April 6, 2022

Mark Little
President and Chief Operating Officer
Suncor Energy Inc.
<email address removed>
 

Mark Little:
 

I am writing regarding Suncor Energy Inc.'s proposed Base Mine Extension Project (the Project).

I have reviewed Suncor's April 5, 2022, letter to the Impact Assessment Agency of Canada (the Agency) requesting an extension to the time limit for the submission of the Impact Statement for the Project. I appreciate Suncor's commitment to accelerating its progress to be a net-zero company by 2050, and its intent to utilize the additional time to allow it to ensure the Project aligns with its strategy to be a net-zero company, to assess project improvements and technology, as well as to review government initiatives such as the 2030 Emissions Reduction Plan. These actions are a positive demonstration of Suncor's commitment to net zero.

As you are aware, the Government of Canada has moved forward with an ambitious plan to reduce greenhouse gas emissions from the oil and gas sector; including our commitment to put in place a cap on oil and gas sector emissions, the requirements of the Canadian Net-Zero Emissions Accountability Act and the recently announced 2030 Emissions Reduction Plan; as well as our international obligations with respect to climate change.

The 2030 Emissions Reduction Plan presents modelling of the most economically efficient pathway to meeting Canada's 2030 target. Drawing on that modelling, the Plan includes a projected contribution from the oil and gas sector of emission reductions to 31 percent below 2005 levels in 2030. The Government of Canada intends to work collaboratively with the oil and gas sector to define and implement a cap on oil and gas sector emissions that will be designed to lower emissions at a pace and scale needed to achieve net zero by 2050.

To provide clarity on these expectations, the Government will develop guidance for how oil production projects subject to review under the Impact Assessment Act should demonstrate that their emissions will be "best in class." This guidance will help ensure oil production projects and activities are lowering emissions at a pace and scale needed to achieve net zero by 2050.

As currently described by Suncor Energy Inc. in its Detailed Project Description, the Project would produce an estimated three million tonnes of carbon dioxide equivalent annually over the life of the Project. As your company and Canada work towards net-zero, I am pleased that we have come to a shared recognition that emissions at this level may not align with the pace and scale of emissions reductions required to achieve our targets, and that this would hinder Canada's international commitments in respect of climate change nor would it make a net positive contribution to sustainability. Under the Impact Assessment Act, these factors are considered in the determination of whether the adverse effects of the Project within federal jurisdiction are in the public interest. As such, I am of the opinion that the Project, as currently proposed, would likely cause unacceptable environmental effects within federal jurisdiction. It is important to ensure that Suncor Energy Inc. is aware of my views at this early juncture in the assessment process in order to ensure clarity and transparency.

Your request to extend the time limit to submit your Impact Statement by nine months under section 19(1) of the Impact Assessment Act has been approved by the Agency.

The Government of Canada remains committed to a timely and efficient review of the Project. Following receipt of your Impact Statement, an independent review panel will be established to carry out the assessment and provide its recommendations to me. To allow the Project to proceed, the Government of Canada must ultimately determine that the Project's adverse effects within federal jurisdiction and the adverse direct or incidental effects are in the public interest. When making the public interest decision, the Government will consider all relevant information about the extent to which the Project would contribute to sustainability, and the extent to which the effects of the Project would hinder or contribute to the Government's ability to meet its environmental obligations and its commitments in respect of climate change.

I would be pleased to meet with you to discuss these matters further.

Sincerely,

<Original signed by>

 

The Honourable Steven Guilbeault, P.C., M.P. (he/him/il/lui)