Canadian Institute for Business and the Environment
Fisherville, Ontario, Canada
Tel. 416 410-0432, Fax: 416 362-5231
Vol. 16, No. 6, October 6, 2011
Honoured Reader Edition

This is the honoured reader edition of the Gallon Environment Letter and is distributed at no charge: send a note with Add GL or Delete GL in the subject line to Subscribers receive a more complete edition without subscription reminders and with extensive links to further information following almost every article. Organizational subscriptions are $184 plus HST nd provide additional benefits detailed on the web site. Individual subscriptions are only $30 (personal emails/funds only please) including HST. If you would like to subscribe please visit If you feel you should be receiving the paid subscriber edition or have other subscriber questions please contact us also at This current free edition is posted on the web site about a week or so after its issue at See also events of external organizations at Back free editions from January 2009 are also available.

Our editorial in this issue addresses the question of partnerships in sustainable development activities. GallonLetter sees this as a key element in moving forward on a more sustainable path and we will be returning to it in future issues.

Our theme in this issue is the linkage between supply chain management and corporate social responsibility. A company is unlikely to have a successful CSR strategy unless its supply chain is complying with similar CSR requirements. Supply chain is not just the raw materials used by the company but also all of the inputs to a production process, especially energy, water, and human labour. As part of our review of supply chain and CSR we review an excellent new book entitled Green to Gold Playbook and look at some exemplary case studies as well as a very interesting study published in association with the Network for Business Sustainability at the University of Western Ontario. One engineer reports that green buildings are not yet achieving much in the way of reductions in energy use by the buildings sector. That corresponds to GallonLetter's impression. We will be reviewing this subject again in a future issue.

GallonLetter has not reported too much on the Keystone XL pipeline issue because it is being quite well-covered in the daily press but we are bringing a report on the opposition that has developed in the state of Nebraska. We suspect that there will be much more to be told about the KXL proposal in the weeks ahead as the US Administration gets its teeth into the issue.

We have two Letters to the Editor, both very thought-provoking, in this issue. We don't usually feel that it is appropriate to comment on such Letters but we have made an exception this time. We are all for debate and argument but buttressing an argument with an opinion of the views of a now-deceased person on a current situation seems to us to be presenting a somewhat intractable point of debate. We always encourage Letters to the Editor, no matter what their perspective, and invite you to send comments on current articles or ideas for new articles to

GallonLetter's editor does not hide and we have a small notice of two events where he will be speaking later this Fall. Invitations to speak on appropriate topics at public or corporate events are always accepted, subject to time and economic considerations.

The CEO of Bullfrog Power spoke recently at the Toronto Board of Trade. We highlight some of his remarks. The Toronto Board of Trade appears to be somewhat in favour of toll roads. GallonLetter found this surprising for a business group and brings you a report on the situation. The US EPA recently produced a Guideline for siting of schools. The Guideline has interesting implications for siting of any building in which children congregate, including homes, and for existing emitting activities that are close to homes and schools. GallonLetter reports appropriately. The Canadian Commissioner of Environment and Sustainable Development, from the Office of the Auditor General of Canada, does not have much good to say about the Government of Canada's record on oil sands, environmental assessment, or climate change. We bring you up to date. We end this issue with our usual funny (peculiar) quip, this issue under the heading Where has Elizabeth May Gone? We encourage you to follow the link - one of the more inspiring videos we have seen in at least a short while!

Our next issue will include a climate change update. The annual United Nations Climate Change Conference is scheduled to be held in Durban, South Africa beginning on 28 November 2011. We will look at the progress that has been made, or not made, in the last year. As the Commissioner of Environment and Sustainable Development has reminded all Canadians, the Kyoto Protocol expires at the end of 2012, Canada has been one of the non-complying countries, and there needs to be a replacement. We will provide our forecast on what will happen in Durban.


Walmart has recently announced plans to install solar panels on the roofs of up to 60 more stores in California, meaning that over 75% of its stores in that state will be meeting between 20% and 30% of their electricity needs from solar power. The Company's goal is to install solar power on more than 130 store rooftops by 2013.

GallonLetter commends Walmart for its solar initiative but also notes that 130 stores represents less than 1.5% (one point five percent) of Walmart stores worldwide. Southern Ontario, for example, is at the same latitude as northern California and generally offers more annual sunshine hours than much of the Pacific state. What are the barriers preventing greater adoption of rooftop solar in Canada?

