Brian Zinchuk is editor and owner of Pipeline Online
Even if Boundary Dam Unit 3’s capture plant reached its designed capture rate of 90 per cent, it would still emit nearly five times more than the federal government will allow under the draft Clean Electricity Regulations. Photo by Brian Zinchuk
REGINA – Premier Scott Moe said Saskatchewan will not attempt the impossible when it comes to power production, in anticipation of impending federal regulations that would all but eliminate natural gas and coal-fired power generation in Canada. That statement was made on May 16. On Aug. 10, the federal government released its draft Clean Electricity Regulations, and it looks like they will, indeed be impossible for Saskatchewan, which on any given day uses fossil fuel-fired power generation for up to 84 per cent of its demand.
Just how realistic are the proposed regulations? Pipeline Online asked SaskPower a list of detailed questions regarding the Clean Electricity Regulations (CER). On Aug. 17, SaskPower spokesperson Scott McGregor responded by email. This is that email, verbatim:
Pipeline Online: The federal Clean Electricity Regulations call for emissions of no more than 30 tonnes CO2 per gigawatt hour (t/GWh) if burning fossil fuels. How does that compare to past and current operations of Boundary Dam 3? Have we ever met those levels?
SaskPower: The proposed emissions limit of 30 t/GWh is more than 10x more stringent that what Boundary Dam 3 (BD3)/carbon capture and storage (CCS) has been able to achieve to date. BD3 has never been able to meet that low of emissions level, nor is it capable of meeting that threshold (its nameplate capture rate of 90 per cent equates to an emissions intensity of approximately 140 t/GWh).
Historically, our CCS operation at BD3 has had varying emission-reductions results, due to when and how the facility has been operated. For example, for the fiscal year ending March 31, 2023, 64 per cent of total GHG emissions from Boundary Dam Unit 3 were captured.
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Pipeline Online: It seems to me that might be possible with carbon capture on natural gas, but unlikely with coal. Can you confirm or discuss?
SaskPower: Theoretically, CCS on a natural gas facility could achieve the 30 t/GWh limit proposed in the CER, though this technology has yet to be commercially demonstrated in a manner that would allow SaskPower to comment one way or another.
Pipeline Online: I haven’t read it through enough to see this. Is coal allowed past 2030 with carbon capture installed?
SaskPower: Between January 1, 2030 and December 31, 2034, current legislation would allow a coal-fired unit outfitted with CCS to operate, provided the unit could achieve annual emissions of no more than 420 t/GWh – should this limit not be achieved, the unit would not be permitted to operate.
From 2035 onward, current federal coal regulations would be repealed and replaced with the CER and its emissions limit of 30 t/GWh, and with this new threshold, BD3 would not meet the emissions thresholds and would not be permitted to operate beyond 2034.
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Pipeline Online: If so, will SaskPower consider adding carbon capture to its remaining fleet, or rebuilding its coal fleet with carbon capture (new power plants with CCS?) When I asked the minister about this a year ago, he implied that coal with CCS would not meet the levels of emissions then being discussed?
SaskPower: As noted above, the emissions intensity of CCS at BD3 is significantly higher than what will be permitted in the CER, even at a 90 per cent capture rate. That said, SaskPower is still evaluating the future of CCS on coal, and no final decisions have been made regarding this technology and how it could fit into our energy future.
Ultimately, CCS on natural gas-fired units is a much more viable option, going forward.
Pipeline Online: There appears to be an allowance to operate natural gas plants commissioned prior to Jan. 1, 2025, for 20 years. What impact would that have on Chinook, Great Plains and Lanigan?
SaskPower: The draft CER does provide an allowance for units commissioned before January 1, 2025 to be able to operate unabated for 20 years. So, legally we could operate Chinook and Great Plains Power Stations for 20 years after they started operation because they were (or will be) operational before 2025. Aspen (near Lanigan) would not begin operation until after 2025, so would have to meet the CER limit of 30 t/GWh by 2035 or operate in a constrained manner to support renewables (the draft CER indicates a unit could operate for up to 450 hours per year to support renewable energy such as wind and solar).
It’s also very important to note that SaskPower would be required to pay for any and all greenhouse gas emissions from the facility, making the operation of any power station producing CO2 extremely expensive. A carbon charge would be in place for any facility emitting greenhouse gases, which could make it very expensive to operate any facility with GHG emissions.
Pipeline Online: There’s allowances for behind the fence power generation to be exempt for industrial users, like mines, if they are not selling into the grid (But they’ll be carbon priced out of existence with the output based pricing). How would that affect our co-generation, like Cory, where we get a lot of power from them? Would Cory have to separate from the grid to keep going?
SaskPower: We are still reviewing how the provisions in the current draft of the CER will affect co-generation and our existing operations.
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Pipeline Online: Are any of the timelines in these regulations realistic or even possible?
SaskPower: SaskPower is working as fast as it can to decarbonize the power grid while also providing reliable, sustainable, and cost-effective power. We’re committed to achieving a net-zero greenhouse gas (GHG) emissions power system and we’re on track to do so by 2050 or earlier. We’re also on track to reduce GHG emissions by 50 per cent below 2005 levels by 2030. However, reaching net zero by 2035 isn’t feasible technically, logistically, or financially.
Once the CER is published in Canada Gazette Part 1 on August 19, a 75-day period to engage with Environment and Climate Change Canada (ECCC) officials to provide feedback on the draft regulation will begin, where SaskPower and Saskatchewan will express our concerns and interests to the federal government.
Pipeline Online: The document talks about increasing grid capacity by 2.5 times in 26 years, three months and 21 days. How are we going to do that, especially without coal and natural gas?
SaskPower: As stated in the previous note, the CER would require SaskPower to effectively rebuild our entire power system, through retiring the majority of our existing generating units and replacing them with new, ultra-low emitting units or non-emitting energy sources, while also growing the system to support expanding electricity needs that are expected to support growing demand for clean electricity for industrial needs, transportation, increased customer participation and other needs. This creates an unprecedented challenge and will require significant discussions with ECCC to ensure they understand the scope of the challenge and possible costs and technical constraints of the regulation.
Saskatchewan’s power system took nearly a century to build, and with the CER, we are being told to rebuild it with new and non-emitting generation sources, expanding our transmission system, and modernizing our distribution network in a fraction of that time. This means that, along with provinces such as Alberta, Nova Scotia and New Brunswick, we are among the Canadian jurisdictions with the longest paths to net-zero.
We have asked the federal government to recognize Saskatchewan’s unique circumstances and challenges, and have asked for regulatory flexibility to ensure reliable and cost effective power for our customers during this transformation.
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