Harrison Dressler at the UNB Human Environments Workshop writes about key interventions at the recent hearings for the renewal of NB Power’s licence to operate the Point Lepreau nuclear reactor, including the presentation by CRED-NB and CELA. You can read the article published by the NB Media Co-op HERE.
* This is the third in a series of blogs by CELA and CRED-NB live from the hearing room, as we share reflections and reactions from the nuclear licensing hearing. You can find our blog from Day 1 and 2 here,
SAINT JOHN, NB – Climate change concerns have repeatedly been raised by public intervenors since day 1 of the hearing for NB Power’s application for a 25-year renewal to its operating licence for the Point Lepreau Nuclear Generating Station on the Bay of Fundy. Several intervenors, including CELA and CRED-NB noted that NB Power has not provided enough information about the impact of climate change on the Lepreau plant.
Yesterday, CELA counsel Kerrie Blaise explained that climate change poses unique dangers to Point Lepreau due to its location on the Bay of Fundy. Today, in an exchange following a presentation by the RAVEN project at the University of New Brunswick and member of the CRED-NB core group, experts from Environment and Climate Change Canada, Canadian Nuclear Safety Commission Staff (“CNSC Staff”) and NB Power referenced reports and studies suggesting that the danger of tsunamis and sea level rise is a low safety and security risk for the Lepreau plant.
However, despite NB Power’s assertions that extreme weather events and sea level rise pose little to no risk to the facility, their licence application and associated studies fail to expressly consider climate change and its potential impacts on Point Lepreau. That’s why CELA and CRED-NB have recommended the Commission deny NB Power’s licence application until site-specific climate impacts have been modelled at least 25 years into the future.
After the exchange, Susan O’Donnell, primary investigator of the RAVEN project, noted that just last week, the CNSC issued a tender for a comprehensive study of the impacts of climate change on nuclear plants in Canada. She recommended to the Commission that after the report is completed, NB Power should be tasked with responding to the issues raised in the report and issue its own report. RAVEN is recommending a 5-year licence renewal period.
Intervenor Margaret McDonald, joining virtually from Fredericton, also raised concerns with climate change and the need for more regular licencing hearings at which the climate monitoring reports could be discussed.
Ann McAllister, a member of CRED-NB and a representative for the Council of Canadians Saint John, intervened to recommend a 5-year licence, rather than a 25-year licence. Such a long licence would significantly limit public input. She recommended better ongoing monitoring of management practices, especially considering the significant debt that the Lepreau plant has incurred, $3.6 billion of NB Power’s $4.9 billion debt.
Ms. McAllister also raised concerns about plans by NB Power to develop the Moltex reprocessing unit on the Point Lepreau site. She cited reports by US nuclear research institutes and a recent letter by US experts that raised concerns about the weapons proliferation risks of the project.
In a discussion of tritium emissions that ensued, both the CNSC and NB Power minimized the health impact of tritium in well water. A CNSC staff person said: “Tritium in the environment is not a concern to CNSC staff,” and NB Power claimed that the lifetime dose from tritium in well water would be less than the amount received by one chest x-ray.
During a presentation by The Brilliant Energy Institute at Ontario Tech University, the only university in Canada that offers an undergraduate program in nuclear engineering, that intervenor said that enrollment in the program had been dropping. CNSC president Velshi expressed concern at this situation. However, in their intervention, the University of New Brunswick’s Center for Nuclear Energy Research said that they are developing a new degree program in nuclear engineering and, given the significant interest in SMR development in New Brunswick, there is considerable interest in the new program.
The Commission will make a final decision on NB Power’s application by June 30, 2022.
Photo: The teams from the Passamaquoddy Recognition Group (Kim Reeder, Chief Hugh Akagi), Leap4wards (Dave Thompson), Council of Canadians Saint John (Ann McAlister), RAVEN (Susan O’Donnell), CRED-NB (Gail Wylie), and the Canadian Environmental Law Association (CELA, Kerrie Blaise). Photo by Mary Milander.
This is the second in a series of blogs by CELA and CRED-NB live from the hearing room, as we share reflections and reactions from the nuclear licensing hearing. You can find our blog from Day 1 here.
SAINT JOHN, NB – Today marks the second day of the hearing for NB Power’s application for a 25-year renewal to its operating licence for the Point Lepreau Nuclear Generating Station on the Bay of Fundy. The Canadian Nuclear Safety Commission heard from sixteen public intervenors, asking questions related to access to information, public engagement, environmental impact, and cyber security risks.