Many of the barriers are economic, due in part to the low price of electricity in much of Canada, and in part to the high cost of photovoltaic panels. However, government programs are helping both consumers and large facility owners to overcome some of the economic barriers.

The biggest barriers are often related to the nature of the facility itself. Retail stores, industrial plants, and institutional facilities are often quite short-lived buildings. Many are likely to be demolished or substantially rebuilt in less than 20 years. Roof structures are often insufficient to take the load of photovoltaic panels. It may add substantially to the cost of a solar project to have to reinforce the roof to take the additional load or to extend the planned life of the building to match the life of the panels. Hopefully Canadians will soon see new buildings constructed with solar panels installed from the beginning or at least with roofs strong enough to take the load of panels as soon as the economics improve, which they are doing very rapidly.

However, the biggest barrier is one that might best be described as 'corporate culture'. Executives representing owners of large buildings regard their company as being in the retail, manufacturing, or service sector and not in the electricity generating sector. Hence they consider that they are not interested in getting into solar power.

GallonLetter agrees with their perspective of their business but not necessarily with the conclusion to which it leads them. That's where the Walmart initiative is noteworthy. It is not actually Walmart that is installing the solar panels on store roofs but a company named SolarCity. SolarCity was established in 2006 to provide solar power system design, financing, installation and monitoring services from a single source. The Company claims that its solar finance systems enable homeowners and businesses to switch to clean, solar power for less than they pay for electricity from the local utility. It currently reports serving more than 15,000 clients residential, commercial, industrial, institutional and governmental clients across the US and it has offices in a dozen states.

Similar but much smaller companies do exist in Canada but their size limits their reach and their perceived reliability. Canada needs massive investment, which need not be government investment, flowing into companies like SolarCity so that they can finance solar installations across the country. Canada also needs a change of culture in the Boardroom. Executives should recognize that the best sustainability projects, from both an economic and an environmental perspective, may not be a do-it-yourself operation but may instead be a partnership between your company and another that has the expertise, experience, and financing to make the project a win-win-win for everyone.

Paid subscribers see link to original documents and references here.
Colin Isaacs


Sourcing and Procurement is one of the chapters in a 2011 business book called The Green to Gold Business Playbook by Daniel Esty and P. J. Simmons. Although this chapter focuses specifically on procurement, in fact most of the other chapters on greening strategies have some relation to the supply chain including: office activities, buildings and facilities, information technology, product design, manufacturing and processing, and logistics and transport.

Acting on responsible supply chain management often costs more in time and money upfront but has benefits which lead to profits over time. Examples include:
The basic "plays" in the chapter include:
Daniel Esty is also the co-author of a previous book called Green to Gold. He is the Hillhouse Professor of Environmental Law and Policy at Yale University and chairs a consulting company Esty Environmental Partners. P. J Simmons is Chairman of the Corporate Eco Forum, a network of corporate executives.

Although GallonLetter's corporate library has thousands of volumes, this type of high-quality overview of many aspects of corporate responsibility especially with lots of advice and recent references to weblinks and other resources in each chapter is not as common as one might think - definitely worth adding to the library. For those really well informed, some of the chapters may be a useful refresher but for many others there will be many nuggets.

Esty, Daniel C. and P. J. Simmons. The Green to Gold Business Playbook: How to implement sustainability practices for bottom-line results in every business function. Hoboken, New Jersey: John Wiley & Sons, Inc, 2011. CAN$33.95


The EcoGlobe'11 awards presented in Germany for the fifth time on September 6, 2011 are self-described as the first internationally recognized environmental award for the mobility industry. They are awarded by a group including the German University of Duisburg-Essen and the German auto club.. The Ford Transit Connect Electric won for the award for the category of production vehicle model with sustainability factor. In its German subsidiary announcement, Ford mentions the close partnership with Azure Dynamics. AZD develops and produces proprietary electric and hybrid electric and electric components and powertrain systems for light and heavy duty commercial vehicles. Among customers for the Transit Connect are Canada Post and the Toronto Atmospheric Fund. Recently the Ontario Ministry of Transportation ordered two of the vans. The Transit Connect Electric vehicle has a range of 80-130 km (50-80 miles) on a single charge of its lithium battery and a load capacity of 500 kg. The vehicle is intended for commercial users who commonly travel known short routes with lots of stops and starts in the city.

