ALBERTA:AN EMISSIONS TRADINGCASE STUDYAlberta
The World’s Carbon Markets: A Case Study Guide to Emissions Trading
Last Updated: April 2015

Compliance Period (2015 )Target50 million tCO2 e reduction by 2020, comparedwith BAU projections

Cap

12% below established 2003-05 baseline
emissions

Carbon price

CAD $15/tCO2e

Greenhouse gases
CoveredCarbon Dioxide (CO2), Methane (CH4), Nitrous
Oxide (N2O) Sulphur Hexafluoride (SF6)
Hydrofluorocarbons (HFCs), Perfluorocarbons(PFCs)

Number of
Entities Covered

108 (2013)

Sectors Covered

Chemical and fertilizer manufacturers; coalmines; forest product producers; gas plants;
mineral and metal processors; oil sand mines,
upgraders and extractors; petroleum refiners;
pipeline transportation; power plants; waste
management

Threshold> 100,000 tCO2

% Total Emissions
Covered50% (of Alberta emissions)

Compliance tools& Flexibility
mechanisms

Offset credits, financial contributions to anemissions management fund, emission
performance credits
Table 1: Program Overview

Page 1 of 11

Brief History & Recent Developments
Year
1988

Event
Alberta announced first Strategy for Action on Climate Change

2002

First climate action plan released: Albertans and Climate Change:
taking action

2003

First Canadian province to develop climate change legislation Climate Change Management Act

2004

Specified Gas Reporting Standard was established2007

Specified Gas Emitters Regulation (SGER) came into force

2008

Alberta sets 2020 emission reduction target of 50 million tCO2e
below business as usual

2010

Alberta meets target to reduce emissions by 20 million tCO2e

2013

Cumulative greenhouse gas reductions achieved from SGER
between 2007 and 2013 equal 51 million tonnes CO2e and thecollection of $497 million in the Climate Change and Emissions
Management Fund to be invested into climate change mitigation or
adaption projects

2014

Government extends expiration deadline of SGER, and othergreenhouse gas regulations, until June 2015
Table 2: Key Dates

In 2013, Alberta emitted 267 million tonnes of carbon dioxide equivalent (million tCO2e), which was the highest
amount of greenhouse gases (GHG) emissions of the 13 Canadian provinces and territories.a Alberta accounted for
36.8% of Canada’s overall emissions (726 million tCO2e).1 Alberta has the world’s third-largest supply of proven crude
oil reserves, after Saudi Arabia and Venezuela.2 Because of its role as a global energy supplier, Alberta has anemissions profile dominated by industrial activity and the fastest growing economy of the Canadian provinces andterritories.3
In 2002, the Alberta Government released an action plan outlining the province’s approach to managing GHG
emissions. This action plan led to the Climate Change and Emissions Management Act (CCEMA), which was passed
in 2003. CCEMA developed a mandatory emissions reporting program, established in 2004, which required all
facilities in Alberta emitting over 100,000 tonnes of CO2e (tCO2e) per year to submit an annual report on theirprevious year’s GHG emissions. The reporting threshold was later changed in 2010 to apply to all facilities emitting
more than 50,000 tCO2e in 2010.4
In 2007, Alberta passed the Specified Gas Emitters Regulation (SGER), North America’s first GHG emissions
regulation for large emitters and compliance carbon pricing system. SGER requires large emitting facilities to reducebaseline emissions intensities from 1 July, 2007 by 12%, during each compliance period. In order to meet theirintensity reductions, covered facilities have four compliance options:••••

Reduce on-site emissions;Purchase or use emission performance credits issued on the Alberta Emission Performance Credit Registry;
Purchase Alberta-based offset credits; orContribute to the Climate Change and Emissions Management Fund.

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
a

Note: in 2013 Environment Canada’s National Inventory Report quantified emissions with IPCC 2007 global warming potentials and IPCC 2006 Guidelines. For
comparison to SGER 2013 compliance, Alberta’s emissions as quantified with IPCC 2004 global warming potentials were 261 million tCO2e.

