2 attachments. Submission - Climate Leadership Plan Mon 17/08/2015 7:25 AM. Good day,

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1 Submission - Climate Leadership Plan Mon 17/08/2015 7:25 AM To: Climate Leadership Plan ENV:EX;... 2 attachments Good day, Marine Renewables Canada would like to take this opportunity to comment (content below) on the BC Climate Leadership discussion document and to resubmit commentary (attached) we offered last month. We are a membership of about 100 companies, researchers, governments and utilities that make up the national leadership association, Marine Renewables Canada. This successor organization to OREG, which was founded by marine renewable energy interests in British Columbia, has significant membership from BC, with several companies already active in this emerging international industry. We have engaged throughout the last decade in all energy and climate action strategic discussions in British Columbia, including the multi sector Electricity Climate Action Working Group, a few years ago. We have witnessed a loss of momentum that is perhaps at odds with the Need for Action element of the discussion paper: Pursuit of emerging energy options, included in the Clean Energy Act, has never materialized The directive to BC Hydro to consider socioeconomics in planning has been reversed so that there is no effort to treat the energy needs of the province as a lever for development of the region s clean energy industry The long-term planning of the system required in the BCUC Section 5 Enquiry, has not been addressed in the most recent BC Hydro resource options analyses The Innovative Clean Energy Fund has been limited in its action and scope The carbon tax has now been capped, rather than being a progressive levy on carbon-based energy use to replace taxes on economic production, and The designation of natural gas as clean in its use for LNG production, and agreement to exempt that industry from any additional cost exposure to carbon fuel consumption, relieves this new industry from any pressure to join the action noted above. We believe that the four areas of action identified in the discussion paper are in fact all crossed by two fundamental policy objectives that were a part of BC s climate action leadership in the past: Shifting taxation to hydrocarbon fuel consumption and away from economic-, wealth- and jobcreation changed individual and business approaches The world-wide shift to decarbonize the economy clearly means that this new phase in our industrial revolution creates new clean-energy-based economic, business and career opportunities. In particular, we feel that the What We Value action focus/goal creates some confusion and perhaps perpetuates a belief that climate action is a cost rather than an investment now to reduce costs later, or in fact an investment in a way of doing things that can endure for generation. We believe that a simple, consistent and progressive pricing of hydrocarbon energy is the most straightforward mechanism to encourage businesses, communities and individuals to make the best climate action choices. Softeners such as..improve the affordability of solutions or complicators such as targets for types of emissions and..regulations and incentives may defeat the objectives of a carbon price being used as a tax transition. We believe that a clear focus, strategy and policy to engage British Columbia as a significant player in the new clean-energy-based economy will be the essence of a renewed climate leadership initiative. Past discussions have shown that traditional industry sees market value in Produced in BC using North America s cleanest energy, and that we already have a basis for existing and new business and careers in the a new world-wide industry. The needs of existing industry, and certainly any new industry like LNG are the markets that qualify us for the international challenge. In The Way We Work, we see the clean

2 technology opportunity as closest to this focus, but see some confusion created by wording that refers to...global carbon markets, global carbon offset markets and exporting innovation worldwide. In The Way We travel, we clearly believe that BC s existing and potential renewable electricity is the biggest lever to respond as a carbon price makes hydrocarbon fuels a less-acceptable cost to business and individuals. This is an option for (almost) all in the province, but it may involve lifestyle decisions! With regard to The Way We Live, we assume that a carbon pricing regime will change the way we all make decisions; it apparently already has. However there may well be a role for government in its ability to use building codes and any support to communities to accelerate the transition of infrastructure investment to meet the needs of the future rather than follow the experience of the past. All in all, we are glad to see a reboot of the climate leadership discussion. To summarize, we believe that a focus on the existing carbon tax shift approach, and on British Columbia s extraordinary opportunity for an expanded and diverse clean electricity supply, and industry, is the simplest leadership step through which most of the goals discussed can be met. As always, we have members and others who can meet with the team if any additional information is needed. Best Regards, Elisa Obermann Executive Director Marine Renewables Canada marinerenewables.ca P.O. Box Halifax, NS B3J 3S elisa@marinerenewables.ca

