UK Report on the Ethics of Biofuels

The Nuffield Council on Bioethics, an independent professional organization made up of academics from around the UK, today issued what some consider a scathing report on biofuels, calling on the EU to set aside the renewable fuel mandates that are currently in place until the concerns that it has raised are addressed.

The Council states that there should be a set of ethical standards for biofuels, including:

1      Biofuels development should not be at the expense of human rights

2      Biofuels should be environmentally sustainable

3      Biofuels should contribute to a reduction of greenhouse gas emissions

4      Biofuels should adhere to fair trade principles

5      Costs and benefits of biofuels should be distributed in an equitable way

Further, it suggests that these standards should be addressed through adoption of a certification program for biofuels within the EU.

Gallon Letter’s first review indicates that in our opinion there are some major issues with the report:

a)   The Council ignored some important scientific issues, such as not determining whether or not biofuels are actually causing a shortage of land for food production. Much evidence, reported in the latest Gallon Environment Letter, indicates that they are not.

b)   The Council relied extensively on hearsay, and somewhat unreliable, evidence regarding fair trading and lifecycle analysis of biofuels.

c)  The Council ignored the alternative – increasing consumption of fossil fuels, which is a far worse alternative on several of the Council’s ethical criteria than development of biofuels.

d)  The Council paid scant attention to the fact that biofuels are a very new product and that substantial improvements to production methods will inevitably emerge if early introduction indicates there is an economically viable market.

Gallon Letter believes that by ignoring these key aspects, the Nuffield Council on Bioethics has itself provided a report which falls short of full disclosure of the facts. GL will be reviewing the report and covering the issues raised in more detail in a future issue.

The report is available at

Back to the Rails: Good for the Economy

José Blanco, Minister of Development of Spain, last week presented his government’s plan for reducing greenhouse gas emissions in transportation and buildings. By far the largest part of the plan involves shifting of freight transportation from road to rail, a move that, with other improvements to the efficiency of rail transportation, is expected to provide annual savings of 28 million tonnes of CO2 and ε9.4 million ($13 million CDN).  Spain’s total GHG annual emissions are currently about 337 million tonnes (compare Canada at 734 million tonnes, both for 2008 ) and have been rising significantly in recent years. Spain’s population is about 46 million compared to 34 million for Canada.

Other benefits identified by the Minister include strengthening of the national and urban transportation systems and a major contribution to economic recovery.

A copy of the plan and associated documents (in Spanish) is available at

US EPA likely to forge ahead on GHGs

Several Canadian environmental commentaries have recently noted that Congress is likely to shut down the US Environmental Protection Agency’s efforts to regulate greenhouse gases (GHGs). Gallon Letter has previously suggested that such predictions are likely to be wrong.

This week the House of Representatives passed legislation to curtail EPA’s GHG regulatory efforts but the US Senate defeated similar legislation. The result: US EPA’s GHG initiatives are likely to be able to go ahead.

Even if the US Senate is somehow persuaded to adopt legislation in this area, the White House has stated that the President will veto it.

The complexities of the US legislative process make it a little less than certain that EPA is now free to regulate GHGs but the odds are very much in that direction.

Why does this matter to Canadian industry? Two big reasons:

1) the Government of Canada has said that it will follow the US lead on GHG policies, though more recently it has been moving away from that commitment.  Reality check: if the US does regulate GHG emissions this year or next it will be quite difficult for Canada not to do something similar.  If Canada does not, it will be essentially the only major industrial country to have taken no effective action on GHG emissions.

2) US initiatives to regulate GHGs are quite likely to have implications for products imported into the US. Companies that export to the US, especially those involved in energy products, energy using products, and products with high manufacturing energy, should be following the issue closely. The US is certainly not going to let GHG regulations impact on the competitiveness of US producers, so Canadian producers can expect that one way or another they will have to comply with US GHG standards.

Oilsands plan headline overly dramatic

The article headlined Alberta conservation plan stuns oilpatch in yesterday’s Globe and Mail newspaper is way too dramatic. The claim that the announcement “sent shock waves rippling across [the] industry” suggests a northern Alberta tsunami. The reality is that it would be virtually impossible to find an oil company operating in the oil sands which was unaware of the provincial government’s thinking.

First it is important to note that the so-called ‘plan’ is at present nothing more than a consultation document. There is no plan.

Second, any communications consultant would have told the provincial government to do exactly what it did: in the face of mounting international pressure against the environmental effects of the oil sands, launch a game changing concept to make it clear that times had changed and that the Provinces was finally going to get really tough on the oil sands industry, doing everything short of shutting it down (as the Globe and Mail article inferred).

Unfortunately the ‘plan’ is unlikely to be effective. Setting aside 20% of the oil sands area for a conservation area that allows only existing operations is unconvincing as a strategy to significantly reduce the environmental effects of the operations. Much of the plan is vague, lacking in numerical targets and definitive regulations, and where limits are stated, for example in the Surface Water Quality Management Framework, they are limits more appropriate to an already contaminated industrial area than to a pristine wilderness area.

That’s the real challenge of the oil sands debate. Many people, including first nations residents of the area and environmentally concerned people in North America and in Europe, want to see the wilderness areas of Canada’s north kept as pristine wilderness. Oil companies with leases in the area and the Alberta and Canadian governments see it as an area ripe for industrial development, with all of the environmental effects that oil recovery and processing inevitably involves.

