This article was written by Toby Heaps and was published in the Toronto Star on June 29, 2024.

TOBY HEAPS IS THE CO-FOUNDER AND CEO OF CORPORATE KNIGHTS, A MEDIA AND RESEARCH COMPANY BASED IN TORONTO FOCUSED ON ADVANCING A SUSTAINABLE ECONOMY.

There’s no question that many major Canadian companies are applying vision and innovation, and making impressive progress toward circular business models, decarbonization and greater social equity.

That’s the encouraging takeaway from Corporate Knights’s comprehensive annual assessment of corporate citizenship on the part of all Canadian companies with $1 billion or more in annual revenues.

But having done this analysis for nearly 25 years, I increasingly focus not just on the achievements of the top ranked Best 50 companies, but also on what our analysis reveals about the comparative scope and pace of progress economywide. That’s the sobering part of the exercise.

But let’s start on the positive side of the ledger.

Looking at the 2024 50 Best Corporate Citizens ranking, I’m encouraged first by diversity. Three distinct sectors and business models are represented at the top of the ranking via first-place Société de transport de Montréal, followed by Stantec Inc. and the Co-operators in second and third spots. Good corporate citizenship is clearly not a niche phenomenon.

More fundamentally, I’m encouraged by the growth in investments and revenues that align with credible definitions of sustainability. We weigh these metrics heavily in our ranking given their outsized importance as drivers of economic transformation and long-term corporate success.

Within the full universe of Canadian companies assessed, total sustainable investments stood at $41.3 billion in 2022 and sustainable revenues at $155.1 billion. That’s up an impressive 82 per cent and 77 per cent respectively from 2019. In contrast, growth in nonsustainable investment was only four per cent in that same sample and time frame, and growth in nonsustainable revenues only 20 per cent.

So money is flowing in the right directions, and driving improvement on key metrics such as carbon.

Average carbon productivity among large Canadian companies — that is, the revenues earned per tonne of carbon emitted — jumped from $700,000 to $1 million between 2019 and 2022 (and averages $1.6 million among the Best 50 companies). Underlying that is an eight per cent reduction in absolute carbon emissions on the part of all companies assessed.

This year’s ranking even provides some reason for optimism on key and often troubling social performance metrics. True, increases in CEO pay continue to far outstrip increases in average worker pay. But cash taxes paid are now trending up faster than corporate profits, and current trends suggest that both gender and racial parity on boards are in sight in the next decade.

So that’s all to the good. But with threats such as blowing past the 1.5-degree temperature-increase threshold bearing down on us, it’s not good enough to only ask: Are we making progress? We also need to know if we’re progressing fast enough — and in many respects we are clearly not.

The $41.3 billion in sustainable private-sector investment is a lot, but combined analysis from our federal government and from the Glasgow Financial Alliance for Net Zero indicates that as of this year, we need to be hitting a level of $98 billion and sustaining it through the decade.

Similarly, an eight per cent reduction in absolute carbon emissions over four years is probably most accurately thought of as a good start, given that the UN Environment Programme has indicated we need to hit about that same level of reduction — 7.6 per cent — on an annual basis through the decade.

So does the bad news eclipse the good? Not entirely, but my net takeaway is that we must insist on a broader scope and faster pace of delivery on the promise of good corporate citizenship. Fortunately, we have means available of doing just that.

Clean Economy Investment Tax Credits (ITC), for example, have been proven in the U.S. and elsewhere to be able to generate large-scale private investment in sustainable activities and revenue opportunities. They can be game-changers in Canada too, but we’re taking too long to implement them, with only two of six promised ITCs passed with detailed guidance by the Canada Revenue Agency.

Our analysis further suggests that even many of those companies who are stepping up would benefit from working within better defined frameworks — ones designed to help maximize the impact of every dollar directed toward a sustainable use. Even among this year’s Best 50 companies for example, only half have formal net-zero plans meeting criteria set by the Science-Based Targets Initiative or something similar (a figure that drops to 14 per cent among the full universe of companies).

If you don’t know where you’re going, any road will get you there, but we don’t have the luxury of meandering. We know where our decarbonization and other essential journeys need to lead to, and we know we need to get there quickly.

So it’s urgent that we pick up the pace and get on track, and ensure that today’s leading corporate actions become tomorrow’s norm.

