An op-ed, short for “opposite the editorial page”, is a written prose piece, which expresses the opinion of an author usually not affiliated with the publication’s editorial board.
Minister Responsible for SaskPower Jeremy Harrison, in the yellow high visibility vest and orange hard hat, and the rest of the tour of the Estevan mine on July 27. The dragline is known as “Big Lou.” Photo by Brian Zinchuk
Round 1: Dr. Brett Dolter’s piece for the C.D. Howe Institute on the cost of coal refurbishment
Round 2: Pipeline Online’s story and analysis on said piece
Round 3: Dr. Dolter’s rebuttal of said analysis, seen here
Editor’s note: Dr. Brett Dolter’s recent contribution published by the C.D. Howe Institute entitled “The High Cost of Coal-Fired Power as a Bridge to Nuclear” has been raised by the Saskatchewan NDP as yet another reason to pump the brakes on refurbishing Saskatchewan’s coal-fired power generation fleet. Here’s the original piece published by the C.D. Howe Institute, and here is the story Pipeline Online wrote about it, the second half of which is an in-depth analysis of Dolter’s original article.
Dr. Dolter is an associate professor, Department of Economics, University of Regina
On July 30 Dolter requested the opportunity to have his rebuttal of that piece published by Pipeline Online. Here it is, in full, uneditted. By the way, civil discourse like this is a strength of a democracy, and Pipeline Online encourages differing opinions as op-eds and letters to the editor.
Dr. Brett Dolter. Submitted
I recently published a comparison of a scenario where coal plants in Saskatchewan are run until nuclear SMRs are built, against scenarios where coal plants are retired as required by the federal coal-fired regulations and replaced with natural gas power plants and wind and solar installations. Mr. Zinchuk offered his critique of the analysis and has kindly agreed to publish my response to his critique. Thank you Mr. Zinchuk for allowing me this opportunity to respond. Below I work through the points made in your article dated July 29th, 2026 and offer my responses.
- “Perhaps the largest issue with Dolter’s report is its practicality…But beyond the coal refurbishment plan now underway, there is nothing in the works to get replacement power in place built before that date.”
- The argument you appear to make here is that we can’t replace coal because we are currently not building anything to replace coal. This is circular logic. We could replace coal if we get busy building new generation capacity.
- “If Dolter’s report were to be followed to the letter and coal were to be shut off on schedule, then the lights would go out for a large portion of Saskatchewan on Jan. 1, 2030.” Related to this point you write about Scenario 3 “This scenario also suggests that four natural gas plants could be built simultaneously, and be online and commissioned within three years, five months and seven days from the time it was posted.”
- The argument you are making seems to be that if we can’t replace coal by January 1, 2030 then we can’t do it at all. This is an oversimplification. The sooner we build out replacement generation facilities, the sooner coal plants can be retired.
- “For scenario 0, This scenario is improbable as Saskatchewan has embarked on building nuclear power” “This scenario also says the greenhouse gas emissions, with nuclear power, would be equal to the scenario with just coal, at 159 megatonnes of CO2 total for both Scenarios 0 and 1. If that’s the case, then one of those scenarios is using an incorrect figure”
- Scenario 0 is a subset of scenario 1. It just pulls out the coal fired electricity generation. The carbon pricing numbers in scenario 0 in the original spreadsheet needed to be updated and have now been updated. Scenario 0 is not comparable to the other scenarios because it does not lead to as much electricity being generated and does not provide the same level of dispatchable power since the coal plants are retired stepwise between 2030 and 2050 under the leaked SaskPower plan.
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- “Scenario 0 is based on the assumption that the only thing SaskPower is doing is refurbishing coal.” “Scenario 1, with coal to small modular reactors, again does not include the build out of wind and solar, which is ongoing.” On scenario 3 “This, too, assumes nothing will happen on the nuclear front.”
- This analysis is not a whole-of-system analysis. I am comparing like-for-like, apples-to-apples options for replacing coal-fired electricity capacity and generation. The scenarios all provide comparable dispatchable power and equivalent electricity generation in each year to what a coal-to-SMR scenario would provide. Your critique misinterprets the analysis. I am not analyzing a complete supply plan for SaskPower, only options to replace the coal plants.
