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Measuring the Success of British Columbia’s Renewable and Low Carbon Fuel Regulation

British Columbia’s (B.C.) Greenhouse Gas Reduction (GHGR) Targets Act (GHGRTA) contains ambitious goals of reducing province-wide greenhouse gas (GHG) emissions by 33% in 2020 and 80% in 2050 (relative to 2007). With ~38% of B.C.’s GHG emissions stemming from transportation (in 2012), it is clear that B.C.’s GHG emissions reduction goals can only be realized with an effective transport fuel policy. Enacted in December 2009, the GHGR Renewable and Low Carbon Fuel Requirement (RLCFR) Act and Regulation have achieved significant GHG emissions reductions accredited to its enforcement with 904,900 t CO2eq emissions reduction in 2012. At face-value, this is a great success. However, there are several accounting issues that suggest these GHG emissions reductions are inaccurate.
In a recent study published in Biofuels, we show that the RLCFR legislation has not been nearly as effective as proclaimed by the B.C. government. Nevertheless, this transport fuel regulation is essential if B.C. wants to achieve its future GHG emissions reduction targets.
If you’d like more details, please feel free to contact us. Otherwise, here’s a brief overview of the paper…

An Intro to BC’s fuel regulation

With overwhelming consensus (Cook et al., 2013), it’s become clear that human-induced climate change is a serious issue and this has led to a number of local jurisdictions stepping up their climate action plan with bold targets written into legislation, where B.C. is poised to be at the forefront. Taking inspiration from California’s Greenhouse Solutions Act (approved September 2005) the Liberal government of B.C. first expressed their ambitious GHG emissions reduction targets during the reading of the provincial Throne Speech in February 2007 with now legislated targets of reducing GHG emissions by 33% in 2020 and by 80% in 2050—relative to GHG emissions in 2007 (64.3 Mega tonnes (Mt) CO2eq) (Sodero, 2011). One act/regulation that has gained particular notice is the GHG emissions reduction Renewable Low Carbon Fuel Requirements (RLCFR) Act/Regulation of B.C. (B.C. Government, 2014), because it has been noted and given media attention as being B.C.’s most effective climate legislation to date in terms of reducing GHG emissions (Thomson, 2015; Wolinetz & Axsen, 2014).
Enacted in December of 2009, the RLCFR Regulation requires two main conditions of large-scale (greater than 75 million m3 per year) transportation fuel suppliers of B.C. Firstly, these fuel suppliers are required to blend their fossil gasoline and diesel fuels with at least 5% and 4% of renewable fuels, respectively (B.C. Government, 2014). Secondly, these fuel suppliers must ensure that the life cycle carbon intensity (CI) of their fuels is below the CI limit prescribed during a given year, where this CI limit is set to be reduced by 10% from 2011 to 2020 (B.C. Government, 2014).
According to B.C. government accounts the RLCFR has been a success thus far, where in its first three years, GHG emission reductions attributed to the RLCFR have increased: 558.7 Kilo (K) tonnes (t) CO2eq in 2010 to 904.9 Kt CO2eq in 2012 (B.C. Government, 2012). In fact, a recent report has stated that the RLCFR is currently B.C.’s most important piece of climate legislation where it has contributed to 25% of B.C.’s GHG emissions reductions in 2012, relative to the 2007 baseline year (Wolinetz & Axsen, 2014). With this early success, it is important to ask how this reduction in GHG emissions is being calculated and whether there are any important life cycle accounting measures being left out of the equations.

What the study did

The study looked into the details of the RLCFR of B.C. to firstly understand how past GHG emissions reductions that are being reported and accredited to the RLCFR are being calculated. Secondly, this study highlighted two key CI accounting items that the RLCFR neglects to consider: incorporating indirect land use change (iLUC) and developing fossil fuel CIs that are representative of the fossil fuel mix of a given compliance period.

Now let’s take a closer look at iLUC.

Why iLUC is important

The inclusion of iLUC is important because GHG emissions due to iLUC can lead to a significant increase in CI (Broch, Hoekman, & Unnasch, 2013). For instance, Ahlgren & Di Lucia (2014) undertook a review of iLUC modelling results and found iLUC factors for corn and wheat ethanol to range from 7 to 104 g CO2eq/MJ and -80 to 155 g CO2eq/MJ, respectively. For canola, soy and palm-based biodiesel, iLUC factors ranged from 2 to 220 g CO2eq/MJ, 2 to 270 g CO2eq/MJ and 3 to 114 g CO2eq/MJ, respectively (Ahlgren & Di Lucia, 2014). These iLUC factors are substantial given that the most recently approved CIs (iLUC not included) reported by the B.C. Government for ethanol, biodiesel and hydrogenated derived renewable diesel (HDRD) ranged from -4.23 to 70.36 g CO2eq/MJ, -0.05 to 38.32 g CO2eq/MJ, and 18.16 to 63.66 g CO2eq/MJ, respectively. The inclusion of iLUC factors for B.C.’s dedicated crop‐based ethanol and biodiesel fuel sources would dramatically change the perceived benefits of a renewable fuel that is derived from cropland.