The Alberta draft plan will not be sufficient to satisfy those who want to see the Lower Athabasca region of Alberta maintained in a pristine condition. There may be a compromise somewhere but it will involve a much bigger reduction of environmental effects than the Alberta Government has so far put on the table.

For the draft plan and details on public consultations, visit and don’t believe the Globe and Mail when it tells you that the plan is really tough on industry – it’s a game to try to make you believe that Alberta is really doing something to protect the northern Alberta environment.

Note that comments on the draft must be filed by June 6th, 2011 at 4.30pm Mountain Summer Time. You are asked to file your comments by completing a 48 page workbook that severely constrains the extent and nature of your comments.

We’ll be following progress on this Lower Athabasca Regional Plan proposal in future issues of Gallon Environment Letter.

Wind Turbines Face Massive Opposition

Having just returned from the Mayor’s Spring Breakfast for Business here in Haldimand County, Ontario (where Gallon Environment Letter is published), we unfortunately have to report that opposition to “industrial wind turbines” has taken over this municipality, even leading to the municipal council asking for a moratorium in installation of new turbines.  The Mayor won loud applause from the business audience when he stated that the Council would have banned wind turbines from the municipality of it had the power to do so.

Gallon Letter’s perception of the problems:

a) under its Green Energy Act, the Ontario Government took away the right of municipalities to have any control over the siting of large wind turbines. Had the municipality had a say as to their location, GL believes that people who have come to agree that some locations would be tolerable.

b) haste. By seeking to get turbines installed very quickly, the Province is seen as “ramming turbines down people’s throats”. If a more normal planning process had been followed, many people would have come round to the idea that turbines are better than the current very large coal-fired power plant that is located in Haldimand County.

c) turbine locations are slated for just about every part of the municipality. While this spreads the economic benefits somewhat, a more concentrated wind farm might have been easier to sell to a populace that for the most part does not want its quiet country life disturbed.

Fines for spills of raw sewage: not in Canada

U.K. Water company Thames Water was recently fined £345,000 (about $550,000) for several uncontrolled releases of sewage from street level access covers which found its way into gardens and under houses.  The company was also ordered to pay legal costs of £139,690  and compensation of £2,250 to two residents.

This story caught Gallon Letter’s eye because similar overflows from sewers occur from time to time in Ontario municipalities. When the sewage goes into basements in Ontario the homeowners may get some compensation from the municipality or its insurer but there are no penalties and no one gets fined. Why is that? Well, expressed simply, it is because the municipality is both the operator of the sewage system and the prosecutor for sewage offences.

Watch a future issue of Gallon Environment Letter for a discussion of why it is unwise to have operators of environmentally risky systems, like sewers, to also have the role of enforcer when trouble arises.

For more information on the Thames Water case, visit

Single Use Shopping Bags: LCA

In February the United Kingdom Environment Agency published a report entitled Life Cycle Assessment of Supermarket Carrier Bags. The report concluded that single-use carrier bags have the lowest carbon footprint per bag when the use part of the life cycle is not taken into account – in other words when you consider only the resources used to make the bag and not how many times it can be used and hence the total amount of shopping it will carry.  Not surprisingly, paper, heavy plastic and cotton bags all use more resources and energy for their production. However, all of these last more round trips than the single use bag and when the multiple uses are taken into account the stronger bags win in terms of carbon footprint per use.

Key finding: whatever type of bag you use, the key is to reuse it as many times as possible to achieve the lowest possible carbon footprint.

The report is available at


EU initializes “End of Waste” process

The European Union Environment Commissioner announced a few days ago that the first regulation under the EU “End Of Waste” initiative has been adopted.  Under End of Waste, the EU expects member countries to move rapidly to convert waste streams to streams of raw materials for recycling and other activities. The first regulation under this initiative includes iron, steel and aluminum scrap and provides a framework under which these materials will not longer be classified as waste as long as those companiews producing such materials have a quality management system in place and certify each load of material as conforming to the EU criteria.

It is expected that this will greatly increase recycling of these scrap metals within the EU and facilitate the export of such metals to countries outside of the EU. Certainly it will significantly decrease the amount of bureaucracy associated with the recycling of scrap metals by those processors that have put a quality management system in place.

We will provide more information about the “End of Waste” initiative in a future issue of Gallon Environment Letter.

For more information see

Bisphenol A and Food Packaging

According to a peer-reviewed pre-publication research article recently published by the journal Environmental Health Perspectives, switching a group of human test subjects from a diet of mostly packaged food to a diet of mostly fresh food led to a rapid and substantial decrease in urinary concentrations of BPA and DEHP metabolites. There is some evidence that BPA and DEHP may be endocrine disruptors and the Canadian government has announced that BPA is banned from baby bottles.

Though the research sample size was quite small the results appear quite definitive. This research is likely to increase pressure on governments to further restrict use of phthalates in food contact applications.


An Opportunity to Interface with the Ontario Ministry of the Environment

On Tuesday April 5th members of the Ontario Environment Industry Association will be holding the annual Environment Industry Day at Queen’s Park. There will be a presentation from a senior environment ministry official, roundtables with environment ministry staff, and a reception with the Minister himself, all with the objective of helping the Ontario Government undertstand the important role played by companies in the environment industry.

For more details, or to participate (members as well as non-members are invited to attend the reception) visit