“Management and reduction of greenhouse gases” from Saskatchewan’s electricity – the devil is in the detail

Any serious programme to address climate change has to include an accelerated phase-out of coal.  That is because it’s the most carbon-intensive fuel in common use.  Among the most carbon-intensive coals is the low-grade lignite which SaskPower uses to supply a little over 40% of our electricity – and which is responsible for over 70% of SaskPower’s greenhouse gas emissions.  Transitioning off coal is low-hanging fruit, provided that it is properly planned.

But coal doesn’t just emit lots of carbon dioxide when it is burnt.  Because there are all sorts of impurities in coal, a number of pollutants get put into the atmosphere – sulphur dioxide, nitrogen oxides, mercury, other heavy metals, particulates.  These are all damaging to human health when breathed.  An exit from coal would not only reduce our carbon footprint, but also save lives, reduce incidence of respiratory illness and save money for our medicare system.  These savings have been quantified in some detail.

As part of the federal package of climate policies, Environment and Climate Change Canada is set to announce regulations to phase out coal-fired electricity generation by 2030.  So for over a year now, the provincial government has been in negotiations with them.  Ontario closed its last coal-fired station in 2014: since then, only Alberta, Saskatchewan, Nova Scotia and New Brunswick have been using coal to generate electricity.

Alberta has developed a clear plan to hit the 2030 deadline.  Provinces are, however, entitled to negotiate “equivalency agreements,” to achieve the intentions of the federal plan by other means.  Thus New Brunswick has also committed to close its one coal-fired power station by 2030, but only “if adequate support can be found to minimize impacts on energy costs and the local economy.”  The uncertainty generated by this conditionality is counterbalanced by a more general commitment to reduce overall emissions from electricity.  Nova Scotia has gone further, with no date quoted for a complete exit from coal but a firm commitment to achieve 55% cuts in emissions from electricity by 2030 (compared to their 2005 peak) through efficiency measures (demand-side management) and new renewables.  Saskatchewan’s position was not made fully public until December 15th, when regulations intended as the framework for its own equivalency agreement were published in the Saskatchewan Gazette (pages 967-972:  the most important information is in the tables in part 4 at the very end of the document).

These are regulations for implementation of parts of The Management and Reduction of Greenhouse Gases Act,which was originally passed in the Legislature in 2009 but never implemented until now. In the official government media release they are presented as “the next step towards an equivalency agreement with the federal government” in lieu of federal coal-fired electricity regulations, together with the claim that “under provincial regulation, future electricity emissions are expected to outperform federal expectations.”

Rather than specifically addressing coal, the regulations set gradually reducing caps on total greenhouse gas emissions from the entire grid-connected electricity sector.  These caps are shown in the graph below – the figures for 2018-19, 2020-24 and 2025-29 respectively are in each case shown as yearly averages (the regulations instead specify totals for those periods).  A more generous cap is offered if SaskPower proceeds with carbon capture and storage (CCS) technology on Boundary Dam units 4 and 5 before the beginning of 2024.  (It appears that despite the high cost, the difficulties encountered in running Boundary Dam 3 with CCS, and the consequent reluctance on the part of SaskPower to extend the experiment to other plant, the government is still keen to apply this technology.)

(To see the graph at higher magnification, right-click it and open in a new tab)

The caps set in the regulations (2018 to 2029 inclusive) still leave emissions levels substantially in excess of the SaskPower target for 2030 – itself less ambitious than Nova Scotia’s.  The government did officially endorse the SaskPower target in its December 4th climate policy document – one of the very few commitments to which a credible number was attached.  Which raises the question:  Why state a commitment without including it in the relevant regulations published the following week?

Assuming that the intention is still to achieve the SaskPower 2030 target, the regulations are framed in such a way that it can be left almost until the last minute – not a climate-friendly approach given that it is cumulative emissions that determine climate impact.  And even then, it will – if accepted as equivalent by the federal government – be the weakest commitment by any of the four remaining coal provinces.  It is difficult to see how these regulations can be viewed as achieving “equivalency.”

Let’s assume that both government and SaskPower genuinely intend to hit the 2030 target.  And let’s assume that SaskPower achieve 50% renewables capacity by the same date (despite the government’s recent softening of the wording to “up to 50%,” which could mean anything).  But we also know that SaskPower is planning for a substantial increase in demand, coming primarily from new industrial customers.  As a result, the 50% fossil capacity on a much larger 2030 grid is unlikely to be smaller than the current approximately 75% fossil capacity.  Indeed, SaskPower has on its website a one-year-old document which shows an actual increase in fossil capacity (from 3300MW to 3500MW).  So it is fair to assume that the new renewable power capacity merely handles the increase in demand (and maybe not even all of it), with any actual reduction in emissions achieved by a shift from conventional coal to less emissions-intensive fossil options.

If this is the case, they could be considering any of the following options:

  1. full replacement of the coal fleet with gas-fired plant emitting about 500kg carbon dioxide per MWh – this is inefficient technology given that modern combined-cycle gas plant can achieve 350kg/MWh.
  2. replacement with more efficient modern gas-fired plant while keeping some coal in place
  3. replacement with a mix of coal+CCS and gas-fired plant, while again keeping some conventional coal in place

This implies a lack of ambition.  It means either a shift to outdated and inefficient designs for gas plant, or else continuation with dirty coal technology well beyond 2030.  In either case, it does not represent true equivalency, let alone “outperforming federal expectations.”

In any case, it appears that all options currently on the table involve heavy dependence on gas.  Given that the reserves to production ratio (R/P) of Saskatchewan fossil gas has been declining steadily and is currently only about 7 years (and already the majority of gas produced in the province is an oilwell byproduct), it appears likely that at some point in the 2020s SaskPower will become dependent on importing gas produced by high-pressure fracking techniques in other provinces (and possibly also in Saskatchewan if the price is right).  Compared to conventional gas extraction, high-pressure fracking increases the risk of surface- and groundwater contamination, air pollution, local earthquakes, and leakage of the potent greenhouse gas methane.

We need instead an option (4) – an ambitious demand-side management programme to increase efficiency, a much more rapid rollout of renewable power, enhanced power trading with Manitoba, no new gas plant, and the closure of all conventional coal plant in a rolling programme to be completed by 2030 (earlier if possible).  If Boundary Dam 3 remains unreliable it should also be shut down early.  The global carbon budget has become so tightly constrained that nobody should be building new fossil infrastructure, but instead planning its phase-out.  And the costs of both wind and solar photovoltaics have been dropping so rapidly that both should be able to outperform fossil options on cost well within the timeframe being considered here.  International experience shows that the variability of wind and solar power only begins to become an issue as their penetration approaches about 20% of total generation, and that is when power trading with Manitoba becomes important – we sell wind and solar power when we have an excess, and buy hydroelectric power when we have a shortage.

Then once we are off coal, we need similar measures (but also some provision for storage) to phase out gas.  There is no such thing as a clean fossil fuel in the age of climate emergency.

We know that a rapid shift to renewables can be done because other jurisdictions are doing it.  In terms of the level of renewables penetration of the grid, Scotland achieved in 6 years (2007 to 2013) what SaskPower announced two years ago it would try to achieve in 15 years.

Let’s see a little more ambition.

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