Canada's ENGO's Offensive Response to New Regulations for coal-fired generators

Yesterday the Canadian government announced new regulation for coal-fired electricity generators.

The rules, promulgated under the Canadian Environmental Protection Act, 1999 (CEPA, 1999), set a performance standard of 420 tonnes/GWh, which is the emissions intensity level of Natural Gas Combined Cycle technology, the government said—but it is much higher than the of 375 tonnes/GWh limit proposed in the draft rule....
Federal Environment Minister Peter Kent on Wednesday admitted the new rules are "at the high end" of the 360 to 425 tonnes/GWh range that had been considered, but he defended the decision, saying it would avoid putting the "consuming public at risk of inadequate power supply." The 375 tonnes/GWh performance standard “would have been applicable only if, in the coal-fired electricity sector, plants operated at a steady productivity," Kent said. "In reality, plants go up and down in the generation of energy depending on demand."

Power Magazine: Canada Finalizes GHG Rules for Coal-Fired Power Plants

That all sounds reasonably aggressive to me, as Germany's latest coal plant will reportedly emit 13 million tons of CO2 annually, on production of 16 million MW (~800 tonnes/GWh).  This for a plant the German environment minister references as 'state-of-the-art' as he viewed a demonstration of the plant's ability to ramp up and down to match the variation in the output of renewable wind and solar generators (reference here)

The reaction of the groups Canada's mainstream media considers green didn't mention their pet projects necessitate higher emissions from the fossil fuel plants that must accompany renewables.

Sierra Club Canada:  Coal Regulations: Not enough is still not enough!

“Mr. Kent has never explained how he will enforce regulations 50 years from now,” said Mr. Bennett. “Kent’s announcement is a either a bad joke or an insult to the intelligence of Canadians. It’s amazing he can make these announcements with a straight face!”

Thus spoke John Bennett.
Speaking is not something he does in noting the real Sierra Club's Beyond Coal campaign (US), which was funded by the natural gas industry.
Nor does he note the 398 tonnes/GWh that natural gas generators are estimated to emit, in Ontario, isn't really different. [1]
He seems incapable of noting that a Minister does not speak on behalf of himself.  It isn't a joke to think Canada will exist in 50 years as an entity capable of enforcing regulation.
Mr. Bennett appears to be a joke.

Pembina Institute:  Pembina reacts to federal climate change regulations for coal-fired power

“These changes mean Canada has gone from moving at a tortoise’s pace to a snail’s pace when it comes to regulating coal. We are missing some of the lowest-cost opportunities to curb climate change pollution and are committing Canada to a dirty electricity grid for decades to come.

Slower?
Nonsense.
As stated earlier, the emissions adjustment makes perfect sense in recognizing the higher emissions intensity of generators sharing a grid with industrial wind turbines - the turbines the Pembina Institute generates revenues promoting.
Pembina's Tim Weis tweeted "its hard to believe these regs do anything"
It's hard to believe the Université du Québec à Rimouski granted him a PhD.

Both Weis and P.J. Partington seem aghast that the regulations recognize a 50 year life for coal plants.  While the average age of a US coal unit is less that 50 years, most are still operational (reference).  The average age of a unit being decommissioned is over 50 (reference)

Environmental Defence:  Statement by Gillian McEachern, Campaigns Director on federal coal regulations announced today

50 years is too long to wait to stop pollution from coal. Burning coal creates pollution that has been linked to hundreds of premature deaths from smog every year, causes the accumulation of toxic mercury in fish and wildlife and is the single largest source of global warming pollution in Canada.

More convincing, but:

• scrubbers and other pollution reduction technology can reduce the emissions that contribute to poor air quality.  In Ontario, where 'death' stats are fabricated, they are a minor contributor (references here and here).
• global warming is a global problem.  Remaining cost competitive while reducing emissions is highly relevant in actually impacting global emissions, instead of simply exporting high-emissions activities (reference)
• regarding mercury, just today Mitt Romney is shown as stating the "Utility MACT” rule is purportedly aimed at reducing mercury pollution, yet the EPA estimates that the rule will cost $10 billion to reduce mercury pollution by only $6 million (with an “m”)."   

Very few people are going to promote coal, but the most recent Canada GHG Inventory report (1990-2010) shows Nova Scotia with a generation intensity of 810 g CO2 eq / kWh (up from 760 20 years earlier), Saskatchewan at 770 (down from 810 over the two decades) and Alberta at 840 (from 980).

Clearly the pace of reductions is quickened with flawed, but implemented, regulations.
I don't see what is environmental about ignoring that.

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UPDATE September 8th

Pembina Institute: Addressing "misperceptions" about Canada's coal power regulations

P.J. Partington's follow-up seems to respond to some of the criticism I had.  Specifically he calls "untrue" the move to 420 from 375 (tCO2/GWh) reflects operation intermittently instead of as baseload, but rather the 375 was set to equate to the levels promised by a "modern natural gas plant."

Both are true - intermittency fires up the heat rate, increasing emissions, and 375 is promised by modern natural gas plants.  What is achieved by modern natural gas plants is an entirely different matter.  Analyses of actual heat rates, and therefore emissions, has been done throughout electricity systems with increasing intermittency/renewables, contentiously (Bentek, C. le Pair, Udo, CEPOS).    

It's clear plants don't run as cleanly as possible when not in baseload mode - it is not clear what that performance difference is, in CCGT units or coal units.  

The Pembina study notes possibilities for low emissions from pulverized coal plants - with a link to a 2009 paper touting the possibilities with Carbon Capture and Storage (CCS).   Google "cancelled CCS project" and it will become quickly apparent the technology is not being implemented either due to price, or technological, failings.  On the day the regulations Pembina is criticizing here, another CCS project was being announced in Canada (by Shell, with funding from multiple levels of government).  

Pembina feigns arguing the point that these regulations are among the world's most ambitious.  They change the channel from nations to provinces, noting high-emissions Nova Scotia and Ontario as exemplary.  Since Ontario's emissions peaked in 2000, coal-fired production is down about ~38TWh while nuclear production is up ~25TWh (gas-fired generation up ~12TWh, and demand is down ~11TWh).  If Mr. Partington is impressed with Ontario's current mix of generation he should say so.  

The aggressive 375 tCO2/GWh he is arguing for is 3.5 times greater than what is achieved in Ontario's current supply system where over 50% of the generation comes from nuclear power.

Endnotes:
1:  Ontario Society of Professional Engineers use the figure in "Wind and the Electrical Grid: Mitigating the Rise in Electricity Rates and Greenhouse Gas Emissions" - which they reference as sourced on Natural Resources Canada RETScreen Clean Energy Project Analyse Software.