Connect with us
[the_ad id="89560"]

MacDonald Laurier Institute

Barriers to care persist but access to MAiD keeps expanding

Published

17 minute read

From the Macdonald Laurier Institute

By Ramona Coelho

Our government has allowed the incredible power of certain lobby groups to control the public discourse and policies around MAiD and its expansion, prioritizing access to MAiD over the safety of Canadians.

My family medicine practice serves predominantly low-income and marginalized patients, including refugees, those who have been in our prison system or are facing charges, and many with disabilities and mental health issues. My patients experience high barriers to care and support and face social isolation and all kinds of discrimination. Observing the impacts of this has left me deeply concerned about our government’s priorities.

When the federal government introduced MAiD (a medical procedure that causes death) to those not at imminent risk of dying, I was appalled to learn that my patients, who are frequently blocked from care as a result of hurdles created by our government and systems, could potentially be offered an expedient death provided by the government.

In 2016, assisted suicide and euthanasia were first legalized in Canada and the term medical assistance in dying (MAiD) was created. Originally MAiD was presented as an exceptional lethal procedure for ending the lives of consenting adults who were experiencing intolerable suffering and were near death. The legislation required that patients meet certain criteria, including having a “grievous and irremediable” medical condition, such as organ failure or cancer, and a “reasonably foreseeable natural death.”

But the Canadian discourse around MAiD rapidly shifted to facilitating access and there has been a broadening of the number and criteria of those who qualify for MAiD. In 2021, Bill C-7 came into effect and removed some of the safeguards within the original pathway, now called Track 1, and created a new, second track, Track 2, for adults with physical disabilities[1] who are not  dying. Furthermore, there is a planned expansion, though the timing is currently being debated in Parliament, for patients whose only medical condition is mental illness. Parliamentary recommendations in 2023 included future expansion to children and to incapable adults who signed advance directives for euthanasia.

Currently, those in Track 1 with a “reasonably foreseeable natural death” can potentially have their life ended the same day as the initial request if all the criteria are met and practitioners are available.

For those in Track 2, those not dying, death by lethal injection is set at a minimum of 90 days after the completion of the first MAiD assessment. To qualify for this track, a patient must also have a “grievous and irremediable” condition and experience intolerable psychological or physical suffering. Suffering is treated as purely subjective with no requirement for further validation. There is also no legal requirement for standard treatment options to be accessible or tried, only that a patient be informed that they exist. This means that a patient who says they are suffering intolerably could access MAiD having declined treatments that would remediate their condition. This could be because the treatment is inaccessible, or unaffordable, or if the patient declines therapy.

The Canadian Association of MAiD Assessors and Providers (CAMAP) has received 3.3 million dollars in funding from Health Canada to educate clinicians assessing and providing for those who have requested the service. So although the existing Track 1 and Track 2 pathways have different safeguards, in aiming to allow those near death to have access to MAiD quickly and with no barriers, CAMAP has created a guidance document that suggests clinicians can be flexible as to whether someone fits Track 1’s reasonably foreseeable natural death, since the law does not require that the person be terminally ill or likely to die within 6 or 12 months. It also states that a person may meet the reasonably foreseeable criterion if they’ve demonstrated a clear and serious intent to take steps to “make their natural death happen soon, or to cause their death to be predictable.” This could come about from a refusal to take antibiotics for an infection, stopping oxygen therapy, or refusing to eat and drink.

This means that people with disabilities can state their intention to or make themselves sick enough to qualify as having a reasonably foreseeable natural death, as is currently happening with adults who are not dying and yet are having their lives ended within days of their first MAiD assessment. In one case, a man had a mild stroke and received MAiD shortly after, even though he wasn’t terminally ill. The reason? He was approved for track 1 as he was temporarily eating less. This was due to following a cautious meal plan ordered by the treating team which was intended to prevent choking and aspiration risks.

Currently, some places in Canada have MAiD rates that are the highest in the world. By the end of 2022, there had been almost 45,000 MAiD deaths across Canada since legalization—more than 13,000 of which took place in 2022 with 463 of those individuals accessing MAiD through Track 2. Estimates based on provincial reporting approximate 16,000 deaths in 2023. Health Canada and MAiD expansionists have tried to reassure the public that the overwhelming number of MAiD deaths have been mostly Track 1 deaths (implying they were dying anyway) but we do not know how many of those persons were “fast-tracked” and may have had many decades of life left to live and the potential to recover with time and care.

