Canada's hydrogen policy landscape: A comparative overview

On April 7, 2022, Ontario released its first-ever Hydrogen Strategy (the "Ontario Strategy"), making it the latest province to address Canadian hydrogen sector growth through policy.^[1] The Ontario strategy is the culmination of a feedback process led by the Government of Ontario and was spurred by the November 2020 Discussion Paper^[2]. The article below provides a comparative analysis of current hydrogen policy initiatives across Canada, including a close look at the new Ontario Strategy.

Ontario's hydrogen strategy
Canada's hydrogen strategy
Alberta
British Columbia
Quebec
Newfoundland and Labrador

Ontario's hydrogen strategy

The Ontario Strategy aims to evolve Ontario's energy system; create local jobs in science, technology, engineering and skilled trades; attract investment; and reduce greenhouse gas emissions. Further, the Ontario Government anticipates that the Ontario Strategy will position the province as a clean manufacturing hub, ready to support new investments to produce clean steel, electric vehicles, and the batteries that power them. The Ontario strategy is guided by the following objectives:

1. Generate economic development and jobs: Capitalize on Ontario's competitive and regional advantages, including our talent, infrastructure and resources, to accelerate growth in Ontario's low-carbon hydrogen economy.
2. Reduce greenhouse gas emissions: Support our Made-in-Ontario Environment Plan targets to reduce greenhouse gas emissions by encouraging the use of low-carbon hydrogen.
3. Promote energy diversity: Consider how low-carbon hydrogen can cost-effectively support Ontario's evolving energy system and build redundancies through electricity storage and clean fuel supply.
4. Promote innovation and investment: Enable opportunities for low-carbon hydrogen use and position Ontario as a leading destination for investment.
5. Strengthen collaboration: Work with the private sector, the federal government, municipalities, Indigenous communities, academic institutions and other stakeholders to grow and sustain a low-carbon hydrogen economy in Ontario.

Notably, the Ontario Strategy sets out eight concrete and immediate actions, which are expected to lead to an eight-fold increase in the province's capacity of low-carbon hydrogen and support the early market to continue its growth:

1. Launching the Niagara Falls Hydrogen Production Pilot: Atura Power proposes to produce hydrogen in Niagara Falls using electricity from the Sir Adam Beck hydroelectric generating station as part of its grid regulation services to Ontario's electricity system. The government filed a regulatory exemption to the Gross Revenue Charge (GRC) for electricity used by this project.
2. Identifying Ontario's Hydrogen Hub Communities: Atura Power is working to identify additional strategic locations across the province for hydrogen "hubs" where low-carbon hydrogen demand can be matched by low-carbon hydrogen production that leverages existing electricity infrastructure and Ontario's clean electricity grid. The Ministry of Energy will also undertake its own third-party led feasibility study to explore opportunities to establish new low-carbon hydrogen or clean fuel hubs in Ontario.
3. Assessing the feasibility of hydrogen opportunities at Bruce Power: Bruce Power will launch a feasibility study to explore opportunities to leverage excess energy from the Bruce Nuclear Generating Station for hydrogen production and support a centre of excellence in the region.
4. Developing an interruptible electricity rate: Ontario will be working towards reducing electricity rates to support low-carbon hydrogen production through a proposed Interruptible Rate pilot that would offer large electricity consumers reduced electricity rates in exchange for reduced consumption during system or local reliability events. The Ministry of Energy will also undertake consultations on other electricity rates that could help to further grow Ontario's low-carbon hydrogen economy.
5. Supporting hydrogen storage and grid integration pilots: Ontario will ask the Independent Electricity System Operator (IESO) to report back on program options to support hydrogen storage and grid integration pilot projects.
6. Transitioning industry through the use of Low-carbon hydrogen: Ontario is taking immediate steps to support the efforts of industry to phase out their use of coal by transitioning to low-carbon processes and hydrogen-ready equipment. For example, Ontario is contributing $500 million in support to the $1.8 billion project by ArcelorMittal Dofasco at its Hamilton facility to replace coal-fed furnaces with a hydrogen-ready electric arc furnace (EAF). This project will reduce GHG emissions by about three million tonnes annually.
7. Consulting on an Ontario carbon sequestration and storage regulatory framework: Ontario is proposing changes to the Oil, Gas and Salt Resources Act and the Mining Act frameworks to enable carbon storage activities on Crown land. Carbon sequestration offers the opportunity to produce low-carbon hydrogen using natural gas.
8. Supporting ongoing hydrogen research: Ontario is supporting two independent hydrogen research projects in partnership with Natural Resources Canada to advance hydrogen development in the province.

