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Grading BC’s Climate Plan: How does the Roadmap to 2030 measure up to BC’s climate goals?

Photo of report card grading BC's Roadmap to 2030 Climate Plan
November 16, 2021

In late October, the BC government unveiled its long-awaited climate plan, Roadmap to 2030, to tumultuous … criticism. A large majority of the environmental groups commenting on the plan, including ourselves, were less than complimentary.

However, a small group of very knowledgeable climate experts, several of whom had worked on the plan, were vocal about their surprise that these environmental groups would disagree with a plan that (in their view) is world-leading. The resulting conversation has at times become nasty and personal, with the strengths and the weaknesses of the Roadmap lost in the shuffle.

We thought that it would be useful to be more specific about what West Coast Environmental Law finds positive and negative about the Roadmap to 2030, because there are positives and negatives. We’ve structured this as a report card for the BC government based on the specific legal requirements set in BC’s Climate Change Accountability Act, as well as the government’s pledge that this roadmap would lay out the steps BC will take to achieve its 2030 target. We hope that this will enable more focused and respectful debate about specific aspects of the plan.

The grading system is found at the bottom of this post, but in general, an A means the roadmap clearly indicates how BC will achieve the 2030 target AND sets us on a good path to achieve the 2040 and 2050 targets, while an F means that the roadmap either fails to address the target or moves us in the wrong direction. The fact that many of BC’s targets arguably should be stronger is not reflected in the grading – rather, this report card is based purely on existing government commitments; this should not be taken as an endorsement of the 2030 target.

2025 Target – F
Did you forget that this was part of the assignment?!

Did you forget that just last year you established, in accordance with the requirements of the Climate Change Accountability Act, a greenhouse gas (GHG) target for 2025 (16% reductions)? I was frankly shocked that this target is not mentioned once in the Roadmap to 2030.

As the Premier said in launching the Roadmap: “British Columbians, and indeed, all Canadians are focused on making progress on climate change not sometime in the future, but right now.” BC’s climate accountability law, like similar laws around the world, emphasizes the importance of setting and achieving short-term targets – such as the 2025 target – to prevent governments from pushing off difficult decisions into the future. A failure to achieve a short-term 2025 target will make it harder to achieve subsequent targets, and call into question the government’s ability and commitment to doing so.

The Minister’s Climate Change Accountability Report 2021, also released last week, seems to confirm that we are not on track to meet the 2025 target and that additional measures are required to do so, which makes the Roadmap’s failure to even mention the target all the more disappointing.

Transportation Sector 2030 Target – A
Very good

The plans in Roadmap to 2030 related to the legislated 2030 target to reduce transportation-related emissions by 27-32% by 2030 are specific and ambitious. If the rest of the roadmap were as good, the climate plan would be world class, although this section does have the advantage of building on some strong past efforts.

I particularly like the improved and new commitments related to zero-emission vehicle (ZEV) sales which will result in 90% of cars purchased by 2030 being emissions-free (continent leading), and a pledge to set ZEV standards for trucks (medium- and heavy-duty vehicles). Also impressive are the commitments to the Low Carbon Fuel Standard and your intention to extend these rules to maritime and aviation fuels by 2023 (although elsewhere in the Roadmap you commit to only “explore” doing so – please be consistent).

Also, very exciting, if a bit vaguer, is a pledge to have a provincial transportation strategy by 2023 and/or partnerships aimed at getting people out of single-occupancy cars and using bikes, walking and public transit more, and reducing the energy intensity of shipping. Done right, these commitments will help move us beyond the 2030 target.

Well done!

Buildings Sector 2030 Target – B-
A good start!

Last year you set a target to reduce GHGs from buildings by between 59% and 64% relative to 2007 levels by 2030. The measures found in the Roadmap move us towards this goal, but in many cases lack the detail and urgency shown in relation to transportation.

One exciting Roadmap measure is the introduction of low carbon building standards for new buildings starting in 2024, increasing in stringency to net-zero by 2030. Proponents of the plan correctly point out that this puts BC ahead of other provincial governments. Critics point out that the plan means another decade worth of buildings that will need to be retrofitted to achieve the 2050 net-zero target. As the City of Vancouver, which has had low carbon building standards since 2016 and is banning gas heating in many new buildings by January 1, 2022, has put it:

If all buildings are to use only renewable energy by 2050, the sooner new buildings achieve near zero emissions, the fewer buildings there will be that require costly and challenging deep energy retrofits to achieve the target.

