New Report Downplays Climate Impact of Energy East: Assumes Oil by Rail Alternative

A new assessment of the climate impact of the proposed Energy East pipeline is significantly lower than the previous assessment, mainly because it assumes the oil would be extracted and shipped by rail if the pipeline is not built.

The proposed Energy East pipeline would transport up to 1.1 million barrels of oil per day from Alberta to the Atlantic coast of Canada, for export or refining.[1] The climate impact of Energy East has been assessed twice, and the results are dramatically different (see Figure 1). The Pembina Institute’s analysis estimated that building Energy East would lead to increased GHG emissions of between 30 and 32 million tonnes CO2e per year.[2] The expert consultant hired by the Ontario Energy Board (Navius Research) concluded that building Energy East would lead to a much smaller increased GHG emissions of between 1 and 4 million tonnes CO2e per year.[3]

Navius vs Pembina Climate Impact of Energy East

Figure 1: Estimated Climate Impact of Energy East by Navius (OILTRANS) and Pembina (Source: Ontario Energy Board)

How could these two assessments of the same project come up with such different results? To answer that question, we need to delve into the somewhat arcane world of GHG accounting.

The climate impact of a project depends on a number of things, including what it is compared to. In GHG accounting jargon, this is called the “baseline”, or what would happen without the project. But because no one knows for sure what would occur in the future if a project doesn’t go ahead, there is no foolproof way to select the best baseline to compare a project to. But that doesn’t mean any baseline will do. Thankfully, the international GHG accounting community has spent a lot of effort developing rigorous and defensible methods for selecting a credible baseline.[4] As far as I can tell, neither Pembina nor Navius used these methods. I say “as far as I can tell”, because neither Pembina nor Navius documented, in a sufficiently transparent way, how they selected their baselines.[5]

The OEB/Navius analysis results in a smaller estimate of increased GHG emissions from Energy East because it assumes that if the pipeline is not built, the oil that would otherwise fill the pipeline would be transported by rail “… if it is economic.”. In other words, they are using “oil by rail” as their baseline. The Pembina analysis results in a higher estimate of increased GHG emissions from Energy East because it assumes that if the pipeline is not built, the oil that would otherwise fill the pipeline would be left in the ground. Let’s call this the “oil in the ground” baseline. There are additional differences in the geographic and life cycle scopes of the analyses by Navius and Pembina, but these don’t appear to affect the results as much as the different baselines used.

How should the baseline be selected? According to internationally accepted best practices, the following steps should be included:[6]

  1. Identify all credible alternatives to building Energy East;
  2. Identify barriers to the identified alternatives (e.g., legal, environmental, technical, economic, political, etc.) and eliminate unrealistic alternatives; and
  3. Conduct a financial analysis of remaining alternatives and identify the most attractive option.[7]

Did either study include these steps? It’s hard to assess the OEB/Navius study, since we only have a 4 page summary of their analysis, and it’s not clear when the full report will be available. From the 4 page summary, it appears that the Navius study spent most of their effort on step 3, but may have glossed over steps 1 and 2. The Pembina study considered the “oil by rail” baseline, and decided it was not feasible due to a number of barriers (e.g., cost, capacity, social license). For both studies, a more systematic and transparent application of best practices for baseline selection would enhance their credibility.

An accurate estimate of the climate impact of the proposed Energy East pipeline is essential to inform the public and decision makers. This requires a transparent and credible methodology, and we should expect it to be consistent with internationally accepted GHG accounting standards and protocols (i.e., codified best practices). This must include, amongst other things, a full documentation and justification of assumptions about what would happen if the pipeline is not built (i.e., selection of the baseline). Until this happens, any estimate of the climate impact of Energy East is incomplete and unreliable.

