Evidence of meeting #115 for Natural Resources in the 42nd Parliament, 1st session. (The original version is on Parliament’s site, as are the minutes.) The winning word was buildings.
A recording is available from Parliament.
Liberal
The Chair Liberal James Maloney
Good morning, everybody. Thank you for joining us.
This morning we have two sets of departmental witnesses from the Department of Natural Resources and the Department of the Environment. Thank you, everybody, for taking the time to be with us today.
You know the format as well as we do. Each department will be given up to 10 minutes to do a presentation, which will be followed by questions.
Why don't we jump right in. I understand, Mr. Jones, that you're going to lead us off. Is that correct?
Matt Jones Assistant Deputy Minister, Pan-Canadian Framework Implementation Office, Department of the Environment
Yes.
Thank you, and good morning.
I'm happy to be here to talk about the role of energy efficient measures in the pan-Canadian framework on clean growth and climate change.
As you know, the framework is our national plan and is intended to make Canada more resilient to the impacts of climate change while allowing us to reach our emissions reduction target of 30% below 2005 levels by 2030. The framework accomplishes this through a number of complementary measures across four pillars.
Increasing energy efficiency has always been an important part of reducing greenhouse gas emissions, here and everywhere in the world, and features quite prominently in the framework. To give you some context for the role that energy efficiency measures play, I will give some quick background on the pan-Canadian framework and how it was developed.
The first ministers meeting in Vancouver launched a process that involved a number of working groups, one for each pillar. The groups were composed of officials from provinces, territories and the federal government. We did work with indigenous peoples, did some public consultation with stakeholders and developed a long list of options that were brought forward for consideration. This input provided the basis for the development of options in the reports, and ultimately in the pan-Canadian framework, which was agreed to in December of 2016.
I was the chair of the mitigation working group, along with a counterpart from British Columbia. From the early stages, energy efficiency was considered and has remained an important component of that suite of measures to reduce emissions. In the report produced by the working group, our proposed options to reduce greenhouse gas emissions through energy efficiency measures covered industy and the built environment in general.
Energy efficiency measures reflected in the framework were drawn from those options. They include a long list that you'll hear more about today, including improved industrial energy efficiency; model building codes that are designed to be net-zero ready; retrofitting of existing buildings, including the development of a model code for existing buildings; improving energy efficiency for appliances and equipment by setting new standards for heating equipment and other devices; and supporting building codes and energy efficient housing in indigenous housing and indigenous communities.
We've made quite a bit of progress in all areas of the implementation of these measures. We have an annual report that goes to first ministers on this data, which we could share with the committee if you're interested.
On industrial efficiency, the federal government introduced some amendments to the energy efficiency regulations, which came into effect in June of 2017, for a number of product categories. This will be important for improving the performance of those devices. The new Energy Star for industry certification program was launched and a new industry challenge program has been announced.
With regard to the built environment, the federal, provincial and territorial ministers of energy are collaborating on improving energy efficiency in buildings through the Canadian energy strategy, and energy ministers have released Canada's buildings strategy, which is tied to the pan-Canadian framework. Energy efficiency requirements for new buildings are also being implemented and retrofits are being supported though financial assistance programs.
In addition, key funding envelopes have been announced to support energy efficiency measures, all of which are currently in the process of being rolled out and implemented at the moment.
I'll pause there, and perhaps turn it over to my colleague Helen, who will tell us more about Environment Canada initiatives related to energy efficiency.
Helen Ryan Associate Assistant Deputy Minister, Environmental Protection Branch, Department of the Environment
Thank you.
I'm also pleased to be here today to speak about the role of energy efficiency in Canada and its contribution to Canada's Paris climate change commitments. As you've heard already from my colleague, Matt Jones, the pan-Canadian framework on clean growth and climate change is our national climate change plan. It is intended to make Canada more resilient to the impacts of climate change while helping us reach our greenhouse gas reduction target of 30% below 2005 levels by 2030.
Energy efficiency is an important part of reducing greenhouse gas emissions and forms part of the regulatory aspect of the complementary measures we're implementing to reduce these emissions. I'm going to talk further about some of those complementary measures, including some of those related to methane in the oil and gas sector, to transportation, to electricity and to the clean fuel standard.
