Dear Prime Minister Carney,
The Canadian Gas Association (CGA) and its members congratulate you on your recent electoral victory, and we look forward to working with your new government. On that point, we are hereby requesting an early opportunity for our Board members to meet with you to outline the Canadian natural gas energy advantage and how we can use it to help deliver on the Canada Strong agenda.
The CGA represents the regulated domestic natural gas energy delivery industry, supplying affordable, reliable energy to over 20 million Canadians, meeting nearly 40% of Canada’s energy needs. Gas energy — natural gas, renewable natural gas (RNG) and hydrogen — isn’t merely another fuel; it underpins the daily life, economic vitality, and resilience of our nation, supporting everything from residential heating and cooking to generating electricity to fuelling vital sectors of our economy such as agriculture, manufacturing, hospitality, transportation and healthcare.
You have reiterated several times your ambition for Canada to become an energy superpower. We believe to achieve it we must show leadership domestically. Gas energy is Canada’s single largest fuel source for home heating, for industrial and manufacturing uses, and for the building sector. Customers choose gas because it offers a significant competitive advantage: keeping energy costs low while being incredibly reliable. This advantage delivers higher productivity and more jobs. Canada could be doing much, much more with its natural gas advantage, but opportunities are passing us by. We believe a new government can change that. We offer three consumer-centred priorities that can help align your ambition of being an energy superpower with what the market and investors need.
1. Signal the critical role of gas infrastructure to ensure reliability and affordability:
Your government has been clear about a Canada-centered energy approach. That turns on the reliability and resiliency of our domestic energy system. You can set a clear, consumer-focused direction in energy policy by prioritizing reliability and resiliency, starting with formal recognition of gas energy infrastructure as critical infrastructure in Canada. Clear metrics should be a part of a decision matrix around energy policy to avoid the kinds of challenges we see energy systems facing elsewhere in the world.
Spanning over 600,000 km, our industry’s infrastructure delivers natural gas, renewable natural gas, and offers a platform for greater deployment of hydrogen across eight provinces and one territory. The reliability and resiliency are exceptional: Gas customers collectively experience service interruptions that are 200 times shorter in duration than those of electric customers. This advantage is critical during severe weather events, such as the January 2024 polar vortex, when gas systems delivered nearly ten times the energy that Alberta’s electricity system provided at peak demand. This support mattered not just for direct gas delivery to homes and businesses, but also for the electric system that relies on gas to maintain its operations.
Our extensive gas infrastructure also boasts significant storage capabilities. A total of just under one trillion cubic feet of gas (1 TCF), or approximately 1/3 of our annual gas demand in Canada, can be stored. This is a phenomenal feature of Canada’s gas infrastructure — equivalent to over 21 billion home electric battery storage systems — providing essential stability and affordability even during extreme weather.
The energy and capacity characteristics of the system are not well understood and are often overlooked, particularly when discussing domestic energy policy with a focus on expanding our electric systems. The gas infrastructure in Canada is a critical component that supports the expansion of electric infrastructure and helps manage the most challenging aspect of energy delivery: peak energy use. Yet, policy that constrains the ongoing investment in the gas system may have negative economic and physical impacts on both the gas and electric delivery systems, at a time when they are critical to our overall wellbeing and the evolution of new innovative ideas and technologies. Developing polices that embed a critical long-term role for gas infrastructure will be important as we balance economic opportunity and reduce emissions.
2. Simplifying the 2025 National Building Code to enable affordably fuelled homes:
Your pledge to build twice as many homes annually to address housing affordability responds to a critical and urgent need. However, current proposals within the National Building Code introduce restrictive and expensive greenhouse gas (GHG) emission tiers, effectively banning gas energy (in several scenarios). Such bans are very short-sighted. Natural gas plays a major role in ensuring affordable home heating across Canada, given the utilization of existing infrastructure and access to Canada’s world class natural gas production. Natural gas and gas delivery infrastructure also play a critical role in emission reduction through the adoption of lower-carbon fuels, such as RNG, and the deployment of innovative technologies and energy efficiency measures. Critically, and what is often misunderstood, is that when the gas system can expand alongside the electric system, it allows for more efficient expansion of the electric system, ensuring the electric system does not have to take on the most challenging and expensive part of any energy system, that of heating load, in particular peak winter heating load, which the electric system has not been designed to do. Such unintended consequences arise from forcing the electric system to take on the full capacity capabilities of the gas system, where the more efficient approach would be to leverage the strengths of both systems. Building codes should prioritize building safe, efficient, and affordable homes, particularly during a housing crisis. Removing building code barriers that increase construction costs and restrict energy choices — and aligning codes with practical realities rather than rigid emissions tiers — will help preserve energy options, lower housing costs, and open the door to solutions that build on the strengths of both gas and electric systems to provide practical solutions to Canada’s housing affordability crisis.
3. Modernizing Measurement Canada’s regulatory framework to fast-track innovation:
Your government is committed to innovation in energy. To deliver on this commitment, Measurement Canada’s regulatory framework needs to be updated. The Electricity and Gas Inspection Act, which facilitates the introduction of new technologies to the market, has approval timelines for new gas technologies averaging 478 days, compared to just 140 days for electricity technologies. This delays innovation from coming to market.
By streamlining approval processes, adopting international standards, and implementing a risk-based regulatory approach, Canada can accelerate the introduction of technologies which enhance energy market access, reduce costs, deliver environmental benefits, and help consumers and businesses.
CGA is committed to working closely with your government to enhance the affordability, reliability, and acceptability of our energy system for all Canadians. We look forward to engaging with you and your cabinet to support Canada’s continued prosperity and your ambitious vision for our nation’s energy future.
Respectfully,
Roger Dall’Antonia
President and CEO, FortisBC Energy Inc.
Chair, Canadian Gas Association
Timothy M. Egan
President and CEO, Canadian Gas Association
Chair, NGIF Capital Corporation