The CAMAP guidance document that seems to circumvent Track 2 safeguards is just the beginning of many serious problems with MAiD legislation and practice in Canada.

Patient safeguards for MAiD are lacking

Other jurisdictions in the world where MAiD practices are legalized, such as New Zealand and Victoria, Australia, frown on or prohibit raising death as a treatment option. This is due to the power imbalance that exists between physician and patient, coupled with the patients’ assumption that the provider will only suggest the best options for their health. Raising  MAiD unsolicited could cause undue pressure to choose death.  Yet Health Canada’s 2023 Model Practice Standard for Medical Assistance in Dying recommends that MAiD should be raised to all who might qualify if the practitioner suspects it aligns with a patient’s values and preferences.

The model practice standard’s approach to “conscientious objection” is equally troubling. Health care providers who object to providing MAiD, even in specific cases, are considered conscientious objectors. A physician who is concerned that MAiD is not a patient’s best option is supposed to ignore their conscience or professional opinion and simply refer the patient on so they can seek access to a MAiD death.

This is further echoed in a CAMAP video training session where experts explain that patients might be driven to MAiD by unmet psycho-social needs. The expert leading the session responds to a trainee’s concerns: “If withdrawing is about protecting your conscience, you have [an] absolute right to do so.” But he adds: “You’ll then have to refer the person on to somebody else, who may hopefully fulfill the request in the end.” This demonstrates precisely how effective referrals can funnel patients toward death despite legitimate professional concerns and obligations that should have instead led to the process being stopped or paused.

In response to this legislation, many from the disability community have advocated for safe spaces where MAiD can’t pose a risk to their lives. The Disability Filibuster, a national grassroots disability community, stated in an open letter that its members have raised fears about seeking health care where death could be offered to them and if at their lowest, they might agree.

The disability community is not being alarmist in this concern. Health care providers often rate the quality of life of those with disabilities as poor despite those patients rating their own quality of life as the same as aged-matched healthy individuals. Put differently, many physicians might consider that patients with disabilities are better off dead, consciously or unconsciously, which might lead them to suggest MAiD.

Besides the problems of mandatory referral and raising MAiD unsolicited, there is another important factor to consider. Persons with physical disabilities systemically lack much of the essential care they need to live and consequently suffer higher rates of isolation, poverty, and marginalization, all of which can make death their most accessible option. The Canadian government commissioned a University of Guelph study, published in 2021, in which the researchers noted that some persons with disabilities were encouraged to explore the MAiD option—even though they had not been contemplating doing so—because of a lack of resources that would enable them to live. Those with disabilities can be approved for MAiD based on their disability, but it is their psycho-social suffering that can drive their requests.

The United Nations Special Rapporteur on the rights of persons with disabilities, the Independent Expert on the enjoyment of all human rights by older persons, and the Special Rapporteur on extreme poverty and human rights have all warned the Canadian government that the current MAiD framework could lead to human rights violations. Their concerns are validated by the numerous fact-checked stories about MAiD abuses that are emerging in Canada. These should give us pause. For example, Sathya Dhara Kovac, 44, ended her life through the MAiD program. She lived with a degenerative disease and her condition was worsening, but she wanted to live but lacked the home care resources to do so. “Ultimately it was not a genetic disease that took me out, it was a system,” Kovac wrote in an obituary to loved ones. All Canadians have a right to humane living conditions, to be treated with respect and dignity, and to receive appropriate timely medical care. Considering the living conditions and lack of care that as a society we allow persons with disabilities to have, choices to die might be understandable for those like Sathya. But we should ask ourselves if choices, made under inhumane conditions, are made freely if driven by structural coercion.

Disturbingly, there are MAiD assessors and providers who seem to be ok with proving MAiD under such inhumane conditions. One such provider testified at a parliamentary committee on MAiD that if someone had to wait a long time for a service that would remediate their suffering, she would still consider that waiting to be irremediable suffering and grant them MAiD in the interim. Therefore, it is not surprising that patients with unaddressed psycho-social suffering are being given MAiD by assessors like her.

When it was considering Bill C-7, the federal government asked the Parliamentary Budget Officer to estimate cost savings to our health care system of the legalization of MAiD. The office did this by looking at the comparative cost savings of MAiD versus palliative care at the end of life. Through this impoverished lens of valuation, it is clear that the cost savings will be even greater when, by many years, we prematurely end the lives of people who have higher care needs, especially when we factor in social services, disability benefits, equipment, and other costs on top of the direct savings to health care budgets. But this is not how we should create budgets or measure outcomes. Our socialized health care system is meant to serve those with disabilities, not consider them a cost to the system.

