Abolition of Coal-Fired Plants: Official Submission - Ont. Reg. 496/07 and Amendment -Implementation of Coal Emissions Reduction

“Carbon dependence has eroded our economic power, destroyed our moral authority, diminished our international influence and prestige, endangered our national security, and damaged our health and landscapes. It is subverting everything we value.”
http://files.tikkun.org/current/article.php?story=2008041309...

Robert F. Kennedy Jr.
Manifesto - May 2008

Ivona Vujica, Coordinator
Paradigm Shift Environmental Alliance
Ottawa, Canada
psea4earth@gmail.com

Public Review and Comment May 16 - June 15, 2008
Ontario Regulation 496/07 (Coal Cessation) and Amendment ( Implementation of Coal Emissions Reductions)

Contents:

Summary...............................................................................p.2

Terminology...........................................................................p.2
The possibility of clean coal not eliminated
“Emissions” talk matches the absence of talk on “clean coal.”
OPG: “no plan to shut coal plants”

Wording of the Amendment Unclear...............................................................................p.4
Slashing emissions or capping their increase: which one?

Survival..............................................................................p.4
What future?

Worsening of Global Warming, War and Conflict, Environmental Destruction and Ill Health effects...............................................................................p.4
Multiple-site fossil fuel burning at home and abroad for our energy in times of Global Warming
Ontario blowing up Appalachia mountains for its coal-fired plants

Ontario Regulation 496/07 & its Amendment.............................................................................p.7
“A positive step” - unbelievable! Renewable alternatives not in place!

At any time, especially in times of “emergency” - trumped!..............................................................................p.7
Head on to economic, humanitarian, environmental disasters, with more coal, of course
Fever pitch: More natural gas means more coal
Action pacifier

Some Notes on Renewable Energy in Ontario..............................................................................p.9
Subsidized for the rich, what about the rest of us?

+ Summary

With current and projected heavy reliance on least energy secure and most expensive fuels – fossil (natural gas) and radioactive fuels, Ontario risks turning to more coal, not less. There is a lack of clarity in the wording of the Amendment to Ontario Regulation 496/07. This lack of clarity opens up possibilities for the rise of coal use. The Amendment needs to be rewritten. It should state in simple and clear language what the goal is and how it is to be achieved referencing all currently existing coal terminology.

People of Ontario should approach the Regulation and its Amendment with extreme caution. We don't have time to wait and see what will come of this legally binding third promise by the McGuinty's Government.

Without cessation and in unison, we must continue demanding a Fully Green Ontario and a complete phase-out (abolition of coal-fired plants) and fossil and radioactive burning for our energy without delay.

It has already been proven that the McGuinty Government could have phased out coal-fired plants by 2007 but in fact just continued exporting energy from coal-fired plants to the U.S. Leaving Ontarians with all the ill effects to our health and the environment, our public health system continuing to absorb the hidden costs of coal. Then it was proven that the coal-fired plants could be phased out by 2010, the toxic carousel goes 'round and round with Ontarians and ultimately the earth paying the ultimate price.

+ Terminology

The possibility of clean coal not eliminated

Under Environmental Protection Act, Ontario Regulation 496/07 called “Cessation of Coal Use” says that “[t]he owner and the operator” of Ontario coal-fired plants “shall ensure that coal is not used to generate electricity at the generating station after December 31, 2014.

“Cessation of Coal Use” Ontario Regulation 496/07 is about ensuring that “coal” is not used.
In itself, it does not ensure that “clean” coal is not used, therefore keeping the door open to indefinite extension of coal-fired plants through the possibility of using of the term “clean” to describe coal. “Clean” coal refers to carbon capture and sequestration rhetoric, which may be used to justify and prolong coal burning in Ontario. Failing to mention “clean” coal, introduces the possibility for using this terminology at a later time to upgrade the game of coal to the level where existing coal-fired plants not only would not close down but would receive public funding for pursuing “innovative” approach to emissions reductions.

“Emissions” talk matches the absence of talk on “clean coal.”

