Follow-up on: Academics getting it wrong on Environmental Assessments – a case study

My previous post Academics getting it wrong about the role of private sector consultants in BC’s Environmental Assessment processes was started in November and sat in my “drafts” folder for over a month. The reason I finished it during my break was that I had been directed to a Narwhal article featuring a critique of Environmental Assessments (EAs) by a group of academics titled The Insignificance of Thresholds in Environmental Impact Assessment: An Illustrative Case Study in Canada by Murray et al. It was the article cited by the authors of the open letter from my previous post. In this post I want to further expand on what academics typically get wrong in their critiques of private sector EAs by looking at this paper in detail.

To begin, I want to point out something that I find somewhat odd about this article. Looking at the affiliation of the primary authors I can’t help but notice that the two primary authors present dual affiliations. Both report being associated with the “Institute for Resources, Environment and Sustainability at the University of British Columbia” but they also both report an affiliation with “WWF-Canada“. At the end of the article the authors declare that “they have no conflict of interest” but it sure has a funny smell when an article of this sort is authored by individuals with ties to an organization that has historically opposed most large resource developments in BC.

My first serious concern about this article goes, ironically, back to the major complaint (debunked in my last post) the authors of the open letter had about private sector EAs: lack of transparency. This article is completely opaque, there is zero transparency. As I mentioned in my previous post, when I do an assessment, I am required to present all the supporting material in a location where interested observers can examine it in detail. In this report the authors create spreadsheets detailing information like 1) the number of impacts evaluated, 2) the significance of the impacts and 3) the rationale for significance determination as well as the approaches used to evaluate this significance. Unfortunately, none of this information is available for review as supporting information. How is a reader to independently evaluate the authors’ work when there is literally no information presented to allow an evaluation to be carried out?

Another odd thing about this paper is that it uses the term “thresholds” liberally throughout the document without fully defining the term. Having read and re-read the paper, it is clear to me they do so to simplify their analysis, but in doing so they conflate an incredibly diverse number of indicators. There is a substantial difference between a regional guideline and a regulatory standard but both are treated identically in this analysis.

To understand why this is important, it is necessary to recognize that BC has a lot of regulations, guidelines and criteria. Some regulations come with strict standards, defined within those regulations, while others are much more flexible. Moreover, even in cases where apparently strict regulatory standards exist, these standards can be adjusted based on site-specific conditions.

To provide an example look at Schedule 3.1 through 3.4 of the Contaminated Sites Regulation (CSR). They provide the standards for soils, groundwater and vapours at contaminated sites but are used as criteria for any site that may eventually be drawn into the CSR process. Looking at the standards you see numbers that appear fixed in regulation, except in Section 18 of the CSR it is acknowledged that these fixed standards can be revised to address site-specific conditions.

The issue with creating standards under a provincial regulatory regime is that the standard necessarily has to be very generic. In order to provide a single number the regulator has to make a lot of different assumptions. Generic standards are created to provide simple guidelines for easy cases. They will usually involve the most conservative assumptions (most protective) with added room for conservatism. What does this mean? Well for water quality guidelines they usually take the most sensitive receptor in the entire province and then add a safety factor (often by dividing that number by 10).

Sometimes (in cases like Schedule 3.1) the regulator provides more specific standards (like the standard for protection of toxicity to soil invertebrates and plants) while in Schedule 3.2 they simply provide a single standard for all soils. Moreover, look at that standard for toxicity of soil invertebrates and plants. It is based on a toxicity reference value (TRV) that is the most conservative (most protective) for all provincial soil invertebrates and plants. If that standard is based on the TRV for a specific plant and that plant does not exist in the vicinity of a site, then an alternative standard for the most conservative regionally-appropriate plants/invertebrate would sensibly be considered to be appropriate.

In a proper assessment the first step is to identify what receptors are in the region. That allows you to establish site-specific standards that are tailored to the area under consideration.

The other thing to understand is that the science always evolves. The original soil standards for the CSR were created when the CSR was initially adopted (in 1996) and they were only just updated in 2018. During that update some of those standards were increased and some were lowered, all to reflect the latest science. That is to say, sometimes standards will increase when new and better information replaces older, less reliable information and in other cases standards will decrease.

In the technical guidance to the CSR, the Ministry of Environment & Climate Change Strategy (BC ENV) provides the information necessary for an expert to derive new risk-based standards to reflect the latest state-of-the-art in toxicology. This includes getting information from other jurisdictions, like the US, which spends a lot of research money on toxicology and generates lots of newer, more reliable numbers.

So you may ask why I went into this level of detail? Well the answer is because this flexibility is literally what the academics feel is wrong about current EAs. Their major critiques involve the fact that the EAs were flexible and that thresholds used were site-specific. Essentially the entire document argues that thresholds “should be consistent and transparent across EISs” (Environmental Impacts Statements). Now this type of thing sounds logical until you translate it in a way one can understand. The best analogy is them arguing that the entire province should have the same speed limit and there should be no flexibility for special cases (like say highways or school zones).

Now let’s look at the “six common rationales” the authors argue are not appropriate to explain cases where a generic threshold was exceeded:

(1) baseline conditions already exceeding thresholds; (2) uncertainty in the assessment models; (3) availability of different guidelines that allow for higher threshold values; (4) the scale of impact (temporal and spatial); (5) literature review contradicted threshold values; and (6) other reasoned argumentation.

Thinking to my earlier explanation about the necessity for site-specific standards, let’s consider that list in order.

  1. If a site has naturally high concentrations of a metal in the water then it would be assumed that the biota in the region may not be sensitive to that metal. Relying on a generic provincial standard in that case would not acknowledge local conditions and would not be scientifically justified.
  2. Assessment models are typically also generic in nature and include a lot of conservatism to address their generic nature. Once you have site-specific information you can correct the work to address the generic considerations. This means the models will better reflect conditions at the site.
  3. When the authors say “different” what they mean is site- or regionally-specific thresholds. Good science mean tuning your models for the local conditions. We don’t use the same speed limit for all roads, why would we have the same guidelines for all conditions?
  4. Scale matters. If you don’t believe that then I really can’t help you. Pretending that an impact that has regional effects is the same as an effect that might effect a couple acres and can be mitigated simply makes no sense.
  5. When the new science shows that the old rules are no longer relevant you trust the new science….that is how science works.
  6. Professional judgement supported by the science is why you hire experts to do these types of analyses.

