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30 Fairmont Park Lane S
Lethbridge, Alberta
T1K 7H7, Canada
Business Telephone: (403) 328-1804
Home Telephone: (403) 328-1704
Mobile Telephone: (416) 568-5437
Fax: (403) 206-7352
Email: duane.pendergast@computare.org
September 30, 2002 


Dr. Roger Palmer
Deputy Minister
Alberta Environment
10th Floor
Petroleum Plaza South Tower
9915 - 108 Street
Edmonton, Alberta 

Re: Alberta Climate Change Stakeholder Meetings - Ref AR 4965 

Dear Dr. Palmer:

Thank you for the invitation to participate in the consultation session in Edmonton on September 16, 2002. I understand that session was on transportation. I also received an invitation to participate in the meeting on energy held in Calgary on September 18. 

Unfortunately, I was unable to participate in the Edmonton meeting due to prior travel arrangements, but I was able to participate in the Calgary meeting. 

I'm taking the opportunity offered at the Calgary meeting to provide additional written comments relating to the topics of both meetings to Alberta Environment. The average of four minutes per participant provided at the meeting was hardly time to do justice to the issues. I have also submitted my comments via the email address climate.change@gov.ab.ca to meet the deadline of October 1 for input. 

Thanks again for this opportunity to contribute to Alberta's plans for action on the climate change issue.


Yours truly,



Duane Pendergast

Principal Engineer


Written Input to Alberta Stakeholder Meetings, September 2002

Duane Pendergast, Computare, October 1, 2002

Transportation, September 16,  2002, 10am - 12pm (Invited, Absent)

Energy, September 18, 2002, 1:30am - 3:30pm (Invited, Present) 

(Some links to references updated - October, 2003)

The two hour discussions followed a defined structure of questions to participants. My written submission follows that structure. 

1) What is your overall opinion of the plan? 

Generally, the Alberta plan warrants very serious consideration by Canadians. 

If climate change is a problem, international action is required to manage greenhouse gases. The concept of a "made in Alberta or Canada" plan has little merit except for the concept that Albertans and Canadians can perhaps lead by example. Meaningful action on greenhouse gas reduction demands international action. The Alberta plan does not emphasize the need for international action. This is noted in the background document and should be moved up front into the plan.  The United Nations initiative with the Kyoto Protocol recognizes the need for international action and should not be rejected too lightly. Consideration of the Kyoto Protocol does not preclude the possibility that a separate and largely Kyoto consistent North American initiative could be established in parallel with Kyoto.  

Having noted that caveat, the Alberta plan is well thought through and presented. It sets a very ambitious goal of a 50% reduction in GHG emissions per unit domestic product by 2020. It reasonably asserts  that meeting the Kyoto commitment by the 2012 deadline is next to impossible as technology development is the key and development timelines need to be extended to deploy significant technology.  It has substantial merit with respect to low greenhouse gas emission management technology development. Development as envisaged by the Alberta plan would help place Canada in an advantageous competitive position as more stringent GHG reduction requirements are imposed in future decades.

 2) What are the best elements? 

The very best element of the plan is its recognition that technology development is the key to reducing greenhouse gas emissions. This is uniquely important, within Canada, to Alberta's energy use in the production of fossil fuels for export and to Alberta's electricity industry.  Alberta shares a need for the development of low emission transportation technology with many other jurisdictions.

3) What are the worst elements?

 It is difficult to pick out any explicit points that can be identified as "worst elements". There may be some elements that are relatively trivial with respect to overall potential for emission reduction.

I do get the impression from the plan that it undervalues energy use as a driver of the Alberta economy and the basis for economic prosperity. This is partly indicated by an overemphasis on energy conservation in the plan. Energy conservation is a separate issue already recognized and practiced diligently across Canada and elsewhere. It is a worthy goal that will have a limited effect.  

Some of the actions proposed, such as sequestration, are actually counter to energy efficiency and conservation in the conventional sense. The goal of reducing emissions while maintaining economic prosperity thus needs a strong focus on developing and deploying major energy sources with much lower lifecycle greenhouse gas emissions.   

Electricity is particularly vital to modern society so this mode of energy supply needs particular attention. Transportation is a major source of emissions and presents even greater challenges in modifying consumer behaviour and developing less emitting technology. 

Overt attention to efficiency and conservation in the plan diverts attention from the primary goal of reducing atmospheric greenhouse gas. 

4) What is missing? 

I suggested at the meeting that the plan seems to project a "Alberta can do  it alone"  attitude. The plan itself underemphasizes that the greenhouse gases driving the alleged climate change problem are a global issue.  The supporting document, "Albertans and Climate Change" better enumerates this fact. Perhaps Albertans are not fully aware of the global nature of the challenge. It should be more clearly established up front in the plan. 