The Canadian government is currently deciding on the timing for its further roll-out of MAiD, this time for mental illness and with no legislative changes to the current safeguards. This expansion is alarming given what we know is happening already to disabled Canadians under the existing MAiD regime. The Canadian Association of Chairs of Psychiatry wrote a letter in 2022—and some testified more recently in Parliament—that we are not ready for this development. They have warned that there is no evidence to guide decisions about who with mental illness would not get better. The evidence suggests that for every 5 people whose lives would be ended based on the sole medical condition of mental illness, 2 or 3 would have recovered. We expect to have much higher numbers qualifying for MAiD on the grounds of mental illness in Canada than in other jurisdictions that allow assisted death for this reason, since barriers to care and unmitigated psycho-social suffering do not have to be rectified in this country (as they do elsewhere) before being granted MAiD.

Our government has allowed the incredible power and influence of certain lobby groups and their members to control the public discourse and policies around MAiD and its expansion, prioritizing access to MAiD over the safety of Canadians. Besides the current discussion about when to legalize MAiD for mental illness, the parliamentary committee has also recommended expansion to children and MAiD by advance directives. With eligibility for MAiD continuing to broaden, we are not giving priority to serving those most in need, but instead seem intent on rapidly expanding a path to end their lives.

[1] Disabilities is an umbrella term that includes impairment, chronic illness and/or other conditions.

Dr. Ramona Coelho is a family physician in London, Ontario. Her practice largely serves marginalized patients.

Alberta

‘Far too serious for such uninformed, careless journalism’: Complaint filed against Globe and Mail article challenging Alberta’s gender surgery law

Published on

Macdonald-Laurier Institute

Macdonald Laurier Institute challenges Globe article on gender medicine

The complaint, now endorsed by 41 physicians, was filed in response to an article about Alberta’s law restricting gender surgery and hormones for minors.

On June 9, the Macdonald-Laurier Institute submitted a formal complaint to The Globe and Mail regarding its May 29 Morning Update by Danielle Groen, which reported on the Canadian Medical Association’s legal challenge to Alberta’s Bill 26.

Written by MLI Senior Fellow Mia Hughes and signed by 34 Canadian medical professionals at the time of submission to the Globe, the complaint stated that the Morning Update was misleading, ideologically slanted, and in violation the Globe’s own editorial standards of accuracy, fairness, and balance. It objected to the article’s repetition of discredited claims—that puberty blockers are reversible, that they “buy time to think,” and that denying access could lead to suicide—all assertions that have been thoroughly debunked in recent years.

Given the article’s reliance on the World Professional Association for Transgender Health (WPATH), the complaint detailed the collapse of WPATH’s credibility, citing unsealed discovery documents from an Alabama court case and the Cass Review’s conclusion that WPATH’s guidelines—and those based on them—lack developmental rigour. It also noted the newsletter’s failure to mention the growing international shift away from paediatric medical transition in countries such as the UK, Sweden, and Finland. MLI called for the article to be corrected and urged the Globe to uphold its commitment to balanced, evidence-based journalism on this critical issue.

On June 18, Globe and Mail Standards Editor Sandra Martin responded, defending the article as a brief summary that provided a variety of links to offer further context. However, the three Globe and Mail news stories linked to in the article likewise lacked the necessary balance and context. Martin also pointed to a Canadian Paediatric Society (CPS) statement linked to in the newsletter. She argued it provided “sufficient context and qualification”—despite the fact that the CPS itself relies on WPATH’s discredited guidelines. Notwithstanding, Martin claimed the article met editorial standards and that brevity justified the lack of balance.

MLI responded that brevity does not excuse misinformation, particularly on a matter as serious as paediatric medical care, and reiterated the need for the Globe to address the scientific inaccuracies directly. MLI again called for the article to be corrected and for the unsupported suicide claim to be removed. As of this writing, the Globe has not responded.

Letter of complaint

June 9, 2025

To: The Globe and Mail
Attn: Sandra Martin, standards editor
CC: Caroline Alphonso, health editor; Mark Iype, deputy national editor and Alberta bureau chief

To the editors;

Your May 29 Morning Update: The Politics of Care by Danielle Groen, covering the Canadian Medical Association’s legal challenge to Alberta’s Bill 26, was misleading and ideologically slanted. It is journalistically irresponsible to report on contested medical claims as undisputed fact.