Page 2 of 11

Although the SGER was intended to expire in September 2014, it, along with the Specified Gas Reporting Regulation,
the Administrative Penalty Regulation and the Climate Change and Emissions Management Fund Administration
Regulation, has been extended through the end of June 2015 to explore new approaches to mitigating emissions andmeeting future targets.5 The review offers an opportunity for Alberta to expand incentives to reduce emissions
through technological innovations and energy efficiency measures or to modify or terminate existing legislations.
Communication regarding the Alberta government’s future Climate Change Strategy is expected in spring 2015.

Figure 1: Total reported 2013 Alberta Greenhouse Gas Emissions by Industrial
Sector
Source: Alberta Environment & Sustainable Resource Development (ARSRD), 2015. Available at:
ec.gc.ca

Summary of Key Policy Features
TARGET: Alberta’s program sets a facility-level emissions intensity goal, as opposed to an absolute cap on
aggregate emissions. Facilities’ total annual emissions are divided by their total annual production. As such, theprogram allows the increase of GHG emissions annually as production expands so long as the facility is able to reduce
GHG emissions per production unit through flexible compliance. For facilities existing in 2000, the goal is to reduce
annual emissions intensity by 12% below a baseline established using 2003-05 averages for emissions andproduction.6
The baseline for new facilities is established during its first three years of commercial operation.7 Importantly,
Alberta’s SGER does not have a declining absolute target for facilities over time, but instead requires facilities to meeta constant emissions intensity target each year. The compliance obligation for these facilities begins at a 2% reduction
per year, starting in the fourth year of commercial operation, and tightens by 2% each year until a 12% reduction
target is reached (over a six-year period).8 Figure 2 depicts Alberta’s planned emissions path relative to business as
usual (BAU). With the exception of SGER’s first compliance period, which spanned only six months and ended on 1
December, 2007,9 all of Alberta’s compliance periods have been annual.

Page 3 of 11

In 2008, the Alberta Government developed their Climate Change Strategy which outlines Alberta’s emission
reduction targets through to 2050:10
Year

Goal

Result2010

Reduce projected emissions by
20 million tCO2e

Meet intensity target established in 2002

2020

Reduce projected emissions by
50 million tCO2e

Stabilise GHG emissions and begin
reductions

2050

Reduce projected emissions by
200 million tCO2e

Emissions reduced by 50% below BAU
level and 14% below 2005

Table 3: Alberta’s Climate Change Strategy
Source: Government of Alberta, 2008. Alberta’s 2008 Climate Change Strategy. Available at: esrd.alberta.ca

Figure 2: Alberta’s Planned Emissions Reductions 2006-2050
Source: IETA Greenhouse Gas Market, 2012.

SCOPE & COVERAGE: Alberta’s program covers any facility that emitted 100,000 tCO2e or more in 2003 or any
subsequent years.11 The SGER covers all sectors and includes emissions from: chemical and fertilizer manufacturers;
coal mines; forest product producers; gas plants; mineral and metal processors; oil sand mines, upgraders andextractors; petroleum refiners; pipeline transportation; power plants; and waste management.12 Industrial process
emissions and CO2 emissions from biomass are exempt from compliance requirements, although reporting isrequired for any facility emitting more than 50,000 tonnes CO2e annually.13 Alberta’s program covers directemissions of six gases: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O) sulphur hexafluoride (SF6),hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs). In 2013, Alberta’s program covered 108 facilities in 13
economic sectors14 and encompassed 50% of Alberta’s GHG emissions.15

Page 4 of 11

COMPLIANCE OBLIGATION: As an intensity-based program, there are no allowance distributions or
auctioning rules in place. Instead, each covered facility is obligated to achieve a 12% reduction below its establishedbaseline intensity Baselines can be revised if:•

the Alberta Environment and Sustainable Resource Development's representative appointed under the
SGER (The Director) believes original baselines are inaccurate;
the facility has undergone an expansion or significant change;•

for additional reasons at The Director’s discretion.16•

Facilities can comply with their intensity target by using one of the four pathways proposed by the SGER:17
•
•

•
•

Reduce emissions intensity on-site through improvements in facility operations and efficiency.
Pay a fee of CAD $15 per tonne of CO2e per year to Alberta’s Climate Change and Emissions
Management Fund (CCEMF), a dedicated fund to achieve emissions reductions in Alberta or prepare
the province to adapt to changing climate. Much of the fund has been granted to the Climate Change
and Emissions Management Corporation (CCEMC), who have invested in green technology andinnovation projects. For each payment to the fund, a facility obtains one fund credit equal to one tonne
reduction in CO2e. This fund creates a pool of resources that enables additional investments in reducing
emissions or adapting to climate change.
Purchase an emission offset generated from non-covered activities in Alberta. A one tonne
reduction in CO2e from a non-covered activity constitutes one emissions offset.18
Purchase or use Emissions Performance Credits (EPCs) from covered facilities that have
reduced their emissions intensity below their target and want to sell any extra reductions, or from theirown stocks of banked credits from previous years.

