6. SUMMARY OF RECOMMENDATIONS – “I’m pressed for time, so please suggest what I might say in my submission!”

6.1.  Suggestions for your submissions about the 20-year EoPL

• ECCC should not extend the 20-year period for the End of Prescribed Life  (“EoPL”).  Doing so would only pander to provincial governments that are willfully refusing to develop their enormous renewable potential.
• The other changes that ECCC are proposing in the Public Update, such as the changes to the 30 tCO2e/MWh performance standard, removing the hourly limit on peaker plants, pooling, and offsets, provide more than enough compliance flexibility.  With even some of them, extending the End of Prescribed Life is unnecessary.

6.2  Suggestions for your submissions on extending the 1 January 2025 deadline

• The deadline for when gas plants must begin operation to benefit from the 20-year End of Prescribed Life exemption, thereby not having to meet the main performance standard by 2035, must not be extended beyond the current deadline of 1 January 2025.  There is no reason why anybody should commission a gas plant in 2024, let alone 2025 and beyond, that does not either have CCS abatement in place at the time of its commissioning or that cannot accommodate CCS abatement technology before 2035.
• Under no circumstances should the deadline for when gas plants must begin operation to benefit from the 20-year End of Prescribed Life exemption be extended until the end of 2027, which would let almost all of Ontario’s planned new gas plants be exempted from the core effect of the Clean Electricity Regulations.
• GHG abatement using Carbon Capture and Storage (“CCS”) is already feasible and available.  It will certainly be even more effective and more available by 2035.  No gas plant commencing operation after 1 January 2025 should be exempted from the rule to operate at or below the emissions intensity standard achievable through CCS at any point beyond 2035.

6.3.  Suggestions for your submissions on the emissions intensity standard

• ECCC should promptly publish the complete formula for unit-specific emissions limits, state how many tonnes of GHG emissions will be eliminated annually and consult publicly on both. Climate-concerned citizens and ENGOs have not been adequately consulted on this potential change to the Draft CERs.
• Given the urgency to reduce GHG emissions to limit the worst effects of climate change, ECCC should ensure the unit-specific emissions limit approach will result in no less emissions reductions than the Draft CERs. This involves setting the performance standard element of the formula appropriately. Crucially, it also means companies must not be allowed to use offset credits to meet their emissions limits.

6.4  Suggestions for your submissions on offsets

• Carbon offsets have been largely discredited. System operators’ concerns are better addressed by the proposed change to a unit-specific emissions limit rather than an emissions intensity limit, as this would allow units that exceed the limit to continue operating at a lower capacity rather than shutting down altogether. There is no need to introduce an offset credit system that would be complex to administer, vulnerable to abuse, and ineffective at actually reducing GHG emissions and the quantity of GHGs in our atmosphere.
• If offsets are included in the CERs, the government must develop a credible system to confirm with certainty that offset projects represent real, independently verified, quantifiable, permanent, and additional negative emissions. The percentage of a unit’s emissions limit that could be covered by offset credits should be set low, and should decrease over time to zero by 2040. For transparency, the use of offsets and the specific projects for which offset credits are purchased should be publicly reported.

6.5  Suggestions for your submissions on cogeneration units

• ECCC should explain what “differential treatment” is being considered for existing cogeneration facilities and give stakeholders an opportunity to respond. Stakeholders have not been adequately consulted on this potential change to the Draft CERs.
• To ensure the CERs achieve their objective of reducing emissions from electricity generation, emissions from cogeneration units should not be treated less stringently than other units. The government should use other mechanisms to incentivize cogeneration facilities to continue selling electricity to the grid while also complying with the CERs. The government should pair those incentives with policies that support development of renewable electricity generation to facilitate the transition away from fossil fuels.

6.6  Suggestions for your submissions on the pooling of units

• The pooling of individual units’ emissions limits is unobjectionable because it would support reliability during the transition to a net-zero grid while not increasing the overall GHG emissions released into the atmosphere.
• To ensure that emissions limits are not exceeded, the pooling of emissions limits must be well-designed and -implemented, and subject to a robust reporting and verification system. The federal government should take on this role to ensure the integrity of the system.
• To ensure the objective to reduce GHG emissions from electricity generation is met, the pooling of emissions limits must not be expanded to also allow banking of unused emissions limits over time.

6.7  Suggestions for your submissions on a unit-specific emissions limit on peaker plants

• Six months after publishing the Draft CERs in Canada Gazette I, it is unacceptable for ECCC to propose limits that are “To Be Determined”.  They need to tell the public specifically what these “To Be Determined” numbers are immediately, so the public can decide whether they are acceptable or not.
• Subject to knowing what the “To Be Determined” numbers might be, unit-specific emissions limits for peaker plants might well be a good idea.  The previous 30 tCO2e/GWh emissions intensity standard was targeted at base load power plants, once they had been operating for several hours or more and were thus operating at peak efficiency.  Both base load power plants and peaker plants do not operate at their best emissions intensity levels when they are first started up from a cold state.  They need to run for at least several hours, so that their many  gaskets, valves, etc. warm up, expand, and thereby operate at their best emissions intensity level.  But we don’t want peaker plants to operate at their best emissions intensity level after many hours or days of permanent operation, because that is not their job.  They should never be operated in that state.  We want them to emit the fewest GHGs possible as they start up from cold, operate for a few or several hours to provide additional electricity to the system when there is a deficit, and then shut back down.  We want them designed to operate at the best emissions intensity level possible during this period of operation, because this is the only period of operation for which they should operate.  Designing for optimal operation for that period will almost certainly be different for designing for optimal operation for near full-time baseload power.  Therefore, it makes sense for peaker plants to have unit-specific emissions limits that are different from gas plants designed to provide baseload electricity.

6.8  Suggestions for your submissions on the emergencies exemption

• You may wish to consider telling ECCC that you approve of this proposed change, for the reasons set out in the Public Update.  However, once a provincial authority declares an emergency and starts the operation of the relevant gas plants, the federal minister should have the power to determine how long that will continue.