Industry groups and nuclear proponents have been vocal in calling for a 25-year licence, going so far as calling for ‘decoupling’ of public engagement from the licensing process, according to Canadian Nuclear Association President John Gorman.
“The process to license a nuclear reactor is the primary opportunity for the public to challenge many of the claims by the proponent. How could public engagement be decoupled from that process? Public engagement without any meaningful outcome would be a meaningless waste of time,” said Susan O’Donnell, core representative of the Coalition for Responsible Energy Development in New Brunswick (CRED-NB).
The need for frequent licensing hearings, which include a statutory public right to be heard, was at the crux of the oral submission by the Canadian Environmental Law Association (CELA) and CRED-NB, who appeared before the Commission today and asked them to deny the 25-year licence request.
CELA and CRED-NB explained that the events of the past 25 years – including the events of September 11 2001 and the Fukushima Daiichi accident in 2011 – should demonstrate that our understanding of the dangers of nuclear power plants and the substantial risk they pose to human health, safety and the environment, is continuously evolving. CELA counsel, Kerrie Blaise, explained that while shorter licence terms and more regular licencing hearings do not remove this risk, “they do allow for the compulsory re-evaluation of these risks stemming from continued nuclear plant operations.”
In response to comments by CNSC Staff made yesterday, that annual status reports, regulatory oversight reports, periodic safety reviews and environmental risk assessments are sufficient stand-ins for public hearings under the Nuclear Safety and Control Act, CELA informed the Commission that all of these mechanisms are discretionary forms of public engagement, and that they often exclude the public from making oral interventions.
The topic of cybersecurity was also raised in the afternoon session, with CNSC Staff sharing that a proposed regulation on cybersecurity threats to nuclear power plants would likely be published to the Canada Gazette in the Summer of 2022. Independent expert Dr. M.V. Ramana – who joined the hearing with CELA and CRED-NB – underscored that we are currently living through a cyber war in Ukraine and Russia, and that over the last decade we have seen cyber attacks on nuclear facilities in Japan, South Korea, and India. Dr. Ramana went on to note that “it is more a question of when, not if there will be an attack on a Canadian facility” and that “we should be much more guarded against the idea of a longer licence” for that reason.
CELA and CRED-NB concluded their intervention before the Commission, noting “a request for a 25 year licence is, quite simply, a blatant attempt to reduce community engagement and involvement” and that “shorter licences and more frequent hearings, which are responsive to the operations being undertaken by licensees, would better serve the public interest.”
Tomorrow, the hearing will continue and you can tune in live online.
Coalition for Responsible Energy Development – New Brunswick (CRED-NB)
For immediate release – May 10, 2022
Today, two Indigenous organizations intervened in the hearing to renew the licence for the nuclear plant on the Bay of Fundy in New Brunswick. The Passamaquoddy Recognition Group and Mi’gmawe’l Tplu’taqnn Inc. both asked for the Canadian Nuclear Safety Commission (CNSC) to recognize their rights under the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).
The Passamaquoddy Recognition Group represents the Peskotomuhkati Nation whose traditional territory includes Point Lepreau where the nuclear reactor is sited. They asked the Commissioners to respect the ongoing development of nation-to-nation relations being undertaken by the government of Canada, and to enable their vital need to enact their law, therefore fulfilling their role as caretakers of their territory.
They also underline that the Point Lepreau Nuclear Generating Station was established in their territory without consultation or consent of the Peskotomuhkati, contrary to the terms of the treaties of Peace and Friendship that cover New Brunswick.
The Passamaquoddy Recognition Group requested a 3-year licence period for the Lepreau reactor. Mi’gmawe’l Tplu’taqnn Inc. requested a 5-to-10-year licence period.
The Coalition for Responsible Energy Development (CRED-NB) is participating in the public hearings of the CNSC to review the request for a 25-year extension of the licence to operate the nuclear reactor at Point Lepreau on the Bay of Fundy.
We urge the CNSC to respect Indigenous rights and desires and grant a shorter licence period than the 25-year licence extension NB Power applied for.
The CNSC reports to Parliament through the Minister of Natural Resources, whose mandate letter from the Prime Minister includes a clear direction to implement the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and to work in partnership with Indigenous Peoples to advance their rights.
CRED-NB and the Canadian Environmental Law Association (CELA) submitted a joint intervention that we will present to the Commissioners on May 11.
