Merci, Pierre.
Within the context of the proposed Clean Air Act, the Canadian Hydropower Association would like to see the federal government rapidly adopt the following measures.
First, the government must send a clear signal to industry by putting in place an integrated emissions management plan, including greenhouse gas and air pollutant regulations.
Secondly, given that generation facilities have long lives, a clear and long-term view is essential for optimal investment decisions. Decisions made in the near future could entrench high emissions for the next 50 years.
Under the greenhouse gas emissions regulation, the electricity sector must be treated as a single integrated key industrial sector, or KIS, rather than be segmented into fossil fuel and other generation sub-sectors.
A domestic greenhouse gas emissions trading system, or DET, should be implemented as soon as possible. This system should allocate permits or credits to all electricity generation, including hydro power, on the basis of a single national emissions standard.
The modern combined-cycle gas turbine should serve as the baseline from which emissions are measured. New hydro power and other renewables should receive an automatic allocation of permits or credits without having to go through an offset system.
Investment in hydro power development involves long lead times. For this reason, it's necessary to have knowledge of the target caps and phase-in schedule as they become rigorous over time, to facilitate timely investment decisions to achieve the targets. An important aspect of the schedule is the transition from intensity-based greenhouse gas targets to caps. The cap targets should be put in place on a faster timeframe than that specified in the notice of intent. Once the DET has been implemented, linkages to international emissions trading systems should be pursued.
With regard to air pollutants, national standards for the electricity sector should be implemented. These should be clear, predictable, and sufficiently rigorous to lead to significant measurable improvements in air quality.
In conclusion, while there is a need to invest in new technologies, it should be noted that Canada can reduce emissions more rapidly with proven existing technology. The use of a technology investment fund as a compliance mechanism is not a cost-effective manner to obtain predictable, large-scale reductions in greenhouse gases and air emissions. Increased development of hydro power potential, wherever possible, is one of the best environmental and economic choices to meet electricity needs while addressing climate change and fighting air pollution.
However, to accomplish this, the federal government must improve the environmental assessment process of energy projects and implement, without further ado, an integrated emissions trading system with clear short- and long-term targets, thus establishing a level playing field where all new generation is held to the same standard.
Thank you for inviting us today. Merci.