Headquartered in Oak Park, Azure Dynamics AZD has offices in Vancouver and Toronto. ADZ's theme is directly related to supply chain, "AZD is in the business of making a difference to our clients - by making a difference to our environment.

Paid subscribers see link to original documents and references here.


"Globalization = public concern about social and environmental issues = increased complexity in managing supply chains."

A key result of globalization is that goods are being produced in countries with developing or transitional economies. The global supply chain leads to a large cheap labour force and low overhead but there are risks associated with cultural, language, legal, political, procedural and other factors varying across borders. The topics relating to the supply chain are similar to those which affect the greening of companies including environmental issues such as reducing greenhouse gas emissions, reducing waste, designing products for end-of-life recovery, social and ethical issues such as working conditions, bribery and corruption.

Despite policies, codes of conduct, inspections and audits, companies still experience environmental and social failures in the supply chain. Apple has been in the news because a large portion of the supplying factories failed to comply with safety requirements and to pay overtime. Shell and Halliburton have paid multimillion fines to the Nigerian government for bribery and corruption. BP's Deep Horizon oil spill was a result of complex interaction of BP, Transocean and other supply chain members.

A review of studies and literature on the social and environmental aspects of the international supply chain and a framework of best practices was conducted by Dr. Stephen Brammer at the UK University of Warwick and coauthors and published in association with the Network for Business Sustainability at the University of Western Ontario. The conclusions identified some of the reasons, motivations and payoffs companies identify about their supply chain management including:
Top-down Supply Chain Management Mostly a Mistake

Problems with some of the practices of managing the supply chain include:
Adaptation and Learning

The review suggests that better than the tick-box approach is building relationships and working with suppliers, NGOs and others such as broader industry groups to develop specific approaches that reflect the interests of the local stakeholders. Support and investment to help suppliers meet the buyer's needs and less tendency on the part of the buyer to remove the contract are essential. Instead of a pre-formulated code written in New York or London which ignores the local priorities, better is learning from experience to develop practices for the future through communication and measurement. Some of the codes make useless statements e.g. complying with local labour laws when few developing countries have any laws at all that protect worker rights. Environmental management certification requirements such as ISO 14001 aren't a safe investment for many suppliers without a long contract duration. A supplier may have poor sustainable practices but step by step improvement can be valuable both to the supplier and the buyer. Except for the most serious of breaches of the code, withdrawal from the contract should be the last threat. Examples of approaches include key performance indicators for suppliers at different levels of capacity for good practices, awareness seminars and support for developing solutions, and performance measures which are practical and valid. Probation periods, action plans for non-compliant suppliers, a risk register to monitor non-compliance, informal intelligence by local groups, supplier recognition and reward programs are actions which exemplify partnership rather than top-down approach. Some buyers invest in suppliers such as providing low interest loan rates for equipment.

Paid subscribers see link to original documents and references here.


Although some new buildings in Canada have achieved as much as 70% energy savings compared to conventional buildings, Lee Norton, retired engineer and editorial advisor to the business magazine Canadian Consulting Engineer wrote in a recent issue that engineering efforts aren't making much of a dent in the amount of fossil fuel that is consumed by the building sector, which may be responsible for up to 48% of carbon emissions. (US Energy Information Administration).

Quick returns and first cost are still the major driver for buildings. The tenants pay the higher energy costs later while the developers just wants to complete the building to start getting a return on investment. The same capital cost restraints occur at the end of the service life of the equipment when there is a tendency to replace with the same type of inefficient energy-using equipment. Lack of measuring when different equipment or operation measures are implemented means building operators often don't know what changes and technology can reduce both costs and energy consumption.

Building codes have too low standards and could achieve over 50% energy improvement just using known and readily available technologies such as energy and heat recovery ventilators, condensing boilers with low temperature loops and heat exchangers for incoming air. Not all the solutions have to be technical e.g. building orientation to avoid heat buildup and white roofs can help to reduce energy use. Building codes fail to set a high enough standard but in some cases pose a barrier. For example, codes which require light in emergency stairwells to be turned on all the time result in empty buildings consuming more energy than they should. In Europe, motion-activated lighting turns lights off when nobody is in the area.

While engineering firms might try to interest their clients in better energy efficiencies, they might lose their clients to competing engineers offering lower first cost solutions. Norton writes "While it would be nice to limit yourself to clients, who think like you do, engineers usually want, and sometimes need, all their paying clients." Norton thinks mandatory energy efficiency requirements for buildings and incentives and grants from governments are needed.