The funny part is that the authors complain that thresholds from other jurisdictions were “weaker”. Except as I mentioned previously, if the latest science from another jurisdiction provides better, more relevant information then a good consultant will note that and incorporate that information in their EA.

As I have made clear, the primary complaint in this article is that the EAs were flexible, because they reflected site-specific conditions. Making a standard, model or “threshold” site-specific should be something we all look for in our environmental assessments. Only a bunch of academics would argue that “flexible”, site-specific thresholds are bad things when used in an EA. The reality is that a good EA has to incorporate site-specific conditions. Flexible thresholds thus reflect a feature of a good EA not sign of a deficient one.

Posted in Canadian Politics, Uncategorized | 1 Comment

Academics getting it wrong about the role of private sector consultants in BC’s Environmental Assessment processes

On November 19th a group of “scientists based in British Columbia” produced an open letter to Premier John Horgan, and several of his cabinet colleagues, about improving British Columbia’s Environmental Assessment (EA) process. The letter, was from the Earth to Ocean Group from Simon Fraser University and co-signed by a number of academics and graduate students and it betrays common, but serious, misconceptions about how science is done in the private sector.

I am a private sector environmental consultant. I am the professional hired by commercial and industrial clients to develop the sampling programs; collect and analyze the data generated; and prepare the reports being criticized by these academic scientists and frankly I am insulted by their faulty claims about our work. As a private sector consultant I am writing this blog post in response to the errors in this letter.

I am not, however, surprised by the content of this letter. The problem lies in the fact that while every private sector scientist has spent time in public institutions, virtually none of the academics or activists, who insult us, have spent significant time in the private sector. As such they really have no clue what is involved in private sector environmental consulting. They create a strawman version of private sector consultants and in creating that strawman demonstrate how little they know or understand about the topic.

As a private sector scientist, I have lots of first-hand experience encountering this type of bias. As a Professional Biologist, I am required to complete ethics courses and sign on to a Code of Ethics. My most recent ethics course was taught by an academic and the target audience was regulators (although one other consultant was in the course with me). Virtually every scenario presented involved the unethical private sector consultant skewing data and the brave regulator identifying the ethical lapses and calling them out on them. This is how we are viewed. We are the cartoon villain with no redeeming characteristics.

Now here is the truth. Unlike these academics (protected by tenure) and NGO scientists (hired precisely because they are willing to push a one-dimensional viewpoint) professional scientists are held responsible for what we say and how we do our work. I have previously written a blog post: A primer on Professional Governance in the Natural Resources Sector where I explain how professional scientists are governed. As I wrote in that piece outsiders like these academics:

imagine that environmental consultants act as advocates for their clients. Nothing could be further from the truth. A consultant who advocates solely for their client will soon cease to be able to operate as a consultant once their professionals lose their revocable professional designations and the government refuses to accept their submissions.  

Put simply, professional scientists in BC are held to much higher standards than our academic or NGO peers. We operate under strict rules of behaviour and practice guidelines and are overseen by regulators and our professional bodies to ensure that our work meets the highest standards. When our work does not meet those standards we are subject to disciplinary panels who have the ability to destroy our careers. We have a huge incentive to behave well and virtually no incentive to behave badly.

So let’s look at what else these academics got wrong in their letter:

1) Lack of scientific independence.

A lot of academics I have spoken seem to think that consultants are like lawyers. Lawyers are hired to advocate for their clients. This is not the case for environmental consultants. We are explicitly constrained from advocating for our clients. We are required to be both objective and independent. It is that very independence that explains our industry’s very existence. Most large industrial firms have the resources to hire in-house staff to do this type of work but no regulator would trust work done solely by in-house experts. That is precisely why our industry exists. To provide arms-length expertise that can be trusted by the regulators.

No consultant would have a career if they were known as being willing to be influenced by their clients. You simply can’t pay me enough to skew my results for one client because doing so would put my entire career at risk. That is why the only people who make these claims are activists and academics who have never done this type of work.

Sometimes junior staff make the mistake of acting as advocates for their clients. But every organization has policies to ensure that our people work in an above-the-board manner. Virtually every story you read about misbehaving consultants involves early-career individuals and junior field technicians rather than actual decision-makers. That is because it takes years to get your professional designation and during that time you have to learn how to be an effective and objective consultant.

This is why being insulted by activists is so ironic. The activist scientists are literally paid to promote the views of their employers. They go into the discussion with a fixed viewpoint and then look for the information to support that viewpoint. That is why it has been so easy for me to debunk their work at this blog. In this case it is clear, they are projecting their lack of objectivity on others.

2. Lack of peer-review of evidence.

This is another common trope from academics who simply don’t understand how private sector science works. These academics imagine that the academic model for peer review is the only model that exists. They are wrong. I have written a long post: On blogging and the irrelevance of academic peer review in multi-disciplinary fields which explains how peer review works in the private sector. Put simply, no report would leave our office until it has had a full review by appropriate experts who are arms-length from the project.

Moreover, as I will describe in the next section, unlike the academics and activists; our work is fully transparent. We include all the information used to generate our analyses in the reports themselves.

So no my report was not reviewed by some outsider who may not be familiar with the details of our work or the regulatory requirements in our region. Our work is reviewed by actual experts in our field and then submitted to regulators with all the information necessary for that regulator to confirm that everything I have produced is scientifically defensible. The letter authors complain that the regulators don’t have the expertise to review the work, but they ignore the fact that the regulators regularly hire outside specialists to review the work on their behalf.

Another important consideration is that I submit my reports under the penalty that if my report does not meet muster I can have my professional designation revoked and I can lose my job. I’m betting more academics would write their articles differently if instead of a rejection letter, every time a paper was judged unsuitable for publication, they were pulled up in front of a disciplinary committee investigation from their professional college. As I wrote in my Professional Governance post:

The college is tasked with ensuring that professionals act within professional standards; they don’t act outside their specific area of expertise; they don’t have undisclosed conflicts-of-interest and they act and operate independently of their client and/or government. You may be paid to do a task by your clients and/or you may work for the government but as a professional you have a responsibility to the public good and to behave ethically and the College has to be there to ensure that every professional measures up to that heady standard.

3. Lack of transparency.

This is another one that makes me laugh. Anyone who has read one of my reports knows that they are designed so that any outsider with time can completely replicate our analyses. The last report I submitted to the government was over 12,000 pages long. It was that long because every analytical result, every borehole log, every monitoring event is documented along with all its supporting information. Unlike academics who hold back critical portions of their work, in the private sector we have to provide the results of every analysis and every monitoring activity in our reports.