- “The cost of coal for the last fiscal year was $313 million. For 20 years, from 2030 to 2050, that would come in at $6.2 billion before inflation. This scenario puts fuel cost for coal and uranium at $11 billion”
- This coal fuel cost number comes from the leaked SaskPower report provided by CBC in this article: https://www.cbc.ca/news/canada/saskatchewan/sask-coal-power-cost-9.7191232. SaskPower has not provided any public detail on the cost of their coal-to-SMR strategy and so I am relying on the only available information we have, which is contained in this leaked SaskPower document.
The south side of Boundary Dam Power Station. Photo by Brian Zinchuk
- “Scenario 2 assumes outdated pricing for additional natural gas plants, at $1.7 billion each, and a consistent, flat natural gas price of the current $3.00 per gigajoule out to 2050 – a highly implausible possibility”
- The first thing to recognize is that all values in the analysis are in real, inflation-adjusted 2025 values. Nominal values in future years would be higher due to inflation, but economists use real values – expressed in constant dollars and adjusted to remove inflation – to compare economic data accurately across different years. The AECO natural gas price forecast base case assumes natural gas prices that average real values of less than $4.00/GJ in the base case. You can find those AECO values and inflation-adjusted values in the ‘AECO prices’ worksheet.
- “Scenario 3 is the only one remotely realistic in its pricing of additional natural gas power plants, as well as a natural gas price that recognized likely inflation out to 2050.”
- This scenario also uses real (inflation-adjusted) natural gas prices in 2025 $CAD. The $8/GJ price is a very high inflation-adjusted natural gas price. This scenario is an upper bound sensitivity test of the cost of a gas and renewables scenario. For this scenario to be realized, inflation-adjusted natural gas prices would need to average $8.00/GJ from 2030 to 2050. This means they wouldn’t just touch $8.00/GJ at some point, they would consistently average $8.00/GJ. In the AECO forecast, the inflation-adjusted high-end forecast of natural gas prices doesn’t even reach $7.00/GJ by 2034. This scenario demonstrates that even with very high gas prices, much higher than are forecast by the Alberta Energy Regulator, a gas and renewables scenario is still less costly than a coal-to-SMR scenario.
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- “According to the minister, one of the reasons SaskPower has been building these power plants sequentially is the workforce requirements. According to SaskPower, at peak, Aspen was expected to have 750 workers on site.”
- This is an interesting point and suggests the need to start building replacement plants now. Likely, the Moose Jaw and Lanigan plants were proposed as part of a plan to retire coal by 2030. The workforce requirements are relevant to the coal-to-SMR scenario as well. A scenario where coal plants continue to operate while SMRs are being built would lead to workforce pressures in Estevan. A scenario where coal plants are retired by 2030 and decommissioned would allow workers in the Estevan to finish the job of running, retiring and decommissioning coal, and then receive training in the nuclear industry for any future nuclear builds. On the gas plants, this again emphasizes the need to begin constructing replacement units as soon as possible.
- “Additionally, Harrison has said on several occasions the order time now for a combined cycle natural gas turbine is now seven years. So even if four were ordered today, that would put completion and commissioning of these four theoretical plants well into the 2030s”
- This also points to the need to order gas turbines now and begin construction of new gas plants as soon as is practical in order to ensure coal plants can be retired in a timely manner.
Looking down at the coal stockpile from the roof of Boundary Dam Power Station. Photo by Brian Zinchuk
- “If coal was shut down on Dec. 31, 2029, then there would be a several year gap between coal shutting down and additional natural gas coming online. So even if his projected wind and solar were built before 2030, there would be many dark, cold nights when the wind isn’t blowing and the sun isn’t shining while coal plants sit idle and natural gas plants aren’t completed and the people of Saskatchewan literally freeze in the dark.”
- This is a straw man argument. I am proposing scenarios where dispatchable gas plants are paired with renewables, not scenarios where wind and solar are built in isolation.
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- “On clear summer days, in Alberta, solar does indeed often high 90 per cent output during the daytime. But in the winter, that number is closer to 30 per cent, for far fewer hours. And wind, of course, is highly variable as well. Seeing 70+ per cent output compared to nameplate capacity for wind is exceptionally rare in Alberta.”
