Thank you, Madam Chair and members of the committee, for the invitation to appear today.
My name is Etienne Rainville. I am vice-president of central Canada for Clean Prosperity. Clean Prosperity is a non-partisan, not-for-profit, climate policy organization focused on market-driven solutions that reduce emissions and grow Canada’s low-carbon economy.
Industrial emissions account for approximately 42% of Canada’s total emissions. Industrial emissions pricing is expected to drive as much as 50% of Canada’s emissions reductions by 2030. Industrial pricing is the single most efficient tool in the tool box for reducing emissions because it achieves two seemingly contradictory things: It creates economically efficient incentives for large facilities to reduce their emissions and it keeps costs to Canadians low.
On the face of it, this seems too good to be true, so let me explain how this works, with the example of cement.
Portland cement is the basis for all modern construction. It is manufactured by heating limestone mixed with clay, shale or sand to approximately 1400°C in a large rotary kiln. This process, calcination, breaks down the limestone into lime and CO2 and releases about two-thirds of the emissions associated with cement production. Because these emissions come from a chemical reaction that is inherent to the production of Portland cement, cement is considered a hard-to-abate sector. Producing one tonne of cement generates around one tonne of CO2, potentially a little less.
A tonne of cement today costs around $100, and the industrial carbon price is set at $95. You would be forgiven for doing the napkin math and thinking that means either that a tonne of cement now costs at least $195 or that $95 in carbon costs are baked into that price of cement, but neither of these is true. This is the math that we often see in the media, but it misses three key things.
First, our industrial pricing system is not a carbon tax. I don’t say this to be a pedant, but rather because it's key to understanding how this actually works. With a carbon tax, every tonne of CO2 is taxed at the same rate, but with our industrial emissions pricing systems, the majority of emissions today are actually unpriced. Facilities only pay any kind of price on a share of their emissions, which is about 20% of their emissions.
Second, in order to avoid paying on that 20%, facilities can reduce their emissions. Facilities that reduce their emissions successfully lower their compliance costs. If they overperform their benchmark, they can generate credits and sell these to underperformers.
Lastly, when facilities do face a compliance obligation, they can often pay a significant share of that obligation with credits—credits that today trade below the headline price of $95 a tonne. For instance, in Alberta today, credits go for between $30 and $40. As of next week, they can be used to cover 90% of their compliance costs. The net result of these three factors is compliance costs for every sector that are a fraction of what many people assume.
When we ran these calculations in our 2025 report “Market Force”, we estimated the additional costs created for a number of industrial and household products in Alberta and Ontario and found that, at the consumer level, these costs are generally negligible.
Now, let's go back to that tonne of cement. We calculated that in both Alberta’s TIER system and Ontario’s EPS, a representative cement facility was likely in a credit position. That is, it could be generating as much as $10 per tonne of grey cement it produces.
If the costs are so low, how does industrial pricing incentivize emissions reductions? As I said earlier, facilities only face compliance costs on a fraction of their emissions. The system is designed to create a carbon cost on a small share of the total emissions, so facilities face a strong incentive to reduce tonnes at the margin. While less intuitive, this design helps to maximize emissions reductions while limiting the costs to industry.
Canada is far from unique in its approach to industrial emissions. Internationally, similar systems are the preferred tool for reducing emissions. They are operating in more than 38 jurisdictions globally, covering 23% of global emissions and, most importantly perhaps, 58% of global GDP.
None of this is to say that our systems are perfect. There remains significant work to be done to harmonize systems across Canada, remove the interprovincial trade barriers associated with them, make them more responsive to economic shocks and ensure that the incentives are working as intended. That’s important, because if we don't get this right we can't drive investment across Canada in low-carbon technology like carbon capture, blue hydrogen, electric arc furnaces and clean electricity.
Thank you. I look forward to your questions.