I would challenge any academic to provide the level of detail in one of their reports that we provide in ours. The NGOs are even worse. Look at their reports. They provide summaries with no information provided to establish the reliability of their results.

What is particularly funny, in a letter of this type, is that one of the few references in the document doesn’t even get the information right. Reference 4 is to a document: The Insignificance of Thresholds in Environmental Impact Assessment: An Illustrative Case Study in Canada by Murray et al. According to the letter that reference makes a claim that:

Under the proposed EA process, there is no requirement that all data generated by the proponent, or the evaluation of evidence by the Technical Advisory Committee, be made available to the public.This has been identified as a major flaw of the current EA process in BC.

I have carefully read reference 4 several times and nowhere in that article do I see the statement the authors of this letter claims it makes. That is not surprising because that claim is false. I am going to say this to be absolutely clear here: the claim made in this letter is simply wrong and is in no way supported by the reference they supply to support their faulty allegation.

Transparency is a fundamental basis of our industry. Often reviewers complain because we provide so much information in our reports that they find it hard to review it all. Anyone who has seen an Environmental Assessment wouldn’t make such a ridiculous claim. I simply cannot believe that so many academics signed this letter without confirming that the references cited actually supported the claims made.

To conclude let me be absolutely clear: the entire premise of the letter is wrong and the authors of the letter demonstrate that they have no clue about how private sector science is conducted. Not terribly surprising that a group of academics who have never held a decision-making, level position in a private sector environmental firm don’t know how the industry works.

The reason organizations and businesses hire private sector scientists is our objectivity. The reason the government trusts our work is because of our objectivity and the reputation our industry has built as being objective and transparent. Certainly like every industry there are bad actors, but unlike our peers in the activist or academic communities, in our industry misbehaviour is punished. We can’t lie about something and then claim it was a “non-verifiable statements of subjective opinion“. To do so will lose us our careers. Unlike academics and activists,we are bound by ethical and legal rules that preclude us from behaving in the manner that these activist academics imply we do. We operate under strict rules of behaviour and practice guidelines and are overseen by regulators and our professional bodies whose sole role is to protect the public by ensuring that we behave in a manner consistent with our rules of ethics and that our work meets the highest standards.

Posted in Canadian Politics, Environmentalism and Ecomodernism, General Politics, Risk Communication, Uncategorized | 2 Comments

A primer on environmental liability under BC’s Environmental Management Act.

Warning Wonky post ahead:

Every now and then I feel the urge to write a post that clarifies a topic I encounter in my professional life. This is one such post. I hope it will serve to explain, in simple language, how our environmental regime in BC protects the public with respect to contaminated sites. In doing so it will also show how even a well-designed system can sometimes result in unfortunate outcomes. In this case, it may help explain why so many old commercial facilities lie vacant as brownfields in and around our communities.

As I have previously noted, I carefully avoid blogging about my work but this post derives from a discussion I had with a friend over the Christmas holidays. My friend was recently informed that his aunt had passed away and, as her sole living relative, the executor of her estate was looking to pass on parts of her estate to him. In particular, she had owned a piece of land nearby that had historically been home to a gas station which shut down decades ago. The property had subsequently been used as a general store which is now closed. It is now a vacant property on a relatively busy street.

My friend asked me what could go wrong if he took over this property and tried to sell it. In reply, I jotted down some notes that I have now turned into this blog post. Be aware, nothing I am writing is intended to represent a legal opinion and shouldn’t be read as such. I’m not a lawyer, but what I do understand is how BC’s environmental legislation was formulated and how it has been interpreted to date by the BC Ministry of Environment & Climate Change Strategy (BC ENV).

The environmental regime in British Columbia is intended as a “polluter pays” system. The stated intention of our legislators was to ensure the costs of managing and remediating contamination is covered by the generators of that contamination rather than the public purse. As such, the program of managing contamination in British Columbia has been designed to connect as many potential responsible parties (i.e. potential pockets to pay for remediation) to a contaminated site as possible to ensure that the ultimate costs of cleaning up any residual contamination is kept off the public books.

The Environmental Management Act (EMA) provides the legislative framework for addressing contamination in British Columbia. The Contaminated Sites Regulation (CSR) provides the specific regulatory regime for managing contaminated sites under the EMA. The CSR includes a number of “Schedules” which represent items subject to the same regulatory restrictions or controls. Schedule 2 of the CSR presents a list of industrial and commercial activities that would draw an industrial or commercial property into consideration under the CSR. The property under discussion had historically be used for a Schedule 2 activity under the CSR (F5: petroleum product, other than compressed gas, dispensing facilities, including service stations and card locks) and as such it would be drawn into the Contaminated Sites regime of the EMA.

The EMA provides an expansive definition of parties who can ultimately be held responsible for cleaning up a contaminated site. Section 45 of the EMA presents a list of “Persons responsible for remediation of contaminated sites”. Section 45(1) (a) indicates that “a current owner or operator of the site” as a person “responsible for remediation of a contaminated site”. That is a party can become liable for remediation of a contaminated site merely by operating a business on that site (or even accepting the property as a gift), irrespective as to whether that party was involved in the generation of the impacts causing the contamination. This is why careful due diligence is recommended prior to any real estate transaction to ensure that unexpected accrual of liability will not occur through that transaction.

As discussed above, the intention of the regulatory regime in BC is to ensure that the “polluter pays” and as such the EMA includes Section 47 which defines “General principles of liability for remediation” of a contaminated Site. Section 47(1) states:

A person who is responsible for remediation of a contaminated site is absolutely, retroactively and jointly and separately liable to any person or government body for reasonably incurred costs of remediation of the contaminated site, whether incurred on or off the contaminated site.”

Note the language in that section. A party that has become a responsible party for contamination at a site, irrespective of relative blame, can be held fully responsible for the entire cost of any subsequent necessary remedial activities at the site (absolutely liable). The party can be held responsible for impacts that occurred prior to the party being associated with the site (retroactively liable). Finally, the party can either share the costs or be required to cover the entire costs themselves (jointly and separately liable). Certainly Section 47 (1) of the EMA does not prevent an injured party from using legal means to seek out other responsible parties to share in the costs, but the initial payment of those costs can be placed, by the government, on one party trusting that the civil litigation system will sort out relative liability at a later date. In doing this the government places the costs to establish relative blame on the individual parties themselves through the civil court system.