As part of the pan-Canadian framework on clean growth and climate change, we've reaffirmed our commitment to reduce methane emissions from the oil and gas sector by 40% to 45% below 2012 levels by 2025. For those of you who don't know, methane is quite a potent greenhouse gas. It's 25 times more powerful than carbon dioxide and makes up about 15% of Canada's total greenhouse gas emissions. The oil and gas sector is the largest contributor of methane emissions in Canada.
In April 2018, Environment and Climate Change Canada published federal methane regulations to deliver on this commitment and reduce methane emissions. We've consulted extensively with provinces, territories, industry, environmental organizations and indigenous people to put in place a robust and cost-effective regulation. The regulations were designed to promote innovation and provide flexibility to enable industry to choose the most cost-effective compliance options.
Transportation accounts for about 25% of Canada's total GHG emissions, half of which are from passenger vehicles, or what we call light-duty vehicles. Our current light-duty vehicle regulations limit greenhouse gas emissions and have associated impacts on reducing energy consumption and increasing energy efficiency. The regulations are designed to promote innovation and provide flexibility to industry to choose the most cost-effective compliance options. New 2025 model year vehicles are expected to burn about 50% less fuel and emit 50% less greenhouse gas than vehicles built in 2008.
Canada's new heavy-duty vehicle emissions regulations, published in May 2018, introduce greenhouse gas standards for a full range of heavy-duty vehicles and engines. These standards increase in stringency from model years 2021 to 2027. It's estimated that some vehicle types can expect pollution reductions of up to 25% for model year 2027 heavy-duty vehicles.
With respect to electricity, about 80% of Canada's electricity generation is from sources that do not emit greenhouse gases, such as nuclear, wind or hydro. However, the remaining 20% is from emitting sources. On February 16, 2018, Environment and Climate Change Canada published proposed amendments to our traditional coal-fired electricity regulations to accelerate the phase-out of coal by 2030. At the same time we published draft standards for natural gas-fired electricity generation.
We expect these regulations to be finalized later this year. They will help Canada achieve its goal of 90% non-emitting electricity by 2030, and they form an important part of the pan-Canadian framework on clean growth and climate change. That is not only part of our plan to reduce emissions and grow the economy, but will also help us to transition as part of our mid-century strategy. The regulations will set greenhouse gas emission intensity performance standards for new gas-fired generation, ensuring that new gas-fired electricity generation is cleaner and more efficient. The new natural gas-fired capacity will be required in the coming years to ensure reliable and affordable electricity. A large amount of coal is coming offline, and it will provide a bridge for increased deployment of renewables.
With respect to clean fuel standards, using lower-carbon fuels in transportation industries and in buildings is one of the biggest steps we can take to reduce carbon pollution and make our economy cleaner and more competitive. The government is committed to developing a clean fuel standard to reduce carbon pollution by 30 million tonnes by 2030, which is a reduction in pollution equivalent to taking about seven million cars off the road each year.
In terms of the development of the standard, we announced in 2016 that we were moving forward with it and then recently announced in the summer that we're taking a phased approach. We'll be starting with liquid fuels. We'll be requiring a reduction in the carbon intensity of the fuel over its life cycle.
That regulation will have flexibility in terms of its compliance mechanisms, which will include things like energy efficiency or other efficiency measures that the refiners or upstream producers can put in place to lower the carbon intensity of their fuels, in addition to a range of other compliance flexibilities.
It's built in two parts. There will also be an element in the second phase to deal with solid and gaseous fuels such as natural gas and coal, and elements to see them moving forward and lowering their carbon intensity.
As mentioned by my colleague Matt Jones, there are a number of research and development initiatives that are designed to support provincial and territorial actions to reduce greenhouse gas emissions and spur clean growth across several sectors. Those funds are there to help support both the innovation that's needed but also the development of these measures that are needed to help us meet our commitments.
I thank you for your time. I'll turn it over to my colleagues from Natural Resources Canada.
Liberal
Kaili Levesque
Thank you, Mr. Chair.
My name is Kaili Levesque, and I am the senior director of Demand Policy and Analysis in the Office of Energy Efficiency at Natural Resources Canada.
I am pleased to be here this morning at the committee's second meeting on the economic opportunities for energy efficiency and its contributions to the Canadian Paris Climate Change commitments.
I will share the time set aside for us for opening remarks with my colleague Cynthia Handler, who will speak to innovation through research, development and deployment.