About the Author

Duncan Noble has developed and/or reviewed dozens of GHG inventories/carbon footprints for organizations, products and projects for clients in various sectors. He has contributed to the development of leading GHG methodologies including the ISO 14064 Standards and the WRI/WBCSD GHG Protocol (Corporate Standard). He actively participated in the “Methodology” Technical Work Group of the GHG Protocol Product Life Cycle Standard and supported a client Road Test of this Protocol. He was actively involved in the development of the GHG Protocol Corporate Value Chain (Scope 3) Standard. Duncan has also developed a methodology for the Verified Carbon Standard, the world’s leading voluntary greenhouse gas program. On behalf of CSA, he has delivered eleven 2-day training sessions on the ISO 14064 Standard and WRI/WBCSD GHG Protocol.

[1] National Energy Board, Energy East Project,

[2] Pembina Institute (2014): Climate Implications of the Proposed Energy East Pipeline: A Preliminary Assessment,

[3] Ontario Energy Board (2015): Preliminary Assessment – Climate Change,

[4] For example, the UN Clean Development Mechanism, ISO 14064 – Part 2, GHG Protocol for Projects, etc. These methods are typically used to assess a project that reduces GHG emissions, but they can also be used to assess a project, like Energy East, that increases GHG emissions.

[5] At time of writing, only the 4 page “Preliminary Assessment – Climate Change” was available from OEB/Navius.

[6] See, for example, the UN CDM “Combined tool to identify the baseline scenario and demonstrate additionality”, available at

[7] The “most attractive option” depends on the perspective taken for the analysis (e.g., a private investor such as TransCanada would have different “most attractive” criteria than a public policy entity).

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Letter to Ontario Energy Board Opposing Energy East Pipeline

18 October 2014

Ontario Energy Board
P.O. Box 2319
Toronto, ON, M4P 1E4

Re: Proposed Energy East Pipeline

I am writing to express my deep concern about the proposed Energy East Pipeline and to recommend that you do not approve this project. This pipeline, if approved, would encourage reckless growth in the tar sands, would make climate change worse, would help ensure that Canada does not meet our commitments on climate change, and would put our local ecosystems and drinking water at risk.

Tar sands production is Canada’s fastest-growing source of the carbon pollution that causes climate change. Canada’s tar sands producers intend to more than triple their production to over 5 million barrels per day by 2030.[1] This growth in production is expected to triple tar sands carbon pollution between 2005 and 2020, an increase large enough to cancel out all emission reductions that other parts of Canada’s economy are expected to make over the same period, including Ontario’s phase out of coal.[2] Filling the Energy East Pipeline would result in upstream emissions of about 30 million tonnes, roughly equivalent to doubling the fleet of passenger cars in Ontario.[3] It is clear that Canada will not meet our international commitments on climate change if this reckless growth in tar sands production is allowed to proceed.[4] If the proposed Energy East Pipeline is approved, it will lock in growth in tar sands emissions for decades, help ensure Canada reneges on our international climate change promises and increase climate change risks for all sectors of our society.

Energy East Pipeline proponents may argue that tar sands oil will get to market one way or the other (e.g., via rail or other pipelines), and that building this pipeline will not affect upstream emissions. However, it is clear that tar sands growth is not inevitable and that pipelines matter. For example, in September 2014 Norway’s Statoil shelved a multibillion-dollar tar sands project, blaming rising construction costs and the repeated delays in new export pipelines that would boost the value of Canadian heavy crude oil.[5] Without the low cost transportation provided by pipelines like Energy East, tar sands growth will not be locked in and we have a better chance to manage our carbon pollution.

Building long lived infrastructure to produce or transport tar sands oil is not consistent with a safe climate. Even the former governor of the Bank of Canada, Mark Carney, recognizes that the “vast majority of reserves are unburnable” if global temperature rises are to be limited to below 2°C.[6] Given this reality, it makes sense to leave the dirtiest fossil fuels like tar sands in the ground. Since Canada clearly does not have a strategy or a plan to achieve our GHG emission reduction targets, no new tar sands production or transportation projects should move forward until their cumulative impacts are consistent with our national and international commitments to reduce carbon pollution.[7]

Please consider my concerns in your review of the Energy East Pipeline, and keep me informed of your review process for this project so that I can participate in this process.


