When I sat down to calculate our household’s carbon footprint last year, I really knew nothing about how electricity is generated. Looking up the rates of greenhouse gas emissions per kilowatt hour, I was surprised and happy to learn that because I live in Quebec, we generated virtually zero emissions from our electricity use.
I also realized that if I lived in Alberta and used the same amount of electricity, our household would have emitted nearly 50 additional tonnes of CO2 – doubling our total annual emissions.
The rates of emissions intensity for electricity generation vary dramatically by province in Canada. That’s a big problem because a clean electricity grid is a necessary first step to achieving a net zero economy.

Canada and the rest of the members of the G7 group of the world’s most industrialized nations have all agreed to put plans in place to achieve a net zero electricity grid by 2035 in order to reach a net zero economy by 2050. Policymakers agree that any path to net zero requires electrifying as much as possible and sourcing the electricity needed from non-emitting generation facilities.
That’s why the release of Canada’s proposed Clean Electricity Regulations last August is so important. The regulations will, by 2035, make it illegal for most electricity-generating facilities to emit more than 30 tonnes of CO2 equivalent emissions (CO2e) per gigawatt hour (GWh) of electricity generated.
According to data released by Environment and Climate Change Canada, electricity produced through coal-fired generating facilities produces around 900 tonnes of CO2e per GWh. A natural gas plant emits around 450 tonnes per GWh. These new regulations will force provinces to accelerate the development of renewable electricity or implement plans to capture and securely store nearly all the emissions from generating facilities that continue to use fossil fuels.
Flexible rules
Why 30 tonnes per GWh and not zero? The regulations have been carefully designed to balance electricity reliability and affordability with the need to reduce emissions. Homes can’t run out of electricity when it’s -30˚C and heating demands are soaring – nor when it’s +30˚C and cooling demands are peaking. And despite the need to invest in a clean grid, electricity needs to remain affordable for everyone. The Federal Government concluded that if the limit was set at zero, the benefit of the additional emission reductions would be outweighed by the added costs and loss of flexibility for the provincial grid operators.
Some energy analysts have praised the design of the new rules as being appropriately flexible to address these concerns. There is flexibility in when the rules start to apply to facilities. There is room for excess emissions for utilities as they scale up carbon capture. And there are provisions to relax the rules in certain cases to meet peak demands and in other emergency situations.
Benefits for all Canadians
The Federal Government estimates that these regulations will result in 342 million tonnes less CO2e being emitted between 2024 and 2050. While the transition will require investment to build and upgrade facilities, the government estimates Canadians will enjoy net economic benefits of $28 billion resulting from the lower electricity costs and the economic spin-offs of upgrading and building generating plants.
The other major benefit of the regulations will be the improvement in air quality. Air pollution from fossil fuel use is responsible for 1 in 5 deaths worldwide, making it the second most important global health issue after heart disease. Combustion of fuels like coal and natural gas exposes populations to pollutants including nitrogen, sulfur oxides, mercury, and small particulate matter.
The new regulations will cut the release of hundreds of thousands of tonnes of these pollutants, improving air quality and health outcomes, particularly in regions that currently rely heavily on fossil fuels for electricity production.
Unequal implications
Implementing the new rules will not be without challenges. Because electricity generation methods and emissions intensity vary greatly by province, the rules are going to have a bigger impact in some provinces than others.

In Quebec, Ontario, Manitoba, and BC where most electricity is generated by non-emitting sources like hydro, nuclear, wind, and solar, the new regulations don’t really change much. In Alberta, Saskatchewan, and Nova Scotia, most power is still generated by coal and natural gas. New Brunswick also relies on fossil fuel generation but to a lesser extent. Nunavut depends on diesel, importing the fuel in the summer to supply generators year-round. In these regions, there will be a lot of work to do to comply with the new rules.
Alberta’s threats
The Alberta Government in particular is not happy with these new rules. They say that the changes cannot be made by 2035 and they’re seeking a special exemption to delay the implementation in their province until 2050. The Alberta Electricity Systems Operator (AESO), the arm’s-length agency responsible for Alberta’s electric system, claims the rules could leave parts of the province without power if those rules come into effect in 2035 as planned.
Alberta’s contention that they can’t comply with the proposed new rules is being criticized as lacking credibility and transparency. AESO has refused to release their analysis that they say forecasts blackouts due to the proposed regulations. Nova Scotia’s recent commitment to add more wind and solar generation to reach 80% renewable electricity by 2030 stands in stark contrast to Alberta’s claim that a transition by 2035 can’t be done. Others point out that similar transitions are successfully underway all over the world.
Alberta’s motivations are more likely driven by economics than feasibility. The province is one of the top 10 producers of natural gas in the world. When it uses its own gas to generate electricity, which it then sells to households and businesses, the province benefits financially at many points in the process. Transitioning their electricity generation systems threatens that beneficial string of transactions.
The rhetoric is pretty intense. In a statement about the proposed regulations, Alberta Premier Danielle Smith said “They will not be implemented in our province — period.” Because electricity is a provincial jurisdiction, Alberta is threatening to challenge the new rules as unconstitutional. The province launched an $8 million advertising campaign to “educate Albertans and Canadians” on the impacts of new emissions regulations. And in a move that has been widely criticized, Alberta declared a seven-month moratorium on all new renewable energy projects.
The moratorium is difficult to understand. The open plains in Alberta and Saskatchewan give these provinces an advantage in becoming leaders in clean wind generation. The market for renewables projects in Alberta had been thriving, creating jobs and investment. An analysis by the Pembina Institute, a Calgary-based energy think-thank, concludes that the pause on new project approvals affects 118 projects representing $33 billion of investment.
Alberta’s rapid growth in wind and solar generation has led some observers to suggest that the government put a moratorium on new renewable energy projects because their rapid growth was undercutting the province’s argument of being unable to comply with the new clean electricity rules by 2035.
The next few months are critical for the Clean Electricity Regulations. The Federal Government anticipates finalizing the rules in 2024 so that they come into force on January 1, 2025. As part of that process, they are accepting comments on the regulations online until November 2, 2023.
There is a lot of pressure on Canada’s Environment Minister, Steven Guilbeault, to weaken the regulations. So far he has said that he is open to tweaks, but there will not be any special deal for Alberta.
Let’s hope so. The regulations as proposed are a very good thing. They will cut emissions, costs, and air pollution. The work to transition our grid will drive investment and create jobs. Most importantly they will help ensure that Canada will have clean electricity so important to achieving a net zero economy by 2050. ■
What you can do?
Anyone can contribute comments on the proposed regulations until November 2, 2023.
There are 2 ways you can comment:
1. You can provide comments directly on the regulations in the general section here.
2. The David Suzuki Foundation has developed an online form and suggested messages that you can edit and submit here.
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