What we found in the accounts as reported

In terms of total GHG savings, the reported GHG savings are 12% higher than those calculated in this study using the regulation’s equation. As illustrated in figure 1, the main disparity stems from GHG savings due to the use of biodiesel and HDRD fuels. In all cases, except for propane, the reported savings tend to be higher than the values we calculated using the regulation’s specified equation.
Figure 1: Greenhouse gas savings (kilotonnes [Kt] CO2eq) in the year 2012 attributed to the RLCFR Regulation for each alternative fuel type. Values are presented as those reported in the government accounts and as a result of own calculations. Percentage values represent the C/¡ % difference of calculated results relative to reported values. HDRD = hydrogenated derived renewable diesel; CNG = compressed natural gas; LNG = liquefied natural gas.

Figure 1: Greenhouse gas savings (kilotonnes [Kt] CO2eq) in the year 2012 attributed to the RLCFR Regulation for each alternative
fuel type. Values are presented as those reported in the government accounts and as a result of own calculations. Percentage
values represent the C/¡ % difference of calculated results relative to reported values. HDRD = hydrogenated derived renewable
diesel; CNG = compressed natural gas; LNG = liquefied natural gas.

How reductions change when iLUC is included

GHG savings are greatly reduced when the average iLUC factors are included. In some cases, from this GHG perspective it would have made more sense to use conventional petroleum-based gasoline and diesel in place of these GHG intense crop derived ethanol and HDRD supplies consumed in B.C. These significant fuel-specific reductions in GHG savings, in turn, equate to significant reductions in total 2012 GHG saving, as is depicted in figure 2.
Figure 2: Total greenhouse gas emissions savings in the year 2012 that are attributed to the RLCFR Regulation when iLUC factors are included. Total values are calculated using own calculations. Calculated and reported savings with no iLUC factors are also included (horizontal broken lines) for comparison. SD = standard deviation of iLUC factors. ‘#’ yr AP = amortization period (years) to divide iLUC related GHG emissions across; K = kilo ('000). Negative values indicate no savings or a net burden.

Figure 2: Total greenhouse gas emissions savings in the year 2012 that are attributed to the RLCFR Regulation when iLUC
factors are included. Total values are calculated using own calculations. Calculated and reported savings with no iLUC factors are
also included (horizontal broken lines) for comparison. SD = standard deviation of iLUC factors. ‘#’ yr AP = amortization period (years) to divide iLUC related GHG emissions across; K = kilo (‘000). Negative values indicate no savings or a net burden.

Figure 2 displays the range of total 2012 RLCFR-related GHG savings when iLUC is factored into the calculations and it clearly shows the importance of including iLUC where even the application of median iLUC factors can lead to greater than 50% reductions (see triangle markers in figure 2) in total GHG savings. As the amortization period increases, the range of GHG savings converges because the iLUC factors decrease. When a 30 year amortization period and the median iLUC factors are applied, total 2012 GHG savings are reduced from the reported 904.9 Kt CO2eq, to 505.4 Kt CO2eq—a significant 44% decrease.

