October 21, 18 Dear Sir or…

October 21, 18

Dear Sir or Madam

The world’s leading scientists have warmed that there is only 10-15 years to keep the climate from exceeding the 1.5 C target for global warming and avoid catastrophic environmental breakdown. The authors of the landmark report by the UN Intergovernmental Panel on Climate Change (IPCC) said urgent and unprecedented changes are needed to reach the target, which is affordable and feasible.

Debra Roberts, a co-chair of the IPCC working group, said: “It’s a line in the sand and what it says to our species is that this is the moment and we must act now. This is the largest clarion bell from the science community and I hope it mobilises people and dents the mood of complacency.”

Christine Furueres, the former UN climate chief has stated that “There is nothing opaque about this new data. The illustrations of mounting impacts, the fast-approaching and irreversible tipping points are visceral versions of a future that no policy-maker could wish to usher in or be responsible for.”

Into this environment, the Government has repealed the Cap and Trade legislation and now the Green Energy Act. The Government is heading in the wrong direction and it just the sort of action that will make it harder to implement the type of measures that are required to address the emergency we now face.

These are my primary objections:
1. It is premature to repeal the Green Energy Act.
The government has not come up with an alternative Plan to address Climate Change. Once again, to repeal the Act without a Plan without an understanding of what actions are required is foolhardy. In addition to the many broader matters, the two small tools are taken off the table for the government's yet-to-be defined "plan". The government may need to incorporate the ability to require mandatory home efficiency disclosure for homes at the time of sale and to require public agencies to consider energy conservation in procurement and capital investments.

2. It is inappropriate to subject to renewable energy projects to a patchwork of municipal regulation
The government cannot chew from both sides of its mouth. Nuclear power plants, gas-fired power plants and dams have wide ranging impacts on communities, much more so than wind turbines, and they are not placed under municipal authority for a very good reason; namely no one wants a power plant in their backyard. This sets a dangerous dynamic to subject the preferred form of power generation on a patchwork framework under the authority of local councils and yet allowing carbon-producing energy power plants to trample on “local authority”. This is ludicrous. All forms of electrical generation should be subject to the same regulatory framework.

3. The ability to appeal a decision of municipal council with regard to a refusal or non-decision on the renewable energy project is contrary to an encouraging renewable energy projects and meeting Paris agreement targets.
Through this provision the Government is taking away the appeal process for a renewable energy company or a third party to appeal a refusal of a planning application. This provision would still allow an appeal of a decision to approve a project. This provides third parties to obstruct a renewable energy project, including competitors in the energy market. So not only is the playing field between renewable energy projects and non-renewable energy projects subject to different approval regimes, even when an approval is given, it is subject to the uncertainty of delay, denial and additional costs through an appeal process. This provision blatantly makes approvals of renewable energy projects more difficult to obtain and will discourage this type of investment.

There are other details but in general the proposed change to repeal the Green Energy Act is a step backwards to the 19th century and not the type of regulatory framework we need to address the very real threat to the future lives of our children.

Yours truly,