We ensure our participation is in compliance with all political contributions and lobbying regulations, and report government interactions consistent with the law and company policies.
Increasingly in Canada, public policy is developed through open and transparent processes, incorporating the expertise and perspective of a broad range of stakeholders. Suncor participates in these forums, bringing our industry perspective and a solutions-based mindset to advance responsible development.
We support governments taking a reasoned and outcomes-based approach to policy development. We believe policy should be built on evidence-based information and perspectives.
Constructive dialogue and transparent sharing of information are critical in guiding our interaction with governments and stakeholders towards the development of practical policy solutions. These activities promote responsible development of existing and new energy sources. We aim to decrease the probability of reactive policy development by working to reduce polarized dialogue.
Our policy position with governments includes:
- applying a broad-based economy-wide carbon price
- encouraging a healthy debate about energy solutions
- understanding the role of and supporting advancements in research, technology and innovation
- considering energy development and distribution costs and benefits
- encouraging Aboriginal economic collaboration and capacity building
- developing vibrant, sustainable communities
- supporting Canada’s long-term prosperity
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 challenges faced by corporations competing in a global economy.
Levies added over and above current royalties and taxes need to be holistically considered and understood in terms of costs, outcomes and competitiveness against other jurisdictions in which Canada’s natural resources compete.
We support policy and regulations that promote transparency and advocate for rules that are consistently applied and respect agreements with First Nations.
Cumulative impact of policy changes
We continually study expected cost increases resulting from existing and proposed policy changes. The study findings are used to inform our approach to the energy systems dialogue. They help us reflect on opportunities holistically and provide context for policy-makers and regulators so that we can fully consider all aspects of potential policy and focus on how to incent constructive outcomes.
Our oil sands industry makes a strong contribution to meeting global energy demands, while creating jobs, contributing to the economy and generating revenues for government to fund social programs across Canada. Suncor supports the development of infrastructure that opens access to new markets and ensures global competitiveness for Canadian resources.
Suncor has an interest in all the major pipelines that are currently proposed and/or approved (Keystone XL, Line 3 and Trans Mountain), but it’s important to note that no single pipeline will affect our ability to execute our growth plans.And, because pipeline projects take several years to approve, develop and make operational, it also makes sense for us to tap into existing rail and marine networks to transport our products to market.
Pipelines continue to be the safest, most efficient means of transportation for crude oil and other petroleum products, and we are working with stakeholders to address many of these concerns from a producer’s perspective and are engaged with governments to the same extent.
In addition to the existing comprehensive and robust regulatory framework in place that governs development and operation of pipelines and other large infrastructure projects, Environment and Climate Change Canada (ECCC) has outlined a new Impact Assessment process through Bill C-69 that focuses its aim to achieve better rules for major project reviews to protect Canada’s environment and grow the economy.
In addition, a new Canadian Energy Regulator (CER) has been identified as part of this new process. This new regulator will have the responsibility of ensuring access to safe, affordable and reliable energy and guiding Canada’s transition to a low-carbon economy. The new CER seeks to achieve modern effective governance, more inclusive engagement, greater Indigenous participation, stronger safety and environmental protections and timely decisions.
We believe efficient, effective and transparent regulatory oversight is the responsible thing to do and will be valuable to accurately inform Canadians, decision-makers and other stakeholders.
Local community capacity
In co-operation with industry partners and local business associations, we have 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 continue to be important components of our work in the region.
We also participate in the Athabasca Oil Sands Area Transportation Co-ordinating Committee, where infrastructure needs, funding and financing options are discussed and prioritized.
Federal Environmental Act Reviews
In May of 2016 the Government of Canada initiated a review of Canada’s environmental assessment processes. These reviews included the Canadian Environmental Assessment Act (CEAA), the modernization of the National Energy Board, the Fisheries Act, and the Navigable Waters Protection Act, and have resulted in proposed legislation in Bill C-68 and Bill C-69 which were released in February 2018. This proposed legislation is expected to put better rules in place to protect the environment, rebuild public trust through increased transparency and engagement, and grow the economy.
Environmental assessment informs government decision-making and supports sustainable development by identifying opportunities to avoid, eliminate or reduce a project’s potential adverse impact on the environment and ensure mitigation measures are in place when a project is constructed, operated and decommissioned.
The proposed legislation has a focus on expanding the types of impacts studied to understand how a proposed project could affect not just the environment, but also health, social and economic impacts as well as impacts on Indigenous Peoples over the long term.
Suncor’s response to the review processes to date has reinforced that impact assessment is critical to project development and must be transparent, and effectively and efficiently managed to ensure public and investor confidence.
The process needs to appropriately balance the economy, the environment and social impact while at the same time incent innovation and future investment.
Lower Athabasca Regional Plan (LARP)
In 2008, the Alberta government introduced the Land Use Framework. The purpose of the Land Use Framework was to manage growth in Alberta by balancing economic, social and environmental goals. The first regional plan, the Lower Regional Athabasca Plan (LARP), was completed in 2012.
The LARP includes management frameworks for:
- air (SO2 and NOx)
- surface water quality
- surface water quantity
- tailings management
- regional groundwater management
Each of these frameworks includes interim triggers to allow early indications of change. In 2017, a five-year review of LARP was initiated. A Biodiversity Management Framework and Landscape Management Plan continue to be under development.