Net emissions intensity is calculated using the following equation:
Net Emissions Intensity = [Emissions Intensity of Covered Facility’s Operations – (Fee + Offsets + Credits)]/Production
Where the fee is equal to the number of credits received from paying into the CCEMF; offsets equals the number ofcredits received from purchasing qualified emissions offsets; and, credits equals the number of EPCs purchased fromover-achieving entities or banked from previous years at an over-achieving facility.

Requirements for Climate Change and Emissions Management Fund (CCEMF)
Credits received from funds paid to the CCEMF cannot be banked for future use. Specifically, a technology fund credit
obtained before the annual compliance deadline (on 31 March) can only be used in meeting a facility’s net emissions
intensity limit for the previous year. Similarly, a fund credit obtained after the annual compliance deadline can only
be used for compliance in that year. Fund credits may also be used to reconcile errors in previous reporting years19

Page 5 of 11

To date, the CCEMC has invested CAD $248.9 million in 100 projects focusing on energy efficiency, clean andrenewable energy and adaptation issues.20

Figure 3: CCEMC Funding by Strategic Investment Area ($ millions)
Source: CCEMC, 2014. Available at: ccemc.ca

Requirements for Emissions Offsets
The SGER details the following requirements for offset eligibility. The reduction must:21-

have occurred in Alberta;
be from an action that is not required by law at the time of its initiation;
result from actions taken on or after 1 January, 2002, and must occur on or after 1 January, 2002;
be real, demonstrable, quantifiable and measurable.

Alberta has approved many existing quantification protocols. Alberta draws on related protocols to inform its
quantification, monitoring and reporting, including – but not limited to – the Clean Development Mechanism (CDM),
the Climate Action Reserve (CAR), the World Resources Institutes (WRI), and the Intergovernmental Panel on
Climate Change (IPCC).22 Currently, oversight occurs through Alberta Environment and Sustainable Resource
Development (AESRD) who provide technical guidance to offset project developers23 which outlines standards,
system criteria and all conditions that must be satisfied to obtain offset project approval. Registered offset projects
must be reviewed by an independent verifier, such as a chartered accountant or professional engineer, who willsubmit a signed statement in support of the project.24
Alberta quantification protocols provide standardized methodologies for specific GHG emission reduction
opportunities within the province. Offset credits are available to Alberta facilities, municipalities, agricultural
producers and others that emit less than 100,000 tonnes of CO2e a year and to projects that intend to start claiming
credits in the same calendar year in which they were registered. Project registrations are valid for eight years, andmost can be extended for an additional five years. The two exceptions are conservation cropping and afforestation
projects, each of which has longer, specific duration periods based on biological cycles.25

MARKET REGULATION & OVERSIGHT: On 31 March of each year, covered facilities must submit a reportconfirming whether the net emissions intensity limit has been met or provide an acknowledgment, explanation andproposal to address non-compliance. In addition, each report must be verified by a third-party auditor.26 In order toPage 6 of 11