We must insist on a broader scope and faster pace of delivery on the promise of good corporate citizenship

Changes to law draw praise from environmental advocates — and outrage from oil companies

This article was written by Mark Ramzy and was published in the Toronto Star on June 28, 2024.

A new set of federal rules meant to crack down on misleading environmental claims is setting off a clash between climate advocates and fossil fuel groups.

To some, it’s a “watershed” moment for corporate accountability over the climate crisis. To others, it’s an overreach that will “silence” an energy industry that claims it’s cleaning up its act.

At issue are incoming changes to Canada’s competition law that can penalize businesses that don’t provide evidence for claims they make about the environmental impact of any products or business practices — an attempt to deter a rise in what’s been dubbed “greenwashing.”

But what do these new rules actually do? Here’s what you need to know.

Current law too ambiguous

Existing laws on deceptive marketing have given the Competition Bureau the power to tackle unsupported environmental claims about specific products or services. That has resulted in penalties against three companies since 2016: Keurig over coffee pod recycling claims and Volkswagen and Audi over claims about their diesel engines’ emissions.

But as concerns about the climate crisis drive demand for “green” products, complaints about misleading environmental claims are also increasing. However, there was no law specific to cracking down on dubious environmental claims and critics warned existing rules didn’t have enough teeth to tackle the issue.

Those critics included commissioner of competition Matthew Boswell. After the Trudeau government introduced in a wide-ranging omnibus bill new rules that would focus on environmental claims about specific products, Boswell pushed for a broader mandate that would also tackle “forward-looking environmental claims about a business or brand as a whole,” like claims to be “net-zero” or “carbon neutral by 2030.”

“Under the old law, there was a substantial amount of ambiguity whether the law would touch claims about not just a product or service, but, you know, a business or business activities in general,” said Keldon Bester, the executive director of the Canadian Anti-Monopoly Project.

In the last stages of passing the bill, parliamentarians made changes to strengthen the new rules, so that environmental claims about business activities must be “based on adequate and proper substantiation in accordance with internationally recognized methodology.”

Cue the outrage.

Oil and gas groups worry

Several fossil fuel industry groups immediately raised alarm over the new changes, arguing the burden of proof was too vague and could be abused. Pathways Alliance, a consortium of the largest oilsands companies in Canada, wiped its entire website, calling for clarity from the Competition Bureau. The Canadian Association of Petroleum Producers said it was a “radical” change that “effectively muzzles Canadian businesses,” claims echoed by Danielle Smith’s Alberta government.

“Creating a public disclosure standard that is so vague as to lack meaning and that relies on undefined ‘internationally recognized methodology’ opens the door for frivolous litigation, particularly by private entities who will now be empowered to directly enforce this new provision of the Competition Act,” said a statement from Pathways Alliance. “This represents a serious threat to freedom of communication.”

Neither group accepted an interview request.

The oil and gas groups, which are under heavy scrutiny for their role in driving the climate crisis, insisted they would not back down on their environmental commitments, but other groups made the argument the changes could deter investment in clean energy from companies afraid they wouldn’t be able to communicate their business practices. In 2022, the oil and gas sector was Canada’s largest source of emissions, accounting for 31 per cent of total national emissions.

Environmental advocates, meanwhile, claimed the negative reaction from the oil and gas groups was evidence they knew their claims to take climate change seriously were “bogus.”

“It doesn’t shut down production, or hold them accountable for oil leaks, or tell them their emissions are too high,” said New Democrat MP Charlie Angus, who has proposed even stricter rules to ban fossil fuel advertising.

Experts in competition law say the bureau needs to give guidance to businesses as to how they will be impacted by the new rules. In the meantime, businesses have the right to be concerned, said Robin Spillette, a lawyer at Fasken.

“There’s a lot of new words in here, and it’s just I think, right now, not clear to companies what exactly this is going to capture and what they need to do to ensure they’re onside these provisions,” Spillette said.

A spokesperson for Industry Minister François-Philippe Champagne said the government understands those concerns. The Competition Bureau, in response, is “assessing the impact of these requirements and expects to provide guidance, in due course, that will offer transparency and predictability for the business and the legal communities in the enforcement of the law,” it said.

More frequent enforcement

Spillette said part of what needs to be clarified is to what standards businesses’ environmental claims will have to adhere.

“It could be hard for a business to say, you know, what’s internationally accepted today or what is not, and then what might change tomorrow,” she said.