On an ongoing basis, we also participate in technical discussions that lay a foundation for future policy and regulation on aspects of tailings management, water return, biodiversity and wetlands.
Greenhouse gas (GHG) emissions
Climate change regulation
We are engaged with all levels of government to establish a credible carbon policy regulatory framework for the oil and gas sector in Canada. Our position is that Canada's oil sands are a world-class responsibly developed resource that is needed to meet growing global energy demand.
We are a strong voice in the call for effective policy to address the Canadian oil and gas industry’s GHG emissions. In our view, this includes a carbon price signal that incents the right behaviour and a practical regulatory architecture.
Since 2008, we have advocated publicly in support of a broad-based, economy-wide carbon price. In 2016, we joined the Carbon Pricing Leadership Coalition (CPLC) – and contributed to the CPLC’s Canadian industry report in 2017 –to support Canada’s Ecofiscal Commission – ultimately broadening the discussion of carbon pricing into the realm of practical policy application.
Our continued collaboration with Canada’s Ecofiscal Commission has generated numerous reports focused on two themes:
- the importance of implementing carbon pricing
- considerations needed for policy design
We support 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
- is flexible and provides for multi-jurisdictional compliance pathways
- avoids duplication
Quebec/Ontario – Cap and Trade
Both Quebec and Ontario are members of the Western Climate Initiative (WCI) cap and trade economy-wide emissions trading system. The WCI partners (which also include Manitoba, British Columbia and California) have agreed to cut GHG emissions by at least 15% below 2005 levels by 2020.
Our Montreal and Sarnia refineries are required to purchase carbon allowances to cover their respective stationary emissions, as well as cover the tailpipe emissions associated with the fuel sold in those provinces.
The WCI cap and trade system imposes a limit on the emissions allowed in each sector of the economy. This provides certainty for industries and creates investment opportunities.
With the announcement of the termination of the cap and trade program in Ontario, Suncor will work with the provincial government to explore solutions that achieve the required outcomes while minimizing impacts to people and business.
Low-carbon fuel standards
We continue to monitor and consult on numerous policy initiatives such as the federal government’s proposed Clean Fuel Standards (CFS) to reduce Canada’s GHG emissions through the increased use of lower carbon fuels.
Suncor’s position is that a well-designed carbon price is the most economically efficient and inclusive way to drive responsible emissions reductions right across the energy system, including fuel carbon intensity.
There are specific circumstances where carbon pricing is not enough and the transportation sector is generally regarded as an example. In these cases, additional policies can play a role supporting carbon pricing and achieving emissions reductions at lowest cost.
The challenge is to design a system without adding duplicative layers of cost and administrative burden, while truly complementing GHG policies that can support a carbon price and drive more emissions reductions at a lower economic cost.
Where complementary policies are added to carbon pricing, the objectives of the complementary policy should be clear and the interaction with other policies, and carbon pricing in particular, should be well understood.
Renewable and Low-carbon power policy
In Alberta, the Climate Leadership Plan (CLP) will accelerate the transition from coal to renewable electricity and natural gas generation by 2030. The government is committed to replacing two-thirds of coal-generated electricity with renewables, primarily wind power, and with natural gas – such as power exported to the grid from Suncor’s cogeneration facilities.
Renewable energy sources are proposed to comprise up to 5,000 MW of renewable capacity, which is estimated to be approximately 30% of Alberta’s total electricity.
Suncor is an active proponent of increased cogeneration as a key part of the power mix in Alberta, particularly as the province transitions away from coal. Cogeneration provides reliable, base-load power to intermittent renewable power at the lowest GHG intensity of any hydrocarbon fuel.
Collaboration between government and industry is the only way to accelerate the step changes needed for Alberta to transition from an “energy only” market design to a “capacity” market design.
As the sixth largest electricity generator in Alberta and an industry player keenly focused on reducing its carbon footprint, Suncor works with policy makers, industry partners and other stakeholders to increase investment in low-carbon power generation.
Biofuel policy advocacy
Canada’s renewable biofuels industry is quickly maturing, and Suncor is working to improve its long-term viability as current government support programs directed at first-generation biofuels decline.
As opportunities arise, we invest in advanced renewable energy technologies to complement the existing biofuel industry. This involves funding outside companies whose technology ideas align with the strategic needs of our operations or businesses.
Suncor supports a flexible performance standard for transportation fuel intensity over more narrowly constructed mandates.
In Canada, there exists a “patchwork quilt” of carbon pricing policies across the provinces, as well as differences in complementary policies across provinces. Over time, this will mean higher costs than necessary. We advocate for both levels of government to ensure that policies work together.
Canada’s energy industry has a responsibility to navigate between the aspirational and the realistic, which for the oil sector specifically means continuing to keep the Canadian economy moving, through continued investment in existing energy supply and maintaining critical infrastructure. Policies should provide the certainty required to make necessary investment decisions and not lead to leakage of investment capital. There remains much work to be done to define a unified Canadian energy vision for 2050. The need exists for collaborative policy solutions that can advance our nation’s economic ambitions while preserving environmental integrity.