I will speak to programming on energy efficiency and low-carbon transportation.
I understand from reviewing the transcripts that last week the Canadian Home Builders' Association and Efficiency Canada both appeared. These are stakeholders that we work and meet with regularly. While it's unfortunate that we couldn't appear on the same day, it's nice to know that they were here and our stakeholders have laid the ground a bit for this.
Speaking of engaging with our stakeholders, on November 1 we will be joining Efficiency Canada and other efficiency leaders from across the country to discuss the enormous potential of energy efficiency as a source for energy savings for Canadians, as well as the economic opportunities that energy efficiency provides in creating jobs, increasing GDP and improving competitiveness.
To set the stage a little bit I would like to briefly tell you about the office of energy efficiency and place our efforts in the context of the government milestones and our efforts to reduce emissions.
The office of energy efficiency, or the OEE as we call it, administers the Energy Efficiency Act and the associated energy efficiency regulations. It provides other programs and information that promote energy efficiency in the major energy-using sectors of the economy. These sectors include residential, commercial, institutional buildings, industry, appliances and equipment, transportation and alternative fuels.
Energy efficiency is an area of shared jurisdiction and shared responsibility, which is why we work closely with all levels of government and the stakeholders. It is not something that any one level of government can do alone. Our activities help address market barriers that prevent investments in cost-saving energy efficiency technologies. We help Canadian consumers and businesses save money, embrace innovation and reduce greenhouse gas emissions.
I won't retread the history put forward by my colleague, Matt, but one thing that NRCan is very proud of in the context of the pan-Canadian framework is that we do play a significant role in the implementation of the PCF, leading or supporting 30 of the 50 initiatives developed under the umbrella. These initiatives span areas including clean electricity, the deployment of electric vehicle infrastructure, forests, adaptation, clean technology and innovation and, of course, energy efficiency. Energy efficiency itself is a critical component of the PCF. More than a third of estimated GHG emissions reductions are expected to come from efficiency measures.
Since the launch of the PCF in 2016, we've moved from commitment to implementation mode. Funding has been mobilized. Regulations to cut emissions have been drafted and consulted on. New policies and programs to build resilience, support clean tech and reduce emissions have been developed and are being implemented. We are making progress on all fronts. This is documented in the publicly released synthesis reports on the implementation of the PCF and also, as Matt alluded to, through the Energy and Mines Ministers' Conference, which is held annually each summer.
Canadians expect action and progress on this front. They care about the environment and they want us to do our part to help fight climate change. Highlights of the work we've done through consultations include the launch of Energy Star for industry challenge, working in close collaboration with industry, and the updated regulations on equipment standards.
The global demand for cleaner economic growth is opening up trillions of dollars of opportunity around the world, giving Canadian developers of clean solutions access to new markets and creating jobs for Canadians. We want to create the conditions that enable them to capitalize on these opportunities.
We work closely with the International Energy Agency. I'm fortunate enough to chair a committee there and work with colleagues from around the world on these issues. Last year, we actually worked with the IEA to develop a potential report for Canada on where the untapped potential on energy efficiency is. This was reiterated in the energy efficiency market report released last week from the IEA that poses the question, “What would happen if policy makers realised all the economically viable potential for energy efficiency that is available with existing technologies?”
The answer is that a range of direct and indirect economic benefits can flow from improving energy efficiency, including employment, productivity and incomes of individuals and businesses. However, enabling investment in energy efficiency at scale is critical.
Energy efficiency generates savings for Canadians. For example, a better insulated home costs less to heat and cool. More efficient equipment, such as a fridge or an air conditioner, lowers electricity costs. Fuel-efficient vehicles save consumers money at the pump. From 1990 to 2014, energy use in Canada increased by 31%, but would have increased by 55% without energy efficiency measures. This means an avoidance of 90.5 megatonnes of GHG emissions and energy savings of $38.5 billion over the same time period.
Energy efficiency also supports competitiveness and innovation. Companies with lower energy needs have a leg up on the competition as a result of reduced operating costs. Our programs and tools, such as the promotion of the ISO 50001 international standard, the superior energy performance program, and the Energy Star for industry, help businesses track, analyze and improve their energy efficiency.
