Alberta
Emissions cap “will not be tolerated in Alberta” – Letter to Environment Minister Guilbeault
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Dear Minister Steven Guilbeault,
The federal government’s draft Regulatory Framework to Cap Oil and Gas Sector Greenhouse Gas Emissions represents a de facto production cap on Alberta’s oil and gas sector. This cap is not realistic or effective, will not achieve its grandiose emissions targets, and will not be tolerated in Alberta.
Today, Alberta is efficiently and effectively regulating and driving emissions from all industrial sectors, including oil and gas, and has been doing so successfully for decades. Our technical submission outlines how your proposed oil and gas emissions cap will undercut this work, and the severe consequences that it will impose on Albertans and all Canadians.
In no way does Alberta’s technical submission alter our province’s position that the proposed emissions cap is unconstitutional. As set out in Section 92A of the Constitution Act, 1867, Alberta has exclusive jurisdiction to manage the rate of non-renewable natural resources production and operational aspects of their development in our province.
If implemented, this cap would have a devastating impact on the economies of Alberta and all of Canada. Analysis from the Conference Board of Canada shows that it would reduce Canada’s GDP by up to $1 trillion between 2030 and 2040 and create up to 151,000 lost jobs across Canada by 2030. Oil and gas production would be curtailed, tens of thousands could be out of work, and the economic impact would be felt from coast to coast.
We have identified an overwhelming number of flaws in your government’s proposed framework. For example, your assumed production forecasts – which form the basis of the cap – are from 2019. Alberta’s total oil and natural gas production has already risen past 2019 levels, and multiple forecasts project oil sands production to increase significantly by 2030. Similarly, the technologies needed to massively abate emissions in the oil and gas sector either don’t yet exist or aren’t being developed at the rate and scale that your modelling requires.
Many of these technologies and investments are supported by Alberta and will eventually deliver real and sustained reductions, but not by 2030. As well, our submission clearly demonstrates that:
• The proposed cap would violate Section 92A of the Constitution, and result in oil and gas production cuts and shut-ins in Alberta.
• It is based on a flawed regulatory framework and policy design that is ineffective, inefficient and will not produce the intended emission reductions.
• The proposed cap will negatively impact Alberta’s economy, as well as the economies of provinces and territories across the country, including the Canadian economy overall.
• It will undercut Canada’s competitiveness and drastically reduce investments in clean technologies like carbon capture, which are critical to meaningfully reducing emissions in the coming years.
• It is unnecessary and will undermine effective provincial-led decarbonizing approaches and initiatives already underway or proposed in Alberta and across Canada.
• It will lead to carbon leakage, with oil and gas production and greenhouse gas emissions increasing in other countries with less robust environmental and human rights standards.
Alberta is confident that the many of issues raised in this document are shared by other provinces and industry leaders, both within the oil and gas sector and beyond.
All greenhouse gas emissions have the same global impact, regardless of the sector or region in which they are produced. Instead of pursuing this unconstitutional cap, we are calling on your government to immediately halt further development and begin meaningful collaboration within established provincial regulatory regimes on oil and gas regulation and emissions reductions.
Alberta would welcome federal investment to help the oil and gas industry – and other industries – advance and adopt technology to reduce emissions to support our goals of carbon neutrality by 2050.
Alberta aspires to achieve a carbon neutral economy without compromising affordable, reliable, and secure energy for Alberta, Canada and the world. We know this relies on and requires investment to advance clean technology solutions.
We invite you to join us in implementing our Emissions Reduction and Energy Development Plan to achieve carbon neutrality while continuing the development of Alberta’s world-class natural energy resources for Canada and the world.
Sincerely,
Rebecca Schulz
Minister of Environment and Protected Areas
Alberta
Open letter to Ottawa from Alberta strongly urging National Economic Corridor
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Canada’s wealth is based on its success as a trading nation. Canada is blessed with immense resources spread across a vast country. It has succeeded as a small, open economy with an enviable standard of living that has been able to provide what the world needs.
