It's a great question.
As our smart tax people tell me, the systems between the two countries aren't the same, so of course they'll never look exactly the same.
I think it's the simplicity. Say, for instance, if you look at the investment tax credit, you see that there are more sticks attached, whereas the IRA has a lot of carrots. It's the same for labour. If you have an ITC for a carbon capture and sequestration project currently and you are unable to attract enough workers of the Red Seal technicians and apprentices to your project, then you actually get significant deductions on your investment tax credit value. We all know what a huge labour shortage we're seeing, and the fact is that many of these workers are transferable. They can go down to the States and work on those projects.
To make the ITC conditional on so many things that are out of your control—like the labour supply—makes it difficult to compete, whereas in the States with the IRA, you know that if you've designed your project to fit the parameters, it's going to be eligible. Also, if you achieve better labour targets than are set as the minimum, then you get bonuses rather than penalties. It's a carrot-and-stick approach.
Part of it is simplicity. Some of the simplicity could even be added incentives rather than takeaways, because for a board to approve a project that is going to, say, build a CCUS project for a large natural gas plant to provide clean energy to Albertans, they can't control the labour supply. If they're not able to achieve the right number of Red Seal technicians and the right number of apprentices, they can actually be at risk of losing a huge percentage because of something completely out of their control. They really don't know what they can count on.
Giving certainty can be just in the way that you design these extra features of the ITC. I would simplify. For instance, for labour, you could simply say to make it a best effort. That would take away the risk to the corporation in saying that of course this is the goal and the desire, but if they make best efforts to achieve it, then they'll know they will get the full ITC. Currently, that's not the case.