Thank you.
Chair and honourable members, it is a pleasure to appear before the environment and sustainable development standing committee to share my comments on Bill C-12. Thank you for the invitation.
For those I have not met, my name is Aaron Henry. I am the senior director of natural resources and sustainable growth at the Canadian Chamber of Commerce. The Canadian Chamber represents over a quarter of a million businesses through our network.
I'd like to start by simply saying that in principle the Canadian Chamber is supportive of Bill C-12. However, we believe that there are some details within the legislation as it's proposed, as well as some mechanisms of execution, that could probably benefit from greater clarity and improvements to strengthen the confidence of Canada's business community in the act.
I would like, though, to start with what we see as a potential value of Bill C-12. I think in many respects it dovetails with some of the comments by the other speakers today.
If developed well and in consultation with Canada's business community, I think this bill could lead to greater policy, certainly in Canada. I think it could create stronger and mutual trust among government, business and Canadians in the pursuit of our efforts to decarbonize.
As many other speakers on this committee have noted on other days, we have a history of setting climate goals and failing to meet them. Not only does this undermine our efforts to meaningfully contribute to global efforts to combat climate change, but it poses a risk to Canada's leadership on the global stage and to its reputation. Also, from the business perspective, it creates a risk for paradigm swings in Canada's policy environment. This takes place as successive governments introduce new measures and more stringent regulations to close ground on lapsed targets. That, in itself, creates uncertainty for an investment environment. It makes it harder for businesses to adapt and cope, and to know where they stand. That, in turn, creates additional financial and political risk for Canadian businesses.
As such, in principle, legislation that increases the transparency and accountability of our efforts to achieve net zero has significant value, especially given that we are discussing policy choices that take shape over the span of decades.
With that said, the chamber recognizes the value in making a few improvements or changes to the legislation. The first is that we acknowledge that climate change has many different dimensions to it. How we approach net zero will have consequences that go beyond simply reducing emissions. There are implications for social inclusion. There are implications for Canada's economic prosperity and labour forces and for rural communities. As some of the witnesses who attended yesterday will attest, there are even public health dimensions.
In short, not all of the pathways to net zero are created equal. Some pathways will carry higher trade-offs than others. Some of them will achieve the desired environmental outcomes, but at the unnecessary expense of other social and economic factors.
While the goal of reducing emissions falls squarely within the remit of Environment and Climate Change Canada, I think those other dimensions demand the attention of other ministers for whom those issues fall within their portfolios. For that reason we'd like to make the suggestion that rather than having the minister approve a five-year plan, that should actually be a Governor in Council decision and made with cabinet.
At the same time, we are concerned that, as described, this legislation doesn't really give full consideration to the economic opportunities and consequences that are attendant to pursuing net zero. The goal of developing sectoral decarbonization strategies has the potential to create closer collaboration between government and industry to ensure greater policy certainty, but there are currently two gaps that I think need to be closed to achieve this.
First, there needs to be a clear economic lens built into the legislation. This lens should set parameters to ensure that the sectoral strategies developed by the proposed advisory body adhere to those parameters such as economic competitiveness, job creation, international opportunities for emission reductions, and the potential export advantages in commodities and clean technologies that Canada can leverage. At a minimum, there needs to be an economic lens that makes the criteria through which different sectoral decarbonization strategies are selected transparent and clear for all concerned stakeholders.
Second, we feel that a very high task has been placed before the net-zero advisory board. It's simply that having 15 people to successfully develop decarbonization plans for multiple economic sectors over multiple years is a big challenge. I think that challenge seems even greater given the absence of the direct inclusion on the advisory board, or through other mechanisms within the act, of industry expertise in developing these sectoral strategies.
Our recommendation would be that the legislation be amended to ensure that industry stakeholders—the stakeholders who are closest to the technological and business opportunities to lower emissions for their sector—are given a clear and formal role in developing sectoral decarbonization strategies.
Finally, we do have some concerns about the scope of the legislation—I think that's already been raised—and how exactly it will interact with provincial jurisdictions and the climate ambitions set by provincial governments. It would be helpful if there were some amendments that would clarify how the targets set by provinces will be integrated into this act. This will be critical in calibrating offset policy and carbon credit creation. It will be very important to ensure greater technological certainty around technologies that are eligible for offset creation and pass the test of additionality. Without strong coordination—