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The Green Ledger, Part 3: The Quota Gap

Published 10 April 2026

Quebec imposed mandatory renewable gas targets by regulation. The distributor misses them by a wide margin. Shale gas stays in the pipes.

Originally published in Le Journal de Montréal, Friday 10 April 2026.

Quebec does not merely encourage renewable natural gas. It requires it. The targets are regulatory obligations, set by the Régie de l’énergie, binding on the province’s sole gas distributor. This installment documents the gap between what the regulation requires and what was delivered.

  1. The renewable gas quotas are not voluntary. Quebec regulation requires Énergir to deliver rising percentages of renewable natural gas in its distribution network. The targets: 1 % of network volume by 2020, 2 % by 2023, 5 % by 2025. These are regulatory obligations recorded in the file of the Régie de l’énergie. [1][2]

  2. Énergir is the only entity bound by these obligations. Énergir S.E.C. is the only regulated natural gas distributor in Quebec, a monopoly serving every home, every farm, and every business connected to the province’s gas network. There is no alternative distributor and no competitive market. The quota obligations rest on Énergir alone. [1]

  3. The 2020 target: no delivery volume publicly reported. The first milestone required 1 % of network volume to be renewable natural gas by 2020. Énergir did not publicly report its delivery volumes against this target in a format allowing independent verification of compliance. [2]

  4. The 2022-2023 result: 0.6 % delivered against a 2 % target. The Régie de l’énergie records confirm that renewable natural gas represented 0.6 % of Énergir’s network volume in 2022-2023. The regulatory target was 2 %. The gap was 70 % below the prescribed level. [2][4]

  5. The 2023-2024 result: 33.7 million m³ delivered against a 123.5 million target. The delivery target for 2023-2024 was 123.5 million cubic metres of renewable natural gas. Énergir delivered 33.7 million. The gap is about 73 %. These figures come from documents filed in file R-4320-2025 of the Régie de l’énergie. [2][4]

  6. The 5 % target for 2025 is now in force. Since 1 January 2025, the regulatory requirement has risen to 5 % of network volume. Given that Énergir delivered 0.6 % two years earlier and missed the 2023-2024 volumetric target by 73 %, the trajectory is documented in the public record. [2][4]

  7. The PSPGNR was designed precisely to close this gap. The Renewable Natural Gas Production Support Program (PSPGNR) was created by the Quebec government specifically to finance agricultural producers and other promoters who would inject renewable natural gas into Énergir’s network. Launched in November 2020 with an initial allocation of 25 million dollars, the program is funded by the Electrification and Climate Change Fund under Action R8-060 of the 2030 Plan for a Green Economy. [3][5] Every project that stalls, every subsidy withheld, every producer that cannot reach commercial operation, is a cubic metre of fracked shale gas that stays in the network.

  8. The Régie de l’énergie is currently examining the structure. In file R-4320-2025, intervenors raised questions about the structure of Énergir’s purchase cap and about whether it disadvantages small agricultural producers in favour of larger industrial projects. The FCEI asked Énergir why it acts against the preference the government expressed for small local PSPGNR projects. The Quebec government itself filed a position with the Régie favouring locally produced renewable gas, citing energy security and regional economic development. [4][6]

Regulatory targets and observed deliveries

Period Regulatory target Volume delivered Gap
By 2020 1 % of network volume Not publicly reported Not applicable
2022-2023 2 % of network volume 0.6 % of network 70 % below target
2023-2024 123.5 million cubic metres 33.7 million cubic metres 73 % below target
By 2025 5 % of network volume Target year in progress Not applicable
By 2030 (proposed) 10 % of network volume Not applicable Not applicable

Paul Sauvé, farmer GNR Shefford, GNRShefford.ca

This is Part 3 of the Green Ledger, an ongoing series of investigations concerning Énergir, Quebec’s renewable natural gas program, and the public funds that underpin them. Further revelations are to come.

References and sources

(1) Régie de l’énergie du Québec, regulation concerning the quantity of renewable natural gas to be delivered by a distributor; delivery targets: 1 % by 2020, 2 % by 2023, 5 % by 2025.

(2) Régie de l’énergie du Québec, file R-4320-2025, decisions and intervenor briefs filed in the record; RNG delivery data: 0.6 % of network volume in 2022-2023; 33.7 million m³ delivered in 2023-2024 against a target of 123.5 million m³.

(3) Government of Quebec, Renewable Natural Gas Production Support Program (PSPGNR), normative framework, version approved 4 July 2022; initial allocation of 25 M$; amendments in 2021 and 2022.

(4) Régie de l’énergie du Québec, file R-4320-2025, intervenor briefs, including the observations of the FCEI and the position of the Government of Quebec on locally produced renewable gas.

(5) Government of Quebec, launch of the PSPGNR in November 2020.

(6) Régie de l’énergie du Québec, decision D-2026-037, version published partially redacted.

(7) Government of Quebec, draft regulation, RNG target raised to 10 % by 2030, Gazette officielle du Québec, June 2022.

(8) Government of Quebec, press release of 14 July 2022, extension and amendment of the PSPGNR.

This content was produced by GNR Shefford. All data are drawn from publicly accessible sources.