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Shake Up The Establishment’s Feedback on CER Public Update

Updated: Apr 2

On February 16th, the Government of Canada released an update on the Clean Electricity Regulations (CER) and opened up a public commentary period which concluded on March 15th, 2024. This update follows the draft CER, originally published on August, 19th, 2023, on which Shake Up The Establishment (SUTE) provided feedback.

WHAT do I need to know about the CER?

  • The CER is an integral aspect of Canada’s 2030 Emissions Reduction Plan which is concerned with allowing so-called Canada to reach net-zero emissions by 2050 while also reducing emissions by 40-45% below 2005 levels by 2030 (1). This is in response to the urgent global need to address the climate crisis.

  •  The CER aims to pursue a low-carbon economy through responding to global demands for a clean, reliable, and affordable electricity grid across so-called Canada while providing competitive economic opportunities to industries (1).

  •  The CER is developed through three core principles (1):

    • Utilizing significant greenhouse gas reductions to facilitate and assist the transition toward a net-zero electricity grid.

    • Sustaining electricity affordability for Canadians and businesses across both provinces and territories.

    • Allowing provinces and territories to retain grid reliability as electricity needs grow in so-called Canada.

WHY is policy intervention important for the development of the CER?

  • The Government of Canada must pursue a CER that is well-rounded and just — centring the wellbeing of structurally vulnerable populations, historically & presently marginalized groups, and underserved communities over industries in the design of this draft.

  • When developing environmental and climate policies, we have continuously seen the desires of fossil fuel companies prioritized over the wellbeing of underserved communities across so-called Canada. This consequently and specifically undermines the effectiveness of the CER by delaying transitions to cleaner and renewable energy sources while also perpetuating inequities in our neighbourhoods by allowing these fossil-fuel industries to continue business-as-usual.

  • The consideration and incorporation of diverse feedback into the regulations, informed by knowledges and worldviews outside of our Western policy-making practices, is crucial if we are to pursue an emissions reduction plan that effectively considers “the most vulnerable of our population” (2).

Executive Summary of Shake Up The Establishment's Feedback

Shake Up The Establishment has three key areas of concern which are further expanded upon throughout the policy brief, that we feel need to be addressed to ensure these regulations are sufficient in supporting a robust response to the climate and environmental crises of today.

  1. Currently proposed tools (i.e. offsets, pooling, and carbon capture/storage, etc.) create loopholes for fossil fuel facilities to continue emitting at extreme levels, rather than enforcing actual emissions reductions.

  2. Allowing natural gas-fired units that are unable to commission by January 1, 2025, to take advantage of the EoPL provisions, while also extending the intended EoPL.

  3. The potential abuse of decision-making power, should systems operators be given authority over allowing exemptions from the emissions limit during emergencies.

Shake Up The Establishment's Key Recommendations

  1. We ask that the government maintains its original stance and not allow fossil fuel companies to use offsets to counterbalance their emissions, when their emissions exceed the limit.

  2.  We cannot rely on greenwashed technologies like carbon capture and storage; we need the government to invest in lower/non-emitting energy and electricity sources.

  3.  The end-of-prescribed-life cannot be extended– in fact, it truly should be shortened.

  4. The government must not leave decision-making responsibility about what constitutes “an emergency” in the hands of systems operators alone.


Policy Brief: Feedback on the Clean Electricity Regulations Update

By Shake Up The Establishment, March 15th, 2024

Authors: Anna Huschka (she/her) & Zeina Seaifan (she/her)

Contributors: Manvi Bhalla (she/her)

SUTE's Clean Electricity Reg Update Submission_Mar 14 2024
Download PDF • 271KB

For any thoughts or feedback you wish to share, please contact:



  1. Canada E and CC. Clean Electricity Regulations [Internet]. 2022 [cited 2024 Mar 18]. Available from:

  2. Government of Canada PW and GSC. Canada Gazette, Part 1, Volume 1, Number 1: Clean Electricity Regulations [Internet]. Government of Canada, Public Works and Government Services Canada, Integrated Services Branch, Canada Gazette; 1841 [cited 2024 Mar 18]. Available from:


Positionality Statement:

Hello/Bonjour! My name is Zeina Seaifan and my pronouns are she/her/elle. Presently, I reside on the traditional and treaty territory of the Huron-Wendat, Haudenosaunee and the Mississaugas of Scugog Island First Nation (currently known as “Ajax, Ontario”). I also want to recognize the stolen labour of marginalized peoples, including but not limited to 2SLGBTQIA+, Black, Indigenous, and other communities of colour who have been enslaved and displaced on this same territory and whose contributions to Canada as a settler state are often overlooked. I would finally like to acknowledge the immense privilege I have been able to have in providing this feedback on parochial government policies that have historically and presently continue to harm both people and the planet. I hope this feedback encourages the government to pursue intersectional and just policies that consider and prioritize the needs of the many underserved communities across so-called Canada.

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