Our recommendations against the requested licence period highlight significant concerns about reduced public participation, emergency zone designation below International Atomic Energy Agency (IAEA) standards, dated climate and environmental modelling, failure to consider imminent plans for Small Modular Nuclear Reactors (SMRs) on the Lepreau site, and inadequacy of Cyber security measures given the current threat environment.
The CRED-NB/CELA intervention is available on the CRED-NB website, HERE.
The proceedings will be Live Streamed HERE.
CRED-NB is comprised of 10 public interest groups in the core coalition, supported by an additional 10 groups and businesses, and more than 100 individuals from across New Brunswick who have signed a public statement in support of CRED-NB’s core objectives.
Coalition for Responsible Energy Development in New Brunswick
PO Box 4561 • Rothesay, NB E2E 5X3
SAINT JOHN, NB – Canada’s nuclear regulator, the Canadian Nuclear Safety Commission, has commenced its three day public hearing of public utility NB Power’s request for a 25-year renewal to its operating licence for its nuclear reactor on the Bay of Fundy. The Point Lepreau nuclear power plant, owned and operated by NB Power, is located 40km southwest of Saint John, New Brunswick; it is Canada’s only nuclear power plant on the ocean.
This hearing considers a first ever request for a 25 year nuclear operating licence. The Canadian Environmental Law Association (CELA) is among the public intervenors appearing before the Commission. On May 11, CELA, jointly with the New Brunswick based community based Coalition for Responsible Energy Development in New Brunswick (CRED-NB), will be asking for the Commission to deny the 25-year licence request, citing concerns about the reduction in public scrutiny and engagement in nuclear oversight.
Central to today’s hearing, reflected in the oral interventions made by the public and questions raised by Commissioners, was the length of licence being requested. We heard from NB Power that a 25 year licence “would not impede informal engagement with the public” with CNSC Staff echoing the Commission has the discretion to hold public proceedings at any time, should it so choose with the licensing period.
We also heard from CNSC Staff that while a 25-year licence would remove the requirement for a public hearing for this duration, it would open up new opportunities, like “strategic and topical discussion on specific issues.” And, without a hearing, these standalone discussions on one-on-one items would allow for more “in-depth considerations.”
In response, intervenors, including Chief Akagi of the Passamaquoddy, noted a longer licensing period would mean “losing the voice of a generation” and would be determinative of the “length of time NB Power will be putting, fresh, hazardous materials on Passamaquoddy lands.”
The Mi’gmawe’l Tplu’taqnn echoed that a longer licence could “negatively affect both public perception of the Commission’s oversight, and opportunities for meaningful engagement with First Nations and other communities.” Both have asked the Commission to support shorter licence terms or 2 – 5 years. As Kim Reeder of Passamquoddy shared, this would simply maintain the status quo where in the station’s 40 year history, the licence length has averaged 2.44 years.
Remarking on today’s hearing event, CRED-NB member Gail Wylie shared “What concerns me about what we have heard today, is the continued reference to nuclear as “clean” and “cheap”. I was pleased that other citizen presentations today have pointed out the very low cost of renewables and have debunked the claims of nuclear being reliable, especially as we’ve experienced Point Lepreau being offline for 40 days last winter and the 3.5 years during its refurbishment.”
As intervenor Ann McAllister shared, “For those of us concerned about being excluded from input during a 25 year licensing period, today was not reassuring to hear – both NB Power and the CNSC acknowledged the need for better public engagement, and yet they have no concrete plan to make that happen.”
Tomorrow, the hearing will continue and you can tune in live online.
Levels of tritium, a carcinogen, emitted by the NB Power Lepreau nuclear reactor are higher than any other reactor in Canada and possibly the world. This alarming information is included in a brief by Dr. Ian Fairlie for the Passamaquoddy Recognition Group. The article by Dr. Fairlie was published by the NB Media Co-op, HERE.
NB Power’s Point Lepreau Nuclear Generating Station on the Bay of Fundy is the only nuclear plant in the Maritimes.
NB Power’s 5-year licence to operate the nuclear reactor on the site will expire in June 2022. They asked for a 25-year licence extension. The decision will be made by the Canadian Nuclear Safety Commission (CNSC) after a public hearing in May.
The Coalition for Responsible Energy Development in New Brunswick (CRED-NB) and the Canadian Environmental Law Association (CELA) submitted a joint intervention to oppose the licence request. You can read or download our intervention document HERE.