What would this mean for my friend? Well let’s assume the absolute best case scenario, that the historic operation had not caused any contamination. He would still be liable for some serious costs if he wanted to develop the piece of land. When he submitted a development permit to the City they would direct him to complete a Site Profile.The Site Profile system is one of the best features of the contaminated sites regime in BC because it forces municipalities to find out, up front, whether a property is potentially contaminated and gets that information on a permanent, publicly accessible, registry.

Due to the historic nature of the operations at the property, the submission of the Site profile would then draw the landowner into the Contaminated Sites process. As part of this process, the property owner would need to address any environmental requirements before a final development on the property could be issued an occupancy permit.

There are a lot of steps I won’t go into right now but suffice it to say that for an old gas station he would be required to carry out a Preliminary Site Investigation, then a Detailed Site Investigation and ultimately obtain a regulatory instrument (typically a “Certificate of Compliance” for a contaminated site or a “Determination” if the property was not contaminated). Since in this example, his property was clean getting a Determination would require an investigation of soil, groundwater and vapour at his property and then a submission to the BC ENV. Depending on the complexity of the site, we are talking about a minimum of tens of thousands of dollars of work.

If, alternatively, his property had contamination then the work would be much harder. The responsible party (my friend in this scenario) would be required to characterize and delineate the historical impacts at the site and remediation of those impacts would be required to meet either the numerical or risk-based standards specified under the CSR. Ultimately, this would need to be submitted to BC ENV as part of a regulatory submission for a Certificate of Compliance. That investigation/submission process easily puts you over $150,000 for a moderately complex site.

So here is my friend’s dilemma. By taking over ownership of the property he runs the risk of becoming retroactively, absolutely and jointly and separately liable for the costs to investigate, and potentially remediate, any historic impacts. Arguably he could always try and see if any of the historic owners/operators might still be around to help share the expense but absent that he would be on his own to cover the costs. Essentially, he is taking a gamble when he has exactly zero information upon which to base this decision.

Were this a multi-million dollar lot in Vancouver, the answer would be simple, accept the site and take a chance that you may spend a few hundred thousand trying to clean it up and getting it through the system. Then sell the property and re-coup his costs.

Similarly, if it was a small lot in the interior worth only a few thousand dollars the choice would be equally simple. Refuse the offer and let the property revert to the Crown. This would be fine for him but would turn the property into a brownfield. This is the sort of thing that has happened all over our province with old dry cleaners and independent service stations that closed leaving no one to cover the costs.

The system, as designed, is pretty robust, but it has some pretty important holes. The biggest of which may get plugged soon is that some municipalities have opted out of the system. This means that their citizens are not fully protected and in those communities it is possible to build on, and occupy a contaminated piece of land, with all the human health risks that entails. I hope that that the ability to opt out of the system will soon be ended giving all communities equal protection under the law.

Another future challenge is the suggestion that responsible parties be allowed to sell the liability associated with their properties. Unless done extremely carefully this has some very real possibilities to allow bad apples to off-load liabilities onto numbered companies, etc.. that could fold leaving the public holding the bag.

Ultimately, the challenge with any polluter pay system is that it only works if the polluters have the resources to pay. Under the CSR process, the government can essentially hold a property ‘hostage’ until a full investigation has been carried out; necessary remediation conducted; and the results confirmed by BC ENV. The problem with this model is that sometimes the cost of the work exceeds the cost of the property and the result is the government is left holding the bag.

What this means is that the current model works very well with large organizations (big oil companies and companies with a large corporate holdings in BC) since they are not in the position to walk away from the province leaving the government with a brownfield. The process works far worse in cases like the one described where no one is left to over to cover the tab and the land is not worth the cost to get it ready for further use.

The current system is really a balancing act. Every new regulation intended to reduce risk to the community runs the risk of creating a more costly system and thus the creation of more brownfields. In the recent past, most of the changes to the regulations have made closure more expensive, but the government does have some programs to help small land-owners deal with the costs of closing out a contaminated site. Still, as systems go, BC’s is the best in Western Canada (and to my mind the best in Canada). It provides real protections for communities; a clear process for stakeholders; and for the most part keeps the costs of polluting when it belongs, on the polluters themselves. Best of all,  it provides a mechanism by which communities can ensure that contaminated sites aren’t simply re-developed without ensuring they are safe for the next generation.

Posted in Canadian Politics, Uncategorized | 1 Comment

Fact-checking the National Observer “Discount Frenzy” oil piece

On December 26th, 2018 the National Observer published an article Discount Frenzy: The dirt on discount oil by Wil Horter, the former Executive Director of the Dogwood Initiative. Given its subject matter, I read the piece and responded to Mr Horter online. Given the number of times this post reappeared on my social media feed; I thought a quick-take blog post would be a good way to respond. 

The report starts with a common error that Alberta heavy oils represent an inferior quality product. I have encountered this error so many times that I have already written a full post debunking this error. Activists seem to have this mistaken idea that for crude oil, light means good and heavy means bad. The truth is that they are different products with different markets and heavy crude oils are a highly desired product. As for the argument that heavier crude oil is more expensive to refine, In my blog post I point out that heavy crude, refined in a heavy crude refinery, gives higher margins and less waste than light crude refined in a light crude refinery. The heavy crude costs more to refine but recoups more per barrel, which results in higher returns…which is why it is so desirable.

The author then claims that the $10-$25 dollar discount between Alberta’s Western Canada Select (WCS) and Western Texas Intermediate (WTI a light crude) is due to a difference in quality. Anyone familiar with world oil prices knows that the difference between heavy and light crudes on the world market is almost always in the low dollar range one way or another. The trick is that the author uses the WCS (which is landlocked) for a comparison rather than a heavy crude that is not land-locked. Anyone familiar with oil pricing knows that Mexican crude Maya is the most comparable crude to WCS. They are both low API blends with about 5% sulfur. Looking at the Oilprices.com price chart we see that today (December 28th) the price of WTI was $45.33 while Maya for delivery to the US Gulf Coast was fetching $48.26 and for delivery to the US West Coast it was getting $48.01. If heavy crude is inferior why is it selling for more than light today? The difference in price is due to Alberta WCS being land-locked, plain and simple.

The next section of the article I want to debunk is the suggestion that the “Trans Mountain pipeline is no solution“. This represents a common argument made by the opponents of the Trans Mountain Pipeline expansion (TMX): that if there was really a market for oil in Alberta then surely we would be selling there already. This trope can be easily debunked just by looking at where all the fuel has been going. Dr. Andrew Leach from the University of Alberta looked at the NEB data for all the oil that ran through the pipeline for the last decade. Virtually every barrel that ran through the pipeline was grabbed for use in BC and the Puget Sound, there was very little left over to sell elsewhere.

