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ENEV - Standing Committee

Energy, the Environment and Natural Resources


THE STANDING SENATE COMMITTEE ON ENERGY, THE ENVIRONMENT AND NATURAL RESOURCES

EVIDENCE


OTTAWA, Thursday, April 16, 2026

The Standing Senate Committee on Energy, the Environment and Natural Resources met with videoconference this day at 8 a.m. [ET] to study Bill S-4, An Act to amend the Energy Efficiency Act; and, in camera, to examine and report on such issues as may arise from time to time relating to energy, the environment, natural resources and climate change.

Senator Joan Kingston (Chair) in the chair.

[English]

The Chair: Good morning, colleagues. Before we begin, I would like to ask all senators to consult the cards on the table for guidelines to prevent audio feedback incidents. Make sure your earpiece is away from all microphones at all times. Do not touch the microphone. Activation and deactivation will be managed by the console operator. Finally, please avoid handling your earpiece while your microphone is on. Earpieces should either remain on the ear or be placed on the designated sticker at each seat. Thank you for that.

I would like to begin by acknowledging that the land on which we gather is the traditional, ancestral and unceded territory of the Anishinaabe Algonquin people.

I am Joan Kingston, and I am the Chair of the Standing Senate Committee on Energy, the Environment and Natural Resources. Now I am going to ask my colleagues to introduce themselves.

Senator Fridhandler: Daryl Fridhandler, Alberta.

Senator D. M. Wells: David Wells, Newfoundland and Labrador.

[Translation]

Senator Arnold: Good morning. Dawn Arnold, New Brunswick.

[English]

Senator McCallum: Mary Jane McCallum, Treaty 10, Manitoba region.

[Translation]

Senator Youance: Suze Youance, Quebec.

Senator Aucoin: Réjean Aucoin, Nova Scotia.

Senator Verner: Josée Verner, Quebec.

[English]

The Chair: Thank you. I would like to welcome everybody here today as well as those listening online on sencanada.ca.

Today, pursuant to the order of reference received from the Senate on March 11, 2026, we are pursuing our study of Bill S-4, An Act to amend the Energy Efficiency Act.

We are pleased to welcome our panel today, all by video conference: From the Canadian Institute of Plumbing and Heating, Olivia Auriat, Director of Advocacy; from Electro-Federation Canada, Carol McGlogan, President and Chief Executive Officer; and from the Heating, Refrigeration and Air Conditioning Institute of Canada, Perry Chao, Director, Regulatory Affairs.

Thank you all for accepting our invitation and for being here this morning. We’re ready to hear your opening remarks, and we’ll start with Ms. Auriat.

Olivia Auriat, Director of Advocacy, Canadian Institute of Plumbing and Heating: Thank you, Madam Chair. I would like to thank all members of the committee for inviting me to appear before you today on behalf of the Canadian Institute of Plumbing and Heating and our membership about Bill S-4, An Act to amend the Energy Efficiency Act.

I am Olivia Auriat, and I’m the Director of Advocacy at the Canadian Institute of Plumbing and Heating, or CIPH, which has served as the indispensable voice for Canada’s essential and thriving plumbing and heating community for over 90 years.

Energy efficiency is a key priority for our membership, and we agree that it is time to update the act to reflect the rapidly evolving modern economy. However, our members have concerns about several parts of this bill.

I would like to thank the officials at Natural Resources Canada, or NRCan, for facilitating the recent round table with our members, which allowed us to highlight the areas of concern that I’ll be sharing with you today.

In its current form, Bill S-4 would provide NRCan with authority to set standards that go beyond what is permitted or required in other jurisdictions, and we are concerned that the bill is giving the minister unfettered powers without consultation or notice.

By broadening the definition of an “energy efficiency standard,” the bill as drafted gives the department authority to regulate product attributes, such as durability and interoperability, that may not directly relate to energy efficiency.

Our members are also alarmed about the bill’s broadened requirements for the electronic collection of data and the potential lack of protection for proprietary information that is shared with government.

Harmonization and alignment on standards across the North American supply chain is a major priority for our membership. Any divergence from U.S. Department of Energy requirements or established international approaches could create unnecessary complexity for manufacturers operating in the highly integrated North American market.

