Thank you, Mr. Chair.
I would also like to acknowledge that we're gathered on the territory of the Anishinabe Algonquin people.
Joining me, as the chair said, is my colleague Terry Toner, who is a senior fellow with Electricity Canada and joins us after 42 years at Nova Scotia Power.
We're an association whose members generate, transmit and distribute electricity in every province and territory. We do it with all kinds of power, and we have that relationship with the customer right up to the meter on the side of their house.
The next 20 years are going to be about how electricity drives emissions reductions across the economy. All told, as Fernando said, we're looking at needing two to three times as much power as we produce now by 2050. What will it take to do that? It's going to take all of the above. We're going to need more power of all kinds, more hydro, more renewables, more nuclear and more transmission and upgrades to the distribution system with innovative solutions.
How are we going to do it? To be successful, we have to get moving quickly, and we need the right mix of policy and regulatory tools to get building. The measures that were introduced in budget 2023 and in the fall economic statement in 2022 are a big step in the right direction and are part of the response. They are a recognition that there's a federal role to play in this. However, there's more work to be done to be sure these measures are as clear and predictable as promised, so that our members can get moving.
Let's talk a little bit about the investment tax credits. I will echo some of the things my colleagues have spoken about. We want to flag a couple of issues. We've made these comments to finance.
The first is that we think Canada should remove the jurisdictional net-zero requirement for the clean electricity investment tax credit. It risks slowing the access to supports for projects that are able to get ready today for reasons that are outside of proponents' control. If a project is clean and meets the work terms, it should be getting going.
Second, the government should ensure that there is equal treatment for equal technologies between the clean electricity and clean technology ITCs, with an aim to harmonize the level of support between the two.
Third, the clean electricity ITC supports transmission between provinces—interprovincial—but we think there's a need, as we build out, for additional transmission within provinces and there's a role for the ITC to include focused transmission within the provinces—intraprovincial—as well for key distribution improvements that allow for the modernization of the grid.
Finally, we want to make sure that worthwhile projects and projects that meet the definitions don't lose out on the value of the ITC for reasons beyond their control. The apprenticeship requirements under the labour provisions are an example of that. Canada's tough labour market means that there just might not be enough apprentices available—period. We recommend, as in the U.S. under the IRA, that there be a good-faith effort exemption to allow for this.
In terms of certainty, the budget talked about the role of carbon contracts for difference, which are a tool that offers policy certainty for investments over the long term, minimizing the “stroke of the pen” risk of changes in the future. It's important that those get moving very quickly to get things going.
Finally, after the financing, how do you actually get building on things? A few years ago, the World Bank ranked Canada 64th in terms of ease of spending and obtaining construction permits. This past year, we had Dunsky Energy + Climate Advisors interview stakeholders from across the country to identify barriers to getting things built. They found five.
The first is that the planning process isn't aligned with the challenges at hand. The second is that there are overlapping regulatory and approval processes. There's also limited capacity with approval bodies and an ongoing shortage of skilled labour and access to capital.
To address these, we suggest that the government move forward with the “one project, one approval” framework as described in the budget, coordinate federal project permitting within a central government agency and not across however many budgets there are, and build regulatory capacity to deliver on net-zero goals.
Penultimately, I'd be remiss if I didn't quickly discuss the draft clean electricity regulations, which sit in the background as we think about building. As you know, we're still in the midst of the public comment period, and Electricity Canada will be submitting detailed comments. However, just at a high level, it's worth underlining that our members have not found that the regulations as drafted will be workable. There will need to be much more flexibility in the final regulations to allow for the affordable and reliable operation of the grid. Obviously, the draft isn't final, so there's work for us to do.
I'll conclude just by emphasizing that, in August, Minister Wilkinson announced the need for a Canadian electricity strategy. When our members are deciding to build a project, they look at everything, what's involved in the whole picture, as Peter talked about at the beginning. It's important, as we think about the government tools, that we take a similar approach and really focus on making sure we build a strategy that mixes all of these things so that when billions of dollars are invested in projects that could last half a century, we are a good fit there.
Thank you, Chair.