Electricity Framework Review Project Team (EFR)
In January 2002, Alberta Environment asked the Clean Air Strategic Alliance (CASA) to develop a new way to manage air emissions from electricity generation in Alberta. Using a multi-stakeholder collaborate approach, CASA developed innovative solutions in the form of 71 recommendations comprising a management framework and presented it to the Government of Alberta in November 2003. The report, An Emissions Management Framework for the Alberta Electricity Sector (the Framework), was accepted by the Government of Alberta and implemented through regulations, standards, and facility approvals. The first emission standards were effective January 1, 2006.
To ensure continuous improvement and keep the Framework timely and relevant, a formal review of the Framework is to be undertaken every five years according to recommendation 29. This review should include a multi-stakeholder group consisting of industry, government, non-government organizations, and communities with an interest in electricity generation in Alberta. The intent of the Five-Year Review is to assess new emission control technologies, update emission standards for new generation units, determine if emission standards for new substances need to be developed, review implementation progress, and determine if the Framework is achieving its emission management objectives.
The first Five-Year Review started in 2008 and the Electricity Framework Review Team submitted their report and recommendations to the CASA Board in June 2009. The report contained ten consensus recommendations and one non-consensus item. The consensus items included revisions to the particulate matter (PM), nitrogen oxides (NOx), and sulphur dioxide (SO2) emission standards for new coal-fired units based on improvements in emission control technologies, effective January 1, 2011. The non-consensus item pertained to NOx emission standards for new gas-fired generation for both peaking and non-peaking units. A final report, including the interests and rationale with respect to the non-consensus recommendation, was forwarded to the Government of Alberta in May 2010 for decision.
The second Five-Year Review started in 2013. The project team reviewed greenhouse gas (GHG) regulations to identify potential implications and emissions management issues of the Framework created by the implementation of federal GHG regulations in addition to environmental and economic triggers (recommendation 34 and 35).
The group was unable to reach consensus on the need to review or adjust the Framework, given divergent views of the members as to what was required to allow changes to the Framework. An interim report identifying the key issues and differing perspectives was submitted to the CASA Board. The CASA Board asked the Government of Alberta to weigh in on the matter and to describe the path forward as appropriate. In August 2014, CASA was notified that the department of Environment and Parks was working on a cross-ministry plan with the departments of Energy and Health that would review the interim report and determine the next steps for the Framework. In June 2015, Environment and Parks notified CASA that in the absence of a decision on the interim report and Framework, the Government of Alberta would continue to make regulatory decisions in accordance with the existing 2003 Framework.
In March 2015 the project team provided 13 recommendations to the CASA Board, one of which was non-consensus (recommendation 3, emissions standards for gas-fired generation).
In October 2017 Alberta Environment and Parks, via a letter from Deputy Minister, asked CASA to develop and recommend a nitrogen oxides (NOx) emissions standard by December 31st, 2017 that could be applied to coal-fired electricity generation units that converted to fire natural gas instead of coal. The work was to include:
- Draft technology requirements for coal-to-gas (CTG) unit conversion
- A draft NOx emission standard for CTG unit conversion
- Allowable lifespan for a CTG unit conversion based on the draft NOx emission standard
CASA established the Coal-to-Gas Project Team to undertake this work.
The multi-stakeholder group met for five days in October and November of 2017, and its discussions were informed by a third-party engineering consultant’s report commissioned by the Government of Alberta. The group reached consensus on a Coal-to-Gas Unit Conversion NOx Emission Standard Agreement, and subsequently obtained the endorsement of industry, ENGO, and Government of Alberta stakeholders who were represented on the working group. The agreement is a two-page document that was presented to and approved by the CASA board at its December 13th, 2017 meeting.
The third five-year review was initiated in 2018. The project team will provide a report and recommendations for the next review once its work is complete.