In other words, building more GHG-emitting buildings in the coming years will make it harder to achieve the 2040 and 2050 targets. That being said, it’s not possible to achieve net-zero buildings overnight and the key to realizing the potential of this pledge will be to hit the ground running in 2024 with strong standards and then increase them rapidly.

Also important is the commitment to shift subsidies away from natural gas-based heating to climate-friendly options. Buildings’ emissions will also benefit from the province-wide cap on emissions from natural gas utilities.

Other proposals for the buildings sector seem positive, but either do not kick in until 2030 (i.e. new standards for home appliances) or are vague as to when they will kick in or what they will involve. The Roadmap also promises a couple of new buildings-related strategies: a Low Carbon Building Materials Strategy (by 2023, apparently a big year for strategy development in the Roadmap), and a strategy for existing government buildings to achieve a “low carbon and resiliency standard” (by 2024).

Surprisingly absent from the Roadmap is any meaningful discussion of retrofitting existing (private) buildings, which is a key climate measure and a job creation opportunity to boot. The Roadmap mentions “next steps” for the Property Assessed Clean Energy (PACE) program – a pilot project aimed at funding clean energy improvements and other climate solutions – and other commitments that might help fund retrofits. But the CleanBC commitments on upgrading buildings could themselves have benefited from an upgrade.

Despite some very promising initiatives, the Roadmap does not seem to grapple with what needs to be done to achieve targets beyond 2030. In addition, while we are assured that the not-yet-released modelling for the plan shows the 2030 building target being met, we are waiting to see how the not-yet-developed plans are addressed in those strategies. These facts, combined with the vagueness compared to the stronger transportation commitments, warrants a B-.

Oil and Gas Sector 2030 Target – D
Some good work, but contradictory efforts

It’s been almost four years since Premier Horgan pledged that no liquefied natural gas (LNG) project would go ahead unless it could be shown to “live up to the Province’s climate commitments”, and one year since you set a GHG target for the oil and gas industry of 33-38% below 2007 levels by 2030. I naively expected the roadmap to finally answer the question of how BC could achieve its oil and gas targets while building and subsidizing LNG Canada. No such luck.  

Reducing methane emissions in the oil and gas industry by 75% by 2030, in line with recent commitments from the federal government, is a positive step.

However, it is difficult to have a credible plan to address oil and gas emissions without talking about the subsidies that the government gives to that industry. The Roadmap commitment to incorporate the climate targets into the current review of oil and gas royalties is positive, but that’s only part of the challenge posed by the oil and gas subsidies that your government has increased, particularly given that you have never delivered on your 2017 campaign promise of a review of oil and gas subsidies.

The government is also committing to money and policy for controversial technologies such as Carbon Capture Utilization and Storage (CCUS) and Negative Emissions Technologies (NETs). These technologies, done right could play some role in meeting global climate targets. However, they also risk being used to greenwash, and subsidize, ongoing emissions from the oil and gas industry. To its credit, the Roadmap only models a little CCS, and no NETs, in achieving the 2030 target.

Which leaves us with a large gap that will need to be filled if BC expects to meet its oil and gas target. The Roadmap says the Provincial government:

will work to implement policies and programs to reduce emissions in line with [the oil and gas] sectoral target of a 33-38% reduction below 2007 levels. … [O]ur new industrial climate program, to be released in 2023, will be designed to ensure the oil and gas sectoral target is met.

Minister Heyman clarified that the policies and programs to achieve the oil and gas target could “if necessary” include regulations (i.e. legal requirements). This is not a “roadmap,” so much as a commitment to come up with a future plan, in 2023, which will be five years after CleanBC was first launched, to achieve the target. British Columbians are still in the dark on how the province expects to increase oil and gas production while significantly decreasing emissions from this sector.

Interestingly, the Premier, at the launch of the Roadmap, referred to a “cap” on oil and gas emissions, as did some other validators. A “cap” refers to a law that restricts the ability of a person or industry to emit more than a certain amount of GHGs. This commitment is not found in the Roadmap, although the federal government seems to be moving towards such a cap. If the Premier is rewriting the Roadmap, and promising that a legislated cap will be in place by 2023 (or, better yet, earlier), this would be a much more powerful commitment that could significantly increase your letter grade for this target.

The bottom line? The Roadmap does not show in any meaningful way how BC will achieve the oil and gas target, and an explanation has been promised for at least three years. This failure is occurring at the same time that you are subsidizing the oil and gas industry. In the meantime, commitments by investors to divest their holdings in oil and gas companies are gaining momentum. On the whole, we think a D grade is deserved.

Industrial Sector 2030 Target – C+
More detail would be helpful

As you know, you have pledged to reduce industrial emissions (not counting oil and gas) by between 38% and 43% by 2030.

