Letter: Yukon’s newest greenfield diesel plant!

A look at diesel power generation in Mayo and elsewhere.

Let’s be honest. Yukon Energy is building a new 9MW greenfield diesel plant just outside Mayo, less than one kilometre from the Five Mile Lake Campground.

Of course this is not what Yukon energy is saying in public or in their YESAB proposal for the project.

The proposal that YEC has submitted to YESAB is for the installation of five rental diesel generators of 1.8MW each (5 x 1.8= 9MW) but with a total permitted capacity of the project of only 4.9MW, the equivalent of 2.72 generators.

So how does this work? Why would Yukon Energy pay for five rental diesel generators and claim they will only run 2.72 of them? And how does Yukon Energy plan to run 2.72 generators without actually running three?

Easy Answer: Yukon Energy is playing games to avoid giving Mayo the assessment and consultation otherwise required by YESAA.

YESAA specifies that a thorough Executive Committee screening is required for projects of 5MW or more. Clearly this is meant to apply to this project. Running 3 generators only up to 4.9MW will have the same socio-economic impact as running three generators for a total of 5.4MW. Was the intention of YESAA to have 9MW projects or 5.4MW projects claim to be 4.9MW projects, or was it to provide assessment relevant to the scale of the project? Pretending to run 2.72 generators but not three to avoid an EC screening is not providing a proper assessment.

YEC has confirmed that the 4.9MW total is simply an attempt to get around the Executive Committee requirement. In YEC’s words:

“The proposed site capacity expansion was limited to 4.9 MW so as not to trigger an Executive Committee (EC) Screening, i.e., a 5 MW increase would trigger an EC Screening.” (1)

Sounds a lot like the Easy Answer above. Yes, in front of the Yukon Utilities Board, Yukon Energy admitted that claiming a 4.9MW capacity is done to avoid the legally required consultation and assessment that would happen if they used the actual capacity of the project. This statement was submitted by Yukon Energy during the 2021 GRA proceeding in discussion of their diesel strategy.

In the current YESAB application for the Mayo rental diesels, Yukon Energy conveniently does not mention that the capacity has been chosen to avoid an Executive Committee screening, but instead claims that two of the five generators are “spares” or “backups” in case two of the permitted 2.72 generators fail. Looked at in terms of capacity, of the 9MW to be installed, 4.9MW is to be assessed and permitted, and 4.1MW is backup, not subject to assessment.

However, in sworn testimony during the 2021 GRA hearings, YEC argued that in the existing rental diesel installations in Faro and Whitehorse, one spare (and only one) was needed in each location. (2)

The Yukon Utilities Board did not find this argument compelling and concluded that NO spares were needed in either Whitehorse or Faro: “The Board finds that the two spare units are therefore redundant, given that they essentially provide backup to the 15 diesel rental units which themselves are backup to YEC’s system.”(3)

It is therefore unclear why Mayo needs two spares in a total of five generators, given that YEC claimed to need only one spare each for Faro and Whitehorse – and that the Utilities Board considered even one to be unnecessary.

Ten per cent of the rental diesels in Whitehorse are considered “spare.” (1 of 10)

Fourteen per cent of the rentals in Faro are considered “spare.” (1 of 7)

Forty per cent of the rentals in Mayo are considered “spare.” (2 of 5??)

Why so many more “spares” or “backups” in Mayo than anywhere else? Are the rentals planned for Mayo amazingly unreliable or is YEC just trying to get around YESAA requirements using the method they described in the 2021 GRA hearings?

The Mayo proposal also mentions the noise study in Faro that supposedly claims the sound difference would be “barely perceptible.” This is deceptive on a number of levels, and not what YESAB concluded in YESAB 2021-0115 for Faro. Is it reasonable to compare noise differences for an addition of more rentals to an existing diesel facility (Faro) to a new greenfield diesel facility in Mayo? The difference in Mayo will of course be far more than the 1dB claimed in Faro – and the 1dB gain claimed in Faro was an estimate that turned out to be nowhere near accurate. The difference between the silence of zero generators by Five Mile Lake now vs the 2.72 (or five) generators Yukon Energy is proposing will be very very perceptible.

YESAB’s conclusions in the case of Faro:

The Watson Lake Designated Office has determined that the Project is likely to have significant adverse socio-economic effects on community wellness that require additional mitigation.

• Reduced quality of life for Faro residents: sound generated by project activities may interact with other users of the land in such a way to impact their quality of life.

• Reduced health: public health may be affected by project operations and long-term activity at the site.

…the use of generators at the FGS is expected to increase as the Proponent has noted a growing demand for electricity in the Yukon.

YESAB noting “Significant adverse effects” is of course not the same as Yukon Energy’s claim of “barely perceptible.” Noise exceeds BC acceptable standards where rental diesels are installed in Faro and in Whitehorse and there have been multiple noise complaints in both locations. Mayo, as the third location of rental diesel, could be expected to have a similar result.

Yukon Energy has provided incorrect and deceptive information about capacity, need for backups and noise in YESAB 2023-0090 for the Mayo greenfield diesel plant at Five Mile Lake Campground. Oh, and they mention distances from Mayo, but conveniently not the distance from Five Mile Lake. The public comment period for the imaginary 2.72 generator project ends on Aug. 28. Mayo deserves honesty from Yukon Energy, and deserves the more thorough Executive Committee screening specified by YESAA.

As a public company, is it ok for Yukon Energy to provide false and deceptive information to the public? Should honesty and integrity be part of the culture? Doesn’t seem to be there now.

In Whitehorse YEC misrepresented their permitted diesel capacity in public meetings. In Faro they used project splitting and superseded documents to avoid YESAA and air quality requirements. Now they bring this lack of integrity to Mayo. Enough already.

-Nathaniel Yee