d. The O&G Emissions Cap Has Effectively Been Dictated By The Oil & Gas Producers

On 23 July 2022, five days after the Discussion Document was released, CBC News reported:

Pathways Alliance, a group that includes six companies representing 95 percent of Canada’s oilsands production, says it is working to reduce its CO2 emissions by 22 megatonnes by 2030. Ottawa’s plan wants the sector’s total emissions (about 191 megatonnes in 2019) reduced to 110 megatonnes by the end of the decade.

 “By 2032 you might get another two or three megatonnes,” Mark Cameron, vice-president of external relations with the Pathways Alliance, told CBC News…

Cameron added that the 22-megatonne-by-2030 goal could potentially be increased if new technology becomes available or significantly more funding is infused. Either way, hitting the reductions outlined in the federal government’s 2030 plan isn’t feasible under current circumstances, he said.

“We would obviously need more time to get to that level. Whether or not we can achieve that by 2032, or it may take longer than that, is another question.”  [Emphasis added.] [57]

Pathways Alliance states that its “Phase 1” goal of reducing emissions by 22 Mt by 2030 “focuses on building a proposed carbon capture and storage (CCS) network in northeastern Alberta.” [58]

We have seen above that what the Framework proposes will require between 17 Mt and 23 Mt of emissions reductions from the O&G Emissions Cap itself.

Pathways Alliance announced their intention to use CCS to reduce emissions from oil and gas production on 21 October 2021. [59] That was five months before ECC released the ERP, and over eight months before ECCC released the Discussion Document on the proposed O&G Emissions Cap.  Now, fully two years after Pathways Alliance announced their intention, the Framework is not requiring them to do any more than they stated they were going to do anyway.