I delivered the following statement this morning at a meeting of the Ministerial Panel on the proposal to expand the Trans Mountain Oil Pipeline:

My name is Simon Donner and I work as an Associate Professor of Climatology in the Department of Geography at the University of British Columbia. For the past 15 years, I have conducted research in the area of climate change science and policy.

I am here today to explain the effect of upstream greenhouse gas emissions due to the proposed Trans Mountain Pipeline expansion on Canada’s international climate commitments following the Paris Climate Agreement.

Let me be clear at the outset. I am here as neither an opponent nor a proponent of the proposed activity. I am personally agnostic about the pipeline expansion. My statement speaks only to whether the project is consistent with Canada’s climate policy.

There are two key points in this statement:

First, the draft upstream emissions analysis conducted by Environment and Climate Change Canada features critical methodological shortcomings. These lead to incorrect conclusions about upstream emissions.

Second, the proposed pipeline expansion “locks in” future greenhouse gas emissions at a level that is not compatible with Canada’s international climate commitments, unless aggressive actions are taken to reduce net emissions from other sectors of the economy.

The “Review of Related Upstream Greenhouse Gas Emissions Estimates” by Environment and Climate Change Canada calculates that upstream emissions associated with production of bitumen that would be transported by the pipeline expansion are 14-17 Mt CO2e.

The report concludes, however, the “incremental” upstream emissions due to the pipeline expansion are likely to be negligible. The reason provided is global competition. To quote:

if oil sands production were to not occur in Canada, investments would be made in other jurisdictions and global oil consumption would be materially unchanged in the long-term in the absence of Canadian production growth.

In other words, the same amount of oil will be produced no matter what development occurs in Canada, so a pipeline decision does not affect global greenhouse gas emissions.

Though this line of reasoning sounds very convincing, it is inappropriate to the problem.

Let me demonstrate. Imagine for a moment that every proposed fossil fuel project in the world were to be independently subjected to the same analysis. Imagine there is a panel like this one in every fossil fuel producing country in the world making an independent decision about each proposed activity.

In each case, the economic modelling would conclude that as long as prices were sufficient, the fossil fuels would be extracted and burned regardless of whether that particular project were constructed. In fact, this was one of the conclusions of the U.S. State Department assessment of Keystone XL; the upstream emissions may be negligible because another pipeline may be constructed even if Keystone XL is not.

Each assessment, on its own, sounds correct, but is not. If the results of all these individual reviews were summed, the conclusion would be that the net greenhouse gas effect of all new fossil fuel projects is negligible. Obviously this is incorrect. How could the world build all these new fossil fuel projects and not increase greenhouse gas emissions?

In sum, the analysis in the Environment and Climate Change Canada review is mathematically inconsistent if applied broadly.

Why? Climate change is a collective action problem. If the existence of other polluters is used as an argument against mitigation, then no mitigation can happen. The review is structured, possibly unintentionally, to always provide an answer of close to zero.

Rules and regulations surrounding pollution, whether in our waterways, the atmosphere, or even inside buildings like this one, are essentially created to address such “tragedies of the commons.” The rules create a framework with which to evaluate whether individual actions are detrimental to the common good.

Canada currently lacks that regulatory framework. We can, however, contrast the emissions from oil sands activities that will occur if the pipeline is expanded to the “emissions” standards, which in this case are Canada’s commitments under the Paris Climate Agreement.

This leads us to the second point.

Recall that the Environment and Climate Change Canada review estimated the upstream emissions, if all the bitumen transported by the pipeline is the result of new oil sands activities, is 14-17 Mt CO2e.

As the review explains, some or all of the additional pipeline capacity may be filled by oil sands production currently transported by rail or from projects to be completed by 2019, especially if prices are above US$60/bbl and no other pipelines are approved. By this reasoning, the incremental upstream emissions will be somewhere from 0 to 14-17 Mt CO2e.

It is important then to look at the baseline for emissions from the oil sands. If the pipeline expansion goes forward, total emissions from oil sands activities are “locked in” at a minimum of today’s level. The lowest scenario for oil sands emissions with the pipeline expansion is today’s level (62 Mt CO2e in 2013); the highest case scenario is today’s level plus the additional upstream emissions (76-79 Mt CO2e/year) .

How does this compare to Canada’s commitments under the Paris Climate Agreement?

The Intergovernmental Panel on Climate Change has been able to estimate how much carbon the world has left to burn before having a high probability of passing a given temperature threshold. My colleague Kirstin Zickfeld and I have calculated Canada’s portion of this global carbon budget for the 1.5 °C or 2 °C warming limits in the Paris Climate Agreement. For shorthand, I’ll refer to these as slices of carbon pie.

Under the low end scenario in which the pipeline expansion displaces bitumen transported by rail, with a 20-year lifetime – the length of time for which Kinder Morgan advertises economic benefits of pipeline expansion – the oil sands emissions would represent 34% to all of Canada’s 1.5 °C carbon pie, or 9-37% of Canada’s 2 °C carbon pie. With a 50-year lifetime – the length of time for which the pipeline is expected to operate without replacement – we use up virtually all of the 1.5 °C carbon pie, and 21-83% to all of the 2 °C carbon pie.

Under the high end scenario, these values increase. Twenty years of operation locks in oil sands emissions that comprise 11-46% of Canada’s remaining 2 °C carbon pie. Fifty years of operation locks in 25% to all of that 2 °C carbon pie.

Therefore, even in the most conservative estimate, with only 20 years of operation and no incremental upstream emissions, the pipeline expansion would lock in oil sands emissions at a level that would make it challenging for Canada to meet its commitments under the Paris Climate Agreement. Oil sands activities would consume a substantial portion of Canada’s share of even the larger 2 °C carbon budget, leaving less space for other sectors of the economy.

In order to approve this activity and remain true to our international commitments, the federal government would need to put in place policies that will significantly reduce greenhouse gas emissions in other sectors of the economy or invest sufficiently in “negative” emission technologies like carbon capture.

Let me reiterate that I’m agnostic about the impacts of the pipeline expansion. I’m actually sympathetic to the members of the National Energy Board and to the members of this panel, who are in the unenviable position of making decisions in an incomplete regulatory environment. The numbers indicate that without national climate policies in place, approval of the pipeline expansion is likely to jeopardize the country’s ability to meet its international climate commitments.

NOTES:

[1] The global carbon budget analysis is based on the relationship between global temperature and CO₂-only emissions. The oil sands emissions in this scenario are 56 Mt CO₂/year, estimated by multiplying 2013 estimate by the fraction of all greenhouse gas emissions from “mining and oil and gas production” and  fugitive oil sources that are in the form of CO₂ (90%).

[2] The 20-year period of pipeline operation is 2020-2039, and the 50-year period of operation is 2020-2068. Cumulative emissions are calculated beginning in 2016, following Donner and Zickfeld (2016).

[3] The percent of Canada’s carbon budget is calculated using the emissions-based (low end) and equity-based (high end) budget estimates from Donner and  Zickfeld (2016).