This issue is far too serious for such uninformed, careless journalism lacking vital perspectives and scientific context. At stake is the health and future of vulnerable children, and your reporting risks misleading parents into consenting to irreversible interventions based on misinformation.

According to The Globe and Mail’s own Journalistic Principles outlined in its Editorial Code of Conduct, the credibility of your reporting rests on “solid research, clear, intelligent writing, and maintaining a reputation for honesty, accuracy, fairness, balance and transparency.” Moreover, your principles go on to state that The Globe will “seek to provide reasonable accounts of competing views in any controversy.” The May 29 update violated these principles. There is, as I will show, a widely available body of scientific information that directly contests the claims and perspectives presented in your article. Yet this information is completely absent from your reporting.

The collapse of WPATH’s credibility

The article’s claim that Alberta’s law “falls well outside established medical practice” and could pose the “greatest threat” to transgender youth is both false and inflammatory. There is no global medical consensus on how to treat gender-distressed young people. In fact, in North America, guidelines are based on the Standards of Care developed by the World Professional Association for Transgender Health (WPATH)—an organization now indisputably shown to place ideology above evidence.

For example, in a U.S. legal case over Alabama’s youth transition ban, WPATH was forced to disclose over two million internal emails. These revealed the organization commissioned independent evidence reviews for its latest Standards of Care (SOC8)—then suppressed those reviews when they found overwhelmingly low-quality evidence. Yet WPATH proceeded to publish the SOC8 as if it were evidence-based. This is not science. It is fraudulent and unethical conduct.

These emails also showed Admiral Rachel Levine—then-assistant secretary for Health in the Biden administration—pressured WPATH to remove all lower age recommendations from the guidelines—not on scientific grounds, but to avoid undermining ongoing legal cases at the state level. This is politics, not sound medical practice.

The U.K.’s Cass Review, a major multi-year investigation, included a systematic review of the guidelines in gender medicine. A systematic review is considered the gold standard because it assesses and synthesizes all the available research in a field, thereby reducing bias and providing a large comprehensive set of data upon which to reach findings. The systematic review of gender medicine guidelines concluded that WPATH’s standards of care “lack developmental rigour” and should not be used as a basis for clinical practice. The Cass Review also exposed citation laundering where medical associations endlessly recycled weak evidence across interlocking guidelines to fabricate a false consensus. This led Cass to suggest that “the circularity of this approach may explain why there has been an apparent consensus on key areas of practice despite the evidence being poor.”

Countries like SwedenFinland, and the U.K. have now abandoned WPATH and limited or halted medicalized youth transitions in favour of a therapy-first approach. In Norway, UKOM, an independent government health agency, has made similar recommendations. This shows the direction of global practice is moving away from WPATH’s medicalized approach—not toward it. As part of any serious effort to “provide reasonable accounts of competing views,” your reporting should acknowledge these developments.

Any journalist who cites WPATH as a credible authority on paediatric gender medicine—especially in the absence of contextualizing or competing views—signals a lack of due diligence and a fundamental misunderstanding of the field. It demonstrates that either no independent research was undertaken, or it was ignored despite your editorial standards.

Puberty blockers don’t ‘buy time’ and are not reversible

Your article repeats a widely debunked claim: that puberty blockers are a harmless pause to allow young people time to explore their identity. In fact, studies have consistently shown that between 98 per cent and 100 per cent of children placed on puberty blockers go on to take cross-sex hormones. Before puberty blockers, most children desisted and reconciled with their birth sex during or after puberty. Now, virtually none do.

This strongly suggests that blocking puberty in fact prevents the natural resolution of gender distress. Therefore, the most accurate and up-to-date understanding is that puberty blockers function not as a pause, but as the first step in a treatment continuum involving irreversible cross-sex hormones. Indeed, a 2022 paper found that while puberty suppression had been “justified by claims that it was reversible … these claims are increasingly implausible.” Again, adherence to the Globe’s own editorial guidelines would require, at minimum, the acknowledgement of the above findings alongside the claims your May 29 article makes.

Moreover, it is categorically false to describe puberty blockers as “completely reversible.” Besides locking youth into a pathway of further medicalization, puberty blockers pose serious physical risks: loss of bone densityimpaired sexual developmentstunted fertility, and psychosocial harm from being developmentally out of sync with peers. There are no long-term safety studies. These drugs are being prescribed to children despite glaring gaps in our understanding of their long-term effects.

