Madam Chair, thanks for inviting Suncor to participate in the work of the committee as you complete your examination of Bill C-69, the impact assessment act.
My name is Ginny Flood. I'm the Vice-President of Government Relations for Suncor. Previous to Suncor, I was with Rio Tinto, and previous to that, I was with the federal government as a regulator for environmental assessment.
I would begin by acknowledging that the land on which we gather here in Ottawa is the traditional unceded Algonquin territory.
Suncor is Canada's largest integrated energy company and a significant contributor to Canada's economy. We are best known for our oil sands production, but we also operate three refineries in Canada, 1,800 Petro-Canada retail and wholesale locations from coast to coast to coast, four wind power projects in three provinces, and the largest ethanol production facility in Canada, which is in Sarnia, Ontario. We are the only company engaged in all four of the major east coast oil exploration facilities, making us the largest producer of oil off Canada's east coast. Together, Suncor's operations are located in every region of the country and in the traditional territories of more than 140 aboriginal communities across Canada.
Suncor has been an active participant throughout the many stages of the consultation held across Canada to provide our views and our experience with CEAA, 2012, the renewal of the NEB, and the Navigation Protection Act. Today we are pleased to share with you our thoughts on Bill C-69.
As part of the committee's call for written submissions on Bill C-69, Suncor did provide a detailed written brief, but today it's not my intention to go through all of those points. I would rather highlight some of the key points. I'll focus my comments on three key themes that are related to the outcomes of Bill C-69.
The first is maintaining competitiveness in the industry. In terms of overall competitiveness, the perception is that the pace, scale, and scope of environmental regulatory change in Canada today is rapid and vast, and is likely unprecedented.
We recognize the need to address environmental concerns related to climate change, and the desire of government to restore confidence in the regulations related to the impact assessment. We recognize the importance of Canada doing its part, but we also are committed to doing our part to advance this agenda and meet Canada's commitments. However, we believe it is absolutely critical for the future of Canada that the federal legislative agenda proceed with great care and deliberation so that environmental policy is enacted in a way that best maintains our competitiveness in a highly fluid, mobile, diverse, and competitive world.
We support broad-based carbon-pricing mechanisms as a tool that can achieve desired outcomes, if they are balanced with other regulatory and fiscal relief, as well as taking into account competitiveness pressures from other jurisdictions that don't have the same costs. We will continue to lead in Canada, but we need to lead with one eye on the environment and one eye on the economy.
New regulations, such as those that will eventually accompany Bill C-69, should strike the optimum balance between improving environmental performance and at least maintaining, and ideally increasing, our competitiveness. We must advance our economy with the same diligence as we protect the environment.
As a producer of a global commodity, we compete on the world stage. We strive to be leaders in sustainability, but limited market access and restrictive policy measures lead to project uncertainty and a diversion of investment outside of Canada. Statistics Canada's latest report shows that direct investment in Canada fell dramatically, with the retreat of investment in the oil sands as a key contributor.
The bottom line is that the cumulative cost and complexity of all the recent regulatory policies across the federal and provincial jurisdictions and the related regulatory uncertainty will have a negative impact on the competitiveness of Canada. While we support strong environmental policy and Canada's ambition to do its part in meeting the 2030 Paris commitment, we also believe that the goals are not mutually exclusive from a competitive regulatory framework.
The second area I want to focus on is to draw your attention to the transition from the CEAA 2012 to the new model that will be put in place under the impact assessment act. By its nature, legislative change introduces uncertainty for project proponents, investors, and the communities where resource development projects are proposed. Bill C-69 needs to clarify the transitional provisions to mitigate uncertainty to the greatest extent possible.
At this time, there is considerable uncertainty with respect to the final wording of the act, the coming-into-force date for the act, the regulations designating physical activities it will include, as well as what guidance will be associated with the new act and the regulations.
Suncor currently commits significant resources and effort to indigenous engagement, discussions with local communities, engineering design, modelling, and the collection of baseline data in the development of impact assessment reports. It is therefore imperative that this work be allowed to continue under the current CEAA 2012 unless a project proponent elects to transition to the new impact assessment act.
Providing this flexibility sends a positive message to industry and the investment community that the government recognizes the value and importance of early engagement work already undertaken by proponents and is willing to provide a level of certainty with respect to project development.
As specified in our written submission, we are formally recommending that the committee consider a change to the transition provisions of the impact assessment act, that the projects undergoing CEAA 2012 assessments will continue under CEAA 2012 unless the proponent requests a transition of the assessment to the IAA. This amendment will clarify the process and mitigate negative impacts related to uncertainty of projects currently undergoing CEAA 2012 review.
The next area I want to talk briefly about is the original intent and spirit of impact assessment. We believe that the original intent of environmental assessments, what we will now know as impact assessment, was never intended to impede development, but it was a mechanism to ensure proponents worked with aboriginal communities and those impacted by the project to mitigate the residual environmental impacts of any project. We strongly recommend that the current IAA clearly articulate this intent to avoid lengthy delays caused by interested parties seeking an avenue to challenge broad policy initiatives of the government of the day, for example, whether to develop our energy resources.
The focus must remain on individual projects, and in fact, should be even more carefully focused on those parts of the project which cannot be mitigated through other activities.
Suncor has stated in its position that where robust provincial environmental assessment processes exist, a harmonized process respecting jurisdictional powers would reduce the risk of duplication and allow the federal government to focus on mitigating residual impacts that fall under their jurisdiction, such as fisheries or navigable waters. We support the proposed impact assessment act's ongoing commitment to coordinate among relevant jurisdictions with the objective of one project, one assessment.
With respect to Suncor's assets, the majority of our resource projects are located in provinces that have proven robust and effective project review processes that are designed to thoroughly assess potential environmental and socio-economic impacts. Provincial governments have the right over the natural resources and some, for example, such as Alberta, have significant experience in weighing the overall economic benefits of the project and assessing the proposed mitigation measures against potential environmental, social, and cultural impacts.
One area of particular interest comes from projects offshore Newfoundland and Labrador that require of Bill C-69 a panel review of offshore projects. This represents a significant change, potentially doubling the review timelines from the current process.
Based on past projects and effects and potential risks associated with offshore development, these are well understood and the environmental assessment process is a standard practice.
For this reason, Suncor would recommend that the requirement of offshore projects to undergo a panel review be removed upon recognizing a rigorous assessment process and the codes of practice currently in place.
I do look forward to your questions.
Thank you.