Duncan Noble

[1] Canadian Association of Petroleum Producers (CAPP), June 2014: Crude Oil Forecast, Markets and Transportation

[2] Environment Canada, 2013: Canada’s Emissions Trends (2013)

[3] Pembina Institute, 2014: Climate Implications of the Proposed Energy East Pipeline: A Preliminary Assessment

[4] Auditor General of Canada, 2014: Report of the Commissioner of the Environment and Sustainable Development

[5] Globe and Mail, September 26, 2014: “Statoil halts multibillion-dollar Alberta oil sands project

[6] The Guardian, October 13, 2014: “Mark Carney: most fossil fuel reserves can’t be burned

[7] Palen et al., Nature (25 June 2014): Energy: Consider the global impacts of oil pipelines

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Tapping Big Data: Was Global Warming Changed to Climate Change?

If you follow climate change/global warming, you will likely encounter people who insist that the term “global warming” was changed to “climate change” for various reasons (e.g., “global warming stopped, so they changed the name”, etc.).

One way to test this hypothesis is to tap into “big data”, in this case Google’s database of English books. Google has a cool tool called the “Ngram Viewer”, which allows you to determine the frequency of words and phrases in their database of books. What does Google’s Ngram Viewer tell us about this hypothesis?


Figure 1: Global warming vs climate change for all English books

American English

Figure 2: Global warming vs. climate change for American English books

British English

Figure 3: Global warming vs climate change for British English books

Some observations:

  1. For all English books and American English books, it’s clear that the phrase “climate change” was in use before the term “global warming”. This contradicts the hypothesis that global warming was changed to climate change.
  2. Global warming is more common in American English than it is in British English, but climate change dominates in both.
  3. Usage of “climate change” peaked in the year 2001. This was driven by British English usage. This is quite interesting and merits additional research about if this is a real trend, or an artifact of the Google Books database.

For additional discussion and the history of these two terms, check out Skeptical Science.

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Open Letter to Environment Minister Leona Aglukkaq


Honourable Leona Aglukkaq, M.P.
Minister of Environment
House of Commons
Ottawa, Ontario K1A 0A6

Re: Living Up to Our Climate Change Promises

Dear Minister Aglukkaq,

On behalf of Canada, your government made a promise to the world to reduce our GHG emissions by 17% by 2020, from a 2005 base year. The world expects Canada to live up to that promise. Canadians expect our government to live up to that promise. I expect you to fulfil that promise.

Before you left for the Warsaw COP conference, you affirmed your government’s commitment to our 2020 Copenhagen reduction target. I would welcome this announcement if it was credible. However, based on your own analysis (Environment Canada, 2013: Canada’s GHG Emissions Projections), there is no plan in place to reach our 2020 goal.

I urge you to develop and implement a plan to meet our 2020 GHG emission reduction target. There are multiple analyses available as to what needs to be included in a credible plan to reach our 2020 target. At a minimum, this plan needs to put a price on carbon pollution and phase out subsidies to the fossil fuel industry.

In his speech at Riverside Church on April 4, 1967, Rev. Dr. Martin Luther King, Jr. said, “We are confronted with the fierce urgency of now. …We may cry out desperately for time to pause in her passage, but time is adamant to every plea and rushes on. Over the bleached bones and jumbled residues of numerous civilizations are written the pathetic words, ‘Too late.’”

It’s already too late for the victims of climate change enhanced extreme weather like Typhoon Haiyan, Super Storm Sandy, and Hurricane Katrina. By the time our children confront extreme heat, terrifying storms and complete loss of summer arctic sea ice, it might well be too late for all of us. It isn’t too late for us to act … yet. We can still avert what could be a disastrous climate crisis. There are no excuses for delay.

I am willing to do my part to avoid dangerous climate change. Are you willing to do yours?


Duncan Noble

Copy:     Stephen Harper, Jim Flaherty, Cheryl Gallant, Megan Leslie, John McKay, Elizabeth May

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Government Newspeak & Greenwash: We Demand Better

Shouldn’t we hold our elected governments to a higher standard than we expect from the folks who sell soap? Or at least as high a standard as we expect from marketers?

