Public policy participation - Suncor's 2013 Report on Sustainability

Public policy participation - Suncor's 2013 Report on Sustainability

Public policy participation - Suncor's 2013 Report on Sustainability

Public policy participation - Suncor's 2013 Report on Sustainability

View the latest Report on Sustainability

Public policy participation

As Canada’s largest energy company — and one of the largest in North America — Suncor is an active participant in public policy discussions on energy and the environment. We regularly communicate with governments in the jurisdictions where we operate. As part of this communication, Suncor complies with all lobbying regulations and reports government interactions, where applicable.

Suncor supports policies that advance research and innovation to promote the responsible development of existing and new energy sources.

The following is a snapshot of some of our thoughts and opinions.

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Royalties and taxes

Royalties and taxes should deliver a fair return to government while providing industry with a competitive, stable and predictable fiscal framework on which to base long-term investment decisions. Policies should recognize market factors, such as the challenges faced by corporations competing in a global economy.

Local community capacity

Suncor, in co-operation with industry partners and local business associations, has been working with the Regional Municipality of Wood Buffalo in northeast Alberta to better forecast future population growth and infrastructure needs. Building non-profit capacity and supporting key community initiatives — such as the MacDonald Island Park expansion — continues to be an important component of Suncor's work in the region.

Read more about community investment

Oil sands and the environment

Sounds policy balances economic, social and environmental factors and prioritizes the issues to appropriately address the cumulative impacts of development. Suncor seeks to actively educate our stakeholders about oil sands development. We encourage and engage in public discussions on oil sands environmental issues and wider energy policy.

Learn more about stakeholder relations

Market Access

There are several proposals for new or expanded pipelines across the country and into the United States that would take oil sands supply to markets. They face significant public scrutiny with concerns being raised about pipeline and marine safety, first nations land rights, and broader objections about enabling the North American economy’s reliance on fossil fuels. Suncor is working with partners to address many of these concerns from a producer’s perspective and are engaged with governments to the same extent.

There is a comprehensive and robust regulatory framework in place that governs the development and operation of pipelines and other large infrastructure projects. The key is to ensure pipeline development is done responsibly and that the respective regulatory bodies are resourced and empowered to ensure this result within an efficient and effective process.

Read more about access to markets

National sustainable energy strategy

Suncor continues to be a strong advocate of a national sustainable energy strategy for Canada. We believe that, as a nation, we should:

  • assess our likely energy requirements 10, 20 and even 50 years down the road
  • determine the mix of proven and potential energy resources that can best meet those requirements
  • draw up a roadmap for achieving our energy objectives in a responsible and timely manner

Our vision of a sustainable energy future is about harnessing existing strengths, while expanding and preparing the way for new opportunities. The future is not about limiting choices; it is about expanding them. The oil sands industry can help to achieve the objectives of such a national plan. This industry can mobilize capital and technical expertise and generate the wealth needed to enable a necessary transition in our energy system.

Targets and goals for reducing greenhouse gas (GHG) emissions would be an integral part of such a national strategy — and it would need to look at how energy is both produced and used. Improved vehicle efficiency, better building construction standards and more mass transit could all be key elements. In this way, a sound national energy strategy would also serve as a national climate change strategy.

Although a national energy strategy did not advance in a tangible form in 2012, it remains a robust part of the energy conversation in Canada. In 2012, the focus shifted to a co-ordinated effort on the part of Canada's provinces to advance those areas that might support an energy framework for Canada. The provinces have led the way, through co-ordinating activities across 10 energy themes, to understanding how the energy system, as a whole, crosses many jurisdictional boundaries and impacts every aspect of the economy.

The dialogue has also raised awareness of the need to develop a united and larger vision for Canada's energy future, rather than just a roadmap of projects or specific policy initiatives. Suncor continues to support framing a strategy more as a process than a grandly designed and prescriptive end product. Looking forward at the very significant energy infrastructure development and replacement needs over the next few decades, there is a critical role for an advisory agency — bringing deep expertise and consensus-building capability — to navigate the complexities of our energy system.

Climate change regulation

Suncor is a strong voice in the call for credible policy to address greenhouse gas emissions from the oil and gas industry in Canada. In our view, this includes a carbon price and practical regulatory architecture. Our perspective is that a carbon price would be most effective if it was to be applied economy-wide, and in a manner that addresses the end-use of carbon emitting products.

Suncor is engaged in the federal government and Government of Alberta process to establish a carbon policy regulatory framework for the oil and gas sector in Canada. Our position is that Canada's oil sands are a world class resource that needs to be developed to meet growing global demand for energy. We also recognize that the environmental performance of oil sands needs to converge, over time, with that of other crude oil production. Suncor supports a regulatory design that:

  • drives best achievable performance from existing facilities
  • provides clear support for innovation and technology development that enables game-changing solutions
  • positions Canada as a leader in energy innovation
  • sets challenging but achievable reduction goals with a process that allows for an increase in ambition as technology develops

Cap and trade in Québec

After a public consultation process, in which Suncor participated, the Government of Québec approved new regulations on a cap-and-trade system for GHG emission allowances in December 2011. The Québec regulations are based on those guiding the Western Climate Initiative (WCI), an economy-wide emissions trading system. The WCI partners (which also include Ontario, Manitoba, British Columbia and California) have agreed to cut GHG emissions by at least 15% below 2005 levels by 2020. Québec, with annual average GHG emissions of about 80 million tonnes, has its own target to cut emissions by 20% below 1990 levels by 2020. In 2012, Suncor registered its Montreal refinery as an emitter under the Québec trading system.