Some important points of discussion

Another important caveat that is lost in the RLCFR reported total savings lies with electric mobility. The majority of GHG savings attributed to electric mobility stems from B.C.’s lower mainland (greater Vancouver area) sky-train and trolleybus system in which most of this transport network existed well before the RLCFR regulation was enforced in 2010. In other words, the RLCFR cannot claim any sort of additionality or credit for implementing the vast majority and if not all of this low-carbon mode of electric public transportation.
Another concern is that there is no public RLCFR documentation that provides an explanation as to why iLUC is not accounted for. Uncertainty should not be an argument for systematically excluding iLUC from the life cycle CI of a biofuel (Muñoz et al., 2015). Even with the level of uncertainty in iLUC factors to date, including iLUC gives us an indication of an extremely relevant hotspot that should not be overlooked. The inclusion of iLUC makes the CIs of biofuels more accurate, not less. In other words, it is better to be ‘approximately right than precisely wrong’.
In the immediate short term the RLCFR regulators need to provide a better publicly accessible explanation of why they are not including iLUC. This explanation should be accompanied with an implementation plan that clearly states milestones and methods for generating iLUC factors to be incorporated into the RLCFR Regulation.
There are numerous reasons to remain optimistic that technological innovation will enable the goals of the RLCFR Regulation to be realized. It is becoming increasingly clear that carbon capture and storage systems will need to be integrated with oil sands related processing units, upgraders and refineries. For instance, results from Cai et al. (2015) indicate that around 16.3 to 39.7 g CO2eq/MJ diesel occurs during the oil sands recovery (9 to 30.1 g CO2eq/MJ diesel) and refining (7.3 to 9.6 g CO2eq/MJ diesel) processes. If CCS units can create even a 50% net reduction in these life cycle emission sources, then B.C.’s increasingly stringent CI limits will be easier to reach.
B.C. needs to continue research, development and provide economic incentives until regional waste wood and agricultural residue-based diesel/ethanol (i.e. 2nd generation biofuels) can be generated at a commercial scale. Generating fuels from such sources have proven to exhibit substantially lower life cycle GHG emissions (in the range of ‐5 to 30 g CO2eq/MJ) than their petroleum counterparts and iLUC is not a significant issue (Chum et al., 2011).
One of B.C.’s big transport related GHG solutions resides in electric mobility. Given B.C.’s vast quantity of hydro power resources and a correspondingly low electricity grid CI, the Government of B.C. has a great opportunity for incentivizing the increased adoption of personal electric vehicles (PEVs). The commercial availability of PEVs is global, and with an already developed and expanding network of charging stations, B.C. is ripe for increasing PEV share in the personal motor vehicle fleet. Smart meters could also be used to account for domestic EV charging and thus increase measured GHG emissions reductions from personal EV transport in B.C. However, caution and analysis is required to ensure PEVs do not end up as just a secondary family vehicle (due to the currently low mileage per charge) and PEVs do not significantly displace more GHG friendly modes of transportation, like bus (trolley), sky train, bicycling and walking.

For a full list of references and more details please contact us…


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About

Ecogamut Consulting – helping you achieve your sustainability goals

At Ecogamut, making sustainability metrics work for you is the bread and butter of our operation. Our toolbox of expertise includes life cycle assessment, environmental product declaration, carbon footprinting, carbon offsetting, and climate change adaptation strategies. With a team of Ph.D.-level experts you can be rest assured that Ecogamut will deliver a high quality and high impact product that will effectively direct your organization or jurisdiction towards its most cherished sustainability goals.
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Have a sustainability project on your mind and think we can help? Contact info@ecogamut.ca


Canada’s Environmental Scorecard on Agriculture

im McCabe / Photo courtesy of USDA Natural Resources Conservation Service.

With nearly sixty-five million hectares of land for crops and livestock production, Canada is among the largest agricultural sectors in the world. Agriculture and Agri-Food Canada (AAFC) has recently published their fourth Agri-Environmental Indicators report providing an insightful look into a number of sustainability metrics used for measuring the environmental trends (1981 to 2011) in Canada’s agricultural sector. In this post we’ll take a glance at the sustainability trends of Canada’s agricultural sector over the past twenty years through four nation-wide environmental indices.
Trends for the four Compound Sustainability Indices that are currently applied in AAFC's Agri-Environmental Indicator reporting

Trends for the four Compound Sustainability Indices that are currently applied in AAFC’s Agri-Environmental Indicator reporting (adapted from AAFC’s report)

It should be kept in mind that AAFC’s science based agri-environmental indicators as presented above are a nation-wide summary of environmental performance covering a range of different environmental indicators across Canada’s diverse regions and commodity mixes. You’re urged to dig deeper into the different indices and region-specific results by following this link.