It is also apparent that the Alberta plan and the federal options are based on assuming that rising greenhouse gases pose a very significant risk and that very significant action must be taken. Evidence that the alleged problem might be insignificant is not only given short shrift - it's given almost no recognition at all. About 5 seconds of our 7200 second meeting on energy in Calgary touched on that possibility. I respectfully suggest that both Environment Canada and Alberta Environment want to initiate major action on climate change. That is understandable given the amount of time and effort spent on the issue. Perhaps some more reflection on the uncertainties of climate change science in the introduction of the plan is warranted. 

5) What do you think of the GHG intensity basis of the plan? 

It is appropriate for Alberta. There is a growing need for Alberta's products outside our borders. Indeed, North America does have more potential for population growth and growing emissions than many of the developed countries signing on to Kyoto. That factor is not sufficiently recognized by the Kyoto Protocol. The plans from the US and Alberta, which are based on reducing greenhouse gas intensity, suggest a direction to help bridge the oversight. However, if  any  plan is to work to actually manage  atmospheric greenhouse gas content, the entire world must be engaged to cap greenhouse gases in the atmosphere as envisaged by the UNFCCC and the Kyoto Protocol in the long term.

 6) What are your suggestions for sectoral agreements? 

As an individual consultant I did not represent a major industrial sector at the Calgary meeting. However, I do represent a sector, personal transportation,  responsible for significant emissions. It seems those   responsible for implementing plans to reduce emissions do not really want to make this sector aware of the implications to them.  

I suggested at the meeting that an emission trading system based on allocating permits to individuals could serve a dual purpose of incenting change in transportation consumer behaviour while providing a source of funds which could be directed to technology development. Another participant suggested that a carbon dioxide cost on the order of $400/tonne would be needed to incent  a change in behaviour on personal transport choices. That participant suggested that planners might not want to go that route as it could arouse resistance to any plan to reduce emissions. That viewpoint is telling. 

Discussion of the possibility was very limited. I believe such a scheme is worthy of more consideration. I submitted the following rationale in support of it at the Calgary federal stakeholder meeting in June. 

"Eric Reguly, a writer for the Globe and Mail, had defined, as an example, a capped permit allowance  and trading system imposed on  personal automobiles. This would be based on providing permits for a capped level of emissions. I suggested, somewhat tongue in cheek, that such a system would allow Canadians to put their money directly into fighting climate change. They would have the option of buying more permits to operate highly emitting vehicles - or investing in lower emitting vehicles  and perhaps selling their permits to others. The Panel noted that such a scheme had been considered and was rejected as being too complex to administer with so many participants.   

Perusal of the Transportation Issue Table background reports reveals that a study of such a scheme was undertaken.  It does not seem to have been considered very seriously in the Transportation Table Options Report.    Perhaps a personal transport permit allocation and trading scheme should be reconsidered in view of the apparent disinterest in a broader scheme imposed on large firms?  Such a scheme would focus public attention on a most important economic sector that is responsible for substantial emissions. It seems it would avoid most of the regional inequities as all regions depend on a substantial component of personal transportation. Personal vehicles have a relatively short life compared with other capital stock making the transition to lower emission technology in transport more fitting to the Kyoto first period timeline. Low emission vehicles are now available. Governments and the public will need experience with capping emissions in the long run and application to the personal transport sector would provide a learning and  experience base for  broader applications. Finally, such a scheme could possibly raise some funding for other measures depending on whether consumers choose to reduce their emissions or just pay for more permits." 

Would it be a bad thing for Alberta's drivers to be aware of the potential future costs of driving high fuel consumption vehicles? I think not.

 7) What changes to the plan would make you likely to support it? 

As you can see from the foregoing, I already support many aspects of the Alberta plan. I believe it is essentially consistent with the goals of the UNFCCC and the Kyoto Protocol. Changes to the plan   should focus on the need to engage global action without placing the entire burden on the backs of Albertans and Canadians.

 8) What is your closing comment? 

At the meeting the flow of closing comments led me to emphasize the need to get the whole world involved in managing atmospheric greenhouse gas concentrations. Action by Alberta alone is futile.  

I would like to add that I share some of the doubts about the reality of climate change in connection with human influence on atmospheric greenhouse gas content. Some precautionary action is likely warranted to prepare for the possibility climate change is a real problem. This will likely pose some economic hardship on current generations. On the other hand it will focus attention on the development of alternatives to the limited supply of fossil fuel energy that is supporting an unprecedented level of quality human activity on the planet. Our short term pain will help future generations prolong a high level of human activity within a supportive global environment regardless of the reality - or not - of climate change.


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