Consistent with an approach taken by California, Québec will include transportation emissions (the tailpipe emissions from vehicles) under its emissions cap in 2015. Fuel suppliers will be accountable for covering those emissions through the purchase of allowances. Suncor supports a carbon price on tailpipe emissions, but has expressed concern that covering this liability under a cap-and-trade program will impose a variable and volatile cost of compliance on fuel distributors, making cost management very challenging for the sector. Instead, Suncor has proposed a fixed cost approach for transportation sector emissions.

Low carbon fuel standards

Suncor continues to monitor initiatives to establish low carbon fuel standards (LCFS) such as in California and is actively involved in reporting and compliance in British Columbia.

Transportation is a key source of GHG emissions representing roughly 33% of total GHG emissions. Of those emissions, combustion of gasoline and diesel fuel in passenger vehicles, trucks and non-road engines account for nearly 90% of total transportation emissions — the remainder is mostly the use of jet fuel in aviation.

A LCFS is designed to reduce the GHG-intensity associated with the production, transport and combustion of transportation fuels. A LCFS regulation requires a percentage reduction in the intensity of GHGs emitted from the production and use of transportation fuels relative to a baseline fuel (i.e., gasoline and diesel).

What distinguishes a low carbon fuel standard from other regulations is the requirement that regulated entities conduct a full life cycle accounting (LCA) of GHG emissions for fuels regulated under the program. Exploration, refining and distribution of transportation fuels (well to tank) account for approximately 20% of the total life cycle GHG emissions. The combustion of transportation fuels (tank to wheel) account for approximately 80% of total life cycle GHG emissions.

Suncor's view is that LCA is a useful and appropriate tool for policy development and evaluating carbon reduction decisions and for measuring progress over time. When LCA is used as a basis for regulation, the need to simplify an extremely complex analysis makes it both less relevant and less accurate. Suncor advocates that the most effective place to regulate well to tank emissions is in the jurisdiction in which they occur.

Both the California LCFS and the British Columbia Low Carbon Fuel Regulatory Requirement regulate a 10% reduction in the carbon intensity of transportation fuel by 10% by 2020. To date blending with biofuels represents the only commercially viable way to reduce the carbon intensity of transportation fuels; however, this method alone is not sufficient to attain the regulated reduction.

In December 2011, the U.S. District Court for the Eastern District of California issued several rulings related to federal lawsuits challenging California's LCFS. The main thrust of the rulings was based on the conclusion that the LCFS violates the Commerce clause of the U.S. constitution by discriminating against out-of-state economic interests and impermissibly attempting to control conduct outside of California's jurisdiction. An appeal by the California Air Resources Board was heard during 2012 but has not concluded.

A proposal by the European Commission Fuels Quality Directive

Suncor advocates against a discriminatory proposal by the European Commission Fuels Quality Directive to assign one average carbon dioxide (CO2) intensity value for all diesel and gasoline, with an exception of an alternate "default value" focused solely on "tar sands and oil shale feedstocks". That is, all crudes would be deemed to have the average intensity with the exception of crude derived from oil sands and oil shale.

Recent studies demonstrate that the refined products supplying the European markets have a wide range of carbon intensities and that oil sands derived refined products sit at the high end, but within that range. Following an economic review, the proposal was expected to go to a final vote in 2013.

Review our Climate Change report

Renewable energy

Government policy needs to take into account factors that influence the development of renewable energy resources, such as:

  • providing a stable, predictable market for investment
  • an appropriate regulatory application process
  • ensuring the necessary infrastructure is in place to support this development

Clean electricity policy activity

Suncor remains active in progressing wind energy policy discussions. Current activities are focused on supporting efforts through the Canadian Wind Energy Association (CanWEA).

In Alberta, Suncor was a member of the Alberta Clean Electricity (ACE) coalition, a collaboration of five wind power industry members as well as The Pembina Institute. The coalition examined various clean electricity policies already in place in other jurisdictions and conducted work toward a made-in Alberta solution, tailored to Alberta's deregulated electricity market.

As CanWEA is progressing similar policy work in Alberta, a decision was made by the ACE members to work within the CanWEA framework. Suncor views the work of the ACE as beneficial in supporting necessary policy discussions and looks forward to continuing to support these discussions as a member of CanWEA.

Biofuel policy advocacy

Canada's renewable biofuels industry is quickly maturing and is working to improve its long-term viability as current government support programs directed at first generation biofuels decline. New policy support is critical to attracting the investment required to develop advanced renewable energy options and build a self-sustaining advanced biofuel industry in Canada to complement the existing biofuel industry.

As one of Canada's largest biofuel producers, Suncor is an active voice in biofuel policy advocacy. Through the Canadian Renewable Fuels Association, Suncor has supported key policy instruments to ensure both market access and incentives for first generation as well as advanced biofuels investment and production.

Explore our renewable energy projects