RAIC Responds to the Government of Canada Regulatory Framework for an Oil and Gas Sector Greenhouse Gas Emissions Cap

February 5, 2024

To the Government of Canada

Please find below the formal written submission from the Royal Architectural Institute of Canada (RAIC) regarding the Regulatory Framework for an Oil and Gas Sector Greenhouse Gas Emissions Cap.

The RAIC is extremely concerned about the climate crisis and what lies ahead for future generations if we do not transition off fossil fuels as soon as possible. Although we were very pleased to see the announcement of an emissions cap, we are concerned that this will not be enacted at the accelerated pace and scale required for meaningful change.

On behalf of the RAIC and the architectural community we call for:

1) Ambitious cap targets that include oil and gas companies who should be forced to comply with a 60% reduction target to meet the standards of the International Energy’s recommendations and Canada’s own targets.

2) Minimizing opportunities to rely on carbon capture, carbon storage and carbon offsets rather than focusing on reduction of physical emissions.

3) Ensuring all GHG emissions from the production and the use of gas and oil should be included in the emissions cap.

4) Immediate, formal and strong accountability measures to ensure compliance.

5) Immediate implementation of emission caps - with the target of January 1, 2025 implementation.

6) Put the focus on people and all living things ahead of profit - decisions made today will affect the well-being and survival of future generations.

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 oil sands 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)

Reducing pollution from oil and gas companies is necessary to meet climate targets. The time is now for Canada to take a leadership role to not only commit but also aggressively implement a framework to limit emissions from oil and gas production.

Sincerely,

Mike Brenann, Hon. MRAIC, Hon. RAIA Jason Robbins, FRAIC, Hon. RAIA

Chief Executive Officer President

About the RAIC

The Royal Architectural Institute of Canada (RAIC) is a not-for-profit, national organization dedicated to representing architects and architecture since 1907. The RAIC is the only national voice for excellence in the built environment in Canada focused on providing Canada’s architectural community with the tools, resources, and education to elevate their practice. The RAIC is committed to showcasing how design enhances quality of life, while advocating for important issues of society through responsible architecture. The RAIC’s purpose is to create a better world for all by empowering Canada’s architectural community. Through our work, the organization envisions a strong architectural community that is valued and empowered to create change. The RAIC’s national office is based in Ottawa with a growing federated chapter model. Current chapters and networks are based in British Columbia, Alberta, and Nova Scotia.

References

(1) https://www.science.org/doi/10.1126/science.adj6233

& https://www.independent.co.uk/climate-change/news/canada-emissions-toxic...

& https://environmentaldefence.ca/2022/10/26/dont-buy-the-hype-lng-is-bad-...

& https://www.ipolitics.ca/opinions/canadian-gas-wont-help-europe-help-ukr...

https://www.nationalobserver.com/2022/06/28/opinion/message-ukraine-dont...

(2) https://www.theenergymix.com/alberta-metis-solar-farm-delivers-4-86-nw-b...

(3) https://apnews.com/article/canada-wildfire-indigenous-land-first-nations...

(4) https://www.cbc.ca/news/canada/wildfires-climate-change-carbon-88-1.6852178

(5) https://policyalternatives.ca/publications/reports/canada%e2%80%99s-ener...

(6) https://www.iea.org/reports/the-oil-and-gas-industry-in-net-zero-transit...

(7) https://www.cbc.ca/news/canada/edmonton/slim-majority-of-albertans-suppo...