Ontario Regulation called “Implementation of Coal Emissions Reductions” made under Environmental Protection Act Amending O. Reg. 496/07 is about an “Interim Cap on CO2 Emission,”and says that “[b]eginning on January 1, 2011, the owner and the operator” of all Ontario coal-fired plants “shall ensure that the generating stations do not collectively emit more than 11,5 megatonnes of CO2 from the use of coal in any calendar year.”

In terms of terminology, this Amendment waters down O.Reg 496/07 talking about reducing “emissions” from coal-fired plants rather than eliminating “coal burning”, “phasing out coal-fired plants” or “coal cessation.”

The terms and phrases such as “phasing out of coal-fired plants,” “phasing out of coal burning,” and “coal-fired plants emissions reductions” differ from each other and are incompatible when it comes to achieving the goal of closing down coal-fired plants.

“Phasing out of coal-fired plants” is different from “phasing out of coal burning.” The latter term means that something else will be burnt in the plants which used to serve as coal-burning plants – maybe gas; maybe garbage.

Both “phasing out of coal-fired plants” and “phasing out of coal burning” differ from “coal emissions reductions / cap on CO2 emissions.” Putting cap on coal burning emissions does not necessarily lead to phasing out of coal-fired plants or coal burning. The use of “emissions” terminology in fact may open the door to indefinite extension of coal-fired plants.

There are a few rhetorical devices used by fossil fuel burning proponents for dealing with “emissions” of coal-fired plants. Some of them are “clean coal” or “carbon capture and sequestration,” “coal gasification” and “cap and trade.” All of these claim to be able to reduce emissions from coal-fired plants. However, the opposite is achieved from the goal of closing down coal-fired plants.

At this time, it is not clear how the Ontario Government will go about reducing coal emissions. The sound of this alarm is amplified by the Ontario Power Generation's assertion that there is “no plan to shut coal plants.”

“Carbon capture and sequestration” has for many decades been in existence and used by the oil industry on very small scale for enhanced recovery of oil. Every reliable source from government to industry to scientists puts at the earliest date for commercial scale carbon capture and sequestration 2020 to 2025. This, of course, is the most optimistic scenario as it does not exist. Its commercialization phase has already failed in Saskatchewan Canada and the Battelle Memorial Institute FutureGen National U.S. project. On which President Bush and the U.S. Department of Energy pulled the plug earlier in the year 2008

“Energy Secretary Scraps FutureGen Clean Coal Project”
http://www.ens-newswire.com/ens/jan2008/2008-01-31-03.asp

The Saskatchewan, Canada – Battelle Memorial Institute etc. giant (clean) coal mega project has been scrapped because of soaring costs. Originally it was $1 billion and is now projected to be $3.8 billion to produce 450 megawatts, but everyone knows the science and technology is on very unstable grounds. The financial risk is too high. The threat to the eco-system is even higher by the continued maintenance of coal mining and coal-fired plants locally and globally. www.theglobeandmail.com/servlet/story/LAC.20070907.RSASKPOWE...
http://quebec.indymedia.org/en/node/28427

OPG: “no plan to shut coal plants”

It is left up to Ontario Power Generation to come up with a plan by November on how to cap emissions beginning next year (Toronto Star May 17, 2008 - Rob Ferguson).

"We don't have plans to shut coal plants ..” said OPG spokesperson Ted Gruetzner on May 17, 2008 in an interview for the Toronto Star. “None of OPG's coal plants, such as the giant Nanticoke generating station on the north shore of Lake Erie, or the Lambton plant near Sarnia, will close as emissions are lowered, said Gruetzner.” http://www.thestar.com/News/Ontario/article/426847

+ Wording of the Amendment unclear

It is necessary to rewrite the Amendment to O.Reg 496/07 and clearly state what the goal is and how it is to be accomplished.

+ Survival

What future?

The question of energy has come down to the question of survival for each one of us.

Ontario Government has, in spite of the threats of extinction by fossil fuel burning – chosen fossil fuel burning as its energy “future.”

