Submissions

Summary of Pathways Alliance’s Submission on the Canada Gazette, Part I, Volume 157, Number 50: Regulations Amending the Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector)

Submission Date: February 14, 2024

On December 16, 2023, the Government of Canada issued Canada Gazette, Part 1, Volume 157, Number 50: Regulations Amending the Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector) (‘draft Methane Regulations’). The Pathways Alliance’s (Pathways’) feedback on the draft Methane Regulations provided in response to the Gazette 1 comment period, which concluded on February 14, 2024, can be summarized into three key areas as follows:

Summary of Pathways Alliance’s Submission on the proposed Regulatory Framework for an Oil and Gas Sector Greenhouse Gas Emissions Cap

Submission Date: February 5, 2024

On December 7, 2023, Environment and Climate Change Canada (ECCC) published the proposed Regulatory Framework for an Oil and Gas Sector Greenhouse Gas Emissions Cap (the “Emissions Cap”). The Pathways Alliance’s (Pathways’) feedback on the proposed Emissions Cap provided in response to the Government of Canada engagement, which concluded on February 5, 2024, can be summarized as follows:

Pathways previously provided comments in September 2022 with respect to the Discussion Paper entitled Options to cap and cut oil and gas sector greenhouse gas emissions to achieve 2030 goals and net-zero by 2050. While there have been some proposed changes between the March 2022 Emissions Reduction Plan, the Discussion Paper and the proposed Emissions Cap, Pathways submits that a cap-and-trade regime administered through CEPA remains untenable. Pathways feedback on the proposed Emissions Cap can be summarized as follows:

---

Summary of Pathways Alliance’s Submission on the Proposed Clean Electricity Regulation

Submission Dates: September 29 and November 2, 2023

In the Canada Gazette, Part I, August 19, 2023, the federal government published draft Clean Electricity Regulations (‘CER’) which, if enacted, would require fossil fuel power generation units to meet an emissions performance standard of 30 t /GWh or operate for less than 450 hours/yr. 

Pathways recognizes that achievement of net zero GHG emissions (scope 1 and 2) by 2050 from Pathways members’ oil sands operations will require the reduction of GHG emissions associated with electricity production. However, the proposed CER have the potential to result in significant impacts to Pathways members’ oil sands operations and plans for carbon capture projects. Pathways is concerned with the proposed CER and the potential cumulative impact of climate-related compliance costs, regulatory risks and increased operating costs, which undermine the competitiveness of the oil sands industry. 

---

Summary of Pathways Alliance’s Submission on the Department of Finance Canada’s Consultation on Budget 2023 Measures

Submission Date: September 8, 2023

Pathways members view the ITCs as a critical component of the fiscal policy framework necessary to incent investment, attract capital, create significant new jobs, and share in economic benefits with Indigenous groups as the oil sands sector moves forward towards decarbonization of Canadian energy production.

The legislative proposals, as drafted, contain design and drafting deficiencies that raise significant concerns with respect to accessing, securing, and retaining credit for decarbonization initiatives. Should these concerns not be addressed, it is the perspective of Pathways that the value of the ITCs will be materially eroded and may not enable intended outcomes to be achieved.

In the submission with respect to the ITCs under the Consultation on Budget 2023 Measures, Pathways urged Finance Canada to address the following key areas of concern.

---

Summary of Pathways Alliance’s Submission on the Federal Oil and Gas Emissions Cap Discussion Paper

Submission Date: September 30, 2022

In the discussion document Options to Cap and Cut Oil and Gas Sector Greenhouse Gas Emissions to Achieve 2030 Goals and Net-Zero by 2050 (Emissions Cap) the federal government proposes two approaches to reduce greenhouse gas (GHG) emissions from the oil and gas sector at a pace and scale deemed necessary to achieve Canada’s 2030 and 2050 climate targets: 1) a new cap-and-trade system or 2) a separate and more expensive carbon pricing system.

The Pathways Alliance (Pathways) supports the government’s goals of achieving a large absolute reduction in GHG emissions by 2030 from the oil and gas sector, and the goal of achieving net-zero by 2050. Canada’s energy transition will require significant investment into a broad suite of technologies, some of which are not yet commercially available. The cost of decarbonization corresponding to Canada’s ambition is expected to be high and will take time. Balancing climate ambition with what is feasible will be key to a successful energy transition. Importantly, Canada needs an enabling policy framework and a competitive investment structure that will attract global capital and incentivize investment in decarbonization technologies within the specific context of Canada’s climate goals otherwise, the country is at risk of flight of capital to jurisdictions with more competitive fiscal policy. Pathways notes the many benefits that Canada stands to realize by advancing decarbonization projects at scale such as lowering emissions, creating jobs, and supporting Indigenous economic reconciliation while enabling a robust economy to support the country’s transition.