Just before the holidays, we learned that NL LNG, a company based in Newfoundland and Labrador, registered their Placentia Bay LNG Facility and Marine Terminal with the provincial government. This proposed LNG project would liquefy and export 4 million tons per year of natural gas in a new liquefaction facility.
Not only is it cataclysmically unwise to propose new fossil fuel infrastructure at this late stage of the climate crisis, but the proposal is very light on details about what exactly NL LNG is proposing to do. The company says its facility would be powered by either gas or electricity – they haven’t decided yet – and that they would consider using carbon capture and storage (CCS) to capture resulting emissions and/or use these emissions for enhanced oil recovery (OER).
The Council of Canadians submitted comments to the Newfoundland and Labrador’s Minister of Environment and Climate Change Bernard Davis, urging him to reject the project based on the urgent climate crisis, and numerous issues with the project registration itself. Our Avalon Chapter submitted comments as well.
Read our full submission here – or read on for a summary of the issues we raised.
We are in a climate crisis
There are 96 months between now and December 2030 – the time by which we need to reduce global emissions by almost half in order to have a reasonable chance at a livable planet. None of that time should be spent pretending that there is room on this planet for new fossil fuel infrastructure or bowing to the pressure the oil and gas industry consistently puts on our communities and governments to prop up their profits.
Last year, climate scientists issued a “code red” warning for humanity to tackle the climate crisis by ending fossil fuel extraction and cutting fossil fuel emissions globally, among other approaches. Months later, the International Energy Agency released a report warning that fossil fuel infrastructure should be considered unwise investments and painted a picture of a global energy future that veers sharply away from fossil fuel extraction and expansion.
Now is the time to invest aggressively and equitably in things that can make our communities more sustainable and resilient in the face of major changes coming our way: renewable energies, energy efficiency, public infrastructure, and our communities’ health and wellness. Fossil fuel infrastructure is not the resilient and sustainable type of investment we need right now.
Industry must account for their greenhouse gas emissions
NL LNG does not assess the Placentia Bay LNG facility’s anticipated climate impacts. At one point, the company suggests this project will reduce NL’s emissions by 400,000 tonnes per year, and at another it suggests that the liquefaction facility will be a source of greenhouse gases. Vague suggestions about climate impacts are insufficient – extractive industry must accurately calculate the GHGs their projects will result in so we can judge that against the remaining carbon budget, which is dwindling.
LNG is not a clean fuel, does not lower global carbon emissions
The proposed facility is proposed to produce 4 million tonnes per annum (MTPA) of LNG, and yet the company claims it will somehow reduce NL’s emissions by 400,000 tonnes per year. This is quite confusing – our calculations based on work by energy analyst Dr. Larry Hughes suggests that this level of LNG export will increase NL’s emissions by 12 per cent. This increase would make it impossible for NL to meet its stated goal of reducing emissions by 30 per cent by 2030.
Remember that these climate targets aren’t just nice numbers: they are changes we need to make to our energy systems and economy that could protect human society on this planet.
The physical climate cannot be negotiated with— these targets are rooted in science, not politics.
Carbon Capture and Storage is not a viable solution
While the company didn’t say anything in particular about its GHG emissions, it did say that it would use carbon capture and storage, and possibly use that captured carbon to extract even more oil and gas via enhanced oil recovery (EOR).
Carbon Capture and Storage (CCS) does not stop fossil fuel production and consumption, which are well understood to be fundamental drivers of the climate crisis. CCS does not meaningfully reduce greenhouse gas emissions. Instead, it prolongs reliance on fossil fuels and increases oil production through enhanced oil recovery, as the proponent intends to. Not only is there no evidence that CCS works, there is some evidence showing that “industrial carbon removal” is a net-contributor to carbon emissions – that is, the process of CCS produces more emissions than it captures and stores.
Carbon capture and storage is a dangerous distraction from real climate solutions.
This proposal relies on an environmental assessment from a different project in 2008
In the registration document, the proponent references a number of environmental approvals and risk assessments associated with a project that was proposed in 2008, but never built. The 2008 comprehensive study report for Grassy Point LNG describes a project that is significantly different from the liquefaction and export facility the company is proposing today.
To rely on the environmental assessments from 2008, which assessed different industrial activities under a different regulatory regime, is not appropriate.
Minister Davis is expected to make his decision about this project by January 21st, 2022.