These changes could run counter to the stated objectives of the Canada-United States-Mexico Agreement, or CUSMA, to promote regulatory cooperation across the continent and avoid unnecessary barriers to trade. This non-alignment has the potential to increase costs for our members and, therefore, all Canadians at a time when our country is facing an affordability crisis and housing starts are already slowing.

We urge the committee and the Senate to consider the costs of non-alignment for Canadian businesses and our country at this precarious time for our economy.

We support this bill and its stated aims of modernizing energy efficiency regulations and encouraging innovation through new tools such as the regulatory sandbox.

CIPH and our membership welcome the opportunity to work with this committee, all senators and the department to ensure that this bill and the associated regulations move Canada’s energy efficiency regulatory regime into the 21st century without creating unnecessary complexity and regulatory non-alignment for industries, like our members, who are committed to energy efficiency.

I thank you for your time.

The Chair: Thank you, Ms. Auriat.

Now we’ll move to Ms. McGlogan.

Carol McGlogan, President and Chief Executive Officer, Electro-Federation Canada: Good morning, chair and members of the committee. Thank you for the opportunity to appear before you today.

My name is Carol McGlogan, and I am speaking on behalf of Electro-Federation Canada, or EFC. EFC represents more than 230 companies across Canada that manufacture and distribute the electrical and automation technologies that power our economy, from transformers and EV chargers to smart buildings and grid infrastructure.

We support the intent of Bill S-4. Energy efficiency is essential to affordability, competitiveness, grid reliability and Canada’s transition to a low-carbon economy. And in the context of electrification, it costs less than half to save a watt versus to build a watt of electricity.

However, we would like to highlight a few targeted improvements to strengthen the bill and avoid unintended consequences.

First, we strongly support modernized enforcement. Stronger tools, such as updated fines, administrative monetary penalties and expanded inspection authorities, are necessary, particularly to address non-compliant offshore sellers and online marketplaces that undermine Canadians.

We also welcome the expanded definition of “dealer” to include online sellers. This is a critical update.

However, enforcement must be proportionate. As currently written, the bill may limit the ability of companies to rely on due diligence as a defence, even in cases of good faith compliance efforts. Combined with significantly higher penalties, this creates real risk for reputable companies that are already investing heavily in compliance.

We are not asking for weaker enforcement. We are asking for fair enforcement.

Specifically, we recommend: clear criteria for how penalties are determined, explicit recognition of due diligence and corrective action and a structured approach for first-time or low-risk violations. This will ensure enforcement targets bad actors, not companies making honest, correctable mistakes.

Second, Bill S-4 expands the definition of “energy efficiency standard” in important ways. We agree that energy efficiency today is about products and systems and how they work together to manage demand and support the grid. However, the bill introduces broad new authorities that could unintentionally lead to regulatory overreach.

Provisions referencing system design, technological composition and the ability to regulate any product or system raises concerns that regulations could begin prescribing specific technical solutions, which would be problematic.

To provide regulatory clarity, we require further transparency on the intended scope of systems and limits of authorities. And we recommend that regulation should focus on outcomes, such as energy savings and system performance, not on selecting specific technologies.

We also have concerns about expanded data reporting powers, particularly regarding information collected from smart devices. Clear limits are needed to ensure proportionality and protect commercially sensitive information.

Finally, we recommend that clause 2(2)(b) align with the legislative summary by referencing the “cooperation with other energy-using products” rather than use the term “interoperability.” This will help preserve flexibility and innovation while still enabling system-level performance.

Third, we support the inclusion of a regulatory sandbox. This is a positive step that can help bring innovative technologies to market faster, support Canadian competitiveness and attract investment. To be effective, the sandbox must include strong protections for confidential business information.

We also want to emphasize that industry needs realistic implementation timelines.

For most regulatory changes, manufacturers require approximately 18 months — not 6 — to redesign products, adjust supply chains, complete testing and ensure compliance.

Finally, alignment is critical. Labelling and efficiency requirements should be harmonized across federal and provincial jurisdictions, which supports the intent of the bill to foster interprovincial and international trade.

Diverging requirements increase costs, delay product availability and reduce competitiveness without improving energy outcomes. For example, Amendment 18 on lighting labelling requiring unique Canadian labels goes against the intent of Bill S-4.

