Comment on the cap here! | Sierra Club Canada

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Subject: Emissions cap framework formal written submission

To the Government of Canada,

Please find below my formal written submission to the Government of Canada regarding the Regulatory Framework for an Oil and Gas Sector Greenhouse Gas Emissions Cap.

I was very happy to see the announcement of an emissions cap, but now we need to act on it rapidly. On behalf of myself and the majority of Canadians who want the oil and gas industry to do its fair share of the work to cut our emissions I am writing to say that:

- The emissions cap must be implemented without delay. It has already been far too long since this policy was first proposed and the oil and gas lobby have delayed it long enough already. 

- There must be no loopholes or exemptions for the oil and gas industry under the cap and no proposed decarbonization fund as a fund does not represent actual emissions reductions. It must be binding across the entire oil and gas sector without exception and focus on actual physical emissions reductions from the sector, not offsets. 

- The emissions cap must not give special preference to LNG or other fuels because industry claims them to be ‘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 (1).

- Real prosperity for communities means supporting the growth of local renewable energy projects, like the Métis Nation of Alberta’s 4.86-megawatt solar farm that will power 1,200 homes and prevent 4,700 tonnes of carbon dioxide emissions each year (2). 

- Communities across the country and Indigenous communities in particular, which were hit hard by wildfires this summer (3), are suffering as a result of the oil and gas industry’s lack of action to tackle industry emissions (4). 

- The oil and gas sector meanwhile contributes less and less to jobs and revenue in Canada even when seeing growth. (5)

- The measures that are proposed in the cap are a good first step but they should be made stronger so it aligns with Canada’s climate targets of 40-45% emissions reductions by 2030. The International Energy Agency is also calling for a 60 per cent reduction in oil and gas emissions by 2030 to avoid the worst climate catastrophes. (6)

- The cap is not an issue of Alberta versus the rest of Canada. Two recent independent polls found a majority of Albertans support a cap on emissions (7).  The cap also has majority support among Canadians, 7 out of 10 (8). The President of the Canadian Labour Congress and Canada’s Building Trade Union have also made statements in favour of the cap.

- An emissions cap is an issue of fairness to Canadians. We are doing our part to fight climate change individually, the oil and gas industry should be required to do the same. The oil and gas sector, while only 5% of Canada’s economy, is Canada’s most polluting sector causing 27% of national emissions. (9,10)

We, individuals, should not be asked to pay to clean up the oil and gas industry’s mess because they won’t do their part to tackle climate change. The emissions cap will not cost consumers. The oil and gas industry is capable of doing their part to lower emissions and has seen huge profits. Of every dollar of inflation over the last two years in Canada, 25 cents of that has gone to oil and gas and mining extraction profits. (11)

A cap on emissions at the same level as Canada’s national climate target (45% below 2005 levels by 2030) would also avoid the premature deaths of about 4,860 people in Canada over a decade, and come with 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. (12)

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.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 
(2) https://www.theenergymix.com/alberta-metis-solar-farm-delivers-4-86-nw-builds-sovereignty-and-self-sufficiency/
(3) https://apnews.com/article/canada-wildfire-indigenous-land-first-nations-impact-3faabbfadfe434d0bd9ecafb8770afce 
(4) https://www.cbc.ca/news/canada/wildfires-climate-change-carbon-88-1.6852178 
(5) https://policyalternatives.ca/publications/reports/canada%e2%80%99s-energy-sector 
(6) https://www.iea.org/reports/the-oil-and-gas-industry-in-net-zero-transitions/executive-summary
(7) https://www.cbc.ca/news/canada/edmonton/slim-majority-of-albertans-support-national-oil-and-gas-emissions-cap-polls-suggest-1.6966787 
(8) 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/ 
(9) https://www150.statcan.gc.ca/n1/pub/36-28-0001/2021007/article/00003-eng.htm 
(10) https://www.canada.ca/en/environment-climate-change/services/climate-change/greenhouse-gas-emissions/sources-sinks-executive-summary-2022.html#toc5 
(11) https://environmentaldefence.ca/2023/02/03/big-oil-is-posting-colossal-2022-profits/
& https://www.facebook.com/reel/885766123024660
(12) https://cape.ca/press_release/fair-oil-gas-emissions-cap-would-prevent-4800-premature-deaths-in-canada/