The team is scheduled to present its intervention in Saint John at 1:30pm Atlantic on Wednesday May 11. The public is invited to watch.
The CNSC received 244 written interventions by the March 28 deadline. Many of these were from CRED-NB Champions. Thank you!
In our intervention, we argue that a 25-year license is too long, as is the 20-year recommendation by CNSC staff. Long licence periods for nuclear reactors are not in the public interest, are unprecedented in Canada, and would limit public oversight and participation for a generation.
NB Power’s licence application fails to consider the impact of new developments, including potential Small Modular Nuclear Reactors (SMRs/SMNRs) and a reprocessing facility to extract plutonium from the existing spent fuel on the site. It also fails to adequately address the potential impact of climate change on the Point Lepreau site.
Our intervention underscores that NB Power’s consideration of off-site emergency planning and preparedness at Point Lepreau is insufficient to protect human health and the environment. In particular, the proposed size of emergency planning zones does not align with international guidance.
Finally, we submitted that NB Power’s consideration of cyber security in their licence application is insufficient to protect the health and safety of persons and maintain national security.
Our intervention requests that the CNSC deny NB Power’s request for a 25-year licence and instead consider a short licence period that would also allow the public to weigh in more frequently on the advisability and timing for shutting down and decommissioning the Lepreau nuclear plant.
An early shutdown of the Lepreau reactor has the added benefit of ending the production of radioactive waste which is expensive to store and which has no proven-safe method of disposal.
Our intervention includes 40 recommendations for the Commissioners to consider in their deliberations.
Read or download our document HERE.
Environment and Climate Change Canada prepared a discussion paper for feedback on the Clean Electricity Standard. The document contained several significant errors related to so-called small modular nuclear reactors (SMRs/SMNRs). Notably the information suggested that SMRs are technically advanced when in reality they are powerpoint designs. CRED-NB submitted a clarification, which you can read HERE.
The CBC Fredericton Information Morning radio show interviewed Dr. Ed Lyman, Union of Concerned Scientists in Washington, DC on April 12, 2022. The link to the CBC interview recording is HERE.
Here’s the transcript.
Well, worried about keeping your home warm and the lights on and a net zero future? No need to panic say more and more politicians and utility experts. They’re putting their hopes on SMRs, small modular reactors. Natural Resources and Energy Development Minister Mike Holland was on the program last month. He calls them an exciting step forward for New Brunswick as it works with other provinces to deploy safe, reliable, and emissions free energy from reactors. And they’re described as not much larger than transport trucks. Edwin Lyman has studied SMRs and their development. He’s a physicist and director of nuclear safety for the Union of Concerned Scientists in Washington, DC. Good morning.
Dr. Edwin Lyman
Before we begin and get into small modular reactors, can you just explain the Union of Concerned Scientists and its role in the US?
Dr. Edwin Lyman
Yes. The Union of Concerned Scientists is a science based nonprofit organization, where we focus on applying science to solving problems such as climate change, and global security, food in the environment, and environmental justice.
You’ve taken a look, a closer look, at small modular reactors, something we’ve been hearing a lot about lately, here in New Brunswick, what potential first of all do you see in SMRs?
Dr. Edwin Lyman
Frankly, I think the actual potential of SMRs is small, like the reactors themselves. I believe that their promise is being overhyped, and just does not jive with the reality.
What makes you come to that conclusion?
Dr. Edwin Lyman
Well, the first observation about a small reactor is that if you hold everything else constant, and you just shrink down a nuclear reactor, it’s going to produce more expensive electricity. And that’s because economies of scale have led to an increase in the size of nuclear reactors over the decades. The larger the reactor, the cheaper the electricity it generates.
So the case for shrinking reactor down depends on the ability to compensate for that penalty by cutting costs in other ways. The advocates of this technology claim that by centralizing production of these modular reactors in a factory that you can achieve significant cost savings in that way. But that would really take a lot of experience, a long time of operation, a large number of orders before you start to realize those cost reductions if, in fact, they will be viable. And so that isn’t a cost savings that you’re likely to see for many years or decades.
So in the interim, these reactors are going to produce more costly electricity unless you can reduce the capital and the operating costs relative to large reactors. And that means cutting corners on things like reactor containment, that is the robust structure that’s designed to protect the reactor and to prevent radiation from escaping into the environment, if there’s an accident that causes damage to the fuel.