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Canada's hydrogen strategy

Ontario's Strategy follows the Hydrogen Strategy for Canada (the "Canada Strategy"), which was released on December 16, 2020. The Canada Strategy aims to achieve net-zero emissions by 2050 and position Canada as a global, industrial leader of clean renewable fuels. To achieve these goals, the Canada Strategy set out near term, mid term, and long term goals:

1. 1. Near term: Between 2021 and 2025, Canada's focus is on laying the foundation by planning for and developing new hydrogen supply and distribution infrastructure to support early deployment HUBs in mature applications while supporting Canadian demonstrations in emerging applications.
2. 2. Mid term: Thereafter, in the 2025 to 2030 timeframe, as the technology matures and the full suite of end-use applications nears commercial technology readiness levels, hydrogen use will be focused on growth and diversification.
3. 3. Long term: Between 2030 and 2050, Canada aims to realize the full benefits of the rapid expansion of the hydrogen economy as more technology is deployed and new commercial applications grow, supported by Canada's foundational backbone supply and distribution infrastructure.

The Strategy contains 32 recommendations developed in consultation with stakeholders across eight pillars:

Pillar 1: Strategic Partnerships - Strategically use existing and new partnerships to collaborate and map out the future of hydrogen in Canada.

Pillar 2: De-Risking of Investments - Establish funding programs, long-term policies, and business models to encourage industry and governments to invest in growing the hydrogen economy.

Pillar 3: Innovation - Take action to support further R&D, develop research priorities, and foster collaboration between stakeholders to ensure Canada maintains its competitive edge and global leadership in hydrogen and fuel cell technologies.

Pillar 4: Codes and Standards - Modernize existing and develop new codes and standards to keep pace with this rapidly changing industry and remove barriers to deployment, domestically and internationally.

Pillar 5: Enabling Policies and Regulation - Ensure hydrogen is integrated into clean energy roadmaps and strategies at all levels of government and incentivize its application.

Pillar 6: Awareness - Lead at the national level to ensure individuals and communities are aware of hydrogen's safety, uses, and benefits during a time of rapidly developing technologies.

Pillar 7: Regional Blueprints - Implement a multilevel, collaborative government effort to facilitate the development of regional hydrogen blueprints to identify specific opportunities and plans for hydrogen production and end use.

Pillar 8: International Markets - Work with our international partners to ensure the global push for clean fuels includes hydrogen so Canadian industries thrive at home and abroad.

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Alberta

In November 2021, Alberta released a "Hydrogen Roadmap" detailing its plan to explore and ramp up hydrogen production in the province.^[3] Alberta has set an ambitious goal of becoming the global supplier-of-choice in clean hydrogen exports by 2030.

Alberta's policy is effectively driven by three objectives: (1) reducing greenhouse gas emissions and decarbonizing the economy, (2) increasing Alberta's investment attractiveness and competitiveness, and (3) leveraging existing advantages for transformation.

Alberta aims to expand hydrogen capacity with seven "policy pillars." The seven policy pillars will be furthered by several proposed actions for each pillar. The seven pillars are as follows:

1. Build new market demand
   • Alberta seeks to establish hydrogen demand to build out supply and commercialization pathways.
   • For example, Alberta aims to accomplish this goal by amending the Gas Utilities Act and Gas Distribution Act to remove roadblocks for hydrogen blending into natural gas distribution systems by 2023.
2. De-risk investment
   • Alberta seeks to enable long-term investment certainty and funding in Hydrogen.
   • For example, Alberta aims to accomplish this goal by increasing access to capital to support hydrogen deployments and infrastructure developments by 2023.
3. Ensure regulatory efficiency, codes and standards
   • Alberta seeks to create a regulatory regime that accommodates hydrogen development and is based on safety across the value chain.
   • For example, Alberta aims to accomplish this goal by harmonizing and clarifying hydrogen regulations with federal and provincial governments.
4. Pursue hydrogen exports
   • Alberta aims to supply the world market for hydrogen, establish market access and close export gaps in the supply chain.
   • For example, Alberta aims to accomplish this goal by pursuing market access through establishment of a clean energy corridor with connection through British Columbia and other jurisdictions.
5. Enable carbon capture, utilization and storage (CCUS)
   • Alberta needs CCUS to be in place to facilitate cost-effective, large-scale production.
   • For example, Alberta aims to accomplish this goal by advancing CCUS hubs and exploring opportunities to improve economics.
6. Activate technology and innovation
   • Alberta seeks to increase research and innovation in the hydrogen sector.
   • For example, Alberta aims to accomplish this goal by supporting pilots and early demonstration projects for domestic and export market development.
7. Lead the way and build alliances
   • Alberta seeks to build public-private partnerships and government-to-government relationships to advance the hydrogen economy.
   • For example, Alberta aims to accomplish this goal by coordinating the development of clean hydrogen hubs and partnerships across the province by 2023.