As for the oil that did make it to Westridge Terminal, it was all gobbled up by the Californians. I pointed this fact out online and Mr. Horter claimed that recent history contradicted my claims. Funny thing, he apparently hasn’t been talking to Greenpeace which wrote an entire report bemoaning all the Alberta crude going to California. Not that the Chinese don’t want to get into the act they just have to deal with higher transportation costs. But wait, the article claims:

“there is no price premium in Asia. In fact, former CIBC Chief Economist Jeff Rubin concludes “heavy oil … typically trade at more than US$8 a barrel less, not more, in Asian markets compared to the prices Gulf Coast refineries pay.”

No surprises here, that factoid is also suspect. The challenge was trying to figure out where that factoid came from. In the article it links to a paper by Jeff Rubin an economist who some have argued should not be listened to on this topic. The original citation links the claim to another paper by Mr. Rubin. When you go to that paper you find that it isn’t really something Mr. Rubin generated, this self-citation hides the fact that he actually got the number from a report at the “Price of oil” website. Go to that report and you discover that the number is not a general one (as suggested in the National Observer piece), rather it is a one-time result from a Reuters story. A convoluted route via which a one-day output by Reuters becomes a “typical” case in a National Observer article. So what is the truth? Well according to Oil Price.com Maya sells at a discount to the Far East. Why does it sell at a discount in that market? Well that is because oil prices have to account for transportation costs.

Maya is derived from the Cantarell and Ku Maloob Zaap oil fields in the Gulf of Mexico. The nautical distance between the Port of Vera Cruz in Mexico to Shanghai China is almost 10,020 nautical miles. The two ports are almost as far apart as you can put two ports. This incredible distance results in much higher transportation costs which explains the lower price for that market.

Going back to the West Coast, the nautical distance from the Port of Vancouver to Shanghai is 5110 nautical miles. By halving the distance the price to transport the oil goes down and the price Albertan producers can get for it goes up. Remember earlier when I talked about all that crude going to California. The trip from Vancouver to San Francisco is only 812 nautical miles and the cost to ship a barrel of oil from Vancouver to San Francisco is only $4/barrel. Given that short trip (and low transportation costs) the Californians can outbid the Chinese for Alberta oil because their shipping costs are so much lower. Given the limited volume of Alberta oil available, the Californians are going to win the battle for the limited supply. Given the transportation cost differential, the fact that any oil is getting to China is a sign of how robust that market is for Alberta oil.

Finally, in the article Mr. Horter claims: “In fact, Trans Mountain frequently operates at less than full capacity and, despite a blip last month“. According to Trans Mountain the Trans Mountain pipeline is almost always oversubscribed. When asked for back-up for his claim Mr. Horter provided a link to a story about the Enbridge pipeline which presents an irrelevant link to a web search of the NEB web site. Nothing in the back-up appears to says what the referencing article suggests it does.

Author’s Note 1:

For another take here is Markham Hislop who further debunks Mr. Horter’s piece.

Author’s Note 2:

In re-reading the post, I can see the effect of being tired in some of the language I used. I have revised the text to reduce the friction of the article and stick to the facts.

Posted in Canadian Politics, Pipelines, Trans Mountain, Uncategorized | 2 Comments

About that questionable IMF survey claiming $5.3 trillion in “subsidies” for fossil fuels

During the break I thought it would be nice to catch up on some blogging. The first topic I want to cover is that questionable International Monetary Fund (IMF) “subsidy” survey we constantly see quoted by anti-pipeline and climate change activists. The IMF Survey (authored by Coady, Parry, Sears and Shang) was mostly ignored in Canada when it came out in 2015, but has been used as cudgel by anti-pipeline activists since the Trudeau government bought the Trans Mountain Pipeline this year. The IMF survey web page claims that worldwide energy “subsidies” were $5.3 trillion in 2015 with Canadian “subsidies” being $46.04 Billion. As I will demonstrate in this blog post, these numbers are at best questionable and at worst designed to misinform presumably for political purposes.

A quick note: a lot of people have described this document as a formal IMF Report which represents the viewpoint of the IMF. This is not the case. The document is actually a working paper and the IMF is explicit about that fact. Here is the disclaimer they put right at the top:

IMF Working Papers describe research in progress by the author(s) and are published to elicit comments and to encourage debate.[bold is their emphasis not mine] The views expressed in IMF Working Papers are those of the author(s) and do not necessarily represent the views of the IMF, its Executive Board, or IMF management.

So the first thing to recognize is that this is not an IMF report, it is a survey produced by employees of the IMF for discussion purposes. Since the survey is about subsidies it seems obvious to first define a “subsidy“. The Google dictionary definition of a “subsidy” is:

a sum of money granted by the government or a public body to assist an industry or business so that the price of a commodity or service may remain low or competitive.

As you can see, traditionally subsidies are viewed as financial help from government either in the form of money or a reduced tax rate to encourage an activity. The IMF survey doesn’t use that definition of a subsidy. Here is how the IMF survey defines “subsidies” in this survey:

A key factor in estimating the magnitude of current subsidies is which definition of “subsidies” is used. Pre-tax consumer subsidies arise when the price paid by consumers (that is, firms and households) is below the cost of supplying energy. Post-tax consumer subsidies arise when the price paid by consumers is below the supply cost of energy plus an appropriate “Pigouvian” (or “corrective”) tax that reflects the environmental damage associated with energy consumption and an additional consumption tax that should be applied to all consumption goods for raising revenues. Some studies also include producer subsidies, which reflect the net subsidy given to energy producers (for example, through access to subsidized inputs, preferential tax treatment, or direct budget transfers) although these are typically much smaller than consumer subsidies (OECD 2013).

So they include traditional governmental subsidies but add what economists have traditionally referred to as “externalities” and as a bonus the “additional consumption tax” which is basically what the authors believe the tax rate should be versus the actual tax rate applied by government (a bonus fudge factor).

Externalities in Economics are social and environmental costs to the community associated with an activity. Economists spend a lot of time trying to establish the cost of externalities because those costs are not always evident (what is the cost to the community of spilling soap into a river as one example?).

