The New Brunswick Anti-Shale Gas Alliance is a coalition of Anglophone and francophone groups from across the province that has since 2010 pursued two mandates – promoting the transition to a clean energy economy, and stopping the development of unconventional fossil fuels in New Brunswick.

We have done so via public education, formal testimony to government, legal actions, and media advocacy, all based on a foundation of scientific, public health, and economic facts and research.  We certainly consider ourselves major stakeholders in the Energy Transition.

The context surrounding all of our comments is the rapidly increasing harms brought by climate change – the underlying reason for this energy transition.

As we write, Fort McMurray has already been evacuated, and smoke from BC fires is creating unhealthy air pollution in the USA.  Monkeys – dead from heatstroke – are falling out of trees in Mexico, while deadly heat waves in Pakistan and India have passed temperatures of 50 C.  Record drought and floods in every continent on earth are causing crop failures and water shortages. Unparalleled heat in the world’s oceans is bringing record high temperatures to Florida, global destruction of coral, and forecasts of a record breaking hurricane season.

These are only some of the current headlines of the growing amount of bad climate news that has caused scientists to reevaluate their previous assessments, and suggest that climate conditions are deteriorating more quickly and seriously than predicted. (Including economic costs.) Our response must reflect this new pace and seriousness of the climate emergency.  It is clear that the plans and goals that the world made after the Paris conference are inadequate, and must be strengthened quickly.

This applies to New Brunswick’s plans as well.  The good and proven parts of the province’s new plans must be larger in scale and more rapid in execution, while those parts that are speculative, or based on political or  economic factors, must be harshly judged on their ability to timely provide the necessary help.

Given that context, plus the name of our organization, it will come as no surprise that we  start our comments by saying that there can be no place for the development of shale gas and/or LNG in our province due to the increase in climate killing greenhouse gas emissions they bring.

Scientists and international institutions have clearly stated that our carbon budget could not include any new fossil fuel development beyond what was in play in 2021.  They proved prophetic, as atmospheric levels of all the greenhouse gases caused by the burning of fossil fuels have increased at a record pace since then, despite any actions the world has taken.

The development of new fossil fuels is the dream of greenwashed advertising from profit seeking corporations and investment bankers, but has no basis at all in climate science or the guaranteeing of our survival.

Globally and locally, the health risks associated with gas are increasingly well documented, as are the exorbitant clean up costs when the industry shuts down, both meaning that there can be no social license.

With gas off of the table we can examine the other sources of energy on the roadmap in the context of the government’s strategic focus – Affordability, Energy Security, Economic Growth, and Regulatory Reform.

Renewable energy

Renewable energy – primarily wind and solar – should be the focus of the lion’s share of our energy investments.  It is the only option that checks all the strategic focus boxes.

Affordability – Renewables are already the most inexpensive source of electricity on the planet, and is a proven technology with few carbon emissions.  The technologies to support it, such as batteries and other methods of energy storage, have already decreased in costs by orders of magnitude and are forecast to continue to do so.  Obviously, the sun and wind provide free fuel for these energies following construction of the infrastructure.  There should never be large fluctuations in price, or increases, attributed to renewable energy.

So the electrification of as many energy applications as possible is a necessary requirement for the roadmap, including increased and upgraded transmission infrastructure, charging infrastructure for electric transportation, smart metering, and conservation of energy wherever possible, including easy and affordable access to heat pumps and insulation.

Finally, the cost of decommissioning renewables at the end of their lifespans will not require the  huge sums of money to close either toxic fossil fuel or nuclear installations.

Energy Security and Reliability – Renewables are the only energy source that are virtually infinite in supply and New Brunswick has vast wind potential. They require no dependence on other countries or provinces beyond the sharing of transmission lines with neighbours in an upgraded electrical grid.

They have proven to be reliable, and a number of countries now produce a substantial amount of their electricity from them – including large ones like Germany, which in 2023 provided over half of its needs with renewables in 2023.

Of all known energy sources, they have the least detrimental effect on climate, and just as importantly, on the environment.

