Shake Up The Establishment’s Feedback on CER Public Update
Author
Zeina Seaifan & Asha Swann
Hello/Bonjour! My name is Zeina Seaifan and my pronouns are she/her/elle. Presently, I reside on the traditional and treaty territory of the Huron-Wendat, Haudenosaunee and the Mississaugas of Scugog Island First Nation (currently known as “Ajax, Ontario”). A daughter of Arab-immigrant parents, I have many fond memories of playing, living, learning, and breathing on this land and am happiest when connecting with nature, including Lake Ontarí’io. I would specifically like to acknowledge how my cherished memories were made possible by more than three centuries of colonialism and land theft in which settler government officials conducted unjust land acquisition treaties with the Mississauga and Ojibwa peoples, who still live on this land and whose livelihood continue to be shaped by these colonial legacies. I would finally like to acknowledge the immense privilege and honour I have been able to have in watching this Senate meeting and listening to the invaluable testimonies of the four witnesses in sharing their lived experiences around environmental racism.
Editor
Manvi Bhalla
On February 16th, the Government of Canada released an update on the Clean Electricity Regulations (CER) and opened up a public commentary period which concluded on March 15th, 2024. This update follows the draft CER, originally published on August, 19th, 2023, on which Shake Up The Establishment (SUTE) provided feedback.
WHAT do I need to know about the CER?
- The CER is an integral aspect of Canada’s 2030 Emissions Reduction Plan which is concerned with allowing so-called Canada to reach net-zero emissions by 2050 while also reducing emissions by 40-45% below 2005 levels by 2030 (1). This is in response to the urgent global need to address the climate crisis.
- The CER aims to pursue a low-carbon economy through responding to global demands for a clean, reliable, and affordable electricity grid across so-called Canada while providing competitive economic opportunities to industries (1).
- The CER is developed through three core principles (1):
- Utilizing significant greenhouse gas reductions to facilitate and assist the transition toward a net-zero electricity grid.
- Sustaining electricity affordability for Canadians and businesses across both provinces and territories.
- Allowing provinces and territories to retain grid reliability as electricity needs grow in so-called Canada.
WHY is policy intervention important for the development of the CER?
- The Government of Canada must pursue a CER that is well-rounded and just — centring the wellbeing of structurally vulnerable populations, historically & presently marginalized groups, and underserved communities over industries in the design of this draft.
- When developing environmental and climate policies, we have continuously seen the desires of fossil fuel companies prioritized over the wellbeing of underserved communities across so-called Canada. This consequently and specifically undermines the effectiveness of the CER by delaying transitions to cleaner and renewable energy sources while also perpetuating inequities in our neighbourhoods by allowing these fossil-fuel industries to continue business-as-usual.
- The consideration and incorporation of diverse feedback into the regulations, informed by knowledges and worldviews outside of our Western policy-making practices, is crucial if we are to pursue an emissions reduction plan that effectively considers “the most vulnerable of our population” (2).
Executive Summary of Shake Up The Establishment’s Feedback
Shake Up The Establishment has three key areas of concern which are further expanded upon throughout the policy brief, that we feel need to be addressed to ensure these regulations are sufficient in supporting a robust response to the climate and environmental crises of today.
- Currently proposed tools (i.e. offsets, pooling, and carbon capture/storage, etc.) create loopholes for fossil fuel facilities to continue emitting at extreme levels, rather than enforcing actual emissions reductions.
- Allowing natural gas-fired units that are unable to commission by January 1, 2025, to take advantage of the EoPL provisions, while also extending the intended EoPL.
- The potential abuse of decision-making power, should systems operators be given authority over allowing exemptions from the emissions limit during emergencies.
Shake Up The Establishment’s Key Recommendations
- We ask that the government maintains its original stance and not allow fossil fuel companies to use offsets to counterbalance their emissions, when their emissions exceed the limit.
- We cannot rely on greenwashed technologies like carbon capture and storage; we need the government to invest in lower/non-emitting energy and electricity sources.
- The end-of-prescribed-life cannot be extended– in fact, it truly should be shortened.
- The government must not leave decision-making responsibility about what constitutes “an emergency” in the hands of systems operators alone.
Policy Brief: Feedback on the Clean Electricity Regulations Update
For any thoughts or feedback you wish to share, please contact: [email protected].
References
- Canada E and CC. Clean Electricity Regulations [Internet]. 2022 [cited 2024 Mar 18]. Available from: https://www.canada.ca/en/services/environment/weather/climatechange/climate-plan/clean-electricity-regulation.html
- Government of Canada PW and GSC. Canada Gazette, Part 1, Volume 1, Number 1: Clean Electricity Regulations [Internet]. Government of Canada, Public Works and Government Services Canada, Integrated Services Branch, Canada Gazette; 1841 [cited 2024 Mar 18]. Available from: https://www.gazette.gc.ca/rp-pr/p1/2023/2023-08-19/html/reg1-eng.html
