Thank you.
I think you'll find our comments to be fairly consistent with what you've heard from the upstream. Just to set the tone, what's different for our industry is that this is about long, linear infrastructure.
I represent the Canadian Energy Pipeline Association. We're very pleased to be here today. Thank you for your time in hearing these views.
Our members represent the companies that move virtually all the oil and natural gas that's produced and used throughout Canada and North America every day. We currently operate over 100,000 kilometres of transmission pipeline companies. These pipelines are energy highways, if you will, really the only feasible and the safest means to transport large volumes of oil, natural gas, and refined products. Our member companies are job creators in themselves. We're currently on the cusp of investing over $20 billion in nationally significant projects, but these job creators themselves are also enablers of the functioning of an appropriate energy system in Canada and enablers of trade over a very long time. So when we look at conservation we're thinking about how to construct an appropriate pipeline that might be needed, but also keeping in mind that these are very long-lived assets. They're not moving around. They're typically there for many decades.
We believe that the national conservation plan or framework is a very positive and progressive step forward. It helps to integrate and modernize Canada's overall framework for environmental legislation to meet the goals of sustainable development in the 21st century. We support the work of the committee in advancing this initiative through some very clear and practical recommendations, eventually to the Minister of the Environment, on how best to move forward with the development of this approach.
We would note that Canada's legislative framework related to energy, environmental assessment, and environmental protection is multifaceted and very complex. Many different acts are involved, some recently promulgated and some that have been in effect for many years. The passage of each piece of legislation reflected the needs of the governments and people of Canada to address specific issues and concerns at that time. Unfortunately, in the past the mindset tended toward prohibiting or regulating certain activities against harm.
I'll come back to that, because we believe that part of the challenge we face in appropriate conservation strategies and in the work under way to look at legislative change is a result of years of effort of trying to knit these processes together. Regardless, there's a real mismatch of legal requirements, and often that's resulted in only a modest improvement in results and a need for some fundamental change. So we support the efforts under way to change legislation with regard to regulation. We believe that the national conservation plan or framework is a great opportunity to change the focus, to complement this change further, by changing the focus from a prohibition of activities to creating better environmental outcomes than are possible today, in part with agreed principles and objectives. While we see various pieces of legislation contributing and mutually reinforcing, this updated framework is important.
How could this work? We think it is time to look at environmental protection as only one component of environmental conservation. The word “protection” brings the context of stopping harm—and clearly environmental protection is necessary in some circumstances. But the word “conservation” really connotes a broader set of actions that promotes desirable outcomes and includes protection.
We believe that conservation should be the business of project proponents, regulators, and citizens alike, and that legislation should enable and support that engagement and productive outcome. A project that is found to be in the public interest could proceed along with an agreed set of conservation objectives that reflect current policies. The attainment of specific permits for activities such as water crossings that have been proven over time to be relatively benign or fully mitigated could be looked at in new and better ways.
Let's be specific. A large pipeline project today costs billions of dollars. Environmental studies, consultant and legal fees, and costs to develop extensive applications to support environmental assessment and regulatory permitting are all part of those costs. We don't begrudge that, but we would observe that currently the estimated costs spent on these permitting activities by our proponents are anywhere from 3% to 5% of the capital cost of each large project. For a billion-dollar project, that amounts to between $30 million and $50 million.