In October 2013, the US Federal Trade Commission (FTC) announced six enforcement actions, including one that imposes a $450,000 civil penalty and five that address biodegradable plastic claims, as part of the agency’s ongoing crackdown on false and misleading environmental claims. In Canada we rely on a voluntary approach, with enforcement weak or non-existent.

Strictly speaking, greenwashing rules apply to claims made about a product. However, it’s getting harder to tell the difference between a marketer selling a product and a government pitching for votes. Susan Delacourt explores this connection in her recent book Shopping for Votes: How Politicians Choose Us and We Choose Them. According to one analyst who reviewed this book, “Canadian politics has moved into an era when voters no longer think much of themselves as citizens, with duties and obligations and longer-term perspectives, but as taxpayers in a consumer society who shop among politicians for those who will give them the most at the lowest cost”.

In a recent example of newspeak, the government of Canada congratulated the government of Australia on its initiative to repeal its carbon tax, and made the following statement:

Our government has reduced greenhouse gas emissions while protecting and creating Canadians jobs – greenhouse gas emissions are down since 2006, and we’ve created 1 million net new jobs since the recession – and we have done this without penalizing Canadian families with a carbon tax.

I won’t examine the jobs number, although I’m skeptical of it. The greenhouse gas emissions claim is incomplete and misleading. The reason that GHG emissions are lower “now” (the latest year with data is 2011) than they were in 2005 is that Canada’s emissions fell during the global recession. Emissions have been rising again since 2009, and the trend is going in the wrong direction. Harper’s government did not reduce greenhouse gas emissions, the global recession did, supplemented by provincial actions such as Ontario’s phase out of coal fired power.


Source: Pembina Institute, Environment Canada

According to the government’s own analysis, Canada will miss, and miss badly, its emission reduction target of 17% by 2020, from a 2005 baseline. Environment Canada estimates our GHG emissions will be 20 per cent higher than our 2020 commitment.

In an article about Canada’s latest GHG Emissions Projections, the Pembina Institute commented:

… this year’s edition shows that Ottawa has done nothing over the past year to change this trajectory: there is not a single new policy (my emphasis) on the list of federal initiatives to reduce emissions in Canada. So it’s little surprise that the country is no closer to reaching its emissions target. In fact, the gap between where we are headed and where we should be headed has grown slightly in the past year.

The central conclusion of this year’s report is inescapable: without a serious ramp up of effort from our government, Canada is headed for another major broken promise on climate change. This is bad news for a lot of reasons, not least for our credibility.

Canada was singled out by authors of the United Nations’ most recent emissions gap report:

The authors picked out Canada as a lead laggard. Canada is on track to exceed its 2020 target of 607 megatonnes by slightly more than 110 megatonnes or about 20 per cent, according to its own reports. (A megatonne is a million tonnes.)

“So it is significantly off track right now,” Taryn Fransen, another report author, said.

Morgan added, “Canada doesn’t seem to fully grasp the risk that climate change poses to it and its people in its approach to climate change.”

“It is very important that countries like Canada meet its targets not only for atmospheric reasons – I mean the need to reduce emissions in the atmosphere – but also because of the signal that it sends to others,” Morgan said. “Canada is a wealthy country. It certainly has the resources to do it.”

If Canada was selling soap, it would be guilty of at least two greenwashing sins. First the “Sin of the Hidden Trade Off”, committed by suggesting a product is “green” based on an unreasonably narrow set of attributes without attention to other important environmental issues. Add to that the “Sin of Irrelevance”, committed by making an environmental claim that may be truthful but which is unimportant or unhelpful for consumers seeking environmentally preferable products. Claiming that Canada is making progress on climate change ignores the bigger reality that, absent drastic actions, we are on track to renege on our promises to the international community.