It also requires reducing operating costs. That is, the personnel who operate the reactor, who maintain it, the security officers who guard it. Those are expensive components of the operation of a nuclear reactor, and to increase the economic viability, you’re going to have to slash those.
And so the question is, can you really cut corners in all those different areas and ensure that this reactor is going to be safe, or as safe as large reactors? And I don’t believe you can.
One of the arguments that our energy minister, Mike Holland, was making recently on our program about them was that: Yes, fine, the initial costs, the startup cost of creating these SMRs could be high, but that after that it will be much cheaper to produce them. Is that true, from your view? And is there a way to recoup those sunken costs?
Dr. Edwin Lyman
Well, I think it’s an unproven proposition. The experience with modularity and nuclear construction so far has already not validated that assumption. For instance, in the United States, there are two large nuclear reactors under construction. And the company that designed those reactors, decided that it would try to cut costs by building a factory to produce modules. So in other words, they were going to build that plant in a modular fashion. And they made the same claim that by centralizing production of these modules, they’re going to cut costs. But it turns out, it’s not so easy to do that, in fact, if the factory that’s producing the modules itself is not doing a good job, then you are not solving your problem, you’re only amplifying it. And that’s, in fact, what happened in the United States.
Right now, the only small modular reactor project that’s moving forward is a reactor called NuScale, which has gotten some level of approval from the Nuclear Regulatory Commission. But it’s still not clear if that company has the full financing to go forward with the project to actually construct it. And there are safety issues associated with that reactor that still have not been resolved, even though the regulator has approved it.
Like what, what are the safety issues there?
Dr. Edwin Lyman
The claim is often that these small modular reactors are passively safe, they can just shut themselves down in case there’s any problem and you don’t even need an operator to intervene or do anything. And that was the claim for NuScale.
But it became clear that there are certain types of accidents, where it doesn’t look as passively safe as it was originally promised. One issue with passive safety, which means instead of having electrically powered pumps and valves that operators can manipulate, really to inject water into the core of the reactor in case there’s something like a leak, and it’s losing water, instead of having those systems that are highly reliable, you have to depend on natural forces like gravity to do the work. And that doesn’t always work out so well.
So there’s actually loss of control, unless you make sure that you have the backup safety systems that you need and you can actually make them work when they’re needed. But the problem is backup safety systems can cost a lot of money. So here’s another example where reactors NuScale are trying to cut costs.
If, as you say, these SMRs are so prohibitively expensive, that they have these safety concerns that there is literally only one of them built off the coast of in Russia, a Russian Arctic town, like they’re not built pretty much anywhere. If all these things are true, why are governments so attracted to them?
Dr. Edwin Lyman
I think it’s because the nuclear industry has been trying different messages to try to get the attention of the public and lawmakers, and the industry puts itself out is the savior of humanity. And the fact is that, in practice, the industry has often fallen short of what it’s promised.
And just taking the example of the two reactors in the United States that I was talking about, they were licensed on the premise that they were going to be cheaper and quicker to build than current generation reactors. In fact, that hasn’t panned out. In fact, they’ve, they’re taking at least twice as long and more than twice the original estimated cost to build.
To say, you know, ‘alright, we’re not going to build large reactors anymore, we’re going to build small ones and a small one is smaller, so it’s going to be cheaper,’ I think that’s a soundbite, really, that a lot of people are falling for. But that’s because they aren’t looking into the fundamental economic issues that I was talking about
Here in New Brunswick, we are looking to replace the energy that is generated by the coal fired power plant, the Belldune plant, which will need to close by 2030. And so that’s why this is on the table, this discussion about this, these SMRs. If not the SMR is what other power sources should we be considering here in New Brunswick to fill that gap?
Dr. Edwin Lyman
Well, let’s talk about the actual designs that are being discussed for New Brunswick. And this is another element. This isn’t really the fact that they’re smaller than conventional reactors, but they’re fundamentally different designs. And they use different types of materials. They raise different safety issues. They require a different supply chain, and they have much less or no operating experience.
So in my view, that the two designs that are being talked about for New Brunswick can’t plausibly be deployed in this decade. They’re going to take a lot more research, development and demonstration before they could be safe to operate. There are a range of options that planners can consider for an energy future that is low carbon. And some of those may involve nuclear power and some others don’t. But don’t take for granted that we’re going to need nuclear power, even if it doesn’t make sense, economically, or from a practical standpoint.
Are you concerned that we are pouring a lot of money into this, hear in this province, and that we will feel obligated to use this technology once it is up and running, even if it takes a long time? Even if there are other options eventually on the table that end up being cheaper?