In line with its ambitious 2030 target, Alberta has set out several targets to measure its success. For example, Alberta aims to have clean hydrogen integrated into the province's energy systems by 2030.

Ontario has tied its hydrogen strategy to several new and immediate action items. In contrast, Alberta discusses its past support for energy development and future policies, but has not tied its strategy to any immediate projects. Notably, Alberta has a list of Measures of Success, which Ontario does not. Further, Alberta has a timeline of achieving its objectives by 2030, whereas Ontario does not.

Alberta and Ontario's future actions are similar. Interestingly, Ontario aims to specifically pursue federal support for nuclear energy to further facilitate hydrogen production. This accords with Ontario's long history of nuclear energy generation.

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British Columbia

British Columbia released its Hydrogen Strategy (the "British Columbia Strategy") in July 2021.^[4] British Columbia aims to become a world-leading hydrogen economy by 2050. The province's strategy has five objectives:

1. Promote innovation and investment in the production and deployment of hydrogen to achieve the energy system transformation required to meet British Columbia's greenhouse gas (GHG) reduction targets.
2. Create economic development opportunities across British Columbia through increased and equitable employment in trades, cleantech and energy services.
3. Improve air quality and reduce contamination and noise pollution in urban and remote communities.
4. Make clean energy solutions more diverse, convenient, available and affordable for British Columbians.
5. Fulfil our commitments under the Declaration on the Rights of Indigenous Peoples Act.

The British Columbia Strategy outlines 63 policy actions grouped into 7 headings. Each heading groups policy actions into 3 time periods: 2020-2025, 2025-2030, and 2030-beyond. Listed below are several examples of policy options the province plans to take:

1. Grow hydrogen production
   • 2020-2025: Stimulate hydrogen production through direct support and incentives.
   • 2025-2030: Consider introducing alternative electricity rate designs to support hydrogen production.
   • 2030-beyond: Support the development of hydrogen liquefaction, distribution and transmission infrastructure.
2. Regulate hydrogen production
   • 2020-2025: Review provincial, federal and international codes, standards and regulations for hydrogen production and establish a compatible regulatory framework.
   • 2025-2030: Develop carbon management frameworks to encourage at-scale production of low-carbon hydrogen and transition policy incentives from direct support to market-based mechanisms.
   • 2030-beyond: Require a phased reduction in the carbon intensity of hydrogen produced and used in British Columbia.
3. Support blending hydrogen with natural gas
   • 2020-2025: Establish a regulatory framework for injecting hydrogen into the natural gas and propane distribution systems.
   • 2025-2030: Mandate that new or modified natural gas or propane pipelines be hydrogen compatible.
   • 2030-beyond: Support large-scale hydrogen injection into the natural gas and propane distribution systems.
4. Encourage the growth of hydrogen in transportation
   • 2020-2025: Pilot the use of hydrogen fuel cells in medium- and heavy-duty vehicles, marine, rail, aviation, off-road and other commercial transportation applications.
   • 2025-2030: Review and expand the pilot demonstration use of hydrogen fuel cells in medium- and heavy-duty vehicles, marine, rail, aviation, off-road and other commercial transportation application.
   • 2030-beyond: Continue to support the widespread use of hydrogen in medium- and heavy-duty vehicles, marine, rail, aviation, off-road and other commercial transportation applications.
5. Support industry to increase hydrogen use
   • 2020-2025: Support pilots for the use of low-carbon hydrogen for synthetic fuel production.
   • 2025-2030: Support the use of hydrogen across industries in British Columbia, including refining biocrude and producing synthetic fuels.
   • 2030-beyond: Where appropriate, support the use of low-carbon hydrogen in industrial processes, such as in pulp and paper mills, petroleum refining and aluminum smelting.
6. Advance hydrogen as a source of clean energy in communities
   • 2020-2025: Commission a comprehensive study for hydrogen in communities.
   • 2025-2030: Implement findings and results from the community feasibility study. Introduce capacity-building tools for community clean energy and hydrogen.
   • 2030-beyond: Support the conversion of a small to medium-sized fossil-fuel-reliant community to hydrogen.
7. Develop British Columbia's export market for hydrogen
   • 2020-2025: Promote British Columbia internationally as an attractive jurisdiction for investment in hydrogen production for domestic supply and export.
   • 2025-2030: Attract domestic and international investment for the development of supply chains to export hydrogen.
   • 2030-beyond: Enable the construction of dedicated infrastructure for hydrogen export.

In line with its 2050 target, British Columbia has set out several targets to measure its success. For example, British Columbia aims to be seen as an attractive jurisdiction for domestic and international investment in hydrogen.

