Clean Electricity Standard Submission Nov 2023

Environment and Climate Change Canada (ECCC) proposed the draft Clean Electricity Regulation (CER) that significantly reduces the ability to use gas-fired generation after 2035. The proposed CER reflects many of the inputs the PWU has provided. However, the proposed CER many risk areas that make it impossible for the CER to achieve its objectives anywhere in the country in the timeframe identified. The PWU has recommended that the ECCC reconsider the timelines contained in the CER given the higher electrification driven demand, the conclusions it is drawing from its modeling about the potential contribution of renewables, and the disconnects between its supply mix assumptions and those of provincial plans which may be related to invalid and/or inconsistent cost assumptions.

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