4. Some Features That Deserve Comment
Some Features of the Draft Regs That Deserve Consideration And Submission Comments
Here are some points you might want to consider making:
- A) It is very good that the federal government is finally making these regulations
- B) The cap set by these Draft Regs is not stringent enough and will make it very difficult to achieve Canada’s 2030 emissions reduction target
- C) The Use of Domestic Offset Credits
- D) Operators Can Pay Into a Decarbonization Fund and Emit More GHGs
- E) Internationally Transferred Mitigation Outcomes (ITMOs)
- F) There is a risk that there could be a “race to emit” in 2026
You can also jump directly to the Summary of Recommendations.
Citations
[1] Regulatory Impact Analysis Statement, draft Clean Electricity Regulations, Canada Gazette, Part I, Volume 157, Number 33, August 19, 2023. Accessed on February 20, 2024 at https://www.gazette.gc.ca/rp-pr/p1/2023/2023-08-19/html/reg1-eng.html.
[2] Emissions intensity is the amount of GHG emissions produced per Gigawatt hour of electricity produced. This is different from the total GHG emissions.
[3] Regulatory Impact Analysis Statement, draft Clean Electricity Regulations, Canada Gazette, Part I, Volume 157, Number 33, August 19, 2023. Accessed on February 20, 2024 at https://www.gazette.gc.ca/rp-pr/p1/2023/2023-08-19/html/reg1-eng.html.
[4] Public Update, page 7.