Similar to Alberta, British Columbia's policy strategy is not tied to any specific announcements, but rather discusses previous policies and looks forward to the future. British Columbia's strategy is more detailed than Ontario's plan, with 63 total policy actions for the province to take in the future. Notably, British Columbia has also uniquely adopted a list of Measures of Success (which Ontario has not). Further, British Columbia has a timeline of achieving its objectives by 2050, which Ontario also does not.

Ontario and British Columbia's objectives are generally similar, though it may be said that Ontario emphasizes investment more. As may be expected, British Columbia also has a specific objective dedicated to addressing the province's commitments to the Indigenous peoples of British Columbia, which aligns with the notable work that the Province has done and is advancing following its adoption of the Declaration on the Rights of Indigenous Peoples Act, and recent release of its first action plan under that notable statute.

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Quebec

Quebec is currently formulating a hydrogen strategy that should be published this spring according to Minister of Energy and Natural Resources, Jonatan Julien. Following the publication of the guiding principles of the Quebec hydrogen strategy, the Quebec Ministry of Energy and Natural Resources ("MERN") has launched a public consultation in the fall of 2021 to validate these principles with stakeholders and to propose concrete measures for their implementation. The MERN recently released a final consultation report in March 2022 (available in French only).^[5] It can be expected that Quebec will release a formal hydrogen strategy in the near future. The final consultation report proposes six objectives to guide the province's hydrogen strategy:

1. To develop production and distribution infrastructure: increase demand with adapted regulation and support the creation of hubs. Favouring complementarity by adopting an ecosystem approach as part of this goal.
2. To increase the use of green hydrogen: by investing in Quebec R&D, creating cooperation between the principal stakeholders i.e. distributors and research developers
3. To improve knowledge and its dissemination: while involving Quebec's regions in the development of expertise and the allocation of projects
4. To develop solutions and innovative processes.
5. To increase the commitment of public and private actor in favour of developing green hydrogen.
6. To promote the support of local and indigenous communities in development sectors.

Quebec's hydrogen strategy is still in the development stages. We can expect that Quebec will use the consultation report to create a comprehensive and ambitious strategy for the province's hydrogen sector all the while implementing risk-reduction strategies for this emerging market.

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Newfoundland and Labrador

Newfoundland and Labrador also appears to be eyeing hydrogen development, albeit without a hydrogen-specific strategy.

In May 2021, Newfoundland and Labrador released a one-size-fits-all plan to address the twin economic crises facing the provinces (COVID-19 and long-term economic problems). The report authored by the Premier's Economic Recovery Team (PERT) and entitled "The Big Reset",^[6] diagnoses the province's ills and makes several wide-reaching recommendations. The report also addresses hydrogen production in the province, specifically tying the hydrogen's potential to the province's oil and gas industry. PERT recommended that the Province develop a green hydrogen plan to:

• Identify infrastructure needs for industrial, transportation and consumer use;
• Identify funding and economic opportunities and potential private sector partners;
• Overcome technical challenges;
• Adapt provincial infrastructure to be ready for export opportunities; and
• Focus on the development of a large-scale green hydrogen pilot project.

In December 2021, the province also released a renewable energy strategy^[7] that addresses hydrogen. The plan does not address hydrogen in depth, but does list several policy actions related to hydrogen the province plans to take. The hydrogen-specific policy actions are:

• Within one year:
  • Continue to enhance the province's ability to determine hydrogen opportunities that provide the highest, long-term benefit for residents of the province.
  • Develop a Hydrogen Development Action Plan.
• Within two years:
  • Build our understanding of opportunities to generate new green products such as green hydrogen, green ammonia or biofuel, and export the energy via ship
• Within two-five years:
  • Explore opportunities to grow research capacity within the province on ways to maximize the use of the province's developed and undeveloped renewable energy resources (e.g. examine opportunities related to the production and use of hydrogen generated from the renewable energy grid).

Newfoundland and Labrador has clearly turned its eye to hydrogen development, and a hydrogen specific strategy may be expected in the next year.

Should you have any specific questions about this article or would like to discuss it further, you can contact one of the authors or a member of our Energy Group.

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[1] Ontario's Low-Carbon Hydrogen Strategy

[2] Ontario's Low-Carbon Hydrogen Strategy: Discussion Paper

[3] Alberta Hydrogen Roadmap

[4] British Columbia Hydrogen Strategy

[5] Towards an Initial Strategy on Green Hydrogen and Bioenergy: Consultation Report

[6] The Big Reset: The Report of the Premier's Economic Recovery Team

[7] Maximizing Our Renewable Future: A Plan for Development of the Renewable Energy Industry in Newfoundland Labrador: https://www.gov.nl.ca/iet/renewable-energy-plan/