But the biggest impact of the changes, she said, will be more frequent enforcement. The Competition Vureau is currently investigating at least four claims of “greenwashing” against Pathways Alliance, the Canadian Gas Association, RBC and Lululemon.

Punishments for non-compliance can include being forced to stop the marketing in question, publishing a notice and significant financial penalties.

Bester said the bureau should also present examples in its guidance of the kinds of claims it is hoping to crack down on.

This article was written by James MacCarthy, Alexandra Tyukavina, Mikaela Weisse, and Nancy Harris, and was published by the World Resources Institute on June 27, 2024. 

The energy giant is lobbying Ontario municipalities to ensure efforts to reduce emissions don’t threaten its bottom line

This article was written by Fatima Syed and was published in the Narwhal on June 25, 2024.

Britain may be chilly, but from Greece to India, people are dying due to record temperatures. The death toll will grow without urgent action

This editorial was written and published by The Guardian on June 16, 2024.

Bill would force firms to prove their environmental claims

This article was written by Amanda Stephenson and was published in the Toronto Star on June 21, 2024.

The Pathways Alliance group of oilsands companies has removed all content from its website and social media feeds, citing uncertainty over a new antigreenwashing rule poised to become federal law, while a major oil and gas industry group has also modified its website.

The Pathways Alliance is a consortium of Canada’s six largest oilsands companies, which together have publicly committed to reaching net-zero greenhouse gas emissions from oilsands production by 2050.

The consortium has previously spent millions of dollars on a countrywide public relations blitz aimed at demonstrating that the oilsands is committed to helping fight climate change.

But as of Thursday, all that remains on the group’s website is a notice saying Pathways has removed its content due to concerns around an anti-greenwashing provision in federal Bill C-59.

“Imminent amendments to the Competition Act will create significant uncertainty for Canadian companies that want to communicate publicly about the work they are doing to improve their environmental performance,” the Pathways statement reads.

“With uncertainty on how the new law will be interpreted and applied, any clarity the Competition Bureau can provide through specific guidance may help direct our communications approach in the future.”

The group — which has not yet responded to an interview request — added it remains committed to the work it is doing to reduce the environmental impacts of oilsands production.

The Canadian Association of Petroleum Producers also said Thursday it has “chosen to reduce the amount of information available on its website and other digital platforms.”

The omnibus bill C-59, which passed third reading in the Senate Wednesday and will soon become law, contains a truth-in-advertising amendment that would require corporations to provide evidence to support their environmental claims.

The provision is not fossil fuelspecific, but applies to all businesses and economic sectors.

The bill’s wording says businesses must not make claims to the public about what they are doing to protect the environment or mitigate the effects of climate change unless those claims are based on “adequate and proper substantiation in accordance with internationally recognized methodology.”

The Pathways Alliance says it remains committed to the work it is doing to reduce the environmental impacts of oilsands production

‘‘ This is basically a very modest provision in the Competition Act. It simply requires companies to tell the truth and to have an evidence base to back up their claims. So I do think this reaction is very telling.

LEAH TEMPER CANADIAN ASSOCIATION OF PHYSICIANS FOR THE ENVIRONMENT

The passage of the provision is a win for Canadian environmental groups, who have been mounting a full-fledged campaign against “greenwashing” — a term given to the perceived tendency by companies to market their products and practices as more sustainable than they really are.

In the last year, Canadian green groups have lodged at least four formal complaints with the federal Competition Bureau alleging greenwashing or false environmental claims by fossil fuel companies or banks.

The Pathways Alliance was the target of one of those complaints. Environmental groups have said the consortium’s ads and public claims about net-zero are misleading, as the Pathways Alliance has not yet made a final investment decision on its proposed $16.5-billion carbon capture and storage network.

Leah Temper, program director with the Canadian Association of Physicians for the Environment, said Thursday she was “thrilled and surprised” to see the oilsands industry react so strongly to the passage of C-59.

“This is basically a very modest provision in the Competition Act. It simply requires companies to tell the truth and to have an evidence base to back up their claims,” Temper said.

“So I do think this reaction is very telling.”

In a statement, the Canadian Association of Petroleum Producers said the anti-greenwashing provision will have the effect of silencing the energy industry and curtailing the ability of Canadians to participate in debates around climate and environmental policy.

