December 20, 2024
The Honourable Steven Guilbeault, P.C., M.P.
Minister of Environment and Climate Change
229 Wellington Street
Ottawa, Ontario, K1A 0A6
Dear Minister Guilbeault,
We hereby provide our submission (see “Appendix”) to the Ministry of Environment and Climate Change Canada’s (ECCC) recently published draft “Oil and Gas Sector Greenhouse Gas Emissions Cap Regulations” (hereafter, “oil and gas cap,” “sector cap,” or “draft regulations”) document in Canada Gazette, Part I (hereafter, “CG1”).
The Business Council of Alberta (BCA) is a non-partisan, non-profit organization composed of the chief executives and leading entrepreneurs of Alberta’s largest enterprises. Our members represent the majority of Alberta’s private sector investment, job creation, exports, and research and development. We are dedicated to building a better and more prosperous Alberta within a strong Canada.
We are disappointed to see the federal government continue to advance the implementation of an oil and gas cap. Simply put, the cap is regionally and sectorally discriminatory; and it is bad for national unity. If implemented, it will result in a host of negative consequences that will vastly outweigh any impact on domestic emissions. It will devastate the economy and drive affordability challenges in Canada. It will undermine existing climate policy and harm our international standing. And, most importantly, it will have no discernible effect on global GHG emissions, which is the problem that Canada and the world are trying to address.
Frankly, the oil and gas emissions cap cannot go forward in any form. It is the epitome of bad public policy, and it must be scrapped.
BCA has always been supportive of reducing national greenhouse gas emissions while positioning Canada as a responsible, competitive energy producer capable of scaling to meet global demand. That is why our last submission on the proposed cap outlined five principles of sound climate policymaking, which we believe must inform all current and future policy actions:
- emissions should be reduced at the lowest possible cost;
- policies are simple and clear;
- emission reductions are sector agnostic;
- regional fairness is considered and protected; and
- Canada’s businesses remain globally competitive.
This sector cap does not uphold any of these principles. By failing to partner with businesses to develop climate policy that aligns business incentives with the deployment of emissions-reducing capital, this government’s policy will be counterproductive for the environment, economic competitiveness, consumer affordability, and national unity.
A tonne of carbon abated is a tonne of carbon abated no matter what sector it comes from. As such, it is time to pivot away from pitting industries and regions against one another. It is time to get back to pragmatic policymaking. We sincerely hope that the government withdraws this problematic proposal. There is no version of it that is in the national interest.
We would be happy to discuss further with you or your staff.
Sincerely,
Adam Legge
President, Business Council of Alberta
CC: Hon. Jonathan Wilkinson, P.C., M.P., Minister of Energy and Natural Resources
Joanna Dafoe, Chief of Staff, Environment and Climate Change
Kyle Harrietha, Chief of Staff, Energy and Natural Resources
John Hannaford, Clerk of the Privy Council and Secretary to Cabinet
Jean-Francois Tremblay, Deputy Minister of Environment and Climate Change
Michael Vandergrift, Deputy Minister of Energy and Natural Resources
Chris Padfield, Deputy Secretary to the Cabinet (Clean Growth)
Mollie Johnson, Deputy Secretary to the Cabinet (Plans and Consultations)