Submitting your natural gas energy system plan

Submitting your natural gas energy system plan

Important: NRCan’s secure portal for system plan submission is under development.

Disclaimer

The information on this and subsequent pages (“these pages”) does not supersede or modify the Income Tax Act (the “ITA”) or the NRCan’s Guidance Documents. Any information in these pages that relates to the provisions of the ITA or the validation or verification of Emission Intensity (EI), for a qualified natural gas energy system (QNGES), in respect of the Clean Electricity Investment Tax Credit (ITC) is provided for information purposes only and does not offer any interpretation of the ITA. Qualifying entities should consult the latest versions of the Clean Electricity ITC legislation and NRCan Guidance documents for qualified natural gas energy systems when considering the submission of a natural gas energy system plan.

In order to claim the Clean Electricity ITC, for qualified natural gas energy equipment that is part of a qualified natural gas energy system, you must be issued a qualified natural gas energy system evaluation (i.e., system evaluation) by NRCan.

To be issued a qualified natural gas energy system evaluation, you need to complete a Final Detailed Engineering Design package (FDED) that is issued for construction (IFC) and submit a system plan that is prepared by an independent qualified validation firm.

For systems at the Front-End Engineering Design (FEED) stage, you may choose to submit a system plan to NRCan for a review. NRCan will provide an initial review of your system plan submission. Submitting a system plan for review at the FEED stage is optional.

Important to note:

General submission process

  1. Your system design documentation packages provided at FEED and/or FDED IFC stages must cover all elements relevant to the qualified natural gas energy equipment and qualified natural gas energy systems, including but not limited to the following:
    • The clean electricity production facility (including all Battery Limit information), and,
    • Assertions of system emission intensity and ratios, and natural gas energy equipment to be claimed
  2. You must submit your system design documentation package to a qualified validation firm to prepare your system plan. The system plan, includes:
    • system design documentation package
    • reference documents
    • the validation report
  3. You will submit the system plan as part of your submission package to NRCan (for more information please refer to Compile the required documents for system plan submission).

To receive a system evaluation, NRCan must review your system plan based on construction ready documentation.

For systems at FEED stage, NRCan’s initial review is not binding. Please note, a FEED stage review of your system plan will not be sufficient to claim Clean Electricity ITC.

To receive this initial review, you need to have completed a FEED study or equivalent and submit a system plan prepared by a qualified validation firm.

Important: An initial review does not constitute a qualified natural gas energy system evaluation. For NRCan to issue a qualified natural gas energy system evaluation, a system plan based on construction ready design documentation package is required.

Consult the following guidance documents for more information about equipment eligibility, emission intensity calculation and validation:

  • Clean Electricity Investment Tax Credit – Qualified Natural Gas Energy System Technical Guidance Document, 30 Sept. 2026 [anticipated]
  • Clean Electricity Investment Tax Credit – Qualified Natural Gas Energy System Emission Intensity Validation Guidance Document, 30 Sept. 2026 [anticipated]

When a system plan is submitted to the NRCan CE ITC intake portal, it may take up to 3-months before NRCan engages with you on your submission.

In order to provide an initial review at FEED stage or issue a system evaluation at ‘construction ready’ stage, NRCan is prepared to receive system plan submissions of varying size and complexity. Once your system plan is submitted, NRCan will engage with you as necessary to conduct an efficient and timely evaluation of your system plan.

It is your responsibility to take your system size, complexity, and filing deadlines into consideration when submitting your system plan (see Claiming the credit page). Please ensure that you have submitted your system plan documents as early as possible to allow NRCan to perform the required reviews.

NRCan will be ready to receive your submissions in the coming months. If you have any questions, reach out to the NRCan’s ITC-CE-Natural Gas Power inbox, itc_ce_naturalgaspower-cii_ep_electriciteaugaznaturel@nrcan-rncan.gc.ca.

Steps

  1. What is qualified natural gas energy equipment

  2. Complete a FEED or FEED equivalent study design package for your natural gas energy system plan submission documentation

  3. Calculate the system’s expected emission intensity and ratios

  4. Validate the system design documentation package

  5. Compile the required documents for system plan submission

  6. Submit your qualified natural gas energy system plan

System plan

From ITA subsection 127491(1): system plan means a plan for a qualified natural gas energy system of a qualifying entity that

  1. has been prepared by a qualified validation firm;
  2. includes a front-end engineering design study (or an equivalent study as determined by the Minister of Natural Resources) for the system;
  3. sets out
    1. an expected emission intensity of the electrical energy to be produced by the system that is below 65 tonnes carbon dioxide per gigawatt hour,
    2. an expected ratio of net electrical energy to net heat energy exported that is above 1, and
    3. an expected ratio of electrical energy used to power equipment that captures and prepares or compresses carbon dioxide to gross electrical energy produced that is below 0.5;
  4. contains any information required in guidelines published by the Minister of Natural Resources; and
  5. is filed by the entity with the Minister of Natural Resources, in the form and manner determined by the Minister of Natural Resources. (plan du système)

Construction ready

Complete Final Detailed Engineering Design (FDED) package supported by all design documents issued for construction (IFC)

 
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