“The burden of proof provision included in the amendments means those making the complaint face no risk or accountability. Rather, the burden falls entirely on companies,” said CAPP president and CEO Lisa Baiton.

“Businesses across Canada are being put at significant risk for communicating their efforts to reduce their impact on the environment.”

But Temper said that as climate change concerns mount, it has become increasingly common for businesses in all industries to make questionable environmental claims in their advertising.

“It has been the Wild West. Companies have been able to make almost any claim they want, using terms such as net-carbon neutral, without any reliable evidence base,” Temper said.

“Hopefully this (C-59) will represent a sea change.”

Alberta Environment Minister Rebecca Shulz has called the antigreenwashing provision an “undemocratic gag order” that creates needless uncertainty for businesses.

Earlier this month, UN secretarygeneral Antonio Guterres urged countries to ban advertising by fossil fuel companies in the face of the climate crisis.

This article was written by Jeffrey Jones and was published in the Globe & Mail on June 21, 2024.

Several Canadian oil companies and lobby groups have added disclaimers to their websites and socialmedia feeds – in one case, scrubbing all content – in response to new federal legislation that aims to stamp out false or exaggerated environmental claims.

A contentious provision within the government’s Bill C-59 makes changes to the Competition Act to combat greenwashing, and puts companies at legal risk for making environmental or social assertions in public communications that do not stand up to scrutiny. Individuals and companies could face sizable fines if found liable.

On Wednesday, Pathways Alliance, a coalition of oil sands producers proposing a multibillion-dollar carbon capture and storage project, replaced its website and social-media content with a disclaimer it said is in response to the C-59 anti-greenwashing measure.

The amendment “will create significant uncertainty for Canadian companies that want to communicate publicly about the work they are doing to improve their environmental performance, including to address climate change,” it reads. The group warned that creating a disclosure standard it described as vague will open the door to frivolous lawsuits.

The legislative changes are part of the Fall Economic Statement Implementation Act, which received royal assent on Thursday.

Environmentalists have lauded the measure, which they say will help protect consumers by injecting reality into green claims.

They allege Canadian regulators have been dragging their feet when it comes to implementing mandatory climate-related disclosures.

Business and energy groups have argued vociferously against the provision, saying they will be forced to back up their assertions against standards that are still undefined. Alberta, a perennial foe of Prime Minister Justin Trudeau’s government on environmental matters, blasted the measure as “draconian.” Provincial Environment Minister Rebecca Schulz said it will hinder Canadians’ ability “to hear the truth about the energy industry and Alberta’s successes in reducing global emissions.”

At least three of the Pathways Alliance member companies, Suncor Energy Inc., Cenovus Energy Inc. and Canadian Natural Resources Ltd., have added notes to their online communications that warn of uncertainty regarding their ability to discuss environmental, social and governance matters.

“We’re going to see a lot more of this from a bunch of companies in a variety of sectors in the coming days,” said Conor Chell, national leader, ESG legal risk & disclosure, at KPMG.

“I think it will be a combination of disclaimer-type language that we’ll see, and some companies will likely choose to withdraw some or all of their ESG disclosure from the public domain,” he said. “Over all, I think what it says is there’s a lot of uncertainty.”

The change is primarily aimed at corporate net-zero or carbon-neutrality assertions, but also to address the authenticity of consumer product claims, he said.

The provision is broad – apart from sustainability reports, it could apply to comments made on social media, in investor presentation slides and even documents submitted to requests for project proposals, Mr. Chell said. In addition, the Competition Bureau could examine commentary made in the social realm, such as adherence to the Modern Slavery Act or regarding diversity, equity and inclusion.

Pathways Alliance said its members are committed to improving the industry’s environmental performance, but urged the bureau to provide clarity so it can determine the material they can publish.

The group has faced criticism over delays in moving forward with a $16-billion project to capture 12 million tonnes of greenhouse-gas emissions by 2030, a development that would require significant taxpayer support.

The Competition Bureau, which in recent years has dealt with greenwashing complaints, has said the amendment will strengthen its ability to police deceptive claims. But it declined on Thursday to provide details on how enforcement and determining infractions would change from current practices.

The Canadian Association of Petroleum Producers, the industry’s main lobby group, said it, too, had reduced the amount of information on its website in response to the amendment, which it contends is aimed at silencing its members and the ability of Canadians to debate climate and environmental policy.

