Improving the flexibility of the Clean Electricity Regulations-Pembina Response to CER Update

If offsets are instead indexed to the carbon price then, on the day the CER is published, the federal government needs to provide further clarity on their intentions for the output-based pricing system and industrial carbon price past 2030. [...] Pembina Institute Improving the flexibility of the Clean Electricity Regulations | 5 Inclusion of net-exporting cogeneration Cogeneration units will continue to be subject to the emissions requirements of the regulation in the years that they have net exports. [...] This is due largely to the fact that the EoPL locks in emissions for a given period, and the regulations apply to a relatively large fleet of fossil fuel generating capacity that is dispersed unevenly across the country. [...] The facility owner must demonstrate that the best alternative to the proposed approach (the project scenario) for the existing facility is not economically or technically feasible or cannot be implemented in time to allow Pembina Institute Improving the flexibility of the Clean Electricity Regulations | 7 the facility to maintain compliance with the Clean Electricity Regulations. [...] The timeline starts at the date of the application for deviation and ends at the date that compliance is achieved.