Given the Globe’s stated editorial commitment to principles such as “accuracy,” the crucial information from the studies linked above should be provided in any article discussing puberty blockers. At a bare minimum, in adherence to the Globe’s commitment to “balance,” this information should be included alongside the contentious and disputed claims the article makes that these treatments are reversible.

No proof of suicide prevention

The most irresponsible and dangerous claim in your article is that denying access to puberty blockers could lead to “depression, self-harm and suicide.” There is no robust evidence supporting this transition-or-suicide narrative, and in fact, the findings of the highest-quality study conducted to date found no evidence that puberty suppression reduces suicide risk.

Suicide is complex and attributing it to a single cause is not only false—it violates all established suicide reporting guidelines. Sensationalized claims like this risk creating contagion effects and fuelling panic. In the public interest, reporting on the topic of suicide must be held to the most rigorous standards, and provide the most high-quality and accurate information.

Euphemism hides medical harm

Your use of euphemistic language obscures the extreme nature of the medical interventions being performed in gender clinics. Calling double mastectomies for teenage girls “paediatric breast surgeries for gender-affirming reasons” sanitizes the medically unnecessary removal of a child’s healthy organs. Referring to phalloplasty and vaginoplasty as “gender-affirming surgeries on lower body parts” conceals the fact that these are extreme operations involving permanent disfigurement, high complication rates, and often requiring multiple revisions.

Honest journalism should not hide these facts behind comforting language. Your reporting denies youth, their parents, and the general public the necessary information to understand the nature of these interventions. Members of the general public rely greatly on the news media to equip them with such information, and your own editorial standards claim you will fulfill this core responsibility.

Your responsibility to the public

As a flagship Canadian news outlet, your responsibility is not to amplify activist messaging, but to report the truth with integrity. On a subject as medically and ethically fraught as paediatric gender medicine, accuracy is not optional. The public depends on you to scrutinize claims, not echo ideology. Parents may make irreversible decisions on behalf of their children based on the narratives you promote. When reporting is false or ideologically distorted, the cost is measured in real-world harm to some of our society’s most vulnerable young people.

I encourage the Globe and Mail to publish an updated version on this article in order to correct the public record with the relevant information discussed above, and to modify your reporting practices on this matter going forward—by meeting your own journalistic standards—so that the public receives balanced, correct, and reliable information on this vital topic.

Trustworthy journalism is a cornerstone of public health—and on the issue of paediatric gender medicine, the stakes could not be higher.

Sincerely,

Mia Hughes
Senior Fellow, Macdonald-Laurier Institute
Author of The WPATH Files

The following 41 physicians have signed to endorse this letter:
Dr. Mike Ackermann, MD
Dr. Duncan Veasey, Psy MD
Dr. Rick Gibson, MD
Dr. Benjamin Turner, MD, FRCSC
Dr. J.N. Mahy, MD, FRCSC, FACS
Dr. Khai T. Phan, MD, CCFP
Dr. Martha Fulford, MD
Dr. J. Edward Les, MD, FRCPC
Dr. Darrell Palmer, MD, FRCPC
Dr. Jane Cassie, MD, FRCPC
Dr. David Lowen, MD, FCFP
Dr. Shawn Whatley, MD, FCFP (EM)
Dr. David Zitner, MD
Dr. Leonora Regenstreif, MD, CCFP(AM), FCFP
Dr. Gregory Chan, MD
Dr. Alanna Fitzpatrick, MD, FRCSC
Dr. Chris Millburn, MD, CCFP
Dr. Julie Curwin, MD, FRCPC
Dr. Roy Eappen, MD, MDCM, FRCP (c)
Dr. York N. Hsiang, MD, FRCSC
Dr. Dion Davidson, MD, FRCSC, FACS
Dr. Kevin Sclater, MD, CCFP (PC)
Dr. Theresa Szezepaniak, MB, ChB, DRCOG
Dr. Sofia Bayfield, MD, CCFP
Dr. Elizabeth Henry, MD, CCFP
Dr. Stephen Malthouse, MD
Dr. Darrell Hamm, MD, CCFP
Dr. Dale Classen, MD, FRCSC
Dr. Adam T. Gorner, MD, CCFP
Dr. Wesley B. Steed, MD
Dr. Timothy Ehmann, MD, FRCPC
Dr. Ryan Torrie, MD
Dr. Zachary Heinricks, MD, CCFP
Dr. Jessica Shintani, MD, CCFP
Dr. Mark D’Souza, MD, CCFP(EM), FCFP*
Dr. Joanne Sinai, MD, FRCPC*
Dr. Jane Batt, MD*
Dr. Brent McGrath, MD, FRCPC*
Dr. Leslie MacMillan MD FRCPC (emeritus)*
Dr. Ian Mitchell, MD, FRCPC*
Dr. John Cunnington, MD

