Response to the Proposed Frame for the Government of Canada’s Clean Electricity Regulations

The Canadian Climate Institute argues that the proposed Clean Electricity Regulations (CER) contain ambiguities and exemptions that could undermine Canada's 2035 net zero electricity target. The Institute recommends clarifying the treatment of existing power units, removing financial exemptions for emergency emissions, and phasing out output-based pricing in favor of a full carbon price. To maintain climate credibility and affordability, it suggests the government use financial compliance revenues to procure negative emissions and address equity concerns through targeted public investment and rate design rather than by diluting the CER's stringency.

• The proposed frame for the CER is ambiguous regarding whether existing units are exempt from the entire regulation or only from the performance standard, which could potentially put the net zero target out of reach.
• Exempting emergency use of emissions-generating units from financial compliance obligations reduces the incentive for operators to secure non-emitting emergency capacity, a move the Institute deems unjustified as costs to ratepayers would likely be low.
• Because financial payments are necessary to avoid criminal liability under the Canadian Environmental Protection Act (CEPA) and prevent blackouts, the government should use these revenues to procure engineered negative emissions to ensure the 2035 net zero goal is met.
• The current output-based pricing approach provides a weak incentive for emissions reductions, particularly for natural gas generation; the Institute recommends replacing it with a full carbon price returned to ratepayers.
• While rising electricity rates may disproportionately affect low-income households, these affordability and equity concerns should be addressed through public investment and new rate designs rather than by reducing the stringency of the CER.

APA

Dion, J. (2022). Response to the Proposed Frame for the Government of Canada’s Clean Electricity Regulations. Canadian Climate Institute. https://climateinstitute.ca/wp-content/uploads/2022/08/Response-frame-clean-electricity-regulations.pdf

Chicago

Dion, Jason. Response to the Proposed Frame for the Government of Canada’s Clean Electricity Regulations. Canadian Climate Institute, 2022. https://climateinstitute.ca/wp-content/uploads/2022/08/Response-frame-clean-electricity-regulations.pdf.

Wikipedia

{{cite press release |last1=Dion |first1=Jason |title=Response to the Proposed Frame for the Government of Canada’s Clean Electricity Regulations |publisher=Canadian Climate Institute |date=August 2022 |url=https://climateinstitute.ca/wp-content/uploads/2022/08/Response-frame-clean-electricity-regulations.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{dion2022response, author = {Dion, Jason}, title = {{Response to the Proposed Frame for the Government of Canada’s Clean Electricity Regulations}}, publisher = {Canadian Climate Institute}, year = {2022}, month = aug, url = {https://climateinstitute.ca/wp-content/uploads/2022/08/Response-frame-clean-electricity-regulations.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }