(June 18, 2021)  The following comments were submitted to the New Brunswick Energy and Utilities Board on behalf on the New Brunswick Anti-Shale Gas Alliance, Inc., (NBASGA) a collaboration of Anglophone and francophone civic groups across the province, reference a planned gas pipeline expansion in Havelock, NB.

(Information about the project and the Energy Utility Board process can be found here:

We had hoped to learn more about this project when it was first announced. I received a confirmation email from the Energy Utilities Board (the Board) in July 2020 affirming that I (as an individual) would be on a list to be notified when Liberty Utilities (Liberty) actually submitted its proposal.  However, that notification never came.

Therefore, some of the questions and issues in these public comments may have already been asked or addressed previously, but we lacked the specific knowledge about the project that may have been available in an earlier intervention.

It might seem that a project of this modest size would not attract much attention, let alone criticism.  But to the contrary, it is precisely because it is just barely noticeable that it escapes the public scrutiny of a larger project, although it may share identical concerns. It is also worthy of comment, because Graymont, the prospective benefactor of this project, is in the business of burning lime.

The burning of lime is very energy intense and is now estimated to be responsible for at least half of the 8% of the global emissions of CO2 attributed to the making of cement. (1) This economic sector is one of the largest producers of CO2 emissions. Thus, there are larger issues for the Board to examine, such as the effects of the project on provincial and national goals for reducing greenhouse gases (ghg).

We assume that Graymont already receives gas from Liberty Utilities by means other than this proposed direct pipeline, and so the pipeline project is not a necessity, but is rather a cost-savings or convenience for Graymont, with the added bonus for Liberty to use it to solicit and service new gas customers.

  • The first questions we would like answered is whether this pipeline project, which does not appear to be necessary, will result in increased lime burning, specifically resulting in increased ghg emissions? If so, how will the Board and government account for them?

Perhaps, the most dramatic statement on the necessity of acting on climate change was issued just a few weeks ago by the International Energy Agency. This agency, long regarded favourably by fossil fuel producers – (it once promoted the “Golden Age of Gas”) – just announced that there can be no new development of any new fossil fuel resources, and that we must start drastically reducing our usage of those we have (2), to have any chance of meeting climate goals.

This bombshell, which finally, accurately reflects the conclusions of climate science, may not yet have begun to sink in completely.  But one of the points of the statement is that investment in new fossil fuel infrastructure runs an increasingly large risk of being a stranded asset.

Governments, businesses and societies must now find ways to halt the expansion of fossil fuels, and to plan how to severely reduce their use in the next 7 or 8 years.  That the IEA is saying this should strip away any doubt that we, and the climate, are is serious trouble.

The reduction in fossil fuels is achievable, as both the IEA and numerous studies have pointed out. There are only a few special applications that cannot be addressed by substitutes for gas and oil. It is often only inertia, force of habit and laziness that limit our choices.

There are alternatives to gas fuelled methods for limestone burning. One can find such alternatives – even patents for such technology (3) – by using a google search.

We are not expert enough to know if Graymont could implement any such alternatives, and we recognize that there may be complicating factors, such as the climate effects of the fuels that make up the energy sources used to generate the electricity for alternatives.

  • So, our second question is whether the Board is satisfied that Graymont has fully examined alternatives to gas, in light of climate considerations, and has Liberty, as Graymont’s utility supplier, assisted them in finding alternatives?

As we noted, the expanded pipeline will allow Liberty to expand its gas customer base.  We object to this for several reasons. We have briefly addressed the fact that any new expansion of fossil fuels is contrary to combatting climate change.

But we also have objections in the areas of public health and safety, environment and human rights, and the province’s economic future.

Public Health and Safety.

Most of what follows in this section can be found in an extensive summary of the research on indoor gas pollution compiled by the online publication Quartz:

Why experts are sounding the alarm about the hidden dangers of gas stoves: https://qz.com/1941254/experts-are-sounding-the-alarm-about-the-dangers-of-gas-stoves/

However, in the discussion below, we have footnoted the actual studies we cite.

The severe health effects caused by the extraction of gas, the air pollution created by its burning in industrial uses, and its fugitive methane emissions are well known, (and the basis for many moratoriums on the extraction of unconventional gas). Yet, little attention has been paid over the years to the indoor effects of gas combustion.