Reasonably speaking we could probably end this blog post here. The report we keep reading about is not really the viewpoint of the IMF and it doesn’t address what an economist would recognize as a “subsidy”. Simply speaking we should simply ignore it when activists cite its results. But what would be the fun with that? Instead, let’s look at the choices made in this “survey”. Let’s do this by considering the Canada numbers. From the spreadsheet associated with the report we get these values (in billions of 2015 dollars). The total “subsidy” in 2015 was reported as $46.04 billion. The breakout was:

  • Pre-Tax subsidies – $1.4 billion – 3% of IMF total
  • Global Warming – $17.20 billion – 37.4% of IMF total
  • Local air pollution – $6.05 billion – 13.1% of IMF total
  • Congestion – $14.89 billion – 32.4% of IMF total
  • Accidents – $2.08 billion – 4.5% of IMF total
  • Road Damage – $0.88 billion – 1.9% of IMF total
  • Foregone Consumption Tax Revenue – $3.53 billion – 7.7% of IMF total

According to the spreadsheet the actual 2015 “subsidy” for the entire fossil fuel industry in Canada was about $1.4 billion made up mostly of preferential tax treatments.

The remainder of the total (97% of the IMF survey “subsidy”) consists 89.3% of externalities and 7.7% of that fudge factor for taxes. I don’t have the patience to deal with the tax side so let’s look at those externalities.

The real flaw in the IMF “subsidy” evaluation is the externalities it considers as being the responsibility of fossil fuels and then how it accounts for those numbers. Unfortunately, the IMF study doesn’t actually give details in this report of how they generate their numbers. The spreadsheet provides the conclusions not how they were generated. It appears that most of the numbers are derived from other reports; the most important being Getting Energy Prices Right from Principle to Practice. Not surprisingly this report was co-authored by one of the IMF survey’s co-authors Parry (with Heine, Lis and Li).

This secondary report provides some of the meat underlying the “subsidies” and some of them are pretty odd. Let’s look at that “Congestion” and “Accidents” values ($14.89 billion and $2.08 Billion for Canada in 2015, respectively). Here is what that report says about congestion and accidents:

Traffic congestion costs imposed by one driver on other vehicle occupants are approximated by using a city-level database to estimate relationships between travel delays and various transportation indicators and extrapolating the results using country-level measures of those same indicators. Travel delays are monetized using evidence about the relationship between wages and how people value travel time. Accident costs are estimated based on country-level fatality data and assumptions about which types of risks drivers themselves might take into account versus those they do not, and extrapolations of various other costs, such as those for medical expenses, property damage, and nonfatal injury.

The easiest way to dismiss this number is to do a simple thought experiment. Imagine if magically every internal combustion engine were converted to electric engines would the congestion or accident rates change? The answer is, of course, no. This tells us that the externalities are not associated with the engine that moves the vehicles but the vehicles themselves. The subsidy has to do with our transportation infrastructure and urban design policies not fossil fuels. The same argument can be made for road damage. All these costs will occur irrespective of the type of engine in our vehicles.

Now if you didn’t think this study was flawed already then take another quick look at the spreadsheet. Do you notice anything funny about the numbers? Look at the congestion, accidents and road damage values for most European countries? Apparently British drivers don’t have accidents because their “subsidy” for road accidents is zero. The same goes for Germany, Italy and Finland. But be careful not to cross the border into France because apparently they have car accidents in France. Oddly enough the supporting reports provide values for these countries, but for reasons unknown those costs didn’t get transferred to this survey.

While I have not been able to completely go through all the underlying supporting information for this study I have also noted what I would argue is another significant flaw. To the best of my ability (and if I am wrong I would encourage my readers to direct me to the research) the authors ignore the fact that the Canadian and provincial governments actually have excise taxes, surtaxes (and carbon taxes) on our fossil fuel consumption. In 2018, total taxes on gasoline were estimated at approximately $24 billion. That number does not appear to be applied against Canada’s “subsidies” (or our Foregone Consumption Tax Revenue”) in the IMF survey math. If this is the case that represents a pretty significant oversight in my mind.

To summarize, there is a reason why economists have different words for different concepts. Because the correct language allows for a better understanding of the concepts under consideration. Economists differentiate between “subsidies” and “externalities” and have defined both for the purposes of policy discussions. To put this into language my readers can understand let’s think of this in biological terms.

In biology, dogs and cats are both mammals but they are not the same species. If I looked at a Labrador Retriever and claimed it was a Persian cat virtually every person reading this blog post would know I was making things up. If I insisted that every reader should consider a Labrador Retriever to be a Persian cat readers might ask why I was making such an obvious misstatement. They would look for some other reason why I am trying to play with language and would suspect that there was some underlying reason I was making such a clear misrepresentation.

The challenge with topics like fossil fuels and climate change is that few Canadians have studied economics. Because of this fact few will recognize the significant difference between a subsidy and an externality. The IMF survey authors calling an externality a subsidy is just as valid as the IMF survey authors calling a Labrador Retriever a Persian cat. It is not the correct use of the language and no matter how many times they choose to do so a dog is not a cat. The simple fact is that by using the correct language of economics these activist scientists would not be able to make a persuasive or effective case for the political goals they seek to achieve and so have decided to re-define the language to better sell their agenda. So no, Canada does not provide a $46 billion “subsidy” and globally we don’t provide a $5.3 trillion “subsidy” for fossil fuels. There is a reason the IMF calls this a “Working Paper” and does not stand behind its results. Perhaps the activists should consider that when citing these numbers.

Posted in Canadian Politics, Climate Change, Climate Change Politics, Fossil Fuel Free Future, Uncategorized | Tagged , , , | 2 Comments

Let’s face it hypocrisy matters in the pipeline and climate change debates

As someone deeply interested in the pipeline and climate change debates I encounter the topic of hypocrisy every day. The discussion usually starts with a pipeline supporter pointing out that pipeline opponents who rely on fossil fuels are hypocrites. The standard activist response to the “hypocrite” label is to point out that it is a tu quoque argument and is therefore not valid (typically while posting the famous Mister Gotcha cartoon from Matt Bors). As someone who has studied logic, I understand how hollow the tu quoque response is and in this blog post I want to explain why hypocrisy matters in the pipeline and climate change debates.

Let’s start with an explainer. RationalWiki provides this definition:

Tu quoque is a form of ad hominem fallacy that occurs when it is assumed that an argument is wrong if the source making the claim has itself spoken or acted in a way inconsistent with it. The fallacy focuses on the perceived hypocrisy of the opponent rather than the merits of their argument.

