Thank you, Mr. Chair.
My name is Francis Bradley, and I am the president and CEO of Electricity Canada. Thank you for the invitation to appear before you today as part of your study on the Fisheries Act.
Electricity Canada is an association that represents the country's power companies, the companies that generate, transport and distribute electricity in every province and territory in the country.
Mr. Chair, let me start by cutting to the chase. The fundamental issue is that we now have a fish act, not a fisheries act.
First, let me put this in context. Canada is experiencing a rapid increase in electricity demand. We expect demand for electricity to double or triple by 2050, and to meet this, we need to build at a pace not seen since the 1950s. According to the Canada Energy Regulator, this will require increasing hydroelectric generation by more than 25%. To do this, we need a regulatory environment that is predictable, and it's urgent.
As it stands now, the Fisheries Act does not offer this. The 2019 changes to the act shifted the focus from protecting fisheries to a narrow focus on individual fish. This has resulted in project delays and increased costs to Canadians, without significant benefits to fisheries. When the changes were originally debated, our industry raised concerns that the Department of Fisheries and Oceans would be overwhelmed with an influx of applications for FAAs, Fisheries Act authorizations. This has been the case, and the department has not been resourced adequately to manage the volume of applications.
It was suggested that, prior to implementing the changes, a pathway to compliance be developed alongside alternative compliance mechanisms. Unfortunately, here we are, five years later, and key regulations and guidance materials have not been developed and no clear pathway has been established for the hundreds of facilities that became non-compliant overnight. How did they become non-compliant overnight? It's because they were designed to protect fisheries, not individual fish.
Some of our members have more than 100 years of experience operating their hydroelectric infrastructure. They take every possible step to be responsible stewards of the local fisheries, from the design of their facilities to developing best practices and entering into local conservation partnerships. They have time-tested processes to mitigate the impacts of routine, low-level projects. Fisheries Act authorizations should be reserved for activities that have a higher potential for adverse impacts.
We have always worked and will always work collaboratively with government to find solutions. In fact, right now, our stewardship committee is in Ottawa for a workshop with the DFO on ways to improve the implementation of the act. While these engagements are necessary for productive industry-government collaboration, we need to get moving on improving the regulatory environment if we want to meet our climate and economic goals.
To enhance regulatory certainty, promote the sustainability of fisheries and better enable economy-wide electrification, we recommend, first, that the purpose of the Fisheries Act should be restored to the protection of fisheries instead of individual fish. This ecosystem approach would be in line with the original intention of the act and allow DFO officials to set reasonable and realistic targets based on the resources they have available. This can be achieved through modest amendments to the act or the development of an electricity-specific regulation that reflects the unique realities of our sector.
Second, the minister should issue an operational directive with guidance to the department on the development of compliance mechanisms for low-risk, routine activities. This will ease the burden on the department, as well as improve implementation for the industry.
Finally, DFO should continue to work to implement the cabinet directive on regulatory and permitting efficiency for clean growth projects. Taking a cross-government approach is how we will achieve the regulatory harmony and efficiency we need to get critical clean electricity projects built.
To conclude, it's the impacts of climate change that present the most existential threat to fisheries. Getting clean electricity infrastructure built is critical to reducing our emissions and mitigating these impacts, ultimately protecting Canadians and fisheries.
Mr. Chair, you will find in the brief that we presented 11 specific recommendations in appendix B.
Thank you for the opportunity to join you today.