Paid subscribers see link to original documents and references here.


The Greenhouse Gas Protocol, which claims to be the most widely used international accounting tool for government and business leaders to understand, quantify, and manage greenhouse gas emissions. has two new standards with an official launch of October 4, 2011. One is a Corporate Value Chain Standard and the other is a Product Life Cycle Accounting and Reporting Standard. The standards are meant to take into account both upstream and downstream greenhouse gas emissions associated with the company's products and operations.

Setting Boundaries Between Emissions by Suppliers and the Reporting Company

The Value Chain standard addresses Scope 3 emissions. Scope 3 emissions are often the largest source of GHG emissions and are defined as separate from direct and indirect emissions controlled by the reporting company::
Direct emissions Scope 1: emissions from operations that are owned and controlled by the reporting company
Indirect emissions Scope 2: emissions from generation of purchased electricity, steam, heating or cooling
Indirect emissions: Scope 3 All other indirect emissions in the value chain both upstream and downstream e.g. production of goods and services, transportation, use of sold products.

Scope 1, 2, and 3 are mutually exclusive and when added together represent the total corporate GHG emissions. Scope 3 are emissions owned and controlled by entities other than the reporting company in the value chain including suppliers of materials, travel, logistics, lessees and lessors, employees and customers and waste management providers.

"Boundaries" are an important element in the standard not only for separating Scope 3 from Scope 1 and 2 e.g. how does the company decide what is owned and controlled by itself but also what is excluded in emissions and what is included
e.g. upstream transportation and distribution upstream includes all third party transportation and distribution purchased by the company in the reporting year including that between Tier 1 (direct suppliers) and the company, between company's own facilities and any purchased services. Guidance is also given on various topics and to clarify ambiguities. For Scope 3 emissions, companies account for the total cradle to gate emissions of purchased capital goods in the year received without amortizing the emissions over the life of the product.

The Greenhouse Gas Protocol is a joint undertaking of the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD) and its approach to calculating GHG emissions serves as the foundation for most major GHG standards.

Paid subscribers see link to original documents and references here.

Honda: Supply Chain and Chemical Substances

Honda in its 2010 North American CSR report described efforts to work with suppliers to reduce use of substances of concern. Honda's supply chain includes 600 original equipment manufacturers and parts logistics companies in North America. A single Honda vehicle contains between 20,000 to 30,000 parts.

Since 2004, Honda has sought to reduce hazardous materials and substances of concern SOCs in Honda products. The Honda Chemical Substance Management Standard lists chemicals which should not be used anymore, chemicals with planned phaseout and chemicals being monitored by Honda for possible elimination. A Supplier Substances of Concern Management manul contains Honda's expectation for producers of parts and materials used in Honda products in relation to SOCs and recyclability.

For example, Honda is seeking to eliminate polyvinyl chloride, mostly to significantly reduce chlorine which is found in shredder residue. It has eliminated PVC in underbody coating in all North American manufacturing plants and is working to implement. PVC-free components such as door sealants, floor mats and seat covers. The biggest challenge is the use of PVC to coat electrical parts and wires. Of the 20 Honda and Acura models sold in the US in FY2010, 13 models had less than 1% concentration of chlorine in material that ends up as waste,

As with all companies, Honda is both buyer and supplier. For products and parts shipped to the European Union, Honda has worked with its supply chain to comply with the EU REACH regulations which requires chemical data for substances used in products and materials.

Other Initiatives in Honda's Supply Chain

Honda also described a number of supply change issues including:
Honda's goals to minimize its environmental footprint uses a lifecycle approach. One of the elements of the LCA is Purchasing which includes resource consumption, air emissions, toxic releases and waste associated with the production and distribution of component parts manufactured by original equipment suppliers. Another LCA element is End-of-life which counts waste and toxic emissions from disposal of Hone and Acura products and parts.

Paid subscribers see link to original documents and references here.


The Governor of Nebraska, a Republican and former supporter of the TransCanada megapipeline has objected to the routing of the pipeline through the state's Sand Hills and over the Ogallala Aquifer, the water supply for Nebraska. Nebraska has no legislation which could be applied to a demand to change the routing but a special session of the legislators could be called even if this is said by supporters of the pipeline to be the final hour.

