UPDATE: This originally appeared as a letter in Yukon News on August 15, 2024. Since then, the “renewal” of the permit has increased permitted capacity by 12.85 MW. An increase of 5 MW or more would require a more thorough Executive Committee Screening – according to YESAA, but… this did not happen, because YEC was (they say) not adding new capacity, but “renewing” more capacity than was on the previous permit. If you think that getting around assessment requirements by calling it a renewal is nonsense, I agree. What is the lesson learned from this? Increasing permitted capacity by 12.85 MW over the previous permit limits is somehow not adding capacity according to YESAB. It is a renewal. So I guess I should ask to “renew” my class 5 drivers license as a class 3 or a class 1 – and skip the assessment process for the change, because it’s a renewal? That is if YESAB rules apply.
Anyway, here’s a what appeared in Yukon News – with links to relevant documents at the end.
Letter: Hike in Whitehorse diesel capacity hidden in Yukon Energy’s permit renewal
Yukon Energy is adding 12.85 MW of diesel generation capacity to Whitehorse, according to YESAB 2024-0103. The public comment period is open now, and ends August 22.
In 2019, YEC had proposed a new diesel plant in Whitehorse, and the response was overwhelmingly negative, causing YEC’s board to abandon the project. Failing to bring any significant renewables online, YEC has continued expanding “temporary” rental diesel, and is now moving to make it permanent.
YEC’s current permit for Whitehorse is for 16.15 MW, and the new assessment is for an increase to 29 MW. So instead of building a new diesel facility in Whitehorse which was not supported, YEC is quietly expanding capacity at their current location, also rejected in 2019.
And when I say “quietly expanding” I do not mean that the generators will be quiet, as Riverdale residents well know. In this case, YEC is being quiet about the expansion, by hiding it in what they are calling a “renewal”. Is an increase of 12.85 MW a renewal? YEC claims they are “renewing” the expired authorization they had for “temporary rental diesel” starting in 2017, and expiring in 2022. An expansion of 5 MW or more requires an Executive Committee screening, providing a much more thorough assessment with more opportunity for public input. Since the “temporary” rental diesel had never been assessed under YESAB, adding 12.8 MW is clearly expansion and not a renewal.
The “temporary” rental diesel was not subject to assessment through YESAB at the time, because YEC took advantage of a provision of YESAA that was in the process of being rescinded. So not only did they fail to renew this temporary authorization when it expired, it was based on a now rescinded provision of YESAA (49.1) that was “illegally put into law” according to Larry Bagnell in his statement about it at the time, pointing out that it violated the Yukon First Nations Umbrella Final Agreement. The permit amendment for “temporary rental diesel” was issued a day after this provision allowing it had been rescinded. So yes, YEC is attempting to renew something that they got in violation of the UFA.
And now YEC is making “temporary rental diesel” a permanent fixture in Whitehorse. There is of course no difference between this permanent expansion and building the previously rejected diesel plant, other than calling it a “renewal”.
Despite calls for renewables, YEC has expanded diesel by 47.8 MW, including planned expansions at Dawson / Callison (15.5 MW), Whitehorse (12.85 MW), Faro (12.25 MW including proposed expansion) and Mayo (7.2 MW on a 4.9 MW permit).
Counting the capacity of renewable projects of over 2MW, YEC has added 0 MW of new renewable dependable capacity. The last significant renewable project was Mayo B (hydro) in 2011.
So again, 47.8 MW of new diesel versus 0 MW of new renewables.
The public comment period for YESAB 2024-0103 Whitehorse Diesel Expansion (what YEC calls “Whitehorse Air Emissions Permit Renewal”) ends on August 22. To comment, go to https://yesabregistry.ca and search on 2024-0103.
References:
– Expansion from 16.15 MW to 29 MW, from YESAB 2024-0103 “Project Proposal” PDF p.8. YEC claims their current permit is for 16.2 MW, but the actual is 16.15 MW. Project Proposal document available on https://yesabregistry.ca with a search for 2024-0103.
– Information about the 2019 diesel plant is from What We Heard report:
https://yukonenergy.ca/energy-in-yukon/projects-facilities/new-thermal-generation/what-we-heard/
– The use of rescinded section 49.1 of YESAA is shown on PDF page 482 of the following document:
https://yukonutilitiesboard.yk.ca/pdf/YEC_2021_GRA/YEC_2021_GRA_consolidated_IRs__March_5__2021.pdf
The permit was amended again in 2018 to add the 6th temporary rental diesel and extend until 2022. It is notable on p. 487 that YEC claimed they would have a “more permanent solution” by 2021. The more permanent solution is now calling the “temporary” solution “permanent”.
– Larry Bagnell’s thoughts on rescinding Section 49.1 of YESAA can be found here:
https://openparliament.ca/debates/2017/10/26/larry-bagnell-1/
He also notes that the Yukon legislature was unanimous in passing the bill to rescind this provision of YESAA. “…the Yukon legislature was unanimous in passing the bill, including the Yukon Party, which is the Conservatives.”
– The bill to rescind is here, and received royal assent on December 14, 2017, a day before the permit amendment was issued: https://lop.parl.ca/sites/PublicWebsite/default/en_CA/ResearchPublications/LegislativeSummaries/421C17E
– Capacities added or or in process:
• Dawson / Callison: 15.5 MW (YESAB 2023-0150)
• Whitehorse: 12.85 MW (YESAB 2024-0103 – PDF p.8 of the Project Proposal document. YEC rounds the actual 16.15 MW to 16.2. There is no rounding in my document.)
• Faro: 12.25 MW increase (20.4 MW capacity total submitted to YESAB according to YEC, but not yet on yesabregistry.ca. Capacity was 8.15 MW from 2014 to 2020 before rental diesel was added.)
• Mayo: 7.2 MW with a permit for 4.9 MW: As YEC explained it, “For the purposes of this GRA Application, YEC is only claiming a dependable capacity of 7.2 MW from the Mayo plant, from 4 diesel rental units. Accordingly, the correct amount of unpermitted diesel assumed in this GRA proceeding for dependable capacity at Mayo is 2.3 MW.”
7.2 MW is from PDF p. 22 https://yukonutilitiesboard.yk.ca/pdf/YEC_2023_GRA/YEC_2023_GRA_IRs_Consolidated_Nov._29__2023.pdf
and 4.9 MW from YESAB 2023-0090
– No new renewables greater than 2 MW since 2011: PDF p. 32
https://yukonutilitiesboard.yk.ca/pdf/YEC_2023_GRA/YEC_2023_GRA_IRs_Consolidated_Nov._29__2023.pdf
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