Economic Growth – Future economic growth will only happen in places that provide clean energy.  Primarily, the inexpensive and secure electricity provided by renewables will be an incentive for businesses to relocate. Secondly, there will be a growing incentive to abandon places without clean energy, because of growing climate concern and regulations surrounding it, resulting in higher costs.

Renewables have recently been designated as the fastest growing source of energy in all of history.  Adopting them will put us on the right side of history and economic security. Getting involved in some aspect of the industry supporting renewables would seem to be a clear imperative.

Regulatory Reform – Beyond streamlining the approval processes for building renewable installations and transmission lines, and running government programs on conservation, there is little regulatory reform required with renewables.  Of course, all energy providers will have to be regulated, no matter the type.  But because renewables don’t produce greenhouse gases,  toxic waste, or water and air pollution, the regulatory burden should be much diminished.

We are happy to see that the New Brunswick plan, calls for the addition of considerable renewable energy, and conservation programs like smart metering and heat pump assistance.

However, we have concerns that the amount and pace of those additions will still be inadequate, because we believe that renewables will be called upon to make up for shortcomings in other parts of the plan.

Virtually all of the rest of the roadmap is based on technological advances that have yet to be developed beyond the theoretical, or which have failed in their initial deployments.

Small modular nuclear reactor’s (SMR’s)

Small modular nuclear reactor’s (SMR’s) are forecast in the roadmap to supply energy by 2030 and a great deal of energy by 2035.  Yet a new report from the Institute for Energy Economics and Financial Analysis (IEEFA)concludes that “modular nuclear reactors (SMRs) will be too expensive, slow, and risky to build in time to help decarbonize the grid over the next 10 to 15 years, but promoting them could take resources away from carbon-free and lower-cost renewable technologies that are available today.”

This solidifies the doubts expressed in earlier evaluations that this new type of nuclear energy would fail to meet any of the strategic focus goals.

Affordability – The report, including New Brunswick’s efforts, states that the estimated cost of SMR energy is already many times higher than renewables, and is increasing even before reactors are built.  It will be the most expensive energy on the market. Indeed, some projects have already been cancelled, because they realized they could never be economically justified.

Energy Security and Reliability – SMR’s are not a unified industry. Many varying designs are now competing to be the winner, and many have differing fuel requirements.  So until there is a clear direction, a fuel supply line cannot be built, a factor that will delay the development of the industry.

We witnessed just weeks ago that the assumed supply for the ARC project in New Brunswick has been disrupted, because it came from Russia.  While developers say they can get new suppliers, Bill Gates USA project, which uses the same fuel, says it will delay them for 2 years.

Other reactor designs involve plutonium, which brings up the problem of nuclear weapon proliferation, and other designs have yet to confirm how long-lived nuclear waste will be stored.

Because of the variety of designs and fuels, we have no idea what the climate impacts over the lifecycle of these reactors will be.

Finally, these reactors haven’t been built, so we have no idea of their reliability.  In the history of our own Point Lepreau reactor (using well-established technology) serves as any guide, counting on a seamless introduction of this industry is a very high risk bet.

Economic Growth – if it were dependent on this technology, would not begin for the next decade.  No industry is going to bet its future on promises. Until functioning SMR’s have a track record no one will bet their company on them.

Building and selling SMR’s in the province will likewise depend on having a proven reliable product to sell.  That dream is in the far future, and assumes that one of the two local SMR designs will be the winners in the race to get to market.  Again, a very risky bet.

Regulatory Reform – will be voluminous, onerous, and require much expertise.  This new nuclear technology requires new engineering, new fuel requirements, new transportation safety regulations and pollution controls, and new means of nuclear waste disposal, all in a field with little local expertise, and virtually no experience.  There will be local, regional, national and international regulatory requirements. All of this will add costs and time delays.

To sum up, at this point SMR’s don’t check any of the strategic focus boxes.  Even if they eventually work, it will be too late to help with the immediate needs of climate action, it will provide very expensive electricity, and divert resources from more suitable pursuits. The IEEFA report warns shareholders about going down this path.  Unfortunately, in Canada, taxpayers are the shareholders.