Dr. Edwin Lyman
Well, that is the problem with nuclear power. And then it does, because of its high costs, its long deployment time, it has the potential to distract attention and resources from other options, which may be more feasible and maybe quicker to implement, and maybe safer.
So nuclear power does require huge investment. I don’t think that the amount of money so far that’s been made available, is anywhere near would be necessary even to build these first of a kind reactors. You don’t want to chase after pie in the sky technologies that are being overhyped, that might distract you from more feasible solutions.
So it’s just necessary to kind of keep perspective and a level of objectivity in analyzing these issues. And certainly, the United States and many other markets, wind and solar costs have come down considerably. But there are the intermittency issues that require additional attention, as when solar becomes greater parts of the grid. So again, you need to keep an open mind, not be swayed by sales pitches by self-interested parties. You need to have an objective fact-based and peer-reviewed, set of policies going forward. And nuclear power can fit into that. But you have to maintain perspective, it’s not going to be a panacea. And it’s going to take a lot of money and time to actually do it safely and reliably.
Dr. Lyman, it’s good to have you on. Thanks for joining us.
Dr. Edwin Lyman
Edwin Lyman is a physicist and director of nuclear safety for the Union of Concerned Scientists based in Washington DC. He’s the author of Advanced isn’t always better: assessing the safety, security and environmental impacts of non-light water nuclear reactors.
Toronto (April 11 2022) – The 2022 federal budget’s investment in unproven nuclear reactor designs, dubbed Small Modular Reactors (SMRs), is being called a “climate throwaway” by civil society groups. Just days after the Intergovernmental Panel on Climate Change released its starkest report yet urging aggressive climate action, the federal government is choosing to invest in yet-to-be proven technologies that miss the mark for halving emissions by 2030.
SMRs refer to a set of proposed nuclear technologies, designed to produce up to 300 megawatts of electricity. They are promoted for both the electric grid and for remote, off-grid communities to replace diesel reliance and to power resource extraction projects.
120+ civil society groups from coast to coast to coast including the Green Budget Coalition have asked the federal government to reallocate funds for SMRs into cost-effective, socially responsible, renewable energy solutions available now.
The budget dedicates $120 million over five years for SMRs:
● Approximately $70 million of the budget is for research, geared to waste minimization.
This could include the reprocessing of used nuclear fuel, a chemical process for extracting plutonium from used radioactive fuel waste. Reprocessing is not currently used in Canada and it raises many proliferation and security concerns. Plutonium is a dangerous material not found in nature. Reprocessing is in no way a solution to reducing radioactive waste, it simply redistributes the highly radioactive fission products into different waste streams. With the fission products removed, the remaining materials are much more susceptible to being stolen or used in nuclear weapons.
● Approximately $50 million to build capacity within Canada’s nuclear regulator to regulate SMRs.
Investment in regulatory processes will not remedy the fact that SMRs have been removed from the federal impact (environmental assessment) process. SMR projects are only required to undergo a narrow licensing process, conducted by Canada’s nuclear regulator. Their expertise and regulatory framework is not equivalent with impact assessment law, which requires an upfront examination of ecological, socio-economic and sustainability impacts spanning the duration of the project.
The budget also includes two other provisions potentially applicable to SMR projects:
● A new tax credit of up to 30% for net zero technologies such as battery storage and clean hydrogen. Nuclear projects should be ineligible for this tax credit as they are not cost-competitive with renewables and as has been previously pointed out, nuclear-powered hydrogen is not renewable hydrogen. Any application for this tax credit must also be required to transparently demonstrate the project’s economic viability.
● Continuing the $8 billion Net Zero Accelerator initiative for projects with the potential to substantially reduce emissions by 2030 and support the goal of net-zero by 2050. SMRs are in the earliest of planning phases and anticipated dates for operation are well into the 2030s. This, coupled with the nuclear sector’s trend of construction delays and cost overruns, should make SMR projects ineligible as they cannot contribute to meeting the most urgent of climate targets, which requires halving emissions by 2030.
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Kerrie Blaise, Northern Services Legal Counsel, CELA
Tel: 416-960-2284 ext 7224
Susan O’Donnell, PhD, Coalition for Responsible Energy Development in New Brunswick (CRED-NB)
Jean-Pierre Finet, Energy Analyst,
Regroupement des organismes environnementaux en énergie (ROÉE)