We also recommend clarifying the definition of “label,” particularly the use of the term “brand.”

In closing, EFC supports the goals of Bill S-4 to modernize Canada’s energy efficiency framework.

With a few improvements — ensuring proportionate enforcement, clarifying regulatory scope, supporting innovation and aligning requirements — we can achieve a framework that is both effective and practical. We look forward to continuing to work with NRCan and this committee to get this right.

Thank you, and I welcome your questions.

The Chair: Thank you, Ms. McGlogan.

We’ll now go to Mr. Chao.

Perry Chao, Director, Regulatory Affairs, Heating, Refrigeration and Air Conditioning Institute of Canada: Good morning. Thank you, Madam Chair and members of the committee, for the opportunity to appear before you today. I would also like to thank officials at NRCan for their continued and constructive engagement with industry stakeholders throughout the development of Bill S-4.

I am here on behalf of the Heating, Refrigeration and Air Conditioning Institute of Canada, or HRAI. HRAI is the national industry association representing manufacturers, wholesalers, contractors and other professionals in Canada’s heating, ventilation, air conditioning and refrigeration, or HVACR, sector. Our members manufacture, distribute and install systems that heat, cool, ventilate and refrigerate residential, commercial, industrial and institutional buildings.

Our sector is central to Canada’s energy and climate objectives. Buildings account for a significant share of national energy use and greenhouse gas emissions, with space and water heating representing the majority of energy consumption in both residential and commercial buildings. As a result, the technologies and practices adopted by our industry are critical to achieving meaningful reductions in energy use and carbon emissions.

HRAI members are already contributing each time they install high-efficiency equipment like heat pumps, advanced controls and integrated building solutions. Progress is enabled by regulatory frameworks that are clear, practical, aligned with major trading partners and supportive of innovation. Our members stand ready to collaborate with governments to identify practical pathways that improve energy efficiency while maintaining affordability, reliability and consumer choice.

We see Bill S-4 as part of this effort. It has addressed industry concerns about regulatory inflexibility through regulatory sandboxes. It shows a shared understanding of the benefits of lowering energy consumption and energy bills for consumers.

We’re pleased that the bill attempts to reflect modern commercial activity and new business models.

We do expect to share targeted improvements to strengthen the legislation and better align it with established regulatory approaches, particularly those of the United States, which are highly relevant to our integrated North American market.

I’ll list a few examples that may require the committee’s attention. In clause 2, some of the definitions such as “label” or “commercial entity” are different from what is permitted in the United States. Some clarifications may be necessary. If you look at the “commercial entity” definition, you should note that U.S. regulations clearly refer to manufacturers and private labellers, for example. One approach could be to define a primary responsible party to clarify who is responsible for ensuring compliance with energy efficiency standards. Within the term “energy efficiency standard,” you should note that U.S. regulations apply to individual products and not integrated systems.

In proposed section 2.2, maybe there could be location of language supporting standards that are cost-effective, technologically feasible and aligned with those of Canada’s major trading partners.

In proposed section 6(1)(c), it should be noted that U.S. regulations allow regulators to approve manufacturer alternative test methods without disclosing proprietary software and tools.

In proposed sections 20(1) and 20(3), the committee should note that certain U.S. rules for standards are product-specific and not class-specific.

In updated section 25, relating to the minister’s exemptions, it should be noted that similar U.S. regulations provide specific conditions where an exemption or waiver is available, as well as when the need is shown for that exemption.

We are also aware that here at committee, in discussing paragraph (a) within the definition of “energy efficiency standard,” it was mentioned that warranty considerations were being considered. HRAI would urge caution and robust industry and public consultation on this matter. Product warranties are very carefully developed within the HVACR industry, and the potential impact on consumers and manufacturers can be large.

We do believe these adjustments are practical, consistent with the intent of the legislation, which HRAI supports, and it will help avoid unintended implementation challenges. A detailed written brief will be submitted shortly and translated and shared with the committee to support the committee’s clause-by-clause review.

Thank you for the opportunity to contribute to your study of Bill S-4. We look forward to continuing to work with members, department officials and other stakeholders to advance Canada’s shared energy efficiency and climate objectives.

Thank you for your time. I’m also available for questions if there are any.

