Response to Corner Brook Pulp & Paper Tire Derived Fuel (TDF) Co-Firing Trial Project Proponent: Corner Brook Pulp & Paper Ltd. (Reg. 1539)

While acknowledging potential economic benefits for Corner Brook Pulp and Paper (CBPP) in using tire-derived fuel (TDF), we remain unconvinced of the net public and environmental health benefits of its use and are concerned with the methodology of the proposed test. We hope that this overview of our concerns can help the Department of Environment and Conservation (DEC) make an informed decision regarding the testing of TDF at CBPP. Guiding our submission is the precautionary principle, which has been adopted by all relevant parties, including the Government of Canada, the Government of Newfoundland and Labrador and CBPP. As such and in light of the issues below, it is our position that additional research is required before moving to a test trial. This can be achieved either by conducting a full Environmental Impact Statement, including component studies and additional public hearings, or by rejecting the undertaking outright

Creating a Climate Responsible Campus: A Report on the 2010-2011 Carbon Footprint of Grenfell Campus, Memorial University

Universities and colleges have a responsibility to be leaders in the challenge to become a sustainable society, practicing what they teach by integrating sustainability policies and practices into their own operations. Developing a carbon footprint, or Greenhouse Gas (GHG) Inventory, to track and reduce greenhouse gas emissions is one way institutions are taking action on climate change and promoting sustainability. There is no standard method for developing a carbon footprint. Institutions across Canada are using a variety of methods and tools for tracking their emissions including SMARTTool, developed by the Government of British Columbia, and the Campus Carbon Calculator, developed by Clean Air – Cool Planet, a non-profit organization based in the United States, and the Sierra Youth Coalition in Canada. Most methods and calculators are consistent with the standards established by the World Resource Institute (WRI) and the World Business Council on Sustainable Development (WBCSD)’s Greenhouse Gas Protocol (World Resource Institute and World Business Council on Sustainable Development, 2004). The Greenhouse Gas Protocol facilitates the preparation of GHG Inventories by separating emission sources into three levels of responsibility. Scope 1 emissions are direct emissions from sources that are owned or controlled by the organization. Scope 2 emissions are indirect emissions from the generation of purchased electricity. Scope 3 emissions include all other indirect emissions that are a consequence of the organizations activities but are not owned or operated by the organization. Scope 1 and 2 emissions are required for most inventories. Scope 3 emissions are often considered optional because they have been vaguely defined and are difficult to estimate (Pandey et al., 2011). However, depending on the organization, Scope 3 activities may contribute significantly to the total carbon footprint. This report contains the first Carbon Footprint, or GHG Inventory, developed for the Grenfell Campus of Memorial University for the fiscal year 2010-2011. The organizational and operational boundaries of the inventory were established according to the GHG Protocol. The inventory includes all Scope 1 and 2 emissions as well as Scope 3 emissions from waste. Emission factors and calculations were completed using CarbonConnect, a web-based, third-party verified application tool designed by CarbonCounted, a Canadian based, not-for-profit organization. The results of the inventory show that Grenfell Campus emitted 101.07 tonnes of carbon dioxide equivalent (CO2eq) from Scope 1 sources (fuel consumed by the vehicle fleet and site maintenance equipment and fugitive emissions from refrigerants) and 306.45 tonnes of CO2eq from Scope 2 sources (electricity consumption). This is a total of 407.52 tonnes from Scope 1 and 2 sources. Emissions from land filled waste (Scope 3) were estimated at 1,425.96 tonnes CO2eq, which exceeds that of larger institutions. Although calculation methods and waste diversion programs vary between institutions, this number seems high. The Grenfell data is based on a number of assumptions including that all the dumpsters are full at the time of pick up and the composition of the waste is the same as that of municipal solid waste. Looking at all three scopes, Scope 3 appears to be the largest contributor of emissions. However, if we compare just Scopes 1 and 2, electricity consumption becomes the largest contributor. This inventory represents a baseline for future inventories and the first step towards developing polices, targets, and an emission reduction plan. We recommend that the next inventory be completed in the summer or fall of 2012 and suggest that this can be achieved by integrating the process into the curriculum, hiring a student, or hiring a Sustainability Coordinator. We also suggest ways to improve the accuracy of the data such as obtaining an estimate of the yearly consumption of propane and diesel on campus rather than relying on purchasing data. We also recommend gathering more detailed electricity consumption data to identify the major contributors to this emission source on campus. Rather than using waste density and volume estimates to determine emissions from waste we recommend working with the contractor to gather data on the actual weight of the waste at the time of pickup. The inventory could also be improved by including other Scope 3 sources such as commuting, directly financed travel, and emissions associated with paper, food, and fuel procurement. We encourage Grenfell to commit to emissions reductions by signing the University and College President’s Climate Change Statement of Action for Canada (Appendix B) and implementing two of the actions recommended by the Statement in the fiscal year 2012-2013

All Party Green Agenda Newfoundland & Labrador 2011 Provincial Election

Newfoundland and Labrador possesses a wealth of natural and environmental resources. This includes important wildlife habitat, forest, freshwater and marine ecosystems. With such wealth comes a duty to protect and enhance the natural environment. The 2011 provincial election is a watershed election for the province. After several years of prosperity which has seen significant revenues from non-renewable offshore resources invested to modernize public infrastructure such as hospitals, roads and schools among other things, the opportunity exists for the next government to chart an environmentally friendly and sustainable future for all Newfoundlanders and Labradorians. This bold innovative environmental future is to focus on: • embracing alternative energy resources; • protecting our peatlands resources; • investing in leading edge waste management practices; • reducing the environmental impacts of the oil industry; • moving to less carbon intensive practices; • repositioning the forestry sector to recognize its diversity and to ensure its environmental sustainability; and, • working to create a food production system that is less dependent on imports. It is to these issues that this environmental brief seeks commitment from all political parties in the 2011 provincial election

Response to Newfoundland & Labrador Public Discussion Document “Climate Change: Responding to Climate Change in Newfoundland & Labrador”

The international scientific community considers climate change to be one of the greatest threats of our time and to limit the very worst consequences of this problem, the global community must reduce carbon emissions steeply and immediately. Newfoundland and Labrador is already experiencing climate change impacts and the province has a responsibility to act given its major fossil fuel industry. This challenge also represents an opportunity for Newfoundland and Labrador to become a leader in addressing climate change in Canada. The province has taken important first steps and this document outlines some of the next key policy directions available to the province to reduce carbon emissions. #1. Set emissions reduction targets that respect the scientific consensus and Canada’s international commitments. #2. Put a fair price on carbon emissions. Provide market signals to encourage emission reductions via a cap and trade system. As a national or regional cap and trade system develops, implement a carbon tax. #3. Facilitate the transition to a renewable energy economy by investing in sustainable, “green” energy research and technology and by requiring energy efficiency standards. #4. Reduce energy demand through, for example, addressing the building code and vehicle standards and investing in public and alternative transit. #5. Integrate climate change considerations into land-use planning across the sectors. 5.1. Forestry: target climate change forest research and focus on broadening current forest management strategies. 5.2. Peatlands: integrate peatland carbon sequestration and storage dynamics into land use policy decisions. This includes trade-offs to be made between GHG mitigation and other policy sectors (food security, energy, economic). 5.3. Water resources: increase monitoring of ground and surface water interactions to support the water needs of natural and managed ecosystems. 5.4. Agriculture: increase research and education to facilitate adaptation and enhance agricultural productivity