Comment on the cap Dec_2024 | Sierra Club Canada

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Subject: Proposed Oil and Gas Sector Greenhouse Gas Emissions Cap Regulations, Formal Written Submission

To the Government of Canada,

Please find below my formal written submission to the Government of Canada regarding the proposed Oil and Gas Sector Greenhouse Gas Emissions Cap Regulations.

I stand with the climate impact survivors who travelled to Ottawa recently to call for this cap and agree we must act now to protect what we love (1). On behalf of myself and the majority of Canadians who want the oil and gas corporations to do their fair share of the work to cut our emissions (2) I am writing to say that the emissions cap must be implemented without delay. Further:

- There must be no loopholes or exemptions for oil and gas corporations under the cap and any carbon credits under the cap must be confined to Canada to localize any benefits and to ensure the system can be adequately regulated. An emissions cap should be used as a measure to spur green innovation in Canada, to localize green jobs in communities, and to provide a stable path to decarbonization that holds the biggest polluters accountable. Per-barrel emissions from oil sands increased since 2018 - this is unacceptable (3).

- For many oil and gas companies the emissions cap can be met through further cheap methane efforts and there are still cost-effective options that are ripe for the picking as shown by the Pembina Institute on November 14th, 2024 (4).

-  The emissions cap must not give special preference to LNG or other fuels because of corporate claims they are ‘cleaner’ as these will not help us meet climate targets. Methane must also not be exempted from the cap in any way. Indeed, large amounts of oilsands emissions go unreported each year, and Canada is underestimating oil sands emissions by up to 6000%, making a well regulated and monitored cap all the more important (5).

- The measures that are proposed in the cap are a good first step but a cap on emissions at the same level as Canada’s national climate target (45% below 2005 levels by 2030) is possible and would also avoid the premature deaths of about 4,860 people in Canada over a decade. Those lives saved would also come with an economic benefit of CAD $45.1 billion and this is before considering the climate change and non-fatal impacts of the air pollution prevented by a strong cap. (6)

An emissions cap is an issue of fairness to individual Canadians and other sectors that have already done their part to reduce emissions. Oil and gas corporations, while only 5% of Canada’s economy, are Canada’s most polluting sector causing around 30% of national emissions. Between 1990 and 2022, emissions from oil sands production grew by 467% and conventional oil production by 24% – since 2005 emissions overall increased 11% (7).

Oil and gas corporations are capable of doing their part to lower emissions with four companies alone (Suncor, CNRL, Cenovus, and Imperial) having combined total profits of $10.4 billion in the first half of 2024 (8). As of 2023, of every dollar of additional inflation in Canada, 25 cents of that was going to oil and gas and mining extraction profits (9). 

We, individuals, should not be asked to pay to clean up oil and gas corporations' mess because they won’t do their part to tackle climate change. Nor should we be burdened with the air pollution or climate impacts their emissions cause.

Sincerely,

[Your Name]

[Postal Code]

Sources and documents with further citations and evidence contained in them that I submit to you, as part of this formal submission, for you to review in regard to the emissions cap:

(1) https://www.protectwhatwelove.ca/ & https://www.hilltimes.com/story/2024/11/04/each-of-our-voices-matter-disaster-survivors-call-for-greater-climate-action-in-ottawa-advocacy-push/440002/ 
(2) https://climateactionnetwork.ca/new-poll-finds-7-in-10-canadians-want-oil-and-gas-emissions-cap-to-ensure-industry-takes-on-its-fair-share-of-climate-action/ & https://www.cbc.ca/news/canada/edmonton/slim-majority-of-albertans-support-national-oil-and-gas-emissions-cap-polls-suggest-1.6966787 
(3) https://www.nationalobserver.com/2024/10/17/opinion/alberta-emissions-cap-math-advertising-campaign
(4) https://www.pembina.org/blog/many-oil-gas-companies-emissions-cap-can-be-met-through-further-efforts-methane
(5) https://www.science.org/doi/10.1126/science.adj6233
&  https://www.independent.co.uk/climate-change/news/canada-emissions-toxic-oil-sands-b2484917.html
&  https://environmentaldefence.ca/2022/10/26/dont-buy-the-hype-lng-is-bad-for-the-climate/
&  https://www.ipolitics.ca/opinions/canadian-gas-wont-help-europe-help-ukraine
&
https://www.nationalobserver.com/2022/06/28/opinion/message-ukraine-dont-be-fooled-push-new-lng-export-facilities
(6) https://cape.ca/press_release/fair-oil-gas-emissions-cap-would-prevent-4800-premature-deaths-in-canada/
(7) https://www150.statcan.gc.ca/n1/pub/36-28-0001/2021007/article/00003-eng.htm & https://www.canada.ca/en/environment-climate-change/services/environmental-indicators/greenhouse-gas-emissions.html & https://www.canada.ca/en/environment-climate-change/services/environmental-indicators/greenhouse-gas-emissions.html#oil-gas
(8) https://environmentaldefence.ca/2024/08/07/big-oil-continues-raking-in-big-profits/
(9) https://policyalternatives.ca/newsroom/news-releases/your-inflation-dollars-may-not-be-going-where-you-think-report