- All of the gas + renewable scenarios combine dispatchable gas plants with variable wind and solar. The relevant statistic for renewables is the annual capacity factor. I have assumed an annual capacity factor of 40% for wind and 20% for solar. These are obtainable values in Saskatchewan where we have very good wind and solar resources. When wind and solar electricity is not available the dispatchable natural gas plants are running. That is how modern electricity systems work. Gas plants and renewables work well together. Simple cycle power plants, which are also lower cost, work best because they can ramp up and down quickly. It may be that a mix of combined cycle and simple cycle gas plants would be the best option for replacing coal. A scenario that combines both plant types would fall somewhere between the costs of these scenarios.
- “But this scenario inexplicably assumes there will be no inflation of gas costs, which is odd, because the previous scenario does indeed include inflation for natural gas price. So there is no consistency in his approach here.”
- You could do a high cost of gas sensitivity analysis on this scenario as well. Just go into the worksheet called ‘S4 Gas peaking + Wind & Solar’ and change the natural gas price in cell BJ4. I did this and set the price of gas at $8/GJ. This increases the cost of the scenario by $4.4 billion over the period of 2030 and 2050, but it still creates savings of $21.9 billion (with carbon pricing) or $10.2 billion (without carbon pricing) compared to the coal-to-SMR pathway. This works out to savings of $721 per resident of Saskatchewan per year with carbon pricing or $384 per resident per year without carbon pricing.
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- “The big number that grabs eye is the $48.5 billion Dolter says would be the “Total cost with federal carbon pricing” under scenario 0 which sees coal refurbishment and “Costs with carbon pricing if OBPS set to 0 tonnes per gigawatt-hour 2031-2050. The majority of that $48.5 billion is the $28.5 billion in carbon pricing Dolter has calculated.”
- Scenario 0 in the original spreadsheet used an old carbon pricing calculation that assumed SaskPower ran all of the coal plants from now until 2050. The correct carbon pricing cost for scenario 0 (which is a subset of scenario 1) is $16.2 billion, the same as scenario 1. Note that ‘scenario 0’ is just a subset of scenario 1 and represents the amount spent on coal-fired power from 2030 to 2050. You can see in the scenario summary that less electricity is generated in ‘scenario 0’ because it only represents part of scenario 1. It is useful to isolate just the coal-fired generation to accurately represent the average cost of coal-fired electricity over the period of 2030 to 2050.
- “Combined cycle natural gas plants in general produce roughly half the carbon dioxide emissions of conventional coal, whereas simple cycle natural gas produces more than half.”
- This is not the case. SaskPower’s coal plants operated at an average emissions intensity of 1071 tonnes CO2e/GWh in 2024 (see worksheet ‘Coal emissions intensity’). Combined cycle natural gas plants operate at an emissions intensity of 319 tonnes CO2/GWh (assuming a heat rate of 6226 btu/kwh, which means a fuel efficiency of 54.8%). Simple cycle gas plants operate at an emissions intensity of 469 tonnes CO2/GWh (assuming a heat rate of 9142 btu/kwh, which means a fuel efficiency of 37.3%).
IBEW Local 2067 assistant business manager Ken Hoste. Photo by Brian Zinchuk
- “So all things being equal, if Dolter’s replacement of coal with an equivalent amount of natural gas production holds, then the carbon tax should be half of what he calculated the coal to be. That would be $14.25 billion, not the $4.1 billion included in the chart. But that doesn’t include the large build out of wind and solar Dolter’s Scenarios 3 and 4 lay out. These scenarios includes much more wind and solar. Clearly, it anticipates wind and solar would be producing the vast bulk of the nameplate capacity of 1,500 megawatts in question and the natural gas plants would hardly be running at all.”
- The point of pairing wind and solar with natural gas plants is to reduce the purchase of natural gas and burning of natural gas. This reduces CO2 emissions and carbon pricing exposure. In the scenarios, combined cycle plants operate at an average capacity factor of 46%, and simple cycle plants operated at an average capacity factor of 33% over the period of 2030 to 2050. It is important to recognize that the scenario costs include the build out, maintenance, and operating costs of both the gas plants and the renewables. When wind and solar electricity is available SaskPower can reduce the amount of natural gas it buys. We can understand this with a gardening analogy. When it rains, you can reduce the amount of water you need to buy from your municipality to water your garden. The renewables are not free, but their cost is comparable to the cost of purchasing fuel, especially with carbon pricing applied to fuel. In your reporting I encourage you to consider the value of renewables as being the value of the fuel they allow SaskPower to avoid purchasing, including any carbon pricing they allow SaskPower to avoid paying.