Under the legislation, individuals could be fined up to $750,000, or three times the amount of any financial benefit gained, whichever is greater. Companies could face fines of $10-million or three times the financial benefit. If that figure is unknown, a company may have to pay 3 per cent of worldwide revenues.

Asked at a news conference about Pathways Alliance removing the content from its website, the Prime Minister said he believes freedom of expression is important in a democracy. “But we need to make sure that people are debating and discussing and basing their worldview on things that are anchored in truth and reality,” he said.

An alliance of green groups – the Canadian Association of Physicians for the Environment, Ecojustice, Équiterre and the Quebec Environmental Law Centre – had made recommendations to the government on the anti-greenwashing provision. The group said on Thursday that it would help address skepticism among consumers and reward companies that make sincere investments in sustainability.

Canada’s big banks are frequent targets of activists who complain that they tout their netzero targets, while at the same time remaining major lenders to fossil-fuel producers. The banks have consistently said they are setting aside billions of dollars to help those companies make the transition to lower-carbon operations.

The Canadian Bankers Association said the financial institutions are reviewing the legislation and its implications, and there appeared to be no changes to the banks’ digital communications on Thursday.

“Banks in Canada are implementing climate action plans and reporting on their actions,” said Maggie Cheung, spokesperson for the association.

Deloitte’s findings contradict federal government

This article was written by Amanda Stephenson and was published in the Toronto Star on June 19, 2024.

Canadian oil and gas companies facing a federally imposed emissions cap will decide to cut their production rather than invest in too-expensive carbon capture and storage technology, a new report by Deloitte says.

The Alberta government-commissioned report — a copy of which was obtained by The Canadian Press — aims to assess the economic impact of the proposed cap.

Its findings contradict the federal government’s stance that its proposed cap on greenhouse gas emissions from the oil and gas sector would be a cap on pollution, not a cap on production. And it supports Alberta’s position that a mandated cap would lead to production curtailments and severe economic consequences.

But the Deloitte report also casts doubt on the idea that widespread deployment of carbon capture and storage technology will drive down emissions from the oil and gas sector in the coming years, suggesting that scenario doesn’t make financial sense.

“We expect that the cap (will impose) 20 megatonnes in emissions reduction on producers by 2030, which will need to be achieved by CCS (carbon capture and storage) investments, or through production curtailment,” the Deloitte report states.

“Curtailing production would be a more cost-effective option compared to investing in CCS.”

The oil and gas sector is Canada’s heaviest-emitting industry, and rising oilsands production has meant total emissions from the sector are increasing at a time when many other sectors of the economy are successfully reducing overall emissions.

Globally, oil demand is growing, with the International Energy Agency forecasting global oil demand to be 3.2 million barrels per day higher in 2030 than in 2023, though the agency also suggests growing supply will outstrip demand growth sometime this decade.

In a draft framework released last December, the federal government proposed mandating a ceiling on oil and gas emissions in order to help slow climate change. The rules would require the industry to cut greenhouse gas emissions by 35 to 38 per cent from 2019 levels by 2030. Companies would also have the option to buy offset credits or contribute to a decarbonization fund that would lower that requirement to cutting just 20 to 23 per cent.

But the Deloitte report suggests oil production in this country could increase 30 per cent, and gas production over 16 per cent, from 2021 to 2040.

Those figures are based on a Canada Energy Regulator forecast and on current government policies.

This means that producers will have two choices to meet the constraints of an emissions cap, Deloitte argues.

They can invest heavily in carbon capture and storage — trapping greenhouse gas emissions from oil production at site and storing them safely underground — or they can cut back on planned production increases.

‘‘ Curtailing production would be a more cost-effective option compared to investing in (carbon capture and storage).”

DELOITTE REPORT

This article was written by Amanda Stephenson and was published in the Globe & Mail on June 19, 2024.

Deloitte’s findings contradict Ottawa, support Alberta’s position that a limit would drop oil production rather than invest in carbon capture

Canadian oil and gas companies facing a federally imposed emissions cap will decide to cut their production rather than invest in too-expensive carbon capture and storage technology, a new report by Deloitte says.

The Alberta government-commissioned report – a copy of which was obtained by The Canadian Press – aims to assess the economic impact of the proposed cap.