In September, a video featuring a 1978 Huskers football squad ended with "Brought to you be the Husker Pipeline" and sponsorship by TransCanada. Shown on a big screen during a football game at Memorial Stadium (home of the Cornhuskers team) at the University of Nebraska in Lincoln, the video caused such an outcry from the fans that the athletic director, Tom Osborne, a famous football coach, cancelled the sponsorship. Some speculate that the football incident will leave an indelible impression on state lawmakers.

GallonLetter thinks that KXL is all about supply chain issues. The pipeline crosses land owned by others. Canadian labour organizations want their members to be refining oil and providing services relating to refineries instead of shipping the bitumen to the US. Some environmental activists are concerned about spills and the easing of oil shortages in the US due to the big flow making climate change goals unreachable but many are protesting because the supply is oil from the oil sands, contributing more to environmental degradation, greenhouse gas emissions and pollution. Nebraska probably could require the pipeline to be rerouted which may make the project financially unfeasible. Whether that happens or not, we think this story is worthwhile for companies to remember before they get overly complacent about identifying the key stakeholders in their supply chain.

Paid subscribers see link to original documents and references here.


            Subject: Judging Political Records - GallonLetter V16 No. 4

Hi Colin.

With regard to the David Suzuki and Peter Tabuns headlines on the forthcoming Ontario provincial election, the elephant in the room is of course nuclear power, so while we want to maintain the important Green Energy Act (GEA) with Feed in Tariffs etc. (Liberal Party policies), however in the actual David Suzuki article, he makes it clear that he is against nuclear expansion for the many reasons we know about (see the DSF website as one example). So both Peter Tabuns and David Suzuki are in agreement about questioning where the billions of dollars should be going - to energy efficiency and conservation which the Liberals have cut - NEGAWATTS - as Amory Lovins described this years ago, sheer folly given the waste of electricity in appliances, buildings, machines, workplaces, etc.. as well as renewables which are absolutely necessary for the sustainable future that we want and need. It’s not rocket science and there are many studies describing how it can be done ( see also the DSF website, Pembina Institute, Canadian Environmental Law Association,, Ontario Clean Air Alliance, Rocky Mountain Institute, etc...). The choice is not coal or nuclear but another paradigm completely. The health of people and the planet is in jeopardy with the continuing emissions of toxicity of both those dirty technologies. What will they say about us in future decades with the increasing cancers, birth defects and other health problems?

Since the Fukushima Reactor ongoing disaster in Japan, many countries have opted out of nuclear expansion whereas Ontario because of the nuclear industry's pressure and hold on the current government, is alas missing the boat. So while we want the good things the Liberals are supporting we certainly don't want the bad. That will make the choice difficult for many environmentally concerned Ontario voters - but not for all.
Dorothy Goldin Rosenberg MES, PhD

Environmental Health Lecturer, University of Toronto
Board Member, Prevent Cancer Now
Toronto Cancer Prevention Coalition (Occupational and Environmental working group)
Canadian Cancer Society, Stakeholder Advisory Group (Occupational and Environmental concerns)
Volunteer Education Coodinator, Women's Healthy Environments Network
Film Producer "Exposure: Environmental Links to breast Cancer", "Toxic Trespass" on children's health and the environment
Grandmother of three beautiful girls who together with all their generation and those to come, deserve a healthy peaceful planet - the only one we have.

            Subject: GallonLetter Vol. 16 No. 5

Here is a perspective (business) on the environment. Some might say Greenwashing. "The electricity company has the vision of "Powering B.C. with clean reliable electricity for generations." this statement would make BC'ers burst out in laughter. Things like sustainable development are an oxymoron. There are a few nuggets like BC Hydro triple based accounting, "while these indexes they are popular amongst people in the financial services sector with interests in the triple bottom line" .

As someone who worked with Gary Gallon for three years, I can tell you that he would embrace an idea that would be much more hard hitting than the baby food dished here. For example, this news letter should have 4 or 5 enviro critiques of BC Hydro's operation. Wow would that be an eye opener. If Gary was in charge, he would create a eco newsletter that is by the people, for the people. Then he would send it out to all businesses so they could see what the public thinks on them.

It is obvious to British Columbians, that BC Hydro has been an environmentally destructive, bloated, fascist, out of control, crown corporation. This Gary Gallon letter states the opposite. Gary would be rolling over in his grave if he read this below letter.

Rod Marining

GallonLetter Responds: The theme of our last issue was on elements of reporting on corporate social responsibility with specific companies used as examples but with no endorsement on our part.