3 July 14, 2015 To: Climate Leadership Team Members and Advisors Dear All: RE: Marine renewable energy an economic and climate action opportunity As Canada s national sectoral leadership association for marine renewable energy, we are encouraging the Climate Leadership Team to look at the unique economic opportunity that British Columbia has in matching its resource and industrial strengths with climate action. In light of this activity, Marine Renewables Canada would like to offer some suggestions on action items that are aligned with the Climate Leaderships Team s mandate. The Climate Leadership Team s mandate, to be fulfilled by Nov. 30, 2015, is to provide advice and recommendations on: How to maintain B.C. s climate leadership: Create a short-term focus on off-grid diesel displacement using marine and other resources and small to medium size commercial marine renewable energy facilities in the long term; Develop the clean energy cluster vision developed by BC Hydro/KWL in 2009, supporting a transition to a more robust and distributed electricity system e.g. Vancouver Island currently only generates about 30% of it s own power; Role model for the world: Focus on selling BC clean energy technology and services to a global market demanding future energy solutions Updates to the current Climate Action Plan as well as new programs and policies required to meet B.C. s greenhouse gas reduction targets while maintaining strong economic growth and successfully implementing the BC Jobs Plan, including the liquefied natural gas strategy: Considering the significant GHG impact of natural gas emissions and burning natural gas to generate power for the first generation LNG plants (built before Site C), there should be investment (through the Innovative Clean Energy Fund, the carbon tax or a Clean Energy Fund) for a diversified clean energy project portfolio to offset this over time; Marketing marine renewable energy technology and services into the emerging global market represents a significant opportunity for the BC Ocean Industry sector

4 Actions to achieve GHG reductions required across the industrial sector, transportation sector and built environment: Marine renewables can have an immediate impact on GHG reduction through an off-grid diesel displacement initiative for coastal and river communities and industries. how to further the Province s government-to-government relationships with First Nations while constructively finding climate solutions; and Clean power for off-grid communities, especially First Nations will support economic activity in those communities, but may offer opportunity for ownership or partnership in which they gain economic sustainability through providing a clean energy service. How to further the Province s collaboration with local governments within the context of mutually-beneficial climate actions: Coastal communities are interested in sustainable development of local resource opportunities. The communities of Campbell River and Ucluelet have both been keen to see development of local tidal and wave resources. I have attached a short opportunity discussion document. As the Ocean Renewable Energy Group, and more recently as Marine Renewables Canada, we have been happy to contribute to past discussions on BC s climate action, energy and economic futures. We would be happy to respond to any questions or to brief members of the Team. Sincerely, Elisa Obermann Executive Director, Marine Renewables Canada

5 Input Climate Leadership 2015 An action focus 1. Recognise the critical need to develop renewable electricity resources that maybe independent of climate change and provide for security of supply. 2. Address this within the climate/economic action plan, by adopting a strategy to capture the energy diversification and economic opportunities offered by using wave, river and tidal energy to meet climate action goals. 3. Recognise that the huge resource opportunity + the fit with BC marine, power technology and IPP industry + the currently open market leadership opportunity = a strategic advantage unique to renewable marine renewable energy creating a global economic development opportunity as well as a local energy diversification opportunity. 4. Recognize that the needs of 2025 and 2050 can only be met if development begins in a. Instruct BCUC and BC Hydro to develop an Emerging Energy Standing Offer to complement the Standing Offer for commercially proven technology - commit them to power purchase agreements that enable project development of 50 MW each of wave and tidal capacity by 2025 (already enabled in the Clean Energy Act). b. Challenge BC Hydro to implement an emerging energy development pathway R&D by Powertech Labs, support for academic research chair and Centre of Excellence, enabling partnerships in development projects aimed at improving costs of production and proving reliability. 5. Ensure that a permitted, grid connected tidal development site near Campbell River, and a similar wave energy site near Ucluelet are developed within 2 years. 6. Ensure that any Cap and Trade, Carbon or emissions trading scheme is incented to diversify the energy portfolio renewable energy credits from strategic resources be more valuable so that more expensive emerging energy opportunities attract the offsets on a preferential basis with commercial initiatives. The BC Opportunity British Columbia s economic history is vested in its use of the ocean to supply a world seafood market and its seaways to deliver resources to industry and goods to market. These natural resources were developed through the evolution of 1