As described the tu quoque argument represents a special type of ad hominem argument. An ad hominem (literally “to the man”) is a type of argument where you attack the messenger to avoid dealing with the message. That is why it is treated as a type of logical fallacy. Whether an activist relies on fossil fuels shouldn’t logically affect our evaluation of the activist’s position. But there is something very important to understand:

Tu quoque is only a fallacy when one uses it so as to divert attention from the issue at hand, or to avoid or fail to respond to an argument that non-fallaciously gave one the burden of proof.

What does this mean in simple language? Tu quoque protects a person’s argument not their reputation. There is no denying that an activist who claims that we should not use fossil fuels while wearing a gortex jacket and driving a car to the protest is indeed a hypocrite. However, that activist can have a strong argument (that we should reduce our reliance on fossil fuels to help fight climate change) and still be a hypocrite and the tu quoque response does nothing to mitigate either of those two truths.

Similarly, a First Nations right’s advocate whose family owns a gas station that relies on fossil fuels that are transported over other First Nations’ lands is truly a hypocrite to insist that a pipeline shouldn’t be allowed to travel freely over her First Nation’s lands.

Now let’s deal with the more important question:

Should hypocrisy matter in the pipeline and climate change debates?

My response is twofold:

  1. the science says it does matter from a credibility standpoint, and
  2. morally and logically it absolutely should as well. 

Let’s start with the first half of the answer.

Regardless of what activists may hope in presenting a tu quoque response, the truth is that their hypocrisy matters in the court of public opinion and thus in policy debates. The science is clear that statements about climate researchers’ carbon footprints affect their credibility and the impact of their advice.

The public has spoken and the public agrees that the personal behaviour of activists matter. If they behave in a manner inconsistent with their proposed policies their credibility suffers. Put another way, there is a reason their opponents want to label activists as hypocrites, because it works. This brings us to the second half of the question:

Should their hypocrisy matter?

In my opinion it absolutely should.

Climate change and pipelines represent global issues that require global solutions. Because they are such big issues a lot of activists claim that their personal efforts won’t make a difference and that any change will need to be implemented by governments and businesses. This response is a cop-out. In essence, these activists are off-loading the responsibility to show leadership and instead demanding that government force a change in behaviour on the population.

Because of the nature of the policies necessary to address climate change or to get off fossil fuels a lack of personal leadership from the activist community really matters. If the activists are successful in implementing their preferred policies then every citizen will be affected and the hardest hit will be the poorest among us. Isn’t it convenient that most activists come from upper middle-class backgrounds and have the means and the resources to insulate themselves from the policies they want imposed, through the coercive power of the state, on others? If the activists fighting for those policies aren’t willing to lead from the front what does that tell you about both them and their policies?

Another important consideration is that the activist class is mostly made up of people without applicable technical backgrounds. Instead, they are mostly political scientists, sociologists and communications and media studies graduates. I can’t count the number of activists I have heard making hollow claims bereft of scientific merit (see my last blog post) because they have no practical/technical understanding of what these types of policies will entail. Their absence of a technical understanding allows them to credulously make impossible demands. This explains why so many of them present the policies necessary to effectively fight climate change as relatively benign when they will be nothing of the sort. By showing leadership the activists can develop a personal understanding about how hard this transition really will be.

What is even worse are the activists who appear to be acting in bad faith. Any informed citizen knows that electricity and liquid fuels serve two distinct roles in our current society. Electricity cannot replace liquid fuels in our transportation system, so until the transportation system is converted over to electric drive engines and hydrogen-powered fleets we will still need liquid fuels to supply our trains, planes and trucks. Any activist arguing that electricity produced by solar panels can replace liquid fuels in our current transportation system is either ignorant or trying to take advantage of the ignorance of their followers. Neither alternative is terribly flattering.

The truth of the matter is that hypocrisy and bad-faith arguments are a feature of these debates and not a bug and when observed should be called out. There are too many professional activists out there making a living making impossible demands (ostensibly “to move the Overton Window“) and demanding that the government impose a cost on others that they are unwilling to voluntarily shoulder themselves. Their attempts to “change the conversation” actually flood the discussion with fake facts and makes it harder to generate the consensus necessary to make real and necessary changes to our energy systems.

Until these arbiters of others’ behaviour demonstrate their personal commitment to live the life they demands of others their opinions should be given no weight and their hypocrisy called out. Demanding that our government give up on developing means to safely transport liquid fuels and instead build more solar panels in a world where virtually all food is moved in fossil-fuel-reliant modes of transportation is simply a demonstration that the individual making that argument either has no clue or is deliberately spreading misinformation. In either case it should be called out for what it is: either propaganda intended to bring in donations from credulous supporters (and not to make a real change in our society), or virtue signalling from self-important hypocrites who are too ignorant to know any better. Climate leaders should lead from the front and that means being on the forefront of the battle against carbon. It is time they stop just talking the talk and start walking the walk.


Posted in Climate Change, Climate Change Politics, Pipelines, Renewable Energy, Uncategorized | Tagged , , | 10 Comments

When political scientists do environmental science the results are not always pretty

Anyone who has followed my social media feed knows I am regularly tagged by activists hoping I will amplify a post they have prepared. Sometimes I re-tweet those posts and sometimes I critique them. This week I had one that definitely fit in the “critique” file. I politely highlighted a couple errors to its author and he immediately blocked me. Normally, I just ignore these posts thereafter, but this one represents a type of argument I hear often from individuals who have spent too much time engrossed in political science and too little time learning environmental science.

The blog post, prepared by a political science grad student called Milan Ilnyckyj (Milan), is titled “Overcoming fossil dependence and building the world we want“. It represents his attempt to defend himself against the “hypocrite argument” used in the climate change/pipeline debate.

The reason the charge of hypocrisy is used so often in this debate is because it represents a valid concern. We live in a world full of hypocrites who will say one thing in public and do another in the privacy of their own lives. The problem is that until you have personally tried to go without fossil fuels you can’t really understand how hard it really will be. So a hypocrite is apt to make claims that are not founded on an understanding of the scope of the challenge, usually that doing so will be relatively easy

Hypocrisy is not the direct topic of this blog post so I will stop there. For a much more nuanced discussion of the hypocrisy argument in the fossil fuel debate see my previous post: On Seattle’s Kayaktivists: Are they really hypocrites? FYI, I am also preparing a post on the tu quoque fallacy which I will put online sometime soon.

Going back the article, Milan claims that his post has three parts/goals: 1) climate change makes it necessary to move on from fossil fuels, 2) we have alternatives to them as both sources of energy and feedstocks, and 3) system change happens at the political level and not at the level of individual choice.

