Today SaskWind submitted, to the Canadian Environmental Assessment Agency (CEAA), our recommendation that SaskPower's proposed gas-fired power station in Swift Current be subject to a federal environmental assessment.
We show the Greenhouse Gas emissions from that facility - in addition to the cooling water requirements - will be significant and will affect federal lands and lands outside of Saskatchewan. We demonstrate that technically and economically feasible alternative means exist to mitigate those effects and also that SaskPower has not given these alternative means adequate consideration prior to proposing the Chinook gas plant.
CEAA will announce their decision by Friday 2 December. Details on their site.
In any event, we are sure our submission will enjoy the full support of Premier Wall since his 18 October 'Climate Change White Paper' states;
Summary of SaskWind submission
CEAA purpose is to protect the Canadian environment from significant adverse effects caused by Designated Projects. It places a duty on the Minister to ensure that protection through application of the Precautionary Principle. This states that where there are threats of serious or irreversible damage; lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.
Canada’s ratification of the Paris Agreement signifies both that Climate Change poses a credible threat of serious damage and also that Canada is committed to concrete steps to address that threat. The question is therefore threefold: Does Chinook create ‘significant adverse effects’? Are ‘cost effective measures’ available to prevent or mitigate them? Has SaskPower given due consideration to those alternatives prior to proposing Chinook?
GHGs. The annual GHG release from Chinook will be 1.04 million tonnes. This represents 6.8% of SaskPower’s total 2015 GHG emissions or, at a 2022 carbon price of $50/tonne, a cost of $52-million annually. By definition any atmospheric emissions will have effects far from their point of origin and, specifically, on federal lands and lands outside of Saskatchewan. It is therefore reasonable to conclude that Chinook’s expected GHG emissions are ‘significant’ within the context of the CEAA. Wind turbines emit no GHGs in operation.
Water. Chinook’s annual cooling water consumption will be 36,500 m3; a volume which would be sufficient to fill 15 Olympic-sized swimming pools. This volume of water, given Swift Current’s semi-arid climate, is arguably significant. Wind turbines require no cooling water.
Wind economic feasibility. Wind energy costs are 60% lower today than six years ago. Wind turbines, given Saskatchewan’s world-class wind resource, can generate zero-emission electricity at a cost which is directly competitive with natural gas-fired power stations such as Chinook. If a carbon price of $50/tonne, equivalent to $20/MWh, is included; wind is significantly cheaper than gas-fired power stations.
Wind technical feasibility. Chinook will at most generate 10% of Saskatchewan’s total electricity (although 6% seems more likely). SaskPower implies that Chinook has to be built before wind energy, which currently supplies 2.9% of total electricity, can supply any more. There is, however, no evidence to support that position. The findings of numerous power system studies, together with the experience of multiple North American jurisdictions, demonstrate the additional fast-acting reserve, provided by Chinook, is not necessary for wind to meet 10%, or even 30%, of the province’s power needs.
SaskPower consideration of alternatives. In the last ten years, the amount of Saskatchewan’s electricity generated by wind turbines has remained unchanged at 2.9%. Although SaskPower states it has plans for the significant expansion of renewable energy; their actions in the last decade suggest otherwise. Their future plans are anyway not relevant to the evaluation of Chinook and, specifically, to whether SaskPower has given adequate consideration to other technically and economically feasible means of carrying out that project. The evidence, we would suggest, demonstrates they have not.
We have shown;
- Chinook creates significant adverse environmental effects;
- Alternative means of carrying out the Project are technically and economically feasible;
- These alternative means result in significantly reduced environmental effects;
- SaskPower has not given serious consideration to these alternative means.
Our view is, therefore, that a Federal Environmental Assessment of Chinook is required.