This is ironic because planning future with that which destroys future is plain insane, irresponsible and dangerous. It is a crime against humanity!

Ontario Government has decided to make the Province of Ontario into a market for natural gas mining, shipping, piping, storing and burning corporations.

Also, the Government has set up the province as the market for uranium mining, transporting, refining, enriching, burning and nuclear waste dumping.

+ Worsening of Global Warming, War and Conflict, Environmental Destruction and Ill Health Effects

Multiple-site fossil fuel burning at home and abroad for our energy in times of Global Warming

Natural gas plants and nuclear plants promise to keep coal-fired plants on-line as long as Ontario ignores implementing integrated renewable energy for all existing and new infrastructure following 100% green building standard, and does not stop subsidizing fossil and radioactive fuel burning industry.

Integrated renewable energy is:
-most affordable
the only type of energy which is secure
can be brought on-line in shortest period of time
eliminates the need for mining for fuels
eliminates the need for long-distance transportation and piping of fuels
eliminates waste
(see Poverty and Energy) http://floodiceorfire.wordpress.com/poverty-energy/

Through its regulatory noose and the absence of needed subsidies, the Ontario Government has shown what they think of renewable energy. Except for a few large scale 2007 electioneering gimmicks, they don't like it at all. (New Rules Jeopardize Wind and Solar Projects, Toronto Star May 19, 2008) http://www.thestar.com/article/427244

Why does not the Ontario Government like Ontario to become environmentally-, economically-, and energy secure by turning the province 100% green through integrated renewable energy systems for all current and new infrastructure?

Province of Ontario – artificially set up as a market for natural gas and uranium mining, transportation, burning and waste release – has chosen to rely on massive fossil fuel burning for its energy – not only at home, but also in multiple locations in Canada, United States and elsewhere.

Power/Energy Privatization

Note: Sithe Global a large multinational U.S. corporation is the major stakeholder in several multi-billion dollar privatized gas plants in Ontario. Also note Sithe Global owns dirty coal fired plants such as the controversial Desert Rock coal-fired plants being opposed by the Navajo peoples in the American SouthWest. Also note, Sithe Global is owned by the world's largest private equity corporation Blackstone, which just over a year ago added Brian Mulroney to its board of directors. A big shark in a small pond escalating the push for Ontario Power Generation to be privatized; presently being privatized essentially through mega natural gas plants and nuclear power plants.

Dirty Coal and Power at the Navajo Blockade

by Brenda Norrell
Human Rights Editor
U.N. OBSERVER & International Report

BURNHAN CHAPTER, N.M. -- As Navajo elderly camp in the cold at a blockade of a planned power plant, the Navajo Nation Council plans to meet in special session to allocate millions for the Desert Rock Power Plant.

At the Navajo blockade Thursday night, the sheepdog of the Navajo elderly protester who lives on the land was skinned alive, run over by a car and thrown next to the blockade.

It comes as no surprise that the power plant parent company Sithe Global LLC is linked to the elite Skull and Bones, the world power elite that the Bush family belongs to.

Lori Goodman, spokesperson for Dine Citizens against Ruining our Environment described the torture of the Navajo’s sheepdog...
http://www.unobserver.com/layout5.php?id=2954&blz=2

With all these new natural gas plants and the price of natural gas going through the roof, Ontario tax payers will be fleeced and subjugated by another fossil fuel – GAS! - for another twenty, thirty, forty year contracts.

And Premier McGuinty is boasting that he would be re-elected with the another majority government in the key year of 2011. http://quebec.indymedia.org/en/node/28427

Brian Mulroney joins Blackstone Group http://www.canada.com/vancouversun/news/business/story.html?...

Why has the Province of Ontario artificially decided to be a driver of massive, multiple-site fossil fuel burning in the times of Global Warming?

This creates a lot of environmental destruction and ill health effects everywhere!!!