Biodiversity

The overall trend from 1981 to 2011 for biodiversity shows steady and consistent improvements across Canada, moving from a ‘Poor’ status in 1981, to a ‘Moderate’ status in 2011, as depicted by the Biodiversity Compound Index above. This compound performance index is a weighted average of the Soil Cover and Wildlife Habitat Capacity performance indices.1 As such, it is a highly  statistical snapshot of these two variables both in terms of current state and over time.2 The improvements are largely due to changes in tillage practices reflected in the Soil Cover Indicator in particular. The use of reduced tillage and no-till has been increasing continuously since the early 1990s, as a means to reduce fuel costs and improve soil health. Between 2006 and 2011, the total area of agricultural land under intensive tillage declined by 30.9%. In 2011, no-till land management was applied on more than 50% of all agricultural areas prepared for seeding in Canada (Statistics Canada, 20116). This reduction in tillage, coupled with the decreased use of summerfallow, resulted in a national-scale improvement in average levels of soil cover in Canada. From 1981 to 2011, average levels of soil cover in Canada increased by 7.6%.
From 1986 to 1996, wildlife habitat capacity (WHC) was relatively stable; however from 1996 to 2011 there was an overall decline in WHC at the national scale, despite the drop in summerfallow (which offers limited capacity for wildlife) and rise in soil cover. The decline in WHC was primarily due to the intensification of farming as well as the loss of natural and semi-natural land, mainly resulting from the shift away from pasture and forage production to annual cropping, especially in Eastern Canada.

Soil Quality

Considering various aspects of soil quality together, as illustrated in the Soil Quality Compound Index above, agriculture’s environmental performance has a ‘Good’ status, and has significantly improved over the 30-year period preceding 2011. This compound index is a weighted3 average of the performance indices reported for the Soil Erosion, Soil Organic Carbon and Soil Salinization Indicators, plus findings from the Trace Elements Indicator (extrapolated from previous years, not reported in this publication).4 As such it is a highly generalized statistical snapshot of soil health, both in terms of current state and over time.
Improvements to the Soil Quality Compound Index can be directly attributed to improvements in land management practices, such as increased adoption of reduced tillage and no-till practices, and the reduction in area under summerfallow. The improved performance was driven by the Prairie Provinces where cultivated agriculture is extensive and is dominated by cereals and oilseeds. This agricultural region is most amenable to reduced-till and no-till practices. Increased soil cover resulting from these has led to a significant increase in soil organic matter. The reduction in tillage has also led to a reduction in soil erosion risk, notably tillage erosion, which has historically accounted for the majority of erosion losses (followed by wind and then water). The extensive reduction in area of summerfallow has also improved soil health, leading to a reduction in soil erosion – particularly from wind and water; and has also reduced salinization risk.
Generally, higher rainfall in Ontario, Quebec and the Atlantic Provinces compared to the Prairies supports more intensive agriculture and a different mix of crops. These regions have seen a shift away from pasture and forage production, following the decline in cattle production in 2006, towards row crops which offer less soil protection. However, as the majority of agricultural land is sited in the Prairies, where soil health is improving, the national picture is also one of improvement for soil health.

Water Quality

Considering various aspects of risks to water quality together ,5 agriculture’s environmental performance currently has a ‘Good’ status. It does however represent an overall decline from a desired state in 1981. This overall declining performance is mirrored by the individual indicator performance indices, which moved from ‘Desired’ status in 1981 to ‘Good’ status in 2011, with the exception of the Phosphorus Indicator, which moved from ‘Desired’ status to ‘Moderate’ status. The deterioration in the index can be attributed to increased application of nutrients (N and P) as fertilizer and manure as well as an increased use of pesticides across Canada.
The declining agri-environmental performance was observed in all regions of the country. In the case of nitrogen, the levels of residual soil nitrogen have increased steadily as inputs from fertilizer and manure in particular have increased at a faster rate than outputs from crop harvests, gaseous losses and leaching. This soil nitrogen is most readily available in the form of water-soluble nitrates, which are at risk of leaching to ground water and, where fields are tile-drained, into drainage water, which can then be directed into ditches, streams and rivers.
Despite this increasing risk, the Nitrogen indicator remains in the ‘Desired’ category. In the case of phosphorus, performance has declined quite dramatically from ‘Desired’ in 1981 to 1991, dipping to ‘Good’ in 1996, recovering to ‘Desired’ in 2001 and declining since that time. This report is the first time this indicator has been classified as ‘Moderate’, reflecting a combination of phosphorus source and transport. Increased surpluses in soil-phosphorus in all regions reflect national increases in fertilizer and manure application as well as increased concentration of livestock. Added to this increased source is the much higher than average runoff in 2011, following a very wet spring throughout the Prairies. This increased runoff increased risk by flushing much of the built-up soil phosphorus into surface waters.
While overall livestock numbers have decreased on a national scale, there is a growing trend towards larger operations, with higher concentrations of animals. A consequence of this increase is that on-farm manure capacity can grow to exceed the capacity of surrounding land to use it as fertilizer, sometimes leading to higher application rates. As a result, the Coliforms Index has deteriorated from ‘Desired’ in all preceding years, to ‘Good’ in 2011. In the case of pesticides, the risk of water contamination has increased on about 50% of cropland over the past 30 years. The index has deteriorated from ‘Desired’ in all preceding years to ‘Good’ in 2011. The highest risk increases occurred in the Prairies between 2006 and 2011 where the area treated by fungicides doubled. This increase, as well as increases in herbicide use, can be attributed to the switch to reduced tillage and no-till which necessitates the use of pesticides to control weeds and diseases (reduced tillage systems are more susceptible to fungal diseases). The increased risk can also be explained by a shift away from pasture and forage to cropping systems that require more pesticide inputs and, to a lesser extent to wetter weather in the Maritime Region in 2010.
Increased efforts are required throughout Canada to minimize the risk of nutrient, pesticide and coliform movement to surface water bodies and leaching beyond the rooting depth of vegetation. This is particularly so in higher rainfall areas of the country. This risk can be further reduced through practices such as regular soil testing and better matching agricultural inputs application to field conditions. Practices that mitigate surface runoff, such as establishing riparian buffer strips, winter cover crops, maintenance of surface residue, etc. will also contribute to a reduced risk to water quality.