In fact, unlike the outdoors, many jurisdictions do not have standards for indoor gas pollution from gas, which produces both CO2 and the more health-damaging NO2 (nitrogen dioxide).

This, however, has changed in the last two decades, and recent scientific studies and reports are finding health problems that are caused or worsened by the indoor combustion of gas.

In “Health Effects from Gas Stove Pollution” (4) researchers found:

    1. Indoor air is largely unregulated and is often more polluted than outdoor air.
    2. Gas stoves can be a large source of toxic pollutants indoors.
    3. Indoor pollution from gas stoves can reach levels that would be illegal outdoors.
    4. There are well-documented risks to respiratory health from gas-stove pollution.
    5. Children are particularly at risk of respiratory illnesses associated with gas-stove pollution.
    6. Lower-income households may be at higher risk of gas stove pollution exposure.

A study from the UCLA Fielding School of Public Health (5) noted:

“The indoor air quality analysis found that concentrations of nitrogen dioxide (NO2) during cooking events can exceed the levels set by national and California-based ambient air quality standards.

Under a cooking scenario where the stove and oven are used simultaneously for an hour, acute exposures to NO2 from cooking with gas appliances exceed these levels in more than 90% of modeled emission scenarios.”

In light of the COVID-19 epidemic, another recent peer-reviewed study led by researchers at Emory University (6) troublingly suggests that, “exposure to NO2—the primary pollutant of concern from gas appliances—could compound the dangers of the novel coronavirus in communities that are already at higher risk of infection and of dying from the disease.”

Examining Covid-19 mortality data in more than 3,000 US counties, they found that long-term exposure to elevated NO2 was correlated with a higher risk of death from Covid-19—and that NO2 appeared to be more dangerous than either particulate matter or ozone.

Even before COVID, studies, such as a 2018 study from the University of Queensland (7), found that in Australia, where 38% of households rely on gas stoves for cooking, more than 12% of the total burden of childhood asthma was attributable to their use.

Most of these studies, and others, note that the impacts of indoor gas pollution include the loss of many lives, the degradation of health and living conditions for many more, and billions of dollars in associated public health costs.

The accumulation of all this evidence led the New England Journal of Medicine to publish an editorial in January, which recommended that, “new gas appliances be removed from the market.” (8)

It was co-authored by Howard Frumkin, a former director of the CDC’s National Center for Environmental Health, which is responsible for investigating environmental drivers of illness and promulgating guidance about those risk factors.

Heeding these studies and the advice from the editorial, many jurisdictions around the globe are acting – for public health and climate reasons – by banning gas appliances from all new construction. This move is already being taken by 40 US cities, including San Francisco (9), and Australia (10), New Zealand (11) and Vancouver, BC. (12)

  • Our third question is whether it is proper for Liberty to seek an expansion of a business that is increasingly being revealed as a health threat to its customers and the public, and should the Board be enabling this?

This is an emerging issue that is being treated by the gas industry in much the same way that the tobacco industry reacted to health studies on its product.

Environmental and Human Rights Concerns

Besides worsening climate change, more gas means the support of more fracking.  There were good reasons for New Brunswick to enact a moratorium on fracking, and those reasons have grown in number and validity every year since.  The detrimental health effects, the air and water pollution, the earthquakes, the methane releases, etc., etc., are all well documented (13), and many other jurisdictions also have bans and moratoria on fracking.

The evidence of its detrimental effects on people and the earth have even reached the point where the International Court on Human Rights has issued a report calling for a comprehensive and complete ban on fracking,” citing nine different areas where fracking infringed on human rights. (14)

It is a simple fact that almost all gas produced in North America, and certainly in the northeast, is extracted through fracking.

  • Our fourth question is whether the Board, representing a province that bans fracking, should literally be complicit in human rights violations by enabling the expansion of fracked gas?

The Province’s Economic Future

Being in the energy field, the Board undoubtedly will be familiar with the statements we will make in this section, so we have not provided references to specific numbers, although they can easily be furnished if necessary.