Its findings contradict the federal government’s position that its proposed cap on greenhouse gas emissions from the oil and gas sector would be a cap on pollution, not a cap on production. And it supports Alberta’s position that a mandated cap would lead to production curtailments and severe economic consequences.

But the Deloitte report also casts doubt on the idea that widespread deployment of carbon capture and storage technology will drive down emissions from the oil and gas sector in the coming years, suggesting that scenario doesn’t make financial sense.

“We expect that the cap (will impose) 20 megatonnes in emissions reduction on producers by 2030, which will need to be achieved by CCS (carbon capture and storage) investments, or through production curtailment,” the Deloitte report states.

“Curtailing production would be a more cost-effective option compared to investing in CCS.”

The oil and gas sector is Canada’s heaviest-emitting industry, and rising oil sands production has meant total emissions from the sector are increasing at a time when many other sectors of the economy are successfully reducing overall emissions.

Globally, oil demand is growing, with the International Energy Agency forecasting global oil demand to be 3.2 million barrels per day higher in 2030 than in 2023, though the agency also suggests growing supply will outstrip demand growth some time this decade.

In a draft framework released last December, the federal government proposed mandating a ceiling on oil and gas emissions in order to help slow climate change. The rules would require the industry to cut greenhouse gas emissions by 35 to 38 per cent from 2019 levels by 2030. Companies would also have the option to buy offset credits or contribute to a decarbonization fund that would lower that requirement to cutting just 20 to 23 per cent.

But the Deloitte report suggests oil production in this country could increase 30 per cent, and gas production over 16 per cent, from 2021 to 2040. Those figures are based on a Canada Energy Regulator forecast and on current government policies.

This means that producers will have two choices to meet the constraints of an emissions cap, Deloitte argues. They can invest heavily in carbon capture and storage – trapping greenhouse gas emissions from oil production at site and storing them safely underground – or cut back on planned production increases.

The oil and gas industry itself has been promoting carbon capture and storage as the key to reducing emissions while still increasing production. The oil sands industry, which is responsible for the bulk of Canada’s overall oil and gas sector emissions, has proposed spending $16.5billion on a massive carbon capture and storage network for Northern Alberta.

But the group of companies behind the proposal, called the Pathways Alliance, has not yet made a final investment decision, saying more certainty about the level of government support and funding for the project is required.

In its report, Deloitte concludes the cost of carbon capture and storage is so high that in many cases, it is “economically unviable.”

It says it is unlikely that many companies would go that route in an effort to comply with an emissions cap, and would instead simply curtail production.

“It is important to note that once implemented, the investment in CCS is irreversible,” the report states.

“However, production curtailment can be reversed. Considering these factors, we do not foresee any oil sands CCS investments being implemented.”

The Deloitte report concludes a mandatory limit on greenhouse gas emissions from the oil and gas sector would result in decreased production, job losses and investment, as well as a “significant” decline in GDP in Alberta and the rest of Canada.

The mining, refinery products and utilities sector will also experience a decrease in real output in the event of an emissions cap, Deloitte says, due to their proximity to the oil and gas sector.

Alberta’s oil production in 2030 would be 10 per cent lower with a cap than without one, the Deloitte report suggests, and its natural gas production would be 16 per cent lower. The cap would also mean decreased fossil fuel production in B.C., Saskatchewan and Newfoundland.

By 2040, Deloitte says, Alberta’s GDP would be 4.5 per cent lower, and Canada’s GDP would be one per cent lower, than if no emissions cap were in place.

Alberta Environment Minister Rebecca Shulz said the report supports what the province has been saying all along.

“We have to use common sense. You have to take socio-economic data into perspective when you’re looking at policies like [an emissions cap],” said Ms. Shulz in an interview.

“I don’t think Canadians want to see us throw the country into further economic decline.”

Ms. Shulz added Alberta recognizes that the economics of carbon capture and storage are challenging. She said heavy handed government policy that makes companies less profitable will only have the effect of discouraging investment in emissions reduction.

“From a policy perspective, the layering of all of these punitive measures are continuing to drive away the emissions reduction technology that we actually want to see happen here,” she said.

The Deloitte report predicts Alberta would have 54,000 fewer jobs in 2030 with an emissions cap than without one.

Once implemented, the investment in CCS is irreversible. However, production curtailment can be reversed. Considering these factors, we do not foresee any oil sands CCS investments being implemented.

DELOITTE REPORT