Your Roadmap appears to rely primarily on an enhancement of the BC government’s CleanBC Industry fund. Although the Roadmap could include more details, this presumably means that the increase in the carbon tax to $170/tonne by 2030 will be used to funnel a lot of money into industrial decarbonization. If that’s correct, this could help BC’s industries re-invent themselves and (hopefully) achieve the 2030 target, although more detail would have been helpful.

The Roadmap also aims to virtually eliminate methane from industry by 2035 (which presumably will mean significant reductions by 2030 also) and promises to require large-scale industrial projects to show how their emissions will be consistent with the 2030 and 2040 targets and net-zero by 2050 (at a broad level much of this is already required by the BC Environmental Assessment Act, but hopefully we can expect more detail).

As with several other sections, these parts of the Roadmap would have benefited from more detail and more concrete steps. 

2030 Target – C
Show your work

At the end of the day, the Roadmap claims to show how BC will achieve a 40% reduction in GHGs by 2030 across the entire economy. But does it? 

I have no doubt that the model shows that we will achieve our 2030 target. However, at several points the actual measures being modelled are pretty vague (sometimes just a plan to make a plan). It is difficult to comment on modelling that hasn’t been released yet, but for these measures the model cannot be calculating the likely emissions reductions from measures that don’t exist yet. Rather, I would suggest that the model simply assumes that those measures (whatever they may be) will be stringent enough to achieve the required additional emissions reductions. That is not a roadmap. It is a model that assumes the result of a plan in accordance with what it’s told to do.

We need a roadmap that is sufficiently detailed that someone could take the measures without knowing what the expected result is supposed to be, and determine that the plan will achieve emissions reductions somewhere in that ballpark. I’m not convinced that the Roadmap to 2030 does that.

Moreover, promising to have a plan for key components of the Roadmap in a few years is not the same as having a plan now. For one thing, if you have a plan now, you can start implementing it in the next year or two. If you’re not going to have a plan until 2023 or 2024, then it’s not going to hit the ground until the second half of this decade.

It is positive that many of the commitments in the Roadmap are based on scaling up existing programs, which can be done more quickly, but there is still going to be a tonne of work and commitment required to keep to the timelines that are assumed in your model.

On the whole, I do not think it’s accurate to say that the Roadmap sets out a path to 2030.

That being said, we should celebrate the important measures found in the Roadmap that will certainly get us a long way forward. Some of these have been discussed above. Others are economy-wide measures that will help with all of the sectors, such as:

  • Pledging to meet or beat the Canadian government’s commitment to increase the carbon tax to $170/tonne by 2030;
  • The development of a circular economy strategy by 2022; and
  • Regular reporting on process to implement the Roadmap.

Also of note, although more controversial, is the commitment to cap GHG emissions from natural gas utilities to six megatonnes (about 15% of the 2030 target). While this should reduce emissions from natural gas to about 47% of 2007 levels, it ignores uses of natural gas which could and arguably should be easily be replaced with existing technology.

Conclusion

The Roadmap to 2030 assignment was intended to provide … well, a roadmap, including details about where we would be in 2025, en route to 2030, and how to stay on course throughout the decade. While parts – notably commitments related to transportation – have that level of detail, much of the Roadmap remains, in the words of one journalist, “vague and unclear … aspirational but no hard figures in many areas.”

At the end of the day, I would be a whole lot more willing to forgive the areas where the 2030 Roadmap is vague if it had included a clear plan to achieve the 2025 target. I also think that in areas, such as oil and gas, where the government has a history of trying to have its cake and eat it too, it’s particularly important to have clear commitments and details.

The important part of the Roadmap is not every single detail of what we need to do in 2030, but rather what we need to do tomorrow and next year, which will allow us to get to our 2025 target and prepare for what we need to be doing in 2030. By that measure, the Roadmap does not deliver.

The grading system

A (A-/A/A+) – The roadmap specifies clearly the measures that will enable BC to achieve the 2030 target and sets us on a good path to achieve the 2040 and 2050 targets.

B (B-/B/B+) - The roadmap specifies clearly the measures that will enable BC to achieve the 2030 target but will make achieving the 2040 or 2050 targets more difficult.

C (C-/C/C+) – The roadmap identifies important measures that will move BC towards achieving the 2030 target, but more measures will need to be identified in the future to achieve the 2030 target.

D – The measures identified by the roadmap are clearly inadequate to achieve the target or are offset by other government action that moves in the wrong direction.

F – The roadmap fails to address the target or overall moves us away from achieving the target.

Author: 
Andrew Gage - Staff Lawyer