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- “As it stands right now, a 200 megawatt nameplate capacity wind farm goes for about $450 million (Rose Valley, just announced) to over $500 million (Seven Stars)”
- I used the numbers for Bekevar which were $380 million for 200 MW. https://www.sasktoday.ca/southeast/local-news/grand-opening-held-for-bekevar-yotin-wind-project-9859841. You could increase the cost to those you have listed, and it would make a slight difference, but would not fundamentally change the conclusions.
- “Thus, the same dollars are counted twice in Dolter’s scenarios – once as a “carbon price” and again as “capital + O&M” to build reactors or other “clean electricity power,” which would presumably include the wind and solar he outlines. His scenarios imply that any money sent to “carbon pricing” would not then be turned around and used to pay for the capital costs of nuclear, or wind or solar.”
- Saskatchewan is currently not in compliance with the federal carbon pricing policy as they have set the carbon pricing charge to $0/tonne CO2. We know that the federal government has the constitutional authority to put a price on carbon, and to impose a backstop on provinces that don’t create their own equivalent system. The federal government won their court case at the Supreme Court in 2021 confirming their constitutional authority to put a price on greenhouse gas emissions. Your argument appears to be that SaskPower doesn’t really pay carbon pricing because the provincial government can collect the money and then give it back to SaskPower to pay for new clean energy projects. It is possible that Saskatchewan can continue to operate its own carbon pricing system and keep the carbon pricing revenue, but that is not a guarantee. The federal government could impose the carbon pricing backstop and then collect the carbon pricing revenues. That revenue could then be returned to Saskatchewan in a myriad number of ways, not necessarily by giving it back to SaskPower (e.g. lower federal taxes, grants to businesses, rebates to individuals). Even without carbon pricing, scenarios 2, 3, and 4 in the spreadsheet are lower cost to Saskatchewan ratepayers than the coal-to-SMR scenario.
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- “So in any calculation of fuel costs, one must consider that nearly all money spent on natural gas as a fuel source leave the province, whereas nearly all money spent on coal remains in Saskatchewan. Yes, Westmoreland does take profits from the current $313 million SaskPower spends on coal. But the vast majority of that money stays in Saskatchewan, from employee salaries to maintenance of equipment, local suppliers and more, supporting hundreds of direct mining jobs in Estevan, Bienfait and Coronach, as well as hundreds more in the power plants.”
- Costs that remain in the province are still costs that must be paid by ratepayers. If an electricity scenario is more expensive, then ratepayers, including households, businesses and industry, pay more for their power. Saskatchewan already has high electricity prices relative to the rest of Canada. Further increasing these prices hurts the profitability and competitiveness of Saskatchewan businesses and industry. To use a counterexample, would we say that firms in Saskatchewan should buy made-in-Saskatchewan laptop computers even if they cost twice as much as laptops imported into the province? Should we justify that decision on the basis that buying the expensive laptops would create jobs in the province? Businesses will rightly look to purchase the most affordable inputs that they can. They can benefit from trade and the ability to find low-cost inputs even if they are purchased out of province. The electricity system is no different. We can benefit from trade by exporting the products we can offer at competitive prices, and importing products for which we do not hold a comparative advantage.
- “In conclusion, each of the scenarios Dolter lays out have significant flaws.”
- I believe I have responded to each of your critiques and have demonstrated that the scenarios are sound. If there are specific assumptions that you believe are incorrect then these can be adjusted to see if the conclusion changes. However, based on these comments the coal-to-SMR scenario proposed by SaskPower is more expensive than competing gas + renewables scenarios both with and without carbon pricing.
Thank you for this opportunity to respond to your critiques. I appreciate your willingness to publish my response.
Sincerely,
Brett Dolter, PhD
Associate Professor
Department of Economics
University of Regina
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