Pembina Institute comments on the proposed Technology Innovation and Emissions Reduction (TIER) systemFormal submission to Environment and Parks, Government of Alberta

Publication - Aug. 30, 2019 - By Jan Gorski, Duncan Kenyon

The Pembina Institute is thankful for the invitation to share our views on the Government of Alberta’s recently released discussion document on the proposed Technology Innovation and Emissions Reduction (TIER) system. We are encouraged to see the Alberta government acknowledge the role of pricing pollution to reduce harmful emissions and build a competitive economy by proposing to create a system that sets a price signal through performance standards for heavy industry. However, we are disheartened by the intention to weaken a very strong existing system, the carbon competitiveness incentive regulation (CCIR). CCIR was developed via thorough engagement with a diverse group of stakeholders including industry, academics, experts and environmental groups. CCIR is a strong carbon-pricing system designed to align the goals of the policy with incentives for facilities to reduce emissions, while preserving competitiveness. The federal carbon pricing backstop was modelled on Alberta’s leading approach, which also influenced the design of B.C.’s system.

Alberta’s oil and gas sector remains the fastest-growing source of carbon emissions in Canada, as rapidly expanding production more than offset the per-barrel improvements. Canada has committed to reduce GHG emissions by 30 per cent below 2005 levels by 2030. The Government of Alberta must show how it plans to do its fair share to address climate change in a meaningful way to meet Canada’s commitments and show we can address climate change before the worst of its affects impact our society.

Alberta’s proposed TIER system is a step in the wrong direction. The TIER system would disrupt the investment landscape, create policy uncertainty, and provide a significantly weaker signal to industry to reduce emissions than is currently provided by the CCIR. Lowering ambition of a recently implemented and well-designed policy that meets the dual objective of reducing emissions while protecting competitiveness would not benefit industry, nor Albertans.


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