This creates a lot of conflict over land rights (especially Indigenous Peoples' land rights) leading to forceful takeovers of land by mining corporations in partnership with state military forces. http://www.uraniumcitizensinquiry.com/

In short, our energy “future” as planned by the Ontario Government - if there is future – relies on environmental destruction, conflict and worsening of Global Warming.

Ontario blowing up Appalachia mountains for its coal-fired plants

*** Over 40 per cent of Ontario's power from coal-fired plants come from the total destruction of Appalachian Mountains tri-state area environment and destruction of local people's habitat and lives. The peoples of Appalachia have called for those receiving coal from Appalachia such as Ontario to call for a boycott of mountain-top-removal coal mining in Appalachia.
(Coal River Mountain Watch) http://www.crmw.net/campaigns.php

People who live here think of themselves as collateral damage – accidental victims of a war to feed the nation's insatiable demand for energy.
What does this have to do with you? This is where Ontario gets 40 per cent of the fuel powering its coal-fired power plants. That means every day you run your dishwasher, you are connected to one of world's oldest mountain chains, 900 kilometres south of Toronto, which is slowly being flattened, one peak at a time.
"When you go home and flip on your lights," says Nelson, looking down at the devastation, "do you think of this?"
(Coal Mining Ravages Appalachia mountains Toronto Star February 23, 2008) http://www.thestar.com/sciencetech/Environment/article/30616...
+ O.Reg 496 /07 & Amendment

“A positive step” - unbelievable! Renewable alternatives not in place!
(Assuming “coal cessation” or “coal emissions reductions” means bringing coal burning to a stop)

Since 2003, the McGuinty's Ontario Government promised twice to close down coal-fired plants. Both promises were broken. The same government made a third promise, and that is to close down the four coal-fired plants by December 31, 2014. (Please note towards the end of 2007 Ontario election, at a convention for energy stakeholders: when asked informally how many members of the audience thought Ontario coal-fired plants would close by 2014, hardly a hand rose in affirmation Globe and Mail August 2007 )

On August 24, 2007, Ontario Government, as if to make its third promise more believable, came up with Ontario Regulation 496/07 making “Cessation of Coal Use” by the end of 2014 legally binding.

Right now, we are in the middle of a 30 day “public review and comment period” May 16 – June 15, 2008 regarding the proposed Amendments to O.Reg. 496/07, which “ensures that the government’s coal cessation commitment has legally binding interim carbon dioxide limits and reporting requirements.”

While phasing out coal-fired plants is necessary and should have been done by the end of last year (2007) as promised in 2003, the third McGuinty's promise regarding “coal cessation” through “emissions cap” – dubbed by some as a “positive step” - is unbelievable.

Just the way the Ontario Government has not taken steps necessary for closing down of coal-fired plants in 2007, it still does not have those necessary steps in place and right now we are in year 2008. "'We have to figure out how to use our coal plants less,' said OPG spokesperson Ted Gruetzner” in an interview for the Toronto Star on May 17, 2008.

Necessary steps for ensuring energy stable economy would amount to full subsidies for the fully green Ontario through integrated renewable energy systems making all existing and new infrastructure 100% green with the concurrent phase-out of fossil and radioactive fuels burning in the province.

Open hostility towards renewable industry and preferential treatment of nuclear and fossil fuel industry measured in billions of public dollar subsidies is a warning that we should approach O.Reg 496/07 and its amendment with caution.

+ At any time, especially in times of “emergency” – trumped!

Head on to economic, humanitarian, environmental disasters, with more coal, of course.

O.Reg 496/07 and its Amendment can be revoked at any time, especially in “times of emergency.”

The current energy planning in Ontario, which keeps door wide open to fossil fuel burning, worsening the Global Warming, is setting the province for energy-, environmental- and economic disasters.

What will be the response to such a manufactured crisis?

More coal!

Fever pitch: More gas means more coal

Emphasis on natural gas, promoted as a solution to closing down of coal-fired plants, IS an emphasis on coal. Natural gas brings “clean” coal into play. Natural gas plants require mining for gas (gas shale, coalbed methane..). Mining for gas is made easier and more abundant with injections of captured carbon. Clean coal is about capturing the greenhouse gases from coal-fired plants, commercializing it into a product for sale to gas and oil miners for the purpose of fuel “enhanced recovery.”