Other examples of greenwashing, or to put it plainly, lying, by Canadian government ministers, are regrettably common. For example, Robyn Allan, former President and CEO of the Insurance Corporation of British Columbia, accused Natural Resource Minister Joe Oliver of resorting to “desperate and false arguments” to sell the Keystone XL pipeline. Allan concludes her article as follows:

Mr. Oliver’s claim that Keystone XL would enhance energy security, create thousands of jobs and support the environment is wrong. For many of us concerned about adding value to our non-renewable resources, meaningful and long term jobs for Canadians, global warming and climate change, his brazen misrepresentations are insulting.

Canadians expect their federal government to demonstrate leadership on climate change.

We also expect them to tell the truth.

Perhaps it’s time to put in place greenwashing rules for governments.

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What Does it Take to Become a Climate Leader?


Image: Duncan Noble

There is a crack, a crack, in everything
That’s how the light gets in

Leonard Cohen, Anthem

Concerning all acts of initiative (and creation), there is one elementary truth, the ignorance of which kills countless ideas and splendid plans: that the moment one definitely commits oneself, then Providence moves too. All sorts of things occur to help one that would never otherwise have occurred. A whole stream of events issues from the decision, raising in one’s favour all manner of unforeseen incidents and meetings and material assistance, which no man could have dreamt would have come his way.

W.H. Murray, The Scottish Himalayan Expedition

I have been resisting becoming a climate change activist. I can resist no more. My heart is broken by what we are doing to our planet. My head is seething with the injustice of it. And now, I know what to do about it.

Chicago is a magic city for me. It sets off eruptions in my heart that reverberate for a long time. In 1998, I attended a conference there on The Natural Step. I was going through some difficult times. It helped me get unstuck. A speech by Paul Hawken touched me deeply, and helped me find the courage to make some difficult decisions.

Fast forward to 2013. I was in Chicago with more than a thousand people from over 70 countries, and all 50 States. We were there as part of the Climate Reality Leadership Corps, being trained to spread the word about the climate crisis, and what to do about it. Al Gore spent the entire day Wednesday going straight through his updated “An Inconvenient Truth” presentation, and then going through it more slowly and in more detail, explaining the transitions between sections, and some of the more complex details. He was a rock star, with an incredible amount of energy and passion. He was also personal and vulnerable, sharing his authentic self. And Gore was only one highlight. There were other incredible speakers, including Jonah Sachs (author of “Winning the Story Wars”), Kim Wasserman (a Chicago community activist who helped shut down a coal fired power plant next to her low income community, and who received the 2013 Goldman Environmental Prize), Maggie Fox (President and CEO, The Climate Reality Project) and many others.

We learned a lot about climate change, and we also learned a lot about how to connect and empower others by telling our own stories. It was truly wonderful to be with so many people that are so aligned, despite our superficially diverse origins, backgrounds and experiences. I met some great people, had some interesting conversations, and plan to stay in touch with many of them. The Climate Reality Project is big on social media; we learned how to leverage social media to tell our story. They also have a good social media infrastructure in place to help people stay connected after the training. I have spent several hours doing just that since being in Chicago. It’s a great way to maintain existing relationships, and build new ones. This seems like a really good way to amplify the impact of a conference.

Carla Shatz famously said “Neurons that fire together, wire together”. I don’t know what the equivalent is for humans that share intense experiences, but whatever it is called, it happened in Chicago.

My time in Chicago was a very positive and empowering experience. I came away from the training with a new perspective. I feel more in touch with my heart, and this seems to make everything easier. I am more comfortable going ahead with things are not yet fully developed – this is a good thing, and helps avoid procrastination. I also feel more open to asking others to help. As the African proverb says: If you want to go fast, go alone; If you want to go far, go together.

So what does it take to become a Climate Leader? It takes knowledge, empathy, courage, convictions, passion, and energy. It takes a rock solid, unshakeable belief that we have the power to change our destiny. We have the power to change our personal destiny and we have the power to change our collective destiny. And, with thanks to The Climate Reality Project Leadership Corps and Chicago, we have the power to get up every day and get it done.