Air Quality

Considering various agricultural atmospheric emissions together,6 agriculture’s environmental performance in air quality is ‘Good’, having been relatively stable between 1981 and 2006, and then significantly improving to 2011. This improvement is mirrored by improvements in all the individual performance indices within this theme.
Improvements in land management practices such as increased adoption of conservation and no-till practices, reduced use of summerfallow, and increased forage and permanent cover crops were primarily responsible for the improved agri-environmental performance for air quality. Adoption of these management practices, particularly in the Prairies, led to soils becoming a net sink for atmospheric carbon, which means more carbon is being sequestered in soil than is being emitted, leading to a reduction in overall greenhouse gas (GHG) emissions. The same practices have led to improvements in particulate matter (PM) emissions over the period of study. A decrease in numbers of livestock across the country between 2006 and 2011 is the primary reason for the improvements in the ammonia emissions performance index, which now sits at just above 1996 levels.
Land management practices that favour sequestration of carbon in the soil, such as reduced tillage and residue management practices to maintain soil cover, need to be continued and expanded in order to maintain and increase the amount of carbon dioxide removed from the atmosphere and stored in the soil. Similar practices that reduce the number of field operations and protect the soil surface from wind erosion are effective in minimizing PM emissions. Improved animal feeding strategies and more efficient use of nitrogen in agriculture are examples of beneficial management practices (BMPs) that can be used to mitigate emissions of methane, ammonia and nitrous oxide.
In future posts, I’ll delve deeper into each of these environmental indicators to better understand key regional differences, and reasons for poor or desirable environmental performance as well as take a closer look at some promising current and prospective best management practices available for farmers to implement.

1. All national “core” indicators, to include Soil Cover and Wildlife Habitat Capacity on Farmland have a weighted value of 1.
2. More information on how performance indices are calculated can be found in Chapter 2 “Assessing the Environmental Sustainability of the Agri-Food Sector.”
3. All national “core” indicators, to include Soil Erosion, Soil Organic Carbon and Trace Elements have a weighted value of 1. In the case of Soil Salinization Indicator, which covers only the Prairie extent, its weighting is reduced to 0.81 to reflect the percentage of farmland area under coverage.
4. The Risk of Soil Contamination by Trace Elements Indicator was developed for the 1981 and 2006 Census years only and therefore does not have a Chapter designated to it in this publication. However, since these trace element values are not likely to change significantly from year to year at the scale of analysis used in this report, they have not been recalculated for 2011. Instead, the 2006 trace element values were extrapolated for use in the 2011 year, and were included in the calculation for the overall Soil Quality compound index.
5. The Water Quality Agri-Environmental Performance Index combines indices for water contamination by nitrogen (N), phosphorus (P), coliforms and pesticides.
6. The Air Quality Agri-Environmental Performance Index combines indices for greenhouse gases (GHGs), particulate matter (PM) and ammonia emissions from agriculture.



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About

Ecogamut Consulting – helping you achieve your sustainability goals

At Ecogamut, making sustainability metrics work for you is the bread and butter of our operation. Our toolbox of expertise includes life cycle assessment, environmental product declaration, carbon footprinting, carbon offsetting, and climate change adaptation strategies. With a team of Ph.D.-level experts you can be rest assured that Ecogamut will deliver a high quality and high impact product that will effectively direct your organization or jurisdiction towards its most cherished sustainability goals.
———————————
Have a sustainability project on your mind and think we can help? Contact info@ecogamut.ca