qualify, auditors must be a professional engineer under the Engineering, Geological and Geophysical Professions Act
or a chartered accountant under the Regulated Accounting Profession Act, or a member of a profession with similarcompetence and practice requirements. Verifiers must also have technical knowledge of specified gas emission
quantification methodologies and audit practices. Auditors cannot be associated or affiliated with the reporting
facility or be an employee or agent of the Alberta Government.27
If a facility is found to be non-compliant, the Director may issue an order to the facility to minimize or remedy theeffects of non-compliance. Moreover, the Director may require the facility to obtain emissions offsets or performancecredits, make contributions to the CCEMF or take any other measure the Director considers advisable. Further, afacility in non-compliance can be charged a fine of no more than CAD $200 for every tonne of CO2e emitted over thelimit.28 For individual offences, the fine will not exceed CAD $50,000, whereas a corporation is liable to a fine notmore than CAD $500,000.29
To ensure accuracy and completeness, all Alberta Compliance Reports must be in conformance with SGER and be
verified by a third-party verifier. For the first time, in 2012 Alberta regulators required these reports to be verified to a
“Reasonable Level of Assurance” (compliance information must be reviewed by a third-party verifier) as opposed toprevious years in which only regulator required the verification to a “Limited Level of Assurance”. This transition to“Reasonable” from “Limited” levels of assurance has resulted in more extensive verification procedures during thequantification and verification of Alberta compliance submissions. The transition also results in more standardized
verification procedures, more reliable and complete reports, and now Alberta is basically reporting at the same levelof assurance as other North American jurisdictions.

COMPLEMENTARY POLICIES: In addition to its carbon pricing system, Alberta has employed several
complementary policies to reduce GHG emissions including:30
•
•
•
•

•

•

A Renewable Fuels Standard Regulation, mandating a 5% blend of ethanol and 2% blend of biodiesel;
Incentives for energy efficiency and conservation in the form of energy efficiency rebates;
Programs to raise awareness and promote environmental stewardship;31
Adaptation Framework and Manual to increase adaptive capacity and inform decision makers to identify
appropriate adaptation responses, by assessing the potential impacts of climate change, prioritizing risks,
identifying vulnerabilities and potential adaptation options; 32
Investment into Carbon Capture and Storage (CCS) (CAD $1.3 billion has been invested in two CCS projects
which will be operational in between 2015 and 2017 and are expected to reduce 2.76 million tCO2 a year);33
and,Projects funded by the CCEMC, such as “Farming 4 Land” which encourages Alberta farmers to adopt the
government-approved Nitrous Oxide Emissions Reduction Protocol.34

RESULTS: From 2007 to 2013, Alberta has reduced GHG emissions by 51 million tCO2e from business as usualand has raised CAD $497 million through the CCEMF, CAD $249 million of which has already been invested into 100
clean energy projects.35 This has been achieved through operational changes as well as investments in offsets createdby other Alberta projects.36 It is expected that by 2020 Alberta’s SGER system will achieve a 10.2 million tCO2
reduction in GHG emissions.37

Page 7 of 11

Emissions
ReductionatFacility’s

OffsetCredits
Submitted

RecognitionofCogeneration

Total
Reductions

Fund
Payment(million
tCO2e)(million
tCO2e)(million
tCO2e)(million
tCO2e)(million
tCO2e)

2007(half year)

1.6

0.88

1.28

3.76

41.3

2008

Compliance
Cycle

1.35

2.68

2.58

6.61

85.4

2009

0.89

3.74

2.66

7.29

61.3

2010

1.02

3.85

2.55

7.43

67.4

2011

3.06

5.4

2.51

10.96

55

2012

1.2

3.2

3.41

7.8

87.7

2013

0.45
9.57

2.04

4.17

6.66

98.6

21.79

19.16

50.51

496.7

Total

Table 4: GHG Emission Reduction Program Resultsb
Source: AESRD, 2015. Available at: esrd.alberta.ca

18

16

Megatonnes	
  CO2	
  e q

14

Fund	
  Credits

12

EPCs	
  Submitted

10

Offset	  Credits	
  S ubmitted
Recognition	
  o f	  Cogeneration

8

Emissions	
  Reductions	
  a t	
  Facility(Relative	
  to	
  Baseline)

6

EPCs	
  Generated	
  (Including
Recognition	
  o f	  Cogeneration)4

Total	
  A voided	  Emissions

2

0
2007	
  (half
year)

2008

2009

2010

2011

2012

2013

Figure 4: Breakdown of Compliance Tools for 2007-2013c
Source: AESRD, 2015. Available at: esrd.alberta.ca

	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  	
  
b

Between 2007 and 2013, emissions and compliance obligations were quantified using Intergovernmental Panel on Climate Change 2004 global warming
potentialsc
Ibid.

Page 8 of 11

What Distinguishes this Policy?
UNIQUE ASPECTS:
1.

Alberta was the first North American jurisdiction to regulate GHG emissions from large emitters and implement
a compliance carbon pricing program.