*Indicates physician who signed following the letter’s June 9 submission to the Globe and Mail, but in advance of this letter being published on the MLI website.

Continue Reading

Alberta

High costs, low returns – Canada’s wildly expensive emissions cap

Published on

CNAPS.org

In this new commentary, Director of Energy, Natural Resources, and Environment Heather Exner-Pirot reveals why the Canadian government’s oil and gas emissions cap isn’t just expensive – it’s economic insanity.

While Canadians complained about the country’s C$80 carbon tax, the federal government is quietly preparing a climate policy that costs between C$96,000 and C$289,000 per tonne of carbon actually reduced. That’s not a typo.
 
Canada’s proposed emissions cap on oil and gas would destroy over 40,000 jobs and slash C$20.5 billion from the Canadian economy – all while barely denting global emissions. Why? Because cleaner Canadian energy will simply be replaced by dirtier oil from Venezuela, Iraq, and Mexico. This will also greatly impact the United States, which relies heavily on Canadian oil to fuel its economy.
 
Canadian oil sands have slashed their emissions per barrel by 30 per cent since 2013, outperforming global competitors. The country’s conventional oil and gas are actually cleaner than world averages. Yet this policy punishes Canada’s best-in-class industry while handing market share to higher-polluting foreign producers. The result? Global emissions could actually increase while Canada’s energy sector gets kneecapped.
 
This isn’t climate policy – it’s economic self-sabotage disguised as environmental virtue. There has to be a better way to build Canada’s – and America’s – energy future.

By Heather Exner-Pirot

Canada is the world’s third-largest exporter of oil, fourth-largest producer, and top source of imports to the United States. Much of Canada’s oil wealth is concentrated in the oil sands in northern Alberta, which hosts 99 percent of the country’s enormous oil endowment: about 160 billion barrels of proven reserves, of a total resource of approximately 1.8 trillion barrels. This is the major source of oil to the United States refinery complex, a large part of which is optimized for the oil sands’ heavy oil.

Reliability of energy supply has remerged as a major geopolitical issue. Canadian oil and gas is an essential component of North American energy security. Yet a proposed cap on emissions from the sectors promises to cut Canadian production and exports in the years ahead. It would be hard to provide less environmental benefit for a higher economic and security cost. There are far better ways to reduce emissions while maintaining North America’s security of energy supply.

The high cost of the cap

In 1994 a Liberal federal government, Alberta provincial conservative government and representatives from the oil and gas industry, working together through the national oil sands task force, developed A New Energy Vision for Canada. Their efforts turned what was then a middling resource into a trillion dollar nation-building project. Production has increased tenfold since the report came out.

The task force acknowledged the need for industry to “put its best efforts toward … reducing greenhouse gas emissions.” However, it also expected governments to “understand” that there “is no benefit to Canada or to the environment to have production and value-added processing done outside of the country in less efficient jurisdictions … policies set by regulator must not result in discouraging oil sands production.”

As part of its efforts to meet its climate goals under the Paris Accord, the Canadian government proposed a regulatory framework for an emissions cap on the oil and gas sector in December 2023. It set a legally binding limit on greenhouse gas emissions, targeting a 35 to 38 percent reduction from 2019 levels by 2030 for upstream operations, through regulations to be made under the Canadian Environmental Protection Act, 1999 (CEPA).

The federal government has not yet finalized its proposed regulations. However, industry experts and economists have criticized the current iteration as logistically unworkable, overly expensive, and likely to be challenged as unconstitutional. In effect, this policy layers a cap-and-trade system for just one sector (oil and gas) on top of a competing carbon pricing mechanism (the large-emitter trading systems, often referred to as the industrial carbon price), a discriminatory practice that also undermines the entire economic rationale of a carbon pricing system.

