c. The Framework’s O&G Emissions Cap Will Do Less Work Than It Appears

We have seen above that, having promised 81 Mt of emissions reduction in the ERP, ECCC now proposes to deliver 34 Mt with the Framework.

However, half of that amount, 17 Mts does not even result from the Framework, but rather from other regulations.

On 16 December 2023, the draft Methane Regulations for the Upstream Oil and Gas Sector were published in Canada Gazette, Part I.  The Regulatory Impact Analysis Statement (“RIAS”) published with them stated that the amendments they propose are estimated to contribute more than 17 Mt of GHG emission reductions in 2030. [56]

 34
-17
 17

Therefore after the downstream refining and natural gas distribution emissions are removed from coverage, after the emissions by allowances are permitted, after the emissions from “other compliance units” are permitted, and after the emissions that will be reduced under the draft Methane Regs are considered, the Framework will only deliver 2030 emission reductions of 17 Mt.

If the 2030 emissions cap (the number of allowances issued) were set at the lower figure mentioned, i.e. 106 Mt instead of 112 Mt, then the Framework would deliver emissions reductions of 23 Mt.  However, given the fact that ECCC rarely even mentions achieving its more stringent targets, such as the more stringent 45% reduction by 2030 instead of the 40% reduction, it is difficult to believe that the federal government will make any real effort to achieve the more stringent reduction from the O&G Emissions Cap.