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Book Review: Immoderate Greatness: Why Civilizations Fail by William Ophuls

Immoderate Greatness: Why Civilizations FailImmoderate Greatness: Why Civilizations Fail by William Ophuls

My rating: 5 of 5 stars

View all my reviews

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Greenhouse Effect: CO2 Concentrations Set to Hit Record High of 400 PPM

Duncan Noble:

When I was born, CO2 was 316 ppm. You work it out ;-). At this rate, we are set to blow right past 450 ppm and any hope of staying within 2C of warming in less than 20 years. Not good… It’s up to all of us to rethink everything we do that contributes to CO2 emissions. Where we live, how we move, what we eat. Everything.

Originally posted on Science & Space:

Climate change is, first and foremost, a consequence of the addition of carbon dioxide into the atmosphere. We emit carbon dioxide, through burning fossil fuels or forests, and some of that carbon stays in the atmosphere, intensifying the heat-trapping greenhouse effect and warming the climate. What kind of global warming we’ll see in the future will largely be due to how much carbon dioxide—and to a lesser extent, other greenhouse gases like methane—we add to the atmosphere. And to fully understand the future, we need to understand the present and the past, and track the concentration of CO2 in the Earth’s atmosphere.

The fact that we can and have been tracking that very important number is due largely to the efforts of the geochemist Charles David Keeling. As a postdoctoral fellow at the California Institute of Technology in the 1950s, Keeling developed the first instrument that could accurately measure the…

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Is Sustainability Naked?


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In the story “The Emperor’s New Clothes”, almost everyone is willing to go along with the emperor’s delusion. Only a child is willing to say the emperor is walking around naked. “Out of the mouths of babes…”

There are a growing number of intelligent adults who have concluded that (corporate) sustainability is either dead, walking around naked, or simply not up to the task. I am seeing, perhaps because I am looking for, more and more critiques and alternatives to “conventional” approaches to (corporate) sustainability. Below are a few of the recent ones that stand out for me. Some common themes include:

  • Our current approach to sustainability will not get us to where we want, and need, to go
  • “Sustainability” has been appropriated by the dominant culture to align with non-sustainable goals
  • We need to rethink our overall goals and strategies

Paul Gilding, The Great Disruption

Patagonia’s founder and CEO, Yvon Chouinard, talks with Joel Makower at the 2013 GreenBiz Forum on authenticity, responsibility and sustainability (video)

John Elkington/Volans
Book: The Zeronauts – Breaking though the sustainability barrier.
Breakthrough Capitalism – a program for people to engage with the idea of businesses creating system-level change

John Ehrenfeld and Andrew Hoffman
The wrong-headed solutions of corporate sustainability

As Dana Meadows so eloquently pointed out many years ago (“Places to Intervene in a System“), changing the goals of a system is one of the most powerful ways of intervening in that system to change outcomes. It’s clear that sustainability has NOT changed the goals of our global economic system. Until that happens, can we really expect to see meaningful change?

Posted in Business, Sustainability | 2 Comments

Duncan Noble:

Sometimes it’s not WHAT is said, it’s WHO is saying it. When large (OK, very large, perhaps ginormous) banks are saying this, perhaps Paul Gilding is right that Victory is in sight for the climate movement.

Originally posted on Grist:

London-based HSBC is a banking and financial services company, very old and very large — the sixth largest public company in the world. Greenpeace it ain’t. So it’s striking that the latest report from the financial giant sounds strikingly like the hippie alarmism of a Bill McKibben, a Joe Romm, or a … me. Then again, our hippie alarmism sounds a lot like the science surveys put out by the International Energy Agency, the World Bank, MIT, and the U.S. National Climate Assessment.

So I guess we’re all hippies now.

The report is called “Peak Planet” (you gotta pay for it, unfortunately — Giles Parkinson has a great write-up) and it’s about the threat of climate change and “the next upswing in the climate agenda.”

The broad story HSBC sketches is familiar. If we want to hold warming below 2 degrees…

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