Gary Gallon, the originator of Gallon Environment Letter, who died in 2003, was always sympathetic with environmental groups but also as energy/environment advisor in Ontario to the Ontario Liberals in opposition headed by David Peterson, and then in the later 1980s working in the office of Liberal Environment Minister Jim Bradley as government, was more active on process: developing policies to protect the environment such as requiring Ontario Hydro to conduct environmental assessment for nuclear expansion plans. Gallon wrote the Gallon Environment Letter from 1997 to 2003 which he described as "A business and environment electronic newsletter published twice a month focussing on economic issues related to environmental developments in Canada, the United States and elsewhere in the world. Provides up-to-the-minute analysis on government decisions and policies that will affect your business, organization, or department." Most of any particular Letter was news and announcements although of course, the selection of the articles was an editorial decision. He wrote editorial opinion as well but he mentioned BC Hydro a half a dozen times at least without feeling the need to critique the company as Marining suggests he should/would have.

Marining was one of the community of co-founders of Greenpeace which included journalist Robert (Bob) and Bobbi Hunter, Gary Gallon, Patrick Moore, Paul Watson and others beginning in 1969. Campaigns were against whaling, seal hunting and nuclear weapons testing. Greenpeace and Sea Shepherd were often active on the same campaigns. After Hunter's death in 2005 one of the Sea Shepherd ships was named after him. Hunter wrote a number of books on the environmental odysseys of Greenpeace and Sea Shepherd. Bobbi, his wife, was part of the fledgling group Greenpeace International of which Bob was the first President. Bobbi became the group's treasurer and as she said in a guest blog on Green Heros was "the first woman to place my body in front of a harpoon to save a whale." Bobbi signs her guest blog with Eco-Activist. Their daughter Emily has edited a book of essays by a new generation of eco-warriors, which Marining mentions in his blog.

Rod, based in British Columbia until radiation concerns caused him to leave the west coast, continues to campaign on environmental issues including crewing and campaigning with Sea Shepherd ships, the other one called the Farley Mowat. He has written in favour of no cosmetic use of pesticides and against developments such as power projects which threaten the habitat of endangered species He sees higher value in the natural state compared to industrial development. GallonLetter sees environmental activists as key to alerting companies, government and the public to threats to the environment. Rod has spent a lifetime on that work and has more than earned the designation Eco-Warrior.

Marining, Rod. Dispatches from the Whole Earth Church.

Hunter, Emily. The Next Eco-Warriors 22 young women and men who are saving the world. Conari Press, 2011. ISBN: 9781573244862 [also available as ebook]. Paperback $19.95.

Hunter. Bobbi. Guest Blog. GreenHeroes.


GallonLetter's Editor will be speaking at two upcoming events in Ontario:
On 20 October 2011, he will be speaking on a post-election panel at an Ontario Environment Industry Association Breakfast meeting. The meeting runs from 7.30am to 9.00am. At the time of going to press the location is still uncertain but it will be in downtown Toronto. Follow and click on Events for details and registration (fee required). Colin Isaacs is a former member of the Ontario Legislature and Environment Critic for the New Democratic Party.

On Saturday 5 November he will be speaking at a public information event on the subject of the Dufferin Eco-Energy Park sponsored by the Mono Mulmur Citizens' Coalition. One of the local issues is gasification of waste and his remarks will particularly address that subject. The event is from 9.00am to noon at the Horizons Event Centre behind Mono Plaza on the east side of Highway 10 north of Orangeville. All are welcome.


Bullfrog Power is arguably Canada's best known supplier of renewable electricity. According to its CEO, Tom Heintzman, speaking recently to a luncheon meeting of the Toronto Board of Trade, launched in September 2005, Bullfrog is now supplying 1000 businesses and 8000 homes in six provinces. Bullfrog supplies green natural gas from landfills and digesters as well as electricity from renewable sources of supply.

Heintzman's topic was the Role of Corporations in Leading Clean Energy Policy and he spoke primarily on voluntary markets, in which people and companies are choosing to buy renewable energy without any regulatory requirement that they do so. In the United States, there are more than 850 green power utility offerings. In many states, the amount of voluntarily purchased renewable electricity is exceeding the amount of regulated power purchased. In most states, utility customers have a check box on their bill asking if they wish to purchase green power. Bullfrog's one ask of governments in Canada is to implement a similarly simple opt-in allowing utility customers to choose green power with a simple check on their utility bill insert.

