Please read the text of the submission made by Elizabeth May, MP for Saanich–Gulf Islands and Leader of the Green Party of Canada, to the government consultation on the proposed oil and gas sector emissions cap regulations. Read the proposed regulations here.
Department of the Environment
Department of Health
January 8, 2025
To the Department of the Environment and the Department of Health,
I appreciate this opportunity to comment on the proposed oil and gas sector greenhouse gas emissions cap regulations. I am pleased to see this cap moving forward, as it will significantly advance Canada’s progress to meeting its emission reduction targets of 45% to 50% below 2005 levels by 2035 and net-zero emissions by 2050. The oil and gas sector remains the largest source of GHG emissions in Canada.
However there are outstanding issues with the framework that need to be addressed. I am concerned that the government is seeking pathways to continue enabling the oil and gas sector to increase production. The IPCC sixth assessment report made clear that global emissions must be dramatically reduced “at the latest before 2025”, a deadline that has already been missed. The oil and gas sector continues to rake in excess profits while Canadians are faced with an affordability crisis. Environment and Climate Change Canada reported that “operating profits in the oil and gas sector increased tenfold from $6.6 billion in 2019 to $66.6 billion in 2022.” These regulations as proposed will maintain Canada’s complicity in a global temperature increase beyond 2°C.
I offer several recommendations to bolster these regulations. I am grateful for the advocacy of environmental organisations and advocates across Canada, many of whom I have met with and who have made similar recommendations since this cap was first announced.
The current regulations enable the Minister of Environment and Climate Change to permit allowances starting in 2029 to oil and gas producers to increase polluting activities so long as the total pollution falls below the cap. No company should be able to delay reductions until 2030. This violates the best practices in other cap-and-trade systems where allowances are auctioned.
I strongly oppose the proposed usage of untested carbon capture, utilisation and storage technology by these companies to justify continued expansion of production. Pathways Alliance corporations like Canadian Natural Resources Limited, Cenovus Energy, Suncor and others have received billions of federal dollars in subsidies to invest in this technology. The government must stop subsidising fossil fuel production and ensure these companies cannot evade their emissions target responsibilities.
I also oppose the provisions allowing producers to purchase offset credits for up to 20% of their compliance obligations and pay into a “decarbonization fund” for 10% of their obligations, rather than actually take steps to reduce emissions from their production activities. In the latter case, revenues from this decarbonization fund must not be allocated to carbon capture, utilisation and storage technology.
The cap must take effect immediately and not in 2029-2030. I am concerned by the offering of “compliance flexibilities” within the first years of the cap being force. These companies have had ample opportunities to start the process of reducing production and these delays, combined with the loopholes discussed above, will only enable further growth of the sector and delays to meeting the stated targets of the regulations. Such flexibilities must only be provided on a limited case-by-case basis, if they are not eliminated altogether.
I appreciate the government’s commitment to putting these regulations in place. The draft policy is not perfect and needs improvements, but it absolutely must not be watered down further amid pressure from the oil and gas sector and others. It is common knowledge that millions of dollars have been spent already to try to ‘scrap the cap’. These must be put into force without further delay and strengthened to ensure the sector does not use loopholes to continue increasing production.
Thank you for this opportunity to offer comments on the proposed regulations. I would be happy to meet with officials to discuss improvements. Thank you for your time and consideration.
Sincerely,
Elizabeth May, O.C.
Member of Parliament
Saanich–Gulf Islands
Leader of the Green Party of Canada