Sunday, September 06, 2009

On absolute requirements

Not surprisingly, I'm in agreement with the consensus view that the Cons' toxic trial balloon on greenhouse gas emissions is an utter joke. But while the "reverse NEP" line (reinforced by the explicitly different treatment of different industries in different provinces) may be an effective one, it's worth noting where the real problem lies.

As long as criticism focuses on differential treatment as opposed to the type of target, the Cons have another choice available to them: namely, putting "intensity" targets in place Canada-wide rather than for the tar sands alone. And that could actually result in a more painful adjustment for a lot of industries than the hard-cap alternative.

That's not because intensity targets reflect better environmental policy in general, but because they impose greater relative compliance costs on industries which can't realistically grow their way around the intensity target. And indeed for any business already looking at having to reduce production to weather the economic storm, an obligation to spend substantial money to reduce per-unit emissions at the same time could well be the last straw - making for a particularly unjust result for those industries which have been ahead of the curve in reducing emissions and thus don't have much low-hanging fruit to improve matters now.

Instead, the ultimate message needs to be a reminder that "intensity" targets themselves are a bad joke - a fact which is particularly obvious based on projections for the tar sands themselves, where they're expected to result in actual emissions increasing several times over. And the fact that the Cons insist on treating such illusory standards as a meaningful development in regulating the most emission-intensive industry in Canada rather than setting out absolute targets should be reason enough to laugh down their position.

(Edit: fixed wording.)

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