We can all agree on point 1. We really do need to move on from fossil fuels. I have made that point repeatedly on this blog and in my other public discussions of the topic. As for points 2 and 3? The simple truth is we don’t have alternatives for most critical uses of fossil fuels (as I will explain later) and political changes are built on individual action. Individual action serves as the impetus for collective action. So to suggest that we can make massive global political changes without anyone making individual changes represents magical thinking.

The blog post starts with a reasonable recitation of the political arguments underlying the science of climate change. The initial introduction demonstrates that, like a good grad student, Milan is capable of correctly regurgitating basic facts as long as you avoid the complex science. But even early in this section it becomes clear that the author is unclear of the science he is regurgitating. As an example, the post demonstrates confusion about the topic of sea level rise claiming that “sea level is always at more or less the same height“. That claim would come as a big surprise to the scientists at NOAA:

Similarly, the author apparently does not understand what the Representative Concentration Pathways (RCPs) used in the IPCC Fifth Assessment Report actually represent. The blog’s claim that RCP8.5 is a “business as usual” scenario is a common error for activists but not one I would expect from someone who claims to understand the topic.

The blogs technical failings are truly exposed in the first interpretive section: “2. We have alternatives for both energy and raw materials“. The section starts with some pablum about solar energy and switches to citing a popular book by “Cambridge physicist David MacKay”: “Sustainable Energy – Without the Hot Air“. The book is a must-read for energy types but only from an electricity generation perspective. Unfortunately, the author passed away before he was able to move from the big picture theoretical discussions to address the nuts and bolts of replacing fossil fuels in the transportation industry (where it really matters to make the cuts we need). It doesn’t say HOW we replace current airliners with hydrogen-powered airliners, it simply asserts it must be done. To suggest that it provides a pathway to a fossil fuel-free future oversells what the author was able to achieve.

The next section of the blog was the one that really caught my eye. Milan asserts that we don’t need petrochemicals because “fossil fuels aren’t made of anything special chemically. We can get carbon and hydrogen from all sorts of carbon-neutral sources.” Such abject ignorance of organic chemistry simply left me stunned. To imagine that we can replace all our complex petrochemicals using carbon dioxide and hydrogen leaves me wondering whether Milan has taken a single chemistry course in his life? Admittedly, we could certainly go back to natural rubber, as long as we were willing to destroy ecosystems to grow massive rubber tree plantations but that wouldn’t be ecosystem-friendly.

The special advantage of petrochemicals is that they provide us with the benefits of millions of years of Mother Nature’s synthetic organic chemistry expertise combined with the input of millions of years of solar energy all captured in the compounds themselves. Petrochemicals represent a treasure trove of stored chemical energy that simply cannot be replaced given our current scientific knowledge and energy systems. So yes, fossil fuels are made of something special and at this point in our technological progress they are simply irreplaceable.

The author also imagines that generations of scientists missed really obvious discoveries and that our current scientific expertise can suddenly make all the huge breakthroughs we failed to make in the last 200 years. He explains we need to find “new ways to make agricultural fertilizer without natural gas, run farming equipment without diesel, manufacture steel without coke, and make low-carbon concrete or concrete substitutes.” Apparently he is not aware that generations of chemists have worked on methods to fix nitrogen and simply waving his hands won’t suddenly allow modern chemists to replace the Haber process with a new approach. But that is only the start. He imagines that all we need to do is make a wish to create new ways to generate synthetic rubbers and plastics, pharmaceuticals, polymers and chemical feedstocks. To imagine this can be done easily is the sign of a political scientist with no awareness of what complex organic chemistry really entails.

The final section of the blog is the topping on the cake. It is called “3. How change happens” and it really needs to be read to be appreciated. It starts with a bad analogy and then proceeds to magical thinking, never once explaining how we can accomplish what the author claims is necessary. It assumes some deus ex machina scenario where all the challenges we face simply melt away. It skips over technological restrictions and imagines that simply by wishing hard enough that we can make airliners that don’t emit carbon and can create a more equitable global system (apparently the Chinese Communist Party and Russia’s Vladimir Putin will simply bow out to make it all work).

The most bizarre part of the entire piece is that this is the only place in the entire blog that attempts to address the hypocrisy argument directly and in response the author simply says that since climate change is such a big problem individual actions don’t really matter. He argues that instead we should rely on some big government to make the changes for us. Since our current governments aren’t doing it fast enough he argues our current system should be replaced by a completely new, never-before-seen, form of government that can ignore the wishes of the populace and impose its will on the planet. Except environmental history shows us that change only happens when a groundswell of individual action makes it politically palatable to institute larger changes.

Honestly while I hate to push eyeballs to his website you really do have to read this last section, because reading it really helps you understand the mindset of the people fighting against things like pipelines. There is simply no connection to reality in this section and this is supposed to be the practical “how do we get it done” part of the post.

Going back to the intention of Milan’s post: we both agree that we need to wean ourselves off fossil fuels, but the post fails in any way to explain how we can do so for our most important uses (transportation and petrochemicals) and why people who live a profligate lifestyle while demanding austerity in others shouldn’t be called out as hypocrites. Most importantly, its plan on making the change happen simply involves wishful thinking. In essence the blog post doesn’t do anything the author says it does. What it does do, however, is display the author’s fundamental misunderstanding about environmental science for all to read.

As a pragmatic environmentalist I can’t emphasize how hard getting off fossil fuels will be. Part of understanding the challenges involves trying to live a low-carbon lifestyle yourself. When you haven’t walked the walk it becomes clear when you try to talk the talk. When activists claim it will be an easy task they make it harder to build up the will to fight the battles that need to be fought.

Addendum

So Milan replied in a blog post. Amusingly the reply demonstrated that he simply doesn’t understand the underlying science. He Misunderstands what the IPCC said about future scenarios (i.e what is business as usual); misunderstands my critique of Dr. MacKay’s work (electricity and energy are not the same thing) and continue to demonstrate that he has no sense of what is involved in organic chemistry. My major complaint is that he simply doesn’t understand the science and his reply is to provide more proof of my point.

The funniest part is his discussion about blocking me. To be clear his block came immediately after I responded to a post where he tagged me. Let’s say that again, he went out of his way to tag me and then blocked me when I responded politely. He initiated the discussion and then metaphorically held his hands to his ears when I responded. Simple suggestion here, if you don’t want someone to reply, then don’t tag them….see how simple that can be?

Posted in Canadian Politics, Climate Change, Climate Change Politics, Uncategorized | 6 Comments