He said that the main reasons that many of Canada's leading companies are voluntarily purchasing green power from Bullfrog, at a premium price, vary by company but include:
Bullfrog does not look for government subsidies for the renewable generation facilities which meet its customers’ needs but instead invests its revenues in new facilities outside of government initiatives. Heintzman sees local renewable power as a key driver for local economic development. He is also a real enthusiast for voluntary action by Canadians to address the challenge of climate change.
Paid subscribers see link to original documents and references here.


Perhaps the day will come when the reality changes but it is still a surprise when a business periodical, let alone a business organization magazine, publishes an article with an environmentally sensible perspective. Thus Gallon Environment Letter's Editor was amazed to read an article supporting road tolls in ONBOARD, the magazine of the Toronto Board of Trade. The surprise was slightly muted when I noticed that the article was written by the VP Sales of Kapsch TrafficCom AG, an international supplier of electronic toll collection systems.

In its Ontario election 2011 position paper entitled Reaching Top Speed, the Toronto Board of Trade comments favorably on congestion charges, such as that implemented in London, England, and toll roads, such as the Toronto region's Highway 407. The Board even goes so far as to state "Pursuing congestion management, for example, will enable the Toronto region to achieve multiple objectives, such as reduced demand for infrastructure, environmental conservation and equity in the provision of services and infrastructure".

For the 2010 Toronto municipal election, the Board of Trade went even further, with expressed interest in discussing such initiatives as a parking surcharge, a gas tax, road pricing, road tolls, and congestion charges. This is further than many Ontario environmental groups are currently willing to go, apparently fearful of donor backlash against proposals that look like increased taxes.

Kudos to the Toronto Board of Trade for at least being willing to discuss these controversial but environmentally sensible policy options.

The Toronto Board of Trade's magazine, with the article from Kapsch TrafficCom on page 3 (electronic page 5) is at

Paid subscribers see link to original documents and references here.


A few days ago, the US Environmental Protection Agency published a report entitled School Siting Guidelines. The intent of the document is to provide advice to communities and school boards on environmental factors to consider when deciding the location of a new school. It is not intended to address environmental aspects of existing schools but it seems to GallonLetter that it will almost certainly be interpreted that way despite such strong messages as "The School Siting Guidelines are not designed for retroactive application to existing school locations or previous school siting decisions, but rather to inform and improve future school siting decision-making processes." In addition, while not intended for such use, it seems to GallonLetter that the Guidelines may be useful when considering sites for residential development (young students spend more time at home than at school) and for potential location of polluting activities in proximity to existing schools and homes. GallonLetter has seen far too many situations where municipalities have allowed new subdivisions to be constructed in close proximity to pollution sources, only to come under fire later when homeowners and renters discover how neighbouring undesirable land use activities can make their new home an unpleasant or unhealthy place to live.

The over 140 pages of the School Siting Guidelines are remarkably detailed and not too short in their description of the impact of pollution on neighbouring land use activity. They include suggested processes for siting of new schools and a "Quick Guide to Environmental Issues" that seems quite comprehensive and up to date in its interpretation of issues. For example, the section on pesticides includes the statement:

"Potential pesticide usage near prospective school sites in rural, suburban as well as urban locations should be considered and evaluated for potential to expose children or staff to pesticides. Where such potential exists, steps to mitigate potential exposures should be considered and implemented. Potential mitigation approaches include:
In a chapter headed Environmental Siting Criteria Considerations, the Guidelines address a very long list for Screening Potential Environmental, Public Health and Safety Hazards. The list includes:
Paid subscribers see link to original documents and references here.


The fall report 2011 by Scott Vaughan, Canada's Commissioner of the Environment and Sustainable Development in the Auditor General's office contains two chapters one on oil sands monitoring plan and one on climate change plans as well as a section called the Commissioner's Perspective. One of the common themes is the information gaps: "Poor information leaves government unable to properly manage environmental change." Canada used to be a world leadership in environmental assessment but previous audits have shown serious deficiencies in assessments. Vaughan is keen on providing supportive information to the House of Commons Standing Committee on the Environment and Sustainable Development as it conducts a statutory review of the Canadian Environmental Assessment Act: "Done right, environmental assessments warn us of potential problems and specify ways to fix them before they spiral into economic and environmental costs, both today and for our children in the future."