While the Canadian government has maintained that it is focused on reducing emissions rather than production – the latter of which would put it at odds with provincial jurisdiction over non-renewable resources – a series of third party analyses as well as the Parliamentary Budget Office’s own impact assessment find it would indeed constrain Canadian oil and gas production. The economic cost of the emissions cap far exceeds any corresponding benefit in reduced emissions.

How much will the emissions cap cost in terms of dollar per tonne of carbon in avoided emissions, both domestically and globally? Based solely on the cost to the Canadian economy, we estimate the emission cap is equivalent to a C$2,887/tonne carbon price by 2032.

Assuming no impact on global demand and full substitution by non-Canadian crudes, it finds that the cost of each tonne of carbon displaced globally is between C$96,000 to C$289,000 for oil sands bitumen production. For displaced Canadian conventional and natural gas, the cost is infinite, i.e. global emissions would actually be higher for every barrel or unit of Canadian oil and gas displaced with competitor products as a result of the emissions cap.

Canadian oil and gas emissions reduction efforts

The oil and gas sector is the highest emitting economic sector in Canada. However, it has made substantial efforts to reduce emissions over the past two decades and is succeeding. Absolute emissions in the sector peaked in 2014, despite production growing by over a million barrels of oil equivalent since (see Figure 1).

Figure 1 Indexed greenhouse gas (GHG) emissions (and gross domestic product (GDP) at basic prices, for the oil and gas extraction industry, 2009 to 2022 (2009 = 100). Source: Statistics Canada 2024.

Much of this success can be attributed to methane capture, particularly in the natural gas and conventional oil sectors, where absolute emissions peaked in 2007 and 2014 respectively.

Since 2014, the oil sands have dramatically increased production by over a million barrels per day, but at the same time have reduced the emissions per barrel every year, leaving the absolute emissions of the oil and gas sector relatively flat. The oil sands are performing well vis-à-vis their international peers, seeing their emissions per barrel decline by 30 percent since 2013, compared to 21 percent for global majors and 34 percent for US E&Ps (exploration and production companies) (see Figure 2).

Figure 2 Indexed Oil Sands GHG relative intensity trend (2013=100). Source: BMO Capital Markets, “I Want What You Got: Canada’s Oil Resource Advantage,” April 2025

On an emissions intensity absolute basis, the oil sands have significantly outperformed their peers, shaving off 25kg/barrel of emissions since 2013 (see Figure 3) and more than 65kg/barrel since the oil sands task force wrote their report in 1994.

As emissions improvements from methane reductions plateau, the oil sands are likely to outperform their conventional peers in emissions per barrel reductions going forward. The sector is working on strategies such as solvent extraction and carbon capture and storage that, if implemented, would reduce the life-cycle emissions per barrel of oil sands to levels at or below the global crude average.

Figure 3 Emissions intensity absolute change (kg CO2e/bbl) (2013–24E) Source: BMO Capital Markets, 2025

The high cost of the cap

Several parties have analyzed the proposed emissions cap to determine its economic and production impact. The results of the assessments vary widely. For the purposes of this commentary we rely on the federal Office of the Parliamentary Budget Officer (PBO), which published its analysis of the proposed emissions cap in March 2025. Helpfully, the PBO provided a table summarizing the main findings of the various analyses (see Table 1).

The PBO found that the required reduction in upstream oil and gas sector production levels under an emissions cap would lower real gross domestic product (GDP) in Canada by 0.33 percent in 2030 and 0.39 percent in 2032, and reduce nominal GDP by C$20.5 billion by 2032. The PBO further estimated that achieving the legal upper bound would reduce economy-wide employment in Canada by 40,300 jobs and full-time equivalents by 54,400 in 2032.

Table 2 Comparison of estimated impacts of the proposed emissions cap in 2030. Source: PBO 2025

However, the PBO does not estimate the carbon price per tonne of emissions reduced. This is a useful metric as Canadians have become broadly familiar with the real-world impacts of a price on carbon. The federal government quashed the consumer carbon price at $80/tonne in March 2025, ahead of the federal election, due to its unpopularity and perceived impacts on affordability. The federal carbon pricing benchmark is scheduled to hit C$170 in 2030. ECCC has quantified the damages of a tonne of carbon dioxide – referred to as the “Social Cost of Carbon” – as C$294/tonne.

Based on PBO assumptions that the emissions cap will reduce emissions by 7.1MT and reduce GDP by $20.5 billion in 2032, the implied carbon price is C$2,887/tonne.

