On April 7, 2016, the Government of Quebec (the “Government”) released the 2030 Energy Policy (the “Policy”), which sets out Quebec’s goal of becoming a North American leader in energy efficiency and renewable energy by 2030. Accordingly, on November 16, 2020, the Government unveiled the 2030 Plan for a Green Economy (the “Plan”), which prioritizes the development of the green hydrogen and bioenergy sector, as well as its action plan for the implementation of the Policy covering the 2021-2026 period.
I. The 2030 Energy Policy and its Implementation
The Policy defines Quebec’s energy transition strategy until 2030. Its objectives include promoting a low-carbon economy, making optimal use of Quebec’s energy resources and taking full advantage of the potential of energy efficiency.
To achieve these objectives, the Government has adopted five targets to be met by 2030, including increasing the share of renewable energy in total energy production by 25% and increasing bioenergy production by 50%. The Policy is implemented through amendments to the existing legislative and regulatory framework.
One of the first implementation action amended the Act respecting the Régie de l’énergie to introduce the concept of renewable natural gas (“RNG”). This legislative amendment led to the adoption of a regulation that now requires natural gas distributors to deliver a minimum volume of RNG to their customers each year. The regulation provides that this volume will gradually increase between 2020 and 2025, from 1% to 5% of the total volume of natural gas delivered in a year.
The Government of Quebec has also legislated that the Minister of Energy and Natural Resources is responsible for ensuring effective governance of the energy transition, innovation and efficiency.
II. The 2030 Plan for a Green Economy
The Plan aims to reduce greenhouse gas emissions by 37.5% compared to 1990 levels by 2030, through the implementation of measures such as increasing the electrification of transportation and buildings, reducing the free allocation of emissions allowances to the industrial sector and increasing the use of other forms of renewable energy.
In addition, in its effort to encourage new forms of renewable energy, the Quebec government announced, in early 2021, the allocation of funding to support the development of the green hydrogen industry.
While several renewable hydrogen production projects aimed at adding hydrogen to natural gas are already under development in Quebec, these projects have evolved until now in the absence of standards and regulations adapted to allow the development of this new form of renewable energy. In fact, the Quebec legislative and regulatory framework only deals with hydrogen as a hazardous material.
However, on September 30, 2021, the National Assembly adopted An Act to amend the Act respecting energy efficiency and energy conservation standards for certain electrical or hydrocarbon-fuelled appliances, which, among other things, amends the Act respecting the Régie de l’énergie to include hydrogen as “gas from renewable sources” that can be added to traditional natural gas. This legislative change should promote the development of the green hydrogen sector in Quebec.
The rapid changes put in place by the Quebec government suggest that renewable energy projects will be accelerated. These measures are intended to facilitate the achievement of the objectives of energy transition and reduction of greenhouse gas emissions by 2030.
 2030 Energy Policy: Energy in Québec – A Source of Growth, Ministère de l’Énergie et des Ressources naturelles, Gouvernement du Québec, https://mern.gouv.qc.ca/energie/politique-energetique/.
 The 2030 Plan for a Green Economy, Gouvernement du Québec, www.quebec.ca/gouv/politiques-orientations/plan-economie-verte.
 See for example: An Act to implement the 2030 Energy Policy and to amend various legislative provisions, SQ 2016, c 35; Petroleum Resources Act, CQLR c H-4.2; An Act mainly to ensure effective governance of the fight against climate change and to promote electrification, SQ 2020, c 19.
 Act respecting the Régie de l’énergie, CQLR c R-6.01.
 Regulation respecting the quantity of renewable natural gas to be delivered by a distributor, CQLR c R-6.01, r. 4.3.
 An Act mainly to ensure effective governance of the fight against climate change and to promote electrification, SQ 2020, c 19.
 Ministère de l’Énergie et des Ressources naturelles, www.quebec.ca/nouvelles/actualites/details/strategie-quebecoise-de-lhydrogene-vert-le-gouvernement-du-quebec-alloue-15-m-pour-soutenir-le-developpement-de-la-filiere-de-lhydrogene-vert.
 Regulation respecting hazardous materials, CQLR c Q-2, r 32.
 An Act to amend the Act respecting energy efficiency and energy conservation standards for certain electrical or hydrocarbon-fuelled appliances, Québec, National Assembly of Québec, 42nd Leg, 1st Sess, Vol. 45, No. 211 (September 30, 2021).