Climate Change

Canada's get-tough-on-crime government is breaking the law. In the 2009 audit, the CESD found that the 2007 and 2008 federal climate change plans were not in compliance with the Kyoto Protocol Implementation Act. Despite the recommendations of that audit and Environment Canada's response accepting 3 out of the 4 recommendations, the 2009 and 2010 climate change plans are still not in compliance with the Act. The plans fail to include:
The report provides some details on how the government's plans relates to these failed requirements. For example, the 2010 plan which is somewhat improved over 2009 still does not provide any information about how the failure to implement the Regulatory Framework for Industrial Greenhouse Gas Emissions in 2009 will be redressed. The Framework accounts for over 85% of the projected emissions reductions for that year. The criticism about information gaps is quite serious and leaves the auditor unable to properly do his job which is holding the government to account. For example, the 2009 and 2010 climate plans make various statements such as there being no notable inequities among economic sectors in the distribution of GHG emission reductions but the CESD concludes "However, we found this conclusion difficult to confirm with the information provided."

The plans don't give a total amount of funding the government has provided. Financial information for individual measures is inconsistent and sometimes not reported at all. The CESD’s office calculated that at least $9.2 billion were allocated to implement climate change With successively lower greenhouse gas reduction targets, the cost per unit of CO2 emissions reduced rises. Because of the scarcity of information, it is essentially impossible for parliament to link dollars spent to results achieved. The substantial spending is not producing the needed results: Canada isn't going to achieve the necessary reductions in greenhouse gas emissions that are required to meet Canada's Kyoto Protocol obligations and likely not the lower targets of Copenhagen either. Industry needs a consistent plan on climate change to reduce greenhouse gas emissions. Since the audit, the government produced its 2011 Climate Change Plan and 2011 National Inventory.

Oil Sands

The oil sands have cumulative effects. Both Environment Canada and Fisheries and Oceans Canada have warned since 1999 that more environmental information is needed to determine the combined impact of the megaprojects in the Lower Athabasca region and in the ecosystem beyond. Lack of data also is a problem in other environmental threats such as airborne toxic substances and the impact on freshwater and wildlife from the oilsands as well as long-term impacts on human health: "As a consequence, decisions about oil sands projects have been based on incomplete, poor, or nonexistent environmental information that has, in turn, led to poorly informed decisions."

The Phase Two of the Plan to monitor the oilsands was released by the federal government in July 2011. Vaughan sees this as an important step forward in terms of acknowledging the data gaps and in setting up a detailed plan to fix them. Vaughan is looking for, "a plan that has clear objectives, timelines, roles and responsibilities, and performance outcomes to help Parliament track the government’s progress." The implementation should also be guided by partnership with First Nations. The report suggests that the plan should become a model for other Canada ecological hotspots, "from Canada's North to the Bay of Fundy and Great Lakes regions." GallonLetter reads that to mean that the oil sands isn't the only area where poor data leads to poor decision-making.

Canada. Office of the Auditor General of Canada. 2011 Report of the Commissioner of the Environment and Sustainable Development to the House of Commons. Ottawa, Ontario: October, 2011. 


If you enjoy Gallon Environment Letter or find it useful for your work or interests, may we recommend the GallonDaily report. Found at, GallonDaily provides short articles and reports on topics of particular interest to green businesses. One article appears almost every day Monday to Friday - we recommend visiting at least once a week. Our real enthusiasts can also sign up for email notification as new articles are posted. Recent topics include:

Readers wondering why Canada has heard so little from Green Party of Canada Leader and MP are referred to Ms May has been in hospital for hip replacement surgery. The clip, focusing primarily on health care, is quite entertaining. Thanks to CTV for not overlooking Canada's Green MP.
Copyright © Canadian Institute for Business and the Environment
119 Concession 6 Rd Fisherville ON N0A 1G0 Canada. Fisherville & Toronto
All rights reserved. The Gallon Environment Letter (GL for short) presents information for general interest and does not endorse products, companies or practices. Information including articles, letters and guest columns may be from sources expressing opinions not shared by the Canadian Institute for Business and the Environment. Readers must verify all information for themselves before acting on it. Advertising or sponsorship of one or more issues consistent with sustainable development goals is welcome and identified as separate from editorial content. Subscriptions for organizations $184 + HST = $207.92. For individuals (non-organizational emails and paid with non-org funds please) $30 includes HST. Subscription includes 12 issues about a year or more.