Emissions cap impact in a global context

Even this eye-popping figure does not tell the full story. The Canadian oil and gas production that must be withdrawn to meet the requirements of the emissions cap will be replaced in global markets from other producers; there is no reason to assume the emissions cap will affect global demand.

Based on life-cycle GHG emissions of the sample of crudes used in the US refinery complex, Canadian oil sands produce only 1 to 3 percent higher emissions than a global average[1] (see Figure 4), with some facilities producing lower emissions than the average barrel.

Figure 4 Life Cycle GHG emissions of crude oils (kg CO2e/bbl). Source:  BMO Capital Markets 2025

As such, the emissions cap, if applied just to oil sands production, would only displace global emissions of 71,000  to 213,000 tonnes (1 to 3 percent of 7.1MT). At a cost of C$20.5 billion for those global emissions reductions, the price of carbon is equivalent to C$96,000 to C$289,000 per tonne (see Figure 5).

Figure 5 Cost per tonne of emissions cap behind domestic carbon all (left) and post-global crude substitution (right)

For any displaced conventional Canadian crude oil or natural gas, the situation becomes absurd. Because Canadian conventional oil and natural gas have a lower emissions intensity than global averages, global product substitutions resulting from the emissions cap would actually serve to increase global emissions, resulting in an infinite price per tonne of carbon.

The C$100k/tonne carbon price estimate is probably low

We believe our assessment of the effective carbon price of the emissions cap at C$96,000+/tonne to be conservative for the following reasons.

First, it assumes Canadian heavy oil will be displaced in global markets by an average, archetypal crude. In fact, it would be displaced by other heavy crudes from places like Venezuela, Mexico, and Iraq (see Figure 4), which have higher average emissions per barrel than Canadian oil sands crudes. In such a circumstance, global emissions would actually rise and the price per carbon tonne from an emissions cap on oil sands production would also effectively be infinite.

Secondly, emissions cap impact assumptions by the PBO are likely conservative. Those by ECCC, based on a particular scenario outlook, are already outdated. ECCC assumed a production loss of only 0.7 percent by 2030, with oil sands production hitting approximately 3.7 million barrels (MMbbls) per day of bitumen production in 2030. According to S&P Global analysis, that level is likely to be hit this year.[2]

S&P further forecasts oil sands production to reach 4.0 MMbbls by 2030, or about 300,000 barrels more than it produces today. This would represent a far lower production growth rate than the oil sands have experienced in the past five years. But assuming the S&P forecast is correct, production would need to decline in the oil sands by 8 percent to meet the emissions cap requirements. PBO assumed only a 5.4 percent overall oil and gas production loss and ECCC assumed only 0.7 percent, while Conference Board of Canada assumed an 11.1 percent loss and Deloitte assumed 11.5 percent (see Table 1). Production numbers to date more closely align with Conference Board of Canada and Deloitte projections.

Let’s make the Canadian oil and gas sector better, not smaller

The Canadian oil and gas sector, and in particular the oil sands, has a responsibility to do their part to reduce emissions while maintaining competitive businesses that can support good Canadian jobs, provide government revenues and diversify exports. The oil sands sector has re-invested for decades in continuous improvements to drive down production costs while improving its emissions per barrel.

It is hard to conceive of a more expensive and divisive way to reduce emissions from the sector and from the Canadian economy than the proposed emissions cap. Other expensive programs, such as Norway’s EV subsidies, the United Kingdom’s offshore wind contracts-for-difference, Germany’s Energiewende feed-in-tariffs and surcharges, and US Inflation Reduction Act investment tax credits, don’t come close to the high costs of the emissions cap on a price-per-tonne of carbon abated  basis.

The emissions cap, as currently proposed, will make Canada’s oil and gas sector significantly less competitive, harm investment, and undermine Canada’s vision to be an energy superpower. This policy will also reduce the oil and gas sector’s capacity to invest in technologies that drive additional emission reductions, such as solvents and carbon capture, especially in our current lower price environment. As such it is more likely to undermine climate action than support it.

The federal and provincial governments have come together to advance a vision for Canadian energy in the past. In this moment, they have the opportunity once again to find real solutions to the climate challenge while harnessing the energy sector to advance Canada’s economic well-being, productivity, and global energy security.


About the author

Heather Exner-Pirot is Director of Energy, Natural Resources, and Environment at the Macdonald-Laurier Institute.

Continue Reading

Trending

X