Calgary Chamber Notice of Objection Regarding the proposed Oil and Gas Sector Greenhouse Gas Emissions Cap Regulations

The Honourable Steven Guilbeault, P.C., M.P.

Minister of Environment and Climate Change

Dear Minister Guilbeault,

Please consider this as a formal notice of objection in response to the Oil and Gas Sector Greenhouse Gas Emissions Cap Regulations under the Canadian Environmental Protection Act, 1999, Canada Gazette, Part 1, Volume 158, Number 45 – November 9, 2024. Additionally, consider this letter a request that a Board of Review be established pursuant to section 333 of the Canadian Environmental Protection Act, 1999 to review the draft regulations.

The Calgary Chamber represents over 1,400 businesses –roughly 400,000 employees – across sectors and sizes. We are an independent, non-profit, non-partisan organization, that seeks to serve and advocate for the business community. We are deeply concerned about the serious impact that the Oil and Gas Sector Greenhouse Gas Emissions Cap Regulations (the emissions cap) would have on affordability, prosperity, energy security and productivity.

The Calgary Chamber and its members remain committed to reducing emissions, recognizing the significant challenge climate change poses to our planet and economy. However, we know a sector-specific cap on emissions is neither an effective nor efficient tool to address this challenge. Rather than support investment, the emissions cap would create uncertainty, unfavorable economic conditions and a punitive regulatory environment, all of which would strand investment and innovation in decarbonization projects. Further, multiple studies have shown that the cap would require a decrease in production of approximately one million barrels of oil equivalent per day, which translates into a $28 billion hit to our economy, the loss of approximately 150,000 jobs and a drop in both economic growth and productivity. Canada cannot afford this.

Ultimately, the emissions cap is based on flawed economic, social and environmental policy. It sets us up to miss targets, not meet them, running counter to actual emissions reduction goals.

Sincerely,

Deborah Yedlin

President & CEO   

Calgary Chamber of Commerce