Energy efficiency standards can also drive the development of innovation that can be marketed in the international energy efficiency marketplace. As committee members may know, the Standing Committee on Environment and Sustainable Development issued a report in June of 2018 entitled “Better Buildings for a Low-Carbon Future”. That report recommended the use of financing tools to accelerate the transition to more efficient existing buildings.
Given that 75% of Canada's current stock of homes and buildings will be standing in 2030, deep building retrofits will be crucial to achieving our GHG emissions reductions targets and facilitating Canada's transition to a low-carbon economy. However, federal investment and interventions are not enough on their own to meet our energy efficiency goals. We need to leverage the untapped private sector capital potential and further cultivate Canada's retrofit economy to reduce emissions from existing buildings.
Retrofits can offer broad gains and a strong return on investment to stakeholders. However, barriers and challenges are currently preventing more meaningful take-up from financial lenders, leading to a lack of confidence and risk aversion on the part of lenders. In its fall interim report, the expert panel on sustainable finance identified retrofits as a key theme, an opportunity for growing a sustainable finance sector in Canada. The panel observed that a national investment road map, supported by a national institution that would source high-potential projects, engage capital providers and facilitate cross-sectoral collaboration, will be an important enabler.
Quite simply, we have to shift from seeing energy efficiency only in terms of reducing our demand for energy, and wake up to its potential to deliver concrete economic and social benefits. That's why we're developing new building codes and standardizing rating systems for the energy efficiency of buildings. We're investing in research that will produce the high-efficient building technologies of tomorrow.
We are lucky here in Canada. We have world-class energy assets and a vision for our energy future. With that comes an enormous responsibility to emphasize the importance of being efficient with these resources as well.
We also work in the area of transportation at all levels of government and industry. We have worked collaboratively to improve energy efficiency and improve GHG reductions in the transportation sector, where efficiency has improved by 36% since 1990, saving $17.9 billion in total by 2019.
With that, I will turn it over to my colleague Cynthia Handler—I am mindful of the time I have been allotted—to speak more broadly about efforts in innovation and clean technology.
Cynthia Handler Director, Office of Energy Research and Development, Energy End-Use, Department of Natural Resources
Thanks, Kaili.
As committee members know, clean technology and innovation make up a pillar of the pan-Canadian framework. Investing in clean technology innovation amplifies carbon pricing signals, enables smarter regulations and drives improved performance from technologies supported by deployment programs. In short, innovation redefines what's possible and lowers the cost of adoption for Canadian businesses and households.
To drive emerging technologies from the lab to the market, NRCan is investing across the energy and natural resource sectors. Budget 2017 funded seven program streams focused in whole or in part on clean technology innovation. This includes the energy innovation program, which is funding research, development and small-scale demonstrations, both those conducted by federal labs and research centres as well as external organizations. Currently we're supporting a wide range of projects, including renewables, smart grids, energy efficient buildings, vehicles, and carbon capture, use and storage.
In addition, four of NRCan's five green infrastructure programs include a demonstration component that funds innovative clean energy technologies to support mitigation efforts. This includes the smart grid demonstration program, the clean energy for rural and remote communities program, the electric vehicle infrastructure demonstration program and the energy efficient buildings program.
Budget 2017 also established the clean growth program, which is providing $155 million over four years for industry-led projects across the natural resources sector in partnership with provinces and territories. This program will better support small and medium-sized enterprises by allowing them to leverage the expertise and resources of the federal laboratories. We believe that by coordinating these investments we're maximizing the impact, further accelerating technological innovation and increasing the odds of success for these projects.
Overall through these programs, we're parallelling efforts internationally through Mission Innovation, a coalition of 22 countries as well as the European Union, which is dedicated to accelerating breakthroughs in clean energy technology.
Why do we do all of this? Because investments in innovation drive both environmental performance and economic competitiveness.
In short, the emissions reductions are driven by demonstration projects that validate new technologies. The additional reductions occur as projects are replicated and commercialized in Canada and around the world. These projects generate significant economic benefits. For example, the Conference Board of Canada found that $1.6 billion invested by Natural Resources Canada in energy technology leveraged $4.3 billion of investment from partners, increased household—
Liberal
Director, Office of Energy Research and Development, Energy End-Use, Department of Natural Resources
—and business income by $5.6 billion and created 58,700 job-years of employment.
I will stop there.
Liberal
TJ Harvey Liberal Tobique—Mactaquac, NB
I guess my first question is for all of you. Your testimony is very relevant and very in line with what we've been hearing throughout this study so far.