The Chair: Thank you to all.

Senator D. M. Wells: Thank you, witnesses, for your presentations.

I have a question for Mr. Chao because I would like to know how it works. For the users of the equipment that your industry association members manufacture, when they are purchased, are they purchased by a lease arrangement or are they purchased outright or is there a long-term plan or is there a volume discount? How is the purchasing done?

Mr. Chao: For a residential system, these purchases happen between the homeowner and a local contractor, installed by certified tradespeople. That contractor makes purchases to wholesalers or distributors. Those wholesalers and distributors will purchase from manufacturers or original equipment manufacturers, or OEMs. There is a supply chain there that is involved in that single transaction to the end-user.

Senator D. M. Wells: Perfect. I understand.

Now I have a question for all of you: For equipment purchases, in particular bulk purchases for an apartment building or condominium or hotel or something like that, if there is a lease-to-own or lease arrangement where there is a long-term or longer-term contract rather than just a specific single purchase, is there a concern that a rule or requirement could change the end-user’s requirement to have certain types of equipment?

I’m thinking of the one change in the bill. I don’t mind “online sellers” being added, but also being added is “commercial entity,” which is obviously not a dealer or an importer or an online seller. It’s the end-user. An end-user could be a commercial entity.

I’m concerned about the changing of the requirements midstream when they already have either a contract to purchase or a longer-term contract to acquire. Is that a concern for any of your members?

Ms. McGlogan: I’ll speak on behalf of EFC. It hasn’t been identified, but what you’re suggesting is the commercial user would also be liable for products that are inappropriately labelled or misrepresented. Is that right?

Senator D. M. Wells: Or if someone buys a piece of equipment that is determined by the unfettered ability of the minister to say this product is no longer acceptable.

Ms. McGlogan: Yes, that would be a concern, especially if they needed to remove that product. Then there would be an additional burden on that particular segment to review specifications in a much more rigorous way. I don’t know that the channel would be able to adapt to that.

Senator D. M. Wells: Okay, thank you. Minister Hodgson said this represents an opportunity for cost savings. Do you see any cost savings for any of your members?

Ms. Auriat: On behalf of CIPH, our members have expressed concerns that this could lead to greater costs if we have non-alignment on regulatory matters and a lot of technical things. There is a specific concern about that. However, a lot of terms are so broad that perhaps there could be cost savings.

Senator D. M. Wells: Anyone else?

Ms. McGlogan: It’s very unclear whether or not there are cost savings. If we are going to be increasing regulations and extending reach, I would say we would imply that there could be some additional costs in doing that.

Senator D. M. Wells: All right. Thanks very much. Thank you, witnesses.

[Translation]

Senator Aucoin: I believe my question is for Ms. Olivia Auriat, but I’m not sure.

Someone talked about intellectual property and exemptions that might be granted by the minister. I believe you mentioned that there were not enough safeguards in the regulations or in the minister’s suggestions for intellectual property to be protected in situations where the minister might intervene.

Can you expand on that?

[English]

Ms. Auriat: Thank you for your question, senator. Our members’ concern is not solely regarding ministerial intervention. It’s around the broader data collection requirements within the bill. There is concern regarding the fact that it’s not specified how intellectual and proprietary commercial information will be fully protected. This is something that concerns our members, especially with regard to competition and the potential mishandling or leaking of information. Our members would like to know more about how their proprietary data will be protected to ensure competitiveness and to ensure safe handling of their data. Really, it’s about wanting to know more about how this data will be collected, properly protected, gathered and then eventually disposed of or managed in line with other government practices.

The concern is just data protection and information protection, both for individual products and also in a larger sense for our industry. Thank you.

[Translation]

Senator Aucoin: Thank you.

My next question is for Mr. Chao.

You talked about several sections of the act that don’t necessarily match up with the definitions or align with the United States. I don’t want any more examples, but what can be done about that? Is it really important to align perfectly with the United States?

[English]

Mr. Chao: Senator, thank you for your question. We do have some proposals that we will be sharing with the committee. In many cases, it would be amendments to specific clauses. In other cases, it may be more difficult because there are practices that simply are not used, specifically for the HVACR industry in the United States. Those situations may be more delicate. Perhaps some regulatory language would be necessary.

