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March 15 2024

Calgary Chamber responds to 'What we Heard' report on the proposed Clean Electricity Regulations

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Alberta businesses acknowledge climate change as one of the most pressing issues facing Canada – and the world – today. Across sectors, companies are working to decarbonize and make investments that support emissions reduction initiatives, ensuring Canada is a leading jurisdiction for investment. Since 2005, emissions have decreased 56 per cent in Canada’s electricity sector, and if provided with adequate and additional supports, streamlined policy and realistic timelines, initiatives like Carbon Capture and Storage (CCS) will continue to lower emissions. Ensuring policy acts as a catalyst for investment, not a deterrent, is critical to achieving our shared climate goals.

Upon reviewing Environment and Climate Change Canada’s (ECCC) February 16, 2024 ‘What We Heard’ report, we acknowledge and appreciate the government’s commitment to continued engagement with businesses to ensure policy balances the need to decarbonize, with the need to provide reliable and affordable electricity. The report reflects this balance, and the concerns previously raised by the Calgary Chamber of Commerce in our November 2, 2023 submission to ECCC, which contends that as drafted, the CER would have significant social and economic consequences by detrimentally impacting the reliability of the grid and affordability of electricity in Alberta. The Chamber’s submission included several recommendations to mitigate the negative economic and social impacts of the CER, which we are pleased to see reflected in the ‘What We Heard’ report.

As the government continues its engagement, we strongly encourage the implementation of the proposed changes to the CER to ensure electricity remains reliable and affordable. To support this work, we’ve provided recommendations on several changes under consideration by ECCC.


Engagement Process

The CER would have broad impacts across the economy as industries seek to reduce their emissions while continuing to deliver services to Canadians. With the possibility of significant revisions illustrated by the depth and range of changes currently under consideration, an additional update prior to Canada Gazette II will provide much needed certainty and stability, minimizing the impact of policy changes to the consumer.

We recommend the Government of Canada:

This recommendation is aligned with Section of the Treasury Board Secretariat’s 2024 Guide to Regulatory Development and RIAS Writing, which states:

“[I]n some cases, comments received as a result of pre-publication may alert regulatory organizations to considerations that did not initially factor into the cost-benefit analysis for the proposed regulatory measure. This may result in a substantial change to the regulatory proposal. In these circumstances, it may be necessary to pre-publish for a second time before proceeding to the Canada Gazette, Part II.”

Performance standard and CCS flexibility

Considering the size and scale of the public and private investment required for the adoption of abatement technologies, such as CCS, regulations must not be so prescriptive that they create unintended consequences or excessive risk for long-cycle investment. As it stands, the emissions intensity limits are too stringent and should be adjusted to respond to more realistic and known capabilities of CCS technologies at this time.

We recommend the Government of Canada:

Peaker Provisions

Preserving the role of natural gas-fired peaking plants within Alberta’s generation portfolio is essential to long-term grid reliability and is especially important as the CER encourages investment in renewables while challenging continued investments in new natural gas-fired baseload generation. Given Alberta’s natural resource mix, the intermittency of renewable technologies currently available in the province, and limited connections to markets in neighbouring jurisdictions, peaking facilities are critical to providing the on-demand, incremental generation needed to meet unforeseen grid demands.

We recommend the Government of Canada:


Carbon markets drive down emissions while spurring innovative economic opportunities. Providing greater flexibility, including through offset provisions, will de-risk the investment required for abatement technologies.

We recommend the Government of Canada:

End-of-prescribed life

The proposed timeline for registered generation units to meet the end-of-prescribed-life performance standard is excessively stringent given the significant, long-cycle investments required to identify and implement cost-effective decarbonization technologies. As such, businesses may not be able to adequately recover costs from existing facilities and will be unable to make final investment decisions on decarbonization technologies.

We recommend the Government of Canada:

Emergency Circumstances

We are encouraged that the CER recognizes generators and system operators must be empowered to act as quickly and efficiently as possible to mitigate threats to grid stability or restore stability following a disruption. However, the proposed definition of emergency circumstance – coupled with enforcement of the CER under the Canadian Environmental Protection Act – creates ambiguities related to criminal liabilities that mean businesses may need to refuse or delay actions required to protect grid stability over concerns of potential penalties. Moreover, a possible disconnect over regional grid challenges may create a situation whereby an independent provincial system operator pre-emptively declares an emergency that may not align with the proposed regulatory threshold, leading to a likely situation where Alberta’s grid needs emergency generation, but generators remain hesitant to deploy over fears of regulatory or criminal penalties.

We recommend the Government of Canada:


We are pleased to see many of the recommendations in our original submission acknowledged by ECCC’s report. We continue to contend that climate policies must balance reducing emissions with the economic impact on businesses and customers. Moreover, policies must be structured in a manner that respects the significant, long-cycle investments required to deploy the capital necessary to achieve decarbonization targets.

Finally, we would like to reiterate that the Calgary Chamber firmly believes emissions reductions and economic growth go hand-in-hand. Our proposed amendments support this point of view, recommending ways in which the CER can effectively incentivize emissions reduction without compromising reliable and affordable power or the environment.

Thank you in advance for your consideration. We look forward to continuing to engage with you and your department as you pursue a sustainable and prosperous future for all Canadians.


The Calgary Chamber of Commerce exists to help businesses reach their potential. 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 founded in 1891, we build on our history to serve and advocate for businesses of all sizes, in all sectors across the city.