I will start with you, Ms. Levesque, and then maybe give all of you the opportunity to chime in.
In going forward, how do you feel the federal government can best take steps to increase funding and programming for energy efficiency and recognize the opportunities as we're beholden to do?
Kaili Levesque
Thank you very much for the question. It's something that I spend a lot of time thinking about.
I mentioned the work we did last year with the IEA, the International Energy Agency, in looking at our potential through 2050. The IEA concluded that the buildings in Canada have the most untapped potential for further lowering greenhouse gas emissions beyond what's already being pursued in looking at the existing framework and going beyond.
That's greater than any other sector in Canada, including transportation and industry, but industry is a close second, particularly when we're looking at resource industries or extractive industries as a source. Canada could lower GHG emission intensity in commercial buildings by 60% by 2050 if all currently available policy tools and technologies were applied, including those focusing on motivating retrofits. We've seen significant returns already—by 23% in this space—but we know there's a significant gap yet to be filled. It's buildings first and industry second, and transportation follows as a close third.
Assistant Deputy Minister, Pan-Canadian Framework Implementation Office, Department of the Environment
I'll just add, very quickly, that I agree that the building stock is particularly important. Certainly, the code is related to new buildings. Given the long-lived potential of all the buildings once constructed, applying the logic of “when you're in a hole, step one is to stop digging,” we can start building buildings that are much more energy efficient. Those technologies exists. That ability exists. It's really just a matter of mainstreaming their application. That's something that I'm quite optimistic about.
In terms of generating longer-term emission reductions, they won't generate significant emission reductions prior to 2030, but have considerable potential to drive deeper reductions in the longer term.
We're trying this collection of policies through the pan-Canadian framework. We've tried to focus both on things that can drive near-term reduction and on things like building codes, equipment standards and other things that can provide deeper reductions in the longer term.
Associate Assistant Deputy Minister, Environmental Protection Branch, Department of the Environment
I would just echo the point about the further reductions that can happen in the transportation sector. As I mentioned, the way in which we regulate in that space is to look at model years for the vehicles you purchase, making them more and more efficient. We don't regulate the efficiency, but that's what the net outcome of the regulations is, in terms of vehicles consuming less fuel and emitting less greenhouse gases.
Then we see the uptake of new technologies—things like zero-emissions vehicles and the role they play there. That will continue to play an important role as we move forward.
Finally, I would mention the importance of a clean fuel standard, which helps to drive down the carbon intensity based on the life cycle. I know that's a complicated statement, but essentially what that means is that, from using or extracting the elements that form the fuel to the way in which you combust it, if you can make that more efficient, it drives down the carbon intensity and results in fewer greenhouse gases.
The design of that will be an important element, and it will influence the emissions from all sectors of the economy because it's related to fuels that you use in your homes, in industry, in your cars and in business. It will be an important tool moving forward. It will be a way to help move forward with continued reductions in that 2030 time frame as well.
Liberal
TJ Harvey Liberal Tobique—Mactaquac, NB
Mr. Jones, you talked about building standards and how we move forward in that direction. Do you feel that the most viable first step is a focus on government-owned infrastructure or privately-owned infrastructure, or both?
I'm wondering especially about housing developments and residential construction, so that we can get to where we need to go as quickly as possible.
Assistant Deputy Minister, Pan-Canadian Framework Implementation Office, Department of the Environment
I'll say a few quick words and then turn to the real experts to my right.
Liberal
Assistant Deputy Minister, Pan-Canadian Framework Implementation Office, Department of the Environment
I mentioned it, yes. I did want to emphasize its importance, and I think it's also worth noting that there are international comparisons that are helpful in this regard. For example, I know that a number of Scandinavian countries with similar climates consume less energy per square foot.
I think there is significant potential in the commercial, retail and residential sectors, and certainly on the industrial side of things. I'll turn to my colleagues to speak to whether there is greater potential in one area or another, but there is similarly significant potential in each of those areas.
Kaili Levesque
This is actually an area of collaboration. We talk about shared jurisdiction. This is shared with our colleagues at the Treasury Board Secretariat, whom I believe have appeared either before this committee or another on the greening of government operations. I was just looking for the specific number. NRCan is responsible for the federal buildings initiative. We work with current building owners—there are land holdings from coast to coast to coast—and try to green these operations at the point.... Helen mentioned life cycle. Buildings have a life cycle as well.