When natural gas plants lead to commercialization and profit making off the DEADLY biproduct of coal-fired plants, they are essentially adding value to existing coal-fired plants. Potential gas shale mining in Quebec could be a source of profit for Ontario if Ontario decided to sell greenhouse gas captured from its coal-fired plants to gas shale mining operations for this fuel's enhanced recovery.

(Will Quebec be a gas, gas, gas? Globe and Mail May 28, 2008) http://www.theglobeandmail.com/servlet/Page/document/v5/cont...

(Re: Will Quebec be a gas, gas, gas? http://floodiceorfire.wordpress.com/re-will-quebec-be-a-gas-...)

The Province of Ontario's energy plan is about making temporary profit rather than creating a stable green and long-term economy. There is no reason to not project that Ontario will not take advantage of carbon capture and sales to gas and oil mining projects, even if it only means relying on the empty rhetoric of such a failed technology.

In short, reliance on natural gas for energy drives the need for coal, as coal burning biproduct ensures enhanced recovery of gas necessary for natural gas plants. Fossil- fuel burning and commercialization of its deadly biproduct leads to a disaster scenario the response to which will more likely than not be more coal – the old way of doing things as new ways have not been GIVEN A CHANCE. "'We have to figure out how to use our coal plants less,' said OPG spokesperson Ted Gruetzner” (Toronto Star May 17, 2008)

Action pacifier

While the Ontario Government's regulation and amendment to regulation regarding phasing out of coal-fired plants in Ontario sound noble, just like the last three promises sounded noble, it serves as a pacifier to concerned citizens - an artificial buffer zone for their disquiet.

It gives a hope and eliminates needed action for the fully green Ontario. It buys time for the government's deadly coal-fired games leaving people to passively wait for the regulation to come to its fulfillment – a repetition of history from which we fail to learn.

I would like to warn People of Ontario to take the 496/07 O. Regulation and its Amendment with extreme caution as the Ontario Government is known for its dishonesty, its steady and confirmed reliance on fossil fuel and nuclear burning and its hostility towards renewable energy industry. http://portland.indymedia.org/en/2007/10/366521.shtml

People of Ontario should in unison and without cessation demand fully green Ontario and a complete abolition (phaseout) of coal-fired plants and fossil and radioactive burning for their energy without delay.

+ Some notes on renewable energy in Ontario

Integrated renewables refer to a variety of locally suited renewable energy systems (geothermal, wind, wastegas, tidal waves, sun) complementing each other to provide all energy required for current and new infrastructure (100% green building standard). Integrated renewable energy should by default be made available to everyone through full public subsidies.

Right now, each type of renewable energy is offered solo accomplishing only a very small percentage of renewable energy needed by the current infrastructure. Also renewable energy is not made a prerequisite for constructing new infrastructure.

Renewable energy is subsidized for the upper middle class and the rich allowing them access to inexpensive and renewable clean energy.

It is left to the poor and the struggling people of this province to absorb the skyrocketing costs of energy generated by burning fossil and radioactive fuels – most expensive and least energy, environmentally and economically secure fuels. They are brought to the point to beg for “affordability rates” to access the dirty types of energy, another aspect of subsidies for fossil fuel and nuclear power industry. (Sounds like a recipe for the world-wide Boston Tea Party – see American Revolution.)