We have already mentioned that any new fossil fuel infrastructure runs an increasing risk of being a stranded asset. This can be seen by the withdrawal of private investment from the oil and gas industry, the divestment from the industry by large institutional investors and hedge funds, and the industry’s ever-increasing dependence on government subsidies and support.

New Brunswick should feel itself lucky that it has no vast fossil fuel infrastructure to decommission, outside of the Irving refinery.  The refinery will undoubtedly be here for some time to come, although even it will be forced to shrink.

Governments in other provinces that have extensive gas and oil infrastructure are already on the hook for 10’s of billions of dollars to wind down the industry.

In reaction to the climate crisis, courts have recently ordered the government in Germany (15), and Shell Oil (16) in the Netherlands, to strengthen their climate actions and reduce their emissions. These are precedents that are likely to be repeated around the world.

Whether the diminishing of the fossil fuel industry happens quickly or gradually, the direction for the industry is clear. This means that other businesses that depend on it will also face decline unless they find alternatives. That is why it is so important that we stop digging our selves deeper into a hole, and instead begin to do things to address all of the issues we have noted above in our exit from fossil fuels.

Business as usual cannot continue. Every little increase in the use of fossil fuels, such as the Liberty Utilities new pipeline project, is an affront to reason, logic and our own well-being.

We must produce energy that does not harm public health, does not damage the environment, does not contribute to climate change, and does not lock us into an economic system that cannot continue to exist for much longer.

If we simply keep approving the small fossil fuel projects, we will never be able to say ‘no’ on the bigger issues that will surely be coming our way soon, and we will delay our start on the necessary alternative path to clean energy, making the transition to our inevitable future harder and more expensive.  Change will be easier the sooner we start to manage it.

Our final question is whether any new fossil fuel project is compatible with our economic future, when the laws of many nations the laws of nature argue against it?

So, we ask you to consider and answer our five questions. We believe the answers to them will result in your rejecting Liberty Utilities application for a pipeline expansion. That is our request.

If the project is approved, we would like to see your answers to our questions in your rationale.

At the very least, Liberty and Graymont should be asked our questions too, as their customers would be better served by the increased public health, the preservation of the landscape, and the protection of the earth’s climate achieved by moving the province away from fossil fuels.

We urge the Board to also consider our comments in any future applications that would increase the use of fossil fuels.

Thank you for your consideration.

Jim Emberger, Spokesperson
New Brunswick Anti-Shale Gas Alliance


(1) Global CO2 emissions from cement production
Robbie M. Andrew
CICERO Center for International Climate Research
Earth Syst. Sci. Data, 10, 195–217, 2018

(2) IEA declares ‘golden age’ for natural gas, LNG over
New IEA roadmap says no new LNG projects are needed in net-zero scenario

(3) Rotary kiln for producing lime through calcination by using electric heating device

(4) Health Effects from Gas Stove Pollution
Brady Seals, Andee Krasner

(5) Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California
Dr. Yifang Zhu
UCLA Fielding School of Public Health Department of Environmental Health Sciences

(6) Urban Air Pollution May Enhance COVID-19 Case-Fatality and Mortality Rates in the United States
Donghai Liang

(7) Damp housing, gas stoves, and the burden of childhood asthma in Australia
Knibbs, Luke D.

(8) The False Promise of Natural Gas
The New England Journal of Medicine
Philip J. Landrigan, M.D., Howard Frumkin, M.D., Dr.P.H., and Brita E. Lundberg, M.D.

(9) San Francisco Bans Natural Gas Use in New Buildings

(10) Net-zero emission buildings: council releases bold post-COVID development plan

(11) ‘The Government will not hold back’: Jacinda Ardern on how NZ could go zero carbon

(12) Vancouver Council Votes Against Delay for Climate Emergency Plan
City bylaw will require new homes built after Jan. 1 to use zero-emissions heat and hot water systems, effectively banning natural gas hook-ups.

(13) Compendium of Scientific, Medical, and Media Findings Demonstrating Risks and Harms of Fracking (Unconventional Gas and Oil Extraction) – 7th edition

(14) ICHR Report International Human Rights Impacts of Fracking.pdf

(15) ‘Historic’ German ruling says climate goals not tough enough

(16) Court orders Royal Dutch Shell to cut net emissions by 45%
The decision could set a precedent for similar cases against polluting multinationals around the world