We need a plan that is aligned with an effective global effort to stay within the 1.5°C warming threshold
Canada’s new Emissions Reduction Plan announced on March 29, 2022, includes a detailed plan by our government to continue increasing Canada’s oil production to 2030 and maintain high production levels for another 20 years after that. The plan envisions no significant reduction in Canada’s oil production levels before 2050.
It shows a 26% increase in our oil sands and conventional oil production by 2030. The data is taken directly from the Canada’s Energy Future 2021 report, published by the Canada Energy Regulator (CER). The CER forecasts 36% growth by 2040.
On April 6, 2022, Canada approved the new offshore oil project called Bay du Nord. Two days earlier at a press conference Canada’s Minister of Environment confirmed that Canada’s new climate plan is “based on” increasing oil production:
… the plan we presented last week, the Emissions Reduction Plan, was based on the Canadian Energy Regulator projections that oil and gas production would increase in Canada between now and 2030 …
He offered Canadians this excuse:
Now, as many of you know, Minister Wilkinson, who is responsible for the Canada Energy Regulator, asked them for new scenarios in terms of production and demand for fossil fuels and different forms of energy that would be compliant with 1.5 scenarios. Now we don’t have those scenarios from the CER so we had to use the last ones that were available which forecast an increase in production between now and 2030 …”
— Steven Guilbeault, Press Conference, April 4, 2022 (emphasis added)
But the promised “new scenarios” based on a 1.5°C-aligned analysis will not be publicly available until early 2023. In the meantime, our government is justifying decisions to expand our oil production (decisions that involve projects and infrastructure that will have an operating lifetime of 20 or 30 years) based on CER projections which are not remotely aligned with 1.5°C.
The CER’s projections are unreliable because they have never been tested against modelled net-zero scenarios consistent with 1.5°C of warming. Guilbeault admitted “we don’t have those scenarios from the CER”.
The Canada Energy Regulator (CER): seven years of failure
For seven years in succession the CER (formerly known as the National Energy Board, or “NEB”) has turned a blind eye to this fundamental question, which remains unanswered. No environmental assessment or public inquiry process of any kind in Canada has ever answered the question, which is whether the planned growth of Canada’s oil production to 2030 and 2040 is compatible with keeping increased warming to 1.5°C.
The CER admits that its scenarios do not model the lower oil production levels that would be required to meet the climate goals agreed in Paris in 2015:
The Evolving and Current Policies scenarios do not explicitly model climate goals or targets … the Current Policies Scenario is extremely unlikely to lead to the significant reductions needed to meet Canada’s Paris commitments.
— Canada’s Energy Future 2021, December 9, 2021, p. 19 (emphasis added)
On July 8, 2021, twenty-one energy economists and climate scientists, all deeply experienced and informed about Canada’s oil production projections and the emissions implications of continued expansion, sent a letter to the Prime Minister. It cited in detail the findings of the IEA’s May 18, 2021 “Net-Zero Emissions by 2050 Scenario” and was copied to the Minister of Environment and Climate Change, and to the Minister of Natural Resources. They wrote: “Specifically, we urge you to mandate that the Canadian Energy Regulator model scenarios consistent with the IEA’s Net Zero by 2050 report”. In plain English, that meant the government should immediately direct or instruct the CER to develop scenarios that will identify the much lower and declining oil production levels in Canada over the next 20 to 30 years that would be safely aligned with an effective global effort to stay within the 1.5°C warming threshold. The Minister of Natural Resources did not act. Mr. Guilbeault remained silent. Six months passed. Undeterred, the CER released its new oil projections on December 9, 2021, entirely ignoring the crucial question.
The CER’s new “Current Policies” forecast for Canadian fossil fuel production (now enshrined in Canada’s official Emissions Reduction Plan) is roughly aligned with the IEA’s recently published “Stated Policies Scenario” which anticipates 2.6°C of warming, far beyond the Paris target.
An independent public inquiry is required
The Minister of Natural Resources belatedly instructed the CER on December 16, 2021, to conduct an internal study to determine what future level of oil production in Canada would be safely aligned with a global effort to limit warming to 1.5°C. We are told that the result of that study will be available in early 2023.
That is the kind of study that the Federal Government should have undertaken seven years ago, before the government on November 29, 2016, committed itself to the construction of a massive expansion of Canada’s pipeline capacity to export an additional 910,000 bpd of exported oil. That approval of the TMX project (and the Line 3 expansion) occurred weeks after the government’s own appointed Ministerial Panel concluded, in its November 1, 2016 report, that the question of whether the growth of emissions from the increased oil production facilitated by the new Trans Mountain pipeline could be reconciled with Canada’s climate change commitments remained “unanswered.” The government ignored that warning.
At the very least, it should have been initiated four years ago, after the IPCC issued its Special Report on Global Warming to 1.5°C in October 2018, warning governments that to stay on a pathway to keep temperatures within the 1.5°C warming threshold, global emissions must be cut 50% by 2030.
But this crucial study should not be left to the Canada Energy Regulator. It is wrong to leave an inquiry on a question of this gravity, which is so irrevocably consequential to our children, to the CER, which is an agency of the Federal Government and entirely unaccountable to the public. The Minister of Natural Resources, Mr. Wilkinson, has assigned this task to an anonymous group of Federal Government employees and others selected and contracted by the government to provide information and evidence behind closed doors.
Under this arrangement, there will be no hearings, no cross-examination, no public record of proceedings, and no media access. There will be no lawful avenue for a Canadian citizen to scrutinize the sources and evidence that is being considered by the CER, or legally challenge the evidence, the process, or the findings. The CER will quietly decide behind closed doors what evidence it will look at, and what lines of inquiry it will ignore.
The issue at stake, the future path of Canada’s oil production to 2030, 2040, and 2050, is too deeply enmeshed in the conflicted economic interests of government and the oil industry to be entrusted to a secretive process out of the public view.
A proper examination of this fundamental question must be done by an independent public inquiry process. That is our guarantee that the evidence will not be pre-selected or “cherry-picked”. There must be an opportunity for Canadians to challenge and cross-examine the experts, and an opportunity to call other expert witnesses who may disagree with those who have been selected by the government. The process must be able to test and challenge the experience and skills of those who are selected as expert witnesses and scrutinize their affiliations and independence. The integrity of the process must also be protected by the basic principles of judicial independence, so we can be confident that the decision makers are not being influenced by pressures, discussions, or other sources of information that have not been tested at a public hearing.
We have sent a letter to the Minister of Environment outlining the reasons why an independent public inquiry is urgently required.
Click the yellow button to get the letter (opens as a PDF in your browser).
Our letter to Jonathan Wilkinson, Canada’s Minister of Natural Resources, dated August 23, 2022, can be found here. It provides a detailed background about Canada’s current plans to continue increasing its oil production and recent findings by climate scientists and energy economists showing why deep reductions in global oil production are required by 2030 and deeper cuts are needed by 2040.