We are raising them as issues that should be considered in the full review of the bill. We will have some proposed language to share with the committee. That may be a good use of this process to see if there are some ways of finding the right balance between modernizing our rules while also making sure that we’re not falling out of sync with other jurisdictions.

If I may also comment on your previous question about intellectual property, that is another area this touches upon, where in the United States, there are some types of test procedures that have regulators approving test methods rather than requiring the disclosure of intellectual property. That may be another area where a solution can be found. Thank you for your question.

[Translation]

Senator Aucoin: Thank you.

[English]

Senator Arnold: Thank you all for being here today. I am replacing Senator Coyle, so I am reflecting some of her questions here. It’s good to hear that there is general support for this bill, but I do have a question for Ms. Auriat. You mentioned the round tables. Were you pleased with the engagement that took place, and do you have a sense of confidence that your input will be welcome as this continues on?

Ms. Auriat: Thank you, Senator Arnold. As a graduate of Mount Allison University in your fine area, it’s delightful to see you here today. Our members were really pleased with the engagement and felt that officials heard their concerns. This is another opportunity to share our concerns in another forum. We felt the areas of concern for our members were really listened to, and they really appreciated that engagement. I admit that I am fairly new to CIPH and that happened immediately before I joined, but I know the feedback from our members was they really did feel heard by the department on this matter, and they really did appreciate the engagement. For us, this is just another opportunity to share our concerns, but we have been feeling that the department has been engaging in a productive fashion. Thank you.

Senator Arnold: Thank you. Anyone else on that topic?

Ms. McGlogan: We were approached for a round table. We haven’t been able to schedule it, but we do welcome that opportunity, especially the opportunity to get some of our members who have specific concerns within their specific product categories so that they can share those concerns. We look forward to that opportunity. Thank you.

Mr. Chao: I’ll also take this opportunity to acknowledge the NRCan staff for being available and hosting a webinar for our member companies to discuss this bill.

Senator Arnold: Thank you.

Senator Fridhandler: Ms. McGlogan, you highlighted a concern that I share with you on the strict liability provisions of this legislation and the enforcement. I was also flipping through and I couldn’t find it right now, but I also believe that liability potentially extends to individuals in what we would call piercing the corporate veil if some director or officer knew of the offence. Both of those are fairly significant measures. I’m wondering about the context that your members and any of the other representatives or groups are used to working with.

In the legislation now or in other related legislation that they operate under, do they face strict liability or personal liability, which this legislation seems to institute?

Ms. McGlogan: I can’t answer that question. I would have to get back to you in terms of the extent of liability that our members do face.

The main concern with our membership is that there was conflicting information within the bill itself. One paragraph said that due diligence could be used as a defence, and in another paragraph, it said it could not. Our concern is mainly when a company is making best efforts and following the rules, but if there is a mishap or a mistake, they could face those significant penalties. It’s more about the clarity and the recognition of due diligence that we’re concerned about.

[Translation]

Senator Youance: My question is for Mr. Chao.

You talked about the definitions of “commercial entity” and “dealer.” To what extent does this distinction really cover all players involved in the supply chain? Are there still segments or situations that aren’t captured by the framework set out in Bill S-4?

[English]

Mr. Chao: Senator, thank you for your question.

For the most part, our members were captured by the previous definition because our members would be either the manufacturers who produce the equipment globally or domestically in Canada or the wholesalers who would be purchasing equipment from manufacturers in large quantities and distributing them throughout Canada. For the most part, they were captured in the previous language of the bill.

The explanation we received from officials, I believe, was that it’s meant to capture maybe online purchasers or other non-traditional purchasers. I’d say that for the most part, our members would be traditional players in the market who were captured by the previous language in the legislation.

[Translation]

Senator Youance: You also talked about consultations with Natural Resources Canada, and that seems like a very interesting step. Can you tell us a bit more about those consultations? Since Bill S-4 amends an existing bill, did you talk about the alignment between the new proposals in Bill S-4 and those in the existing act?

I’m particularly interested in your thoughts on the time frame. The existing act provided 120 days for assessments. Is that still appropriate in light of the amendments proposed by Bill S-4?

[English]

Mr. Chao: Senator, thank you for the follow-up.