Hydrogen may have a future in uses such as fuel cells, ammonia for fertilizer, and in niche industrial applications that are otherwise hard to decarbonize.  However, its widespread use in other applications – including as a substitute for, or addition to, natural gas – will very likely not happen, as more research in response to the hoopla surrounding hydrogen shows it to be ill-suited or too expensive.

Affordability – can only be discussed after deciding what method will be used for producing the hydrogen. We will discuss only two.  The first is called blue hydrogen, a process using a natural gas feedstock with the resulting high CO2 emissions captured and stored away underground (CCS).  This method is mentioned several times in the transition plan, but it should be a total non-starter on many grounds.

Just like SMR’s, CCS remains largely theoretical, but it has had a number of real world projects that can be examined.  Not one of them has been successful.  Just this past month, one of Canada’s big projects was abandoned because of costs, and another was deemed a failure, as after nine years and a billion dollars, it only achieved a 57% efficiency – far from the 95% plus promised by industry.   Both industry and 3rd party reports state that CCS targets either can’t be met by 2035 and/or will require huge government subsidies.

On the science side, research finds that the energy necessary in creating blue hydrogen, including energy required for CCS,  produces considerably more greenhouse gases than simply burning the gas itself.  And scientists question whether the gas stored underground will stay there forever.

No blue-hydrogen should be in the transition plan.

Green hydrogen is produced by electrolysis from water.  However, it is very energy intensive, so unless the process is powered by clean energy, it would be bad for the climate and expensive. Therefore, only hydrogen produced using renewable energy is considered green.

A large green hydrogen industry would require a huge amount of renewable energy to be built.  The economic and practical question to be answered is whether the renewable energy created would be better used directly as electricity, as opposed to producing hydrogen for energy and other uses, and whether the building costs of infrastructure for hydrogen will be justified.

Energy Security and Reliability – for hydrogen will depend on how its vaunted potential stands up against new research being conducted on its proposed various uses.

Because it is the smallest of molecules, hydrogen is hard to contain and escapes easily into the atmosphere.  While not a greenhouse gas itself, hydrogen depletes chemicals in the atmosphere that break down methane, a very potent greenhouse gas.  It, therefore, indirectly worsens climate change.

Recent research has also shown that when mixed with methane (natural gas) for use in stoves and boilers, it actually increased the amount of methane emissions that escaped as fugitive emissions. This directly contradicts some of NB’s plans for mixing gas and hydrogen.

Along with its escape properties, its low boiling temperature – twice as low as LNG – and its low ratio of energy to volume, the prospects of shipping it long distances are extremely unlikely.  Converting it to ammonia for shipping may be possible, but creates other powerful greenhouse gas emissions – nitrous oxide – that are also the leading threat to ozone layer destruction.

Economic Growth – resulting from hydrogen is hard to predict, as so many uncertainties remain about its viability.  Many places are having second thoughts, such as in Edmonton, Alberta, where the energy transition committee recently asked to remove hydrogen from its plans.  There are reasons why hydrogen has been touted as the next new energy source for 30 years, but it has never delivered.

New Brunswick has a lot of renewable potential, but if it uses that to power hydrogen production, will there be a sufficient supply for other needs?   Hydrogen produced close to its end use in various industrial applications may be useful in decarbonization, but its use as a fuel substitute or additive to gas is not viable.

Regulatory Reform – will be a major undertaking as we are just learning a lot about hydrogen and its climate and public health issues.


Biomass as a fuel for the Belledune power plant is neither a climate or energy solution and could have serious repercussions.  The European Science Advisory Council concluded that biomass was “a ‘renewable’ energy that actually increases atmospheric CO2 for decades. Such technology is not effective in mitigating climate change and may even increase the risk of dangerous climate change.”  Based on the Joint Research Council’s report on “Use of woody biomass for energy,” they concluded that, “billions in public subsidy for biomass conversions are worsening carbon emissions for many decades.”