6 the Province from pre-contact to recent social, economic and industrial growth. As the world moves to reduce climate change causes and to mitigate impacts, once again the ocean provides BC with a strategic advantage. BC is almost uniquely endowed with enormous resources in wave, tidal and in-stream river energy. These perpetual renewable resources can be a significant part of the climate action toolbox. They can also be the basis of a new low-carbon opportunity for the businesses, communities and economy of the coast. In undertaking action on climate change, British Columbia can diversify its electrical resource options and attract economic benefits directly from development of new energy infrastructure. However, government, utilities, industry and the research community must move toward implementation of a regionally focused marine renewable energy development initiative. The high-point in recent climate and energy discussions was the inclusion of wave, tidal and river energy as targets for an emerging energy feed-in-tariff regime enabled by the Clean Energy Act of

7 In the preparation for the BCUC Long-term Transmission Enquiry, BC Hydro incorporated marine renewable energy into its clean energy resource cluster analysis. Its significance is that marine renewable energy is a significant part of several of these clusters and the cluster distribution suggests that the longer-term architecture of the BC electricity system will make the coastal region into generation centres rather than load at the end of the existing system. The Standing Offer Programme and the Feed-in-Tariff provision in legislation could be departure points for action on climate impact mitigation, energy diversification and economic diversity. Opportunity recognition elsewhere An emerging strategy for Canada, as marine renewable energy development emerges globally has led to adoption of a focus on the industry development in Nova Scotia. A renewable electricity plan (and specific marine renewable energy legislation this year), facilitated permitting of an industry incubation site and its establishment with 64 MW of offshore cabled interconnection has attracted the world leading project developers to join the local utility (Emera) and bring most of the lead tidal technology developers to the Bay of Fundy. Emera in partnership with OpenHydro and the government of Nova Scotia are expecting the pioneer developments to be extended into industrial scale tidal at 300MW, and perhaps as much as 2 GW, backed by hydro and aimed at a recovering US electricity market. While the UK and France are also working on the launch of the tidal energy industry, British Columbia s wave energy expertise and resource opportunities can still be a focus for the world industry. Climate Leadership 2015 Departure points 1. The Climate Action agenda The agenda has clearly advanced to impact mitigation. Surely diversification is needed for a provincial electricity system that is almost entirely dependent on precipitation. Off-grid diesel power must be reduced or eliminated. Industry has benefitted from its powered by clean electricity base and new industry should have the opportunity to use renewables. The clean electricity agenda in neighbouring provinces and states will have demands that cannot be met domestically. BC Hydro has looked at long-term resource development potential and needs to redevelop this perspective. 3