When you're getting to the point of needing a retrofit of a building, or a full-scale gutting in some cases, as we move to further densification in urban areas, there has been a commitment made through the greening government strategy to reduce our carbon footprint by 80% by 2050. That's the long-term piece, but we're also taking immediate measures through the federal buildings initiative, as well as on the fleet side, by greening the fleet of ministerial vehicles as well as those for deputy ministers.
Thank you.
Conservative
Shannon Stubbs Conservative Lakeland, AB
Thanks, Mr. Chair, and thank you, everybody, for being here today.
I just have some questions for you around the various competitiveness analyses going on related to the carbon tax. No other top 10 oil-producing country in the world except Canada is imposing a carbon tax on itself, aside from China, which is considering a cap-and-trade system in the next year. Given that, I understand there's a phase-three competitive analysis going on about the carbon tax, particularly related to emissions-intensive, trade-exposed sectors, which obviously would include oil and gas.
NRCan has also launched the study on competitiveness in the oil and gas industry, saying, “investment in Canada's oil and gas industry has fallen by over 50%,” while investment has recovered from the low point. It's not expected to reach previous levels any time soon.
I just wonder, are all of these efforts on the competitiveness analysis of the carbon tax on the energy sector being coordinated? Are all departments involved?
Judy Meltzer Director General, Carbon Pricing Bureau, Department of the Environment
Hi, I'm Judy Meltzer, from Environment and Climate Change Canada, and I'll give you the first part of the response and then turn to my colleagues to add.
Thank you for that question. The short answer is yes, insofar as there is close collaboration and folks across the departments who are working on this are working together. I will flag that while competitiveness is a broad theme that cuts across these various pieces of analysis that are under way, there are some important differences, which is why they're being done in different ways.
The one I'll speak to is with respect to the federal carbon pollution pricing system and the approaches, as you said, for the big, heavy industry—the output-based pricing system that we're still in the process of developing. When you reference the phase three analysis, what you're referring to is the analysis that's still very much under way. As you've said, we've done a three-phase systematic process for those sectors that will be part of the federal output-based pricing system.
The first phase is looking at a static analysis, looking at historical data. There are some commonly used metrics to assess competitiveness. When we talk competitiveness in terms of pollution pricing, what we're concerned with is the risk of carbon leakage, and how it may impact a shift of economic activity to other jurisdictions with different types of polices.
The first phase is based on historical data, static testing. The second phase is taking the same metrics—and these are used in other systems, including Alberta's—and looking at it through the dynamic model we have at Environment and Climate Change Canada, which is used and referenced. We have a third phase under way to recognize that there are additional considerations. We are looking to industry to provide additional considerations, whether it's to their particular facilities, their competitors in other jurisdictions or the impact of indirect inputs, etc.
We're in that process, but that's very much part of feeding into the design of the output-based pricing system regulations. For that reason, this is a very particular analysis.
Conservative
Shannon Stubbs Conservative Lakeland, AB
Is that connected or integrated with the competitiveness study being done—I think by Finance or is it by NRCan—on the oil and gas sector? When can Canadians expect the conclusions?
Director General, Carbon Pricing Bureau, Department of the Environment
I'll finish on my point and then turn to that. It's related insofar as some of the themes are common, but remember, in our case, we're looking very specifically at the risks to carbon leakage and competitiveness that result from the application of the pollution price.
There is of course a wide range of factors that influence competitiveness impacts on a given sector. For these particular regulations, we're focusing very specifically, using these pretty consistent metrics that are used when you develop other similar systems, to try to distill the impact of that carbon pollution price signal. That's where it's a little more focused than, for example, the broader analysis that I'll let my NRCan colleagues speak to.
In our case, we're the next big milestone in terms of information. I think there have been ongoing updates, including recently this past summer, in terms of where we're at. The next big milestone I would flag is that we will be releasing draft regulations for the output-based pricing system that will include the sector-specific output-based standards, at least the proposed ones.
Director General, Carbon Pricing Bureau, Department of the Environment
It will be later this fall, and certainly before the new year. Again, those will be draft and we will be continuing to consult. We have a pretty intensive systematic consultation going on with industry, the provinces and territories through 14-plus working groups, so that's still very much under way.