Affordability – Biomass may represent some savings compared with coal, but it will be more expensive than any renewable energy.  Costs will grow as supply will have to come from ever shrinking sources located further away.

Energy Security and Reliability – is questionable in the future.  Current biomass usage uses up almost all of the availability of supply, and as more places use biomass, the industry starts to use more good lumber and even whole trees.   Recent audits from the UK, tracking the operations of Drax, Europe’s largest producer of electricity using biomass, found that it was having large impacts in British Columbia forests, including logging in old growth areas.  Other reports have noted the destruction of European and US forests by the biomass supply industry.

Growth in its use will mean both higher prices in the future and more ecological damage.  Because wood is less energy dense than coal, much more of it has to be burnt to produce the same amount of electricity.

This also produces more greenhouse gas emissions per KWH of electricity. than coal.  Supposedly, biomass is still carbon neutral, but this is doubtful.  The carbon released by burning wood enters the atmosphere immediately, while it takes decades or more for an equivalent capture of carbon by trees, which have to be planted and reach maturity.  Who will assure that these trees are planted and will reach maturity?

Until then there will always be a carbon deficit – meaning more carbon in the atmosphere now, when we desperately need to reduce it.  It’s a losing game of catching up.

Economic Growth – coming from biomass is hard to envision, beyond profits for the suppliers of the wood.

Regulatory Reform – would be needed to tightly regulate supply sources in perpetuity, not just to ascertain where the biomass is coming from, but also to account for losses due to forest fires, droughts or subsequent logging that negate any carbon savings.


We have not addressed the Mactaquac dam, as its continued use in some form seems to be a politically forgone conclusion.  Whatever its future, we hope money is available to do it in an ecologically non-destructive manner.  Likewise, it appears that nothing will alter the existence of the Point Lepreau reactor, despite its inadequacies   We have concentrated on those things which can be done.

The obvious conclusion we reach, using the criteria of strategic focus contained in the Energy Roadmap, is this:

All possible efforts and resources should be put into the rapid development of renewable energy and its necessary accompaniments of an improved and expanded grid with connections to neighbouring jurisdictions, energy storage, energy conservation such as heat pump subsidies, and technologies like smart metering and EV charging.

These things check every one of the strategic foci, from affordability to growth to climate.  We also recognize that:

There may be some niche places for locally produced and used hydrogen.

Beyond that, all the other energy options on the roadmap face severe challenges to check even one of the focus boxes.

They are not plans, they are wish lists, and often contradict the scientific and economic facts we already know. [See Table below]

Clinging to ideas like CCU, natural gas, and blue hydrogen is to ignore reality.  Other items like SMR’s are long shot gambles that, even if possible, will arrive too late to help us with climate change – the overarching reason for this exercise.

We urge you to revisit the roadmap and reallocate resources from the speculative ideas to the existing concrete renewable technologies.  It can almost be guaranteed that by embracing renewables we will prosper not only now, but down the road, as the world increasingly will be forced to face climate change.

We will not be stuck with stranded assets, nor the expensive clean up costs of fossil fuels and nuclear plants. Renewables are  clearly the right roadmap to follow.

Thank you for your consideration.

Jim Emberger, Spokesperson
New Brunswick Anti-Shale Gas Alliance


Energy Source Affordability Reliability Growth Regulatory Ref.
Renewables Cheapest energy sources in the world. Proven technology

and most climate friendly.  NB has vast wind potential

Fastest growing energy source ever. Minimal, beyond streamlining siting of infrastructure.
SMR’s Expensive – perhaps most costly. Unknown – no existing plants, or dominant designs, or fuel sources. Unknown – until first plants in 2030 at best. Novel technology. Requires new health, safety & pollution regs.
Hydrogen Expensive Unknown – depending on usage. Has climate effects. Unknown – depending on usage and solving many problems. Novel technology & Safety concerns – new modes of transporting it.
Biomass More expensive than renewables, likely to increase. May cause environmental damage.  Harms climate in near term. Unlikely.  Supply will not support much increased demand. Insuring integrity of supply and accounting of carbon equivalency in perpetuity.