There is no reason why citizens and local politicians anywhere in Ontario wouldn’t or couldn’t together with Ministries of Energy and Environment form partnerships with renwable energy developers to enable access-for-all to integrated renewable electricity/heating/cooling systems. (Poverty and Energy) http://floodiceorfire.wordpress.com/poverty-energy/

In vary rare and sporadic instances, and with some exception, accessible renewable energy (leased over time) exists through limited time offers. Some current renewable energy initiatives among local hydro utilities and renewable energy developers, allowing access to renewable energy systems through leasing are as follows:

Next Energy company and Waterloo North Hydro offer installment and maintenance of geothermal systems without asking for upfront payment, instead leasing equipment over 20 years.
Mondial Energy Inc. installs solar hot water systems on buildings with a central boiler without upfront payment. With Mondial’s help, Hospital for Sick Children, Woodgreen Community Centre, seniors homes (Hillcrest Lodge in Orillia) and hotels have been able to go green http://www.mondial-energy.com/projects.htm
In Mississauga, Brampton, King Township, East Gwillimbury, Georgina or Whitchurch-Stouffville, Enersource Hydro Mississauga, Hydro One Networks and Hydro One Brampton Networks currently provide a limited offer on zero-interest loans or rebates for residential installations of solar (PV and solar hot water), geothermal and small wind systems. http://www.powerhouseprogram.ca/
Orangeville hydro utility works with renewable developers offering PURE, a Community-Based Sustainable Energy Strategy for Dufferin County and the Headwaters Region http://powerupenergy.ca/projects.html

Additional References and Links

Abolition of King Coal Everywhere, Paradigm Shift Environmental Alliance
http://quebec.indymedia.org/en/node/28427

Water and Informed Consent: Citizen's Inquiry on the impacts of the Uranium Cycle http://www.uraniumcitizensinquiry.com/submissions/submission...

Natural Gas Plants Not an Answer to Phasing Out of Coal-Fired Plants
http://floodiceorfire.wordpress.com/natural-gas-plants-not-a...

A Note on Carbon Sequestration
http://floodiceorfire.wordpress.com/re-western-premiers-rema...

Gas Shale Mining in Quebec
http://floodiceorfire.wordpress.com/re-will-quebec-be-a-gas-...

IGCC stands for Integrated Gasification Combined Cycle http://www.energyjustice.net/coal/igcc/factsheet.pdf

Ontario Quebec Carbon Trading System
http://www.cbc.ca/canada/story/2008/06/02/ont-que.html

PORTLANDS power play (Toronto's Waterfront 550MW gas plant)
Residents walk out of consulting committee charging Energy Centre kept them in the dark
http://www.nowtoronto.com/news/story.cfm?content=159110&arch...

Three letters in reference to “Portlands Power Play”: 1.) Burning question, 2.) Clean Air's pro-gas plank, 3.) A dirty future in coal http://www.nowtoronto.com/letters/index.cfm?content=159179

It's Tuesday time to protect the planet Toronto Star May 2007
http://www.thestar.com/article/216687
Terminator gunning to save lives Toronto Star May 2007
http://www.thestar.com/News/article/219810

Dogging Big Coal, NOW Magazine July 2007
http://www.nowtoronto.com/issues/2007-07-19/news_story8.php

DINE CARE'S HISTORY & MISSION:
http://www.desert-rock-blog.com/blog/DineCAREMissionContact

Diné Citizens Against Ruining our Environment (Diné CARE) formed in the late 1980's as the the first Navajo grassroots environmental organization within the Navajo homeland. We continue to educate and advocate for environmental justice, based on our traditional Diné teachings and a commitment to protect and provide a voice for all life within the Four Sacred Mountains. We promote alternative uses of natural resources that are consistent with the Diné philosophy of the "Beauty Way." Our main goal is to empower local and regional community people to organize, speak out on issues that matter to them, and participate in nurturing a healthy environment. Diné CARE's goal to preserve the Diné lifeway starts from the ground up, within the homes of those living in the most impacted communities.

We are a non-profit organization by and for the Diné, the People. We do not collect dues or run membership drives. Our work is funded primarily through the support of volunteers, foundations and donors. Our members are not only those who are leaders in their communities, but all those Diné who strive to maintain a relationship with Mother Earth based on the concepts of Balance and Harmony. For us, membership means taking up the cause of Honoring Mother Earth and Honoring our Relations to our Environment. We are local, community people working together on issues that affect our communities.

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