Canada has been stuck in a situation where it cannot complete nation‑building projects like the Canadian Pacific Railway that was completed in 1885, or the Trans Canada Highway that was completed in the 1960s. With the uncertainty of U.S. tariffs looming over our country and province, Canada needs to take bold action to revitalize the productivity and competitiveness of its economy – going east to west and not always relying on north-south trade. There’s no better time than right now to politically de-risk these projects.
A lack of leadership from the federal government has led to the following:
- Inadequate federal funding for trade infrastructure.
- A lack of investment is stifling the infrastructure capacity we need to diversify our exports. This is despite federally commissioned reports like the 2022 report by the National Supply Chain Task Force indicating the investment need will be trillions over the next 50 years.
- Federal red tape, like the Impact Assessment Act.
- Burdensome regulation has added major costs and significant delays to projects, like the Roberts Bank Terminal 2 project, a proposed container facility at Vancouver, which spent more than a decade under federal review.
- Opaque funding programs, like the National Trade Corridors Fund (NTCF).
- Which offers a pattern of unclear criteria for decisions and lack of response. This program has not funded any provincial highway projects in Alberta, despite the many applications put forward by the Government of Alberta. In fact, we’ve gone nearly 3 years without decisions on some project applications.
- Ineffective policies that limit economic activity.
- Measures that pit environmental and economic objectives in stark opposition to one another instead of seeking innovative win-win solutions hinder Canada’s overall productivity and investment climate. One example is the moratorium on shipping crude through northern B.C. waters, which effectively ended Enbridge’s Northern Gateway proposal and has limited Alberta’s ability to ship its oil to Asian markets.
In a federal leadership vacuum, Alberta has worked to advance economic corridors across Canada. In April 2023, Alberta, Saskatchewan and Manitoba signed an agreement to collaborate on joint infrastructure networks meant to boost trade and economic growth across the Prairies. Alberta also signed a similar economic corridor agreement with the Northwest Territories in July 2024. Additionally, Alberta would like to see an agreement among all 7 western provinces and territories, and eventually the entire country, to collaborate on economic corridors.
Through our collaboration with neighbouring jurisdictions, we will spur the development of economic corridors by reducing regulatory delays and attracting investment. We recognize the importance of working with Indigenous communities on the development of major infrastructure projects, which will be key to our success in these endeavours.
However, provinces and territories cannot do this alone. The federal government must play its part to advance our country’s economic corridors that we need from coast to coast to coast to support our economic future. It is time for immediate action.
Alberta recommends the federal government take the following steps to strengthen Canada’s economic corridors and supply chains by:
- Creating an Economic Corridor Agency to identify and maintain economic corridors across provincial boundaries, with meaningful consultation with both Indigenous groups and industry.
- Increasing federal funding for trade-enabling infrastructure, such as roads, rail, ports, in-land ports, airports and more.
- Streamlining regulations regarding trade-related infrastructure and interprovincial trade, especially within economic corridors. This would include repealing or amending the Impact Assessment Act and other legislation to remove the uncertainty and ensure regulatory provisions are proportionate to the specific risk of the project.
- Adjusting the policy levers that that support productivity and competitiveness. This would include revisiting how the federal government supports airports, especially in the less-populated regions of Canada.
To move forward expeditiously on the items above, I propose the establishment of a federal/provincial/territorial working group. This working group would be tasked with creating a common position on addressing the economic threats facing Canada, and the need for mitigating trade and trade-enabling infrastructure. The group should identify appropriate governance to ensure these items are presented in a timely fashion by relative priority and urgency.
Alberta will continue to be proactive and tackle trade issues within its own jurisdiction. From collaborative memorandums of understanding with the Prairies and the North, to reducing interprovincial trade barriers, to fostering innovative partnerships with Indigenous groups, Alberta is working within its jurisdiction, much like its provincial and territorial colleagues.
We ask the federal government to join us in a new approach to infrastructure development that ensures Canada is productive and competitive for generations to come and generates the wealth that ensures our quality of life is second to none.
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Devin Dreeshen
Devin Dreeshen was sworn in as Minister of Transportation and Economic Corridors on October 24, 2022.
Alberta
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