Powering the Future: Recommendations for developing effective low-carbon electricity regulations

June 20, 2023

The Honourable Steven Guilbeault

Minister of Environment and Climate Change

Alberta businesses appreciate climate change as one of the most pressing issues facing Canada today. Across sectors, businesses are working to advance decarbonization initiatives, invest in clean technologies and position Canada as a leading jurisdiction for climate-friendly investments. At the Calgary Chamber of Commerce, we applaud the government’s commitment to incent investment, including through significant financial supports such as the Clean Electricity Investment Tax Credit and Zero Emission Vehicle Infrastructure Program. We also recognize strategic climate policies play an integral role in this progress, ensuring that regulatory frameworks and incentives are available to support industry in decarbonizing. However, continued progress on decarbonization requires that climate policies effectively balance environmental and economic goals. Moreover, they must be structured in a manner that recognizes the long cycle investment time frame associated with deploying the capital required to achieve decarbonization targets.

After assessing Canada’s 2030 Emissions Reduction Plan (ERP) and the proposed Frame for the Clean Electricity Regulations (CER), the Calgary Chamber of Commerce contends the national approach of the proposed regulations may not adequately account for regional differences in Canada’s electricity markets, leading to unintended social and economic consequences by challenging the reliability and affordability of electricity in Alberta. Considering Alberta is Canada’s only deregulated electricity market, the private sector will be required to make the necessary investments to decarbonize Alberta’s grid – not the government. As such, the risk to affordable and reliable electricity is heightened as ratepayers will bear the long-term cost of businesses’ investments. These concerns have been echoed during consultations with Chamber members across Alberta’s electricity value chain, including non-renewable and renewable generators, transmission and distribution companies, and retail businesses.

While we recognize the CER will be made public in the Canada Gazette in the coming weeks, during which time formal feedback will be collected, we would like to offer preliminary feedback based on recent consultation with our members to inform the continued advancement of the regulations. To this end, the Calgary Chamber of Commerce is providing this letter to request your department consider the following recommendations:

1. Ensure affordability and reliability are central to policy development, with a commitment that decarbonization policies will prioritize a technology-agnostic approach to emissions reduction. 
   
2. Work with Finance Canada to immediately provide additional clarity on financial supports, such as the investment tax credits that support decarbonization technologies, and further the objective of net-zero electricity systems by 2035. 
   
3. Ensure the availability of financial support for all decarbonization technologies appropriately balance the urgency to decarbonize with realistic project timelines.  
   
4. Provide timelines on the development of Carbon Contracts for Differences.  
   
5. Streamline and harmonize regulatory processes and review periods for federally designated projects. 
   
6. Foster collaboration between industry, Indigenous partners and all levels of government to ensure alignment on decarbonization policies and support Indigenous communities’ participation in decarbonization projects. 
   
7. Recognizing the unique nature of Alberta’s electricity market, acknowledge policy and regulatory certainty are required to support long-cycle private sector investments in Alberta’s market.  

Sincerely,

Deborah Yedlin

President & CEO
Calgary Chamber of Commerce

ABOUT THE CALGARY CHAMBER OF COMMERCE

The Calgary Chamber exists to help businesses thrive. As the convenor and catalyst for a vibrant, inclusive and prosperous business community, the Chamber works to build strength and resilience among its members and position Calgary as a magnet for talent, diversification and opportunity. As an independent, non-profit, non-partisan organization, we build on our 131-year history to serve and advocate for businesses of all sizes, in all sectors and across the city.