions to BC Reporting Regulation now in force for 2011 Reporting Year

Recent amendments made to BC’s greenhouse gas Reporting Regulation have come into effect for 2011 calendar year emission reports (to be reported by March 31, 2012)

The amendments made in order 849 dated 17th of December 2010 to BC’s greenhouse gas Reporting Regulation have come into effect for 2011 calendar year emission reports (to be reported by March 31, 2012). These amendments include:

  • Establishment of a third class of reporting operation – electricity import operation – for the purpose of including imported electricity under the regulation.
  • Establishment of a reporting-only class of emissions for the purpose of including aboveground coal mine fugitive emissions, along with mobile equipment and carbon dioxide from Schedule C biomass sources.
  • Miscellaneous improvements including: (i) addition of further requirements to ensure that changes between methods on the part of reporting operations will result in improved emissions estimates; (ii) clarification on handling of terminals/storage tanks; (iii) addition of red liquor to Schedule C; and (iv) an update of quantification method references to incorporate new and revised quantification methods developed by the Western Climate Initiative.
  • Various changes to data to be reported, including: (i) addition of Income Tax Act business numbers, DUNS and Bradstreet numbers to reports; and (ii) addition of process flow diagrams to reports starting in 2012.
  • Clarifications have been made to site visit requirements for linear facility operations and changes have been made to the required contents of verification statements.

Additional updates to the Reporting Regulation may be introduced by the government based on the proposed Emissions Trading Regulation and Offsets Regulation, which are expected to be finalized in 2011. These changes could include further reporting-only sources, additions to the Schedule C list of biomass, and additional verification and compliance requirements.