8 Capacity Grid infrastructure As British Columbia moves to incorporate more power from distributed generation and supplies that are more variable than heritage hydro resources, structural and other constraints due to grid design, age and capacity will limit ability to realize the potential. In fact this constraint was recognized in launching the cancelled Transmission Inquiry before BC Utilities Commission Proposition: Launch studies now in order to ensure that planning accommodates marine renewable energy resources. Action: Priorities are Refining studies for British Columbia to access its resource potential o Refine studies of wave, tidal stream and river/estuary in-stream resource opportunities o Studies matching this to British Columbia grid capacity and constraint analysis o Studies addressing potential competitive/complementary developments in wind and other sectors Capacity Off-grid solutions British Columbia s off-grid and regional grid needs are typical of large numbers of worldwide ocean energy applications. Refinement of suitable approaches for British Columbia will demonstrate Canadian capacity and solve cost, reliability and GHG issues. There has been interest in the Queen Charlotte Islands as a model project incorporating tidal stream power. There are a number of remote lodge and aquaculture sites currently being looked at. In all cases, the ICE (or a new technology) fund or carbon tax could help Proposition: Launch incubation projects now assessing the renewable ocean energy resources, permitting, engineering and other challenges while allowing technology and project developers to focus on their more narrow needs. Action: Priorities are Establish Public/Private leadership team for each project Confirm project/site focus for off-grid tidal and wave energy project development based on o Interconnection and integration feasibility study o Strategic environmental assessment/facilitated permitting of project sites o P3 business/transition plan o Site/project engineering Establish enabling power sale/market access agreement o Commitment to purchase and distribute power o Feed in Tariff or other financing mechanism Establish enabling financing mechanisms o Support for infrastructure o Levering individual project financing Establish project monitoring for the benefit of technology developers, project developers, regulators, remote communities and the power distribution sector. 4

9 2. BC s place in a new clean energy economy Diversifying the marine industry supply chain potential, including the National Shipbuilding Procurement Strategy (NSPS) was one of the objectives of the multi-year infrastructure development intended to extend the marine fabrication industry into new markets. Marine renewable energy will create new supply chain demands that can benefit from the marine operations and construction experience of the primary contractor, and provide them with a new market. The international suppliers will have Industrial Regional Benefits and skills and experience that could be combined in joining development efforts of enormous benefit for the marine energy sector. The region has a strong network of ocean science and technology companies with technologies, experience and knowledge that will become critical in moving marine energy forward. The experience in taking some of those tools into a new arena in the cabled observatories (VENUS and NEPTUNE) has led to a large monitoring system development project at FORCE in Nova Scotia the Fundy Advanced Sensor Technology Platform project (FAST). Activity in the west may help test approaches on the way to the Bay of Fundy or Fundy results may be able to be exploited in BC in ways that accelerate development of the industry. First Nations, remote community and sustainability needs could coincide with the BC Hydro strategy. For example, BC Hydro identified 50 communities in need of a renewable solution to a low diesel-electricity future. Many First Nations find themselves in this group. Others are looking for energy options to re-establish coastal and river communities for eco-education, tourism and other industrial needs (the Atlin, China Creek, and others projects are now well understood). Some recognise that river and tidal currents, or waves, might be resources that can provide careers and revenues that will sustain their communities. The matching of needs and resource options has yet to be addressed systematically by First Nations, but past work by BC Hydro and marine energy resource prospectors might be accessed. There are a number of technology development players who can be promoted for local and other projects. The range of technical solutions being offered in the region extends from a few kilowatts to several hundred. This is a niche that Canadian companies occupy in the international wind industry. It is a massive market in the developing world, many communities lying along rivers or the ocean. There is also regular interest from technology developers (and sometimes, power project developers) in the region s resources. These are connections we need to keep alive until such time as cost and price meet. The West Coast Wave Initiative led by University of Victoria, with community engagement by Ucluelet is strengthening the understanding of the west coast wave resources and the potential for the regional grid to absorb it. An essential part of the project will look at integrating wave energy into a remote community micro-grid, which makes it one prototype for remote community projects for First Nations and other coastal communities. It is also advancing the art of wave resource assessment and wave convertor performance assessment. It is keeping a number of Canadian and international wave technology developers interested in these resources. Another role is the development of the young professionals who will lead in the launch of this industry. This project has the capacity to draw in more partners and to extend its geographic focus. We need to build out from it. Conclusion Climate action can be a source of industrial and economic transformation, if approached with a view to meeting needs and exploiting regional strengths. Marine renewable energy is an excellent fit for this climate action transformation. 5