The conversations or the discussions that were held with NRCan officials were virtual discussions with many members of the association. They provided a thorough and informative review of the proposed legislation. It allowed our members to raise a number of questions.

During those discussions and during the comments from the minister this week, I think officials underlined, at least for our members and the HVACR industry, the importance of reflecting the fact that we operate within a global or North American landscape where producers are producing equipment and having that equipment tested to meet standards internationally and in Canada. The message was sent to us that this is a priority for NRCan and for the department.

On your questions about the timelines, I think we may need a little more time to study those timelines. We will want to make sure that they make sense based on the fact that when equipment is developed, there are significant timelines. I think some of the other panellists mentioned that equipment may take 12 to 18 months before it is ready for the market.

On that question, I think some additional review by our members would be needed.

Senator McCallum: Thank you to the presenters for being here.

A discretionary exemption can affect competition if some firms receive relief from regulatory requirements that others must meet.

Are you concerned about the creation of an uneven playing field between firms that compete in the same market? Should special considerations apply to small- and medium-sized businesses that may have less capacity to apply for exemptions?

Ms. Auriat: Thank you for your question, senator.

This is absolutely something that could lead to an unfair competitive landscape if exemptions are applied unevenly. Obviously, big businesses will have more ability and more bandwidth to pursue such regulatory exemptions, and that would be a concern for small- and medium-sized enterprises. We can absolutely see how that would be a concern in terms of competition and in terms of the landscape in general.

Ms. McGlogan: I would agree with Ms. Auriat. Same thing: If there were exemptions, they should apply to all members of the industry in the segment. We’ve got members of extreme variability in size in certain segments. I think about the particular segment of lighting, for example. Any exemption needs to be applied across the board.

Senator McCallum: Mr. Chao, do you have anything to add?

Mr. Chao: I would probably just add that we’re familiar with other exemptions in other areas, such as some Transport Canada exemptions that exist.

From our industry’s perspective, we’re familiar with transparency measures to make sure that information about exemptions is made publicly available and searchable. It would be our expectation that these types of fairness measures would be in place in measures like these.

Senator McCallum: Thank you.

Senator Wilson: First of all, I’d just like to thank the witnesses for their constructive feedback on the bill and their engagement with NRCan to date.

My question is specifically for Ms. McGlogan. It relates to the interoperability provisions. Thank you for your written submission and also for your testimony today.

One of the things that you suggest is that in the legislative summary, they should use the term “cooperation” versus “interoperability.” In your submission, you are recommending that’s the direction that the bill go.

Also, you were talking about the legislation needing to be outcome-focused, and I completely agree with that. To me, cooperation is not the outcome that we’re desiring; the interoperability is the outcome that we’re desiring.

Do you have any suggestions in terms of how we can achieve that outcome with something that is stronger than “cooperation”?

Ms. McGlogan: I think, in this case, the devil could be in the details. As an industry person, when we hear the word “interoperability,” our heads go straight to a common protocol, language and so on, and then you’re almost selecting a technology where you have winners and losers. Meanwhile, there are systems and products that you can use that allow products to work with each other within an ecosystem.

What’s true for one segment of Electro-Federation Canada members, like motors and generators, is not true for the lighting segment and may not be true for products within the grid. This is why we suggest language that is more flexible so that you can get into those particular areas because at the end of the day, we want energy savings that are reliable, and we want to be able to encourage innovation. The tighter you make that language — and interoperability from a technical perspective is quite tight. That’s why we favour “cooperation” versus “interoperability.”

I don’t know if I answered your question, but that’s an industry person looking at those words in particular.

Senator Wilson: Thank you. I think you did answer it. If I understand you correctly, basically what we need to get right is what is meant by “interoperability.” There may be a heated agreement around this. It’s just that it means something different to you than it maybe means to the officials who put this together.

Ms. McGlogan: Also, what is meant by a system? A system is one thing in one segment versus another. I have heard arguments within particular segments of what a system is. It’s a very broad term. There’s concern around those details. We look forward to working with NRCan and having those conversations to finalize those kinds of things.

Senator Wilson: Thank you.

[Translation]

Senator Aucoin: I don’t know who to direct this question to. I’m a little concerned about the exemptions that the minister can grant, and I have two questions about that. First, will the criteria be clear and flexible enough? Second, will the department or the minister be able to react quickly enough to agree to or grant the exemption? If this becomes an administrative burden, it may be difficult for industry to use it. Does anyone want to comment on that?

[English]

Ms. McGlogan: I would agree with you. It’s difficult to answer that broadly because it depends on what kind of exemption you’re looking for, which is probably why you’re hearing some silence within this panel.

The one thing that we did talk about was making sure that exemptions are fair and the fact that if you have industry coming together to deal with an exemption, that takes some time from our side. Of course, you want things to go as quickly as possible. Some things are easier than others. I’m sorry I can’t give you a better answer than that.

Ms. Auriat: As Ms. McGlogan spoke to, similarly I think there are a lot of variables in this question, and I’m sorry I won’t be able to give a more satisfactory answer. It would really depend on the scale of the exemption, if this is the industry coming together to seek an exemption versus an individual player seeking an exemption. All of those things make it something that could be highly variable and very unique from situation to situation.

[Translation]

Senator Aucoin: Thank you.

[English]

Mr. Chao: I’ll just add a little bit. Something that the committee may want to consider is that certain exemptions do exist within other jurisdictions where rather than a minister, for a U.S. example, their Secretary of Energy may make exemptions. You may see either in legislation or regulation or the rules, there could be some sort of limitations that are imposed on that ability to issue exemptions, which may be of interest to the committee. The exemption may be limited to certain areas, and certain information may be required to be presented by the individual issuing the exemption. That is some information that we’ll try to share with the committee in our comments as well.

[Translation]

Senator Aucoin: Thank you.

I was more concerned that it might take too long. If it’s very vague and the department is very busy, it could take too long. That was my question.

Thank you.

[English]

The Chair: Regarding the senator’s last comment, do you need further time to answer that part, or are you going to be sending some remarks to the committee?

Mr. Chao: Yes, I expect that we’ll have some comments on this topic. It was expected to be one of the topics we would cover in our written comments.

The Chair: Thank you.

Senator D. M. Wells: Again, thanks, witnesses.

We heard — and it’s really great — that industry and officials from the department engaged in a lot of positive consultation. That’s really good because we don’t see that in all government bills.

Was there anything that was included in the requests by industry that ended up not getting covered in the bill to your satisfaction? This leads to my next question: If there were amendments to be made, what would they be?

Ms. McGlogan: This is one of the things that came up, and I wasn’t directly involved in this: It’s the labelling requirements from — I forget the number — Amendment 15 or 18. There are specific labelling requirements for Canada from the lighting segment that will de-harmonize Canada versus the U.S. and Mexico. Meanwhile, our supply chains are highly integrated. So you are now separating inventory and product for Canada only, and that is definitely going to increase costs within the supply chain and time, and it will possibly sacrifice delivery time and availability because you can’t share a pool of inventory as you normally would if products were harmonized. That was a specific request. It was Amendment 18 on lighting labelling.

Senator D. M. Wells: Is that a labelling issue or is that a product change issue?

Ms. McGlogan: It’s a labelling issue, I believe.

Senator D. M. Wells: Okay. Thank you very much for that. Anyone else?

Mr. Chao: We will be providing some written comments that will mention suggestions mostly in areas related to harmonization with other jurisdictions.

In fairness to department staff, these issues came up following discussions we had with department staff. I do expect to have those available to be submitted, and then, of course, there will be time for translation. We do intend to support the committee’s work by providing written comments.

Ms. Auriat: Similar to Mr. Chao, most of our members’ concerns are really around regulatory alignment with other jurisdictions. I was not directly involved in the consultations. Again, our members feel they’ve been heard in a lot of ways by NRCan staff, but this is just another opportunity to share how important continuing to have as much regulatory alignment as possible is to our membership in terms of things like affordability and keeping costs down for all Canadians.

The Chair: Regarding your written comments, we would need those as soon as you can. The clerk will be communicating with you by email about when we need them in order to have them considered by the committee, so thank you.

It looks like we’ve come to the end of our panel. Thank you very much to all of you for being here. We appreciate your testimony, and we look forward to the written comments that will come soon so that we can deliberate on them. Thank you.

(The committee continued in camera.)

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