2.

Alberta uses a unique carbon pricing system, based on GHG emissions rates and featuring intensity targets,tradable compliance units (EPCs and offsets) measured in tCo2e, and a first-of-its kind technology fund.

3.

Due to the fixed-price (CAD $15/t) and unlimited access to Alberta’s CCEMF (technology fund), Alberta’s
program features a price ceiling, with trading and offsets allowed. This feature leads some to confuse Alberta’s
system with a carbon tax.

CHALLENGES:
1.

A major challenge for Alberta’s SGER will be how it will interact with future federal Canadian government oil andgas sector regulations. It is unclear whether or how regulations coming into effect in 2016 will impact Alberta’s
ability to achieve its 2020 and 2050 targets.

2.

While the deadline of the program has been extended to June 2015, policy-makers must agree on whether tocontinue, modify, or terminate the program in the first half of 2015. As of 22 April 2015, Alberta has yet to definecore proposed amendments (including revised targets, technology fund pricing/structure changes, offset systemchanges etc.), or clear steps and timelines for stakeholder review and consultations. The delayed process andincreasing uncertainty about the shape of Alberta’s future program is prompting concern across industry,
investors, and other affected stakeholders.

3.

As the SGER is an intensity-based program, GHG emissions can rise annually so long as the carbon footprint perunit diminishes annually.

4.

Compared to other emissions trading schemes, Alberta’s 100,000 tCO2e threshold is relatively high (thethreshold is 25,000 tCO2e in California and Quebec). As such, the Alberta Government is considering lowering
the regulatory threshold to include smaller emitters during the SGER review.

5.

Since 1990, Alberta’s GHG emission levels have risen 65% (to 2013) and are likely to grow. While Alberta
remains committed to reducing their emissions through the SGER, the Alberta government may want to consider
fortifying new and existing complimentary policies to provide greater flexibility in meeting emission reduction
targets for 2020 and 2050.

Page 9 of 11

Author Acknowledgements:
If you have any comments or suggestions for this case study, please do not hesitate to contact lead authors:
CDC Climat Research co-authors:
Lara Dahan(lara.dahan@cdcclimat.com) &Marion Afriat(marion.afriat@cdcclimat.com)

EDF co-author:
Katherine Rittenhouse(krittenhouse@edf.org) &Peter Sopher(psopher@edf.org)

IETA co-author:
Katie Kouchakji(kouchakji@ieta.org) &Katie Sullivan(sullivan@ieta.org)

CDC Contact: Emilie Alberola(emilie.alberola@cdcclimat.com)

EDF contact: Katherine Rittenhouse(krittenhouse@edf.org)

IETA Contact: Katie Sullivan(sullivan@ieta.org)

CDC Climat Research
47 rue de la Victoire,
75009, Paris,
France.

Environmental Defense Fund
18 Tremont Street, Suite 850,
Boston, MA 02108,United States

IETA
350 Adelaide Street West - 3rd Floor
Toronto, Ontario
Canada M5V 1R8.

The authors would like to thank Emilie Alberola, for very helpful comments and information for this case study. We
take full responsibility for any remaining errors.
Disclaimer: The authors encourage readers to please contact the CDC Climat Research, EDF or IETA contacts withany corrections, additions, revisions, or any other comments, including any relevant citations. This will be invaluable
in strengthening and updating the case studies and ensuring they are as correct and informative as possible.

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  Section	
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  Technical	
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  Version	
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  Available	
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  esrd.alberta.ca	  1
2Page 10 of 11

23 	
  Alberta	
  Environment	
  and	
  Sustainable	  Resource	  Development	
  (AESRD)	
  2013	
  Technical	
  Guidance	
  for	
  Offset	
  Project	
  Developers,	
  version	
  4.0,	
  Published	
  February	  2013.	
  Available	
  at:	  http://esrd.alberta.ca/focus/alberta-­‐and-­‐climate-­‐change/regulating-­‐greenhouse-­‐gas-­‐emissions/alberta-­‐based-­‐offset-­‐credit-­‐system/offset-­‐credit-­‐system-­‐protocols/default.aspx	
  24 	
  AESRD	
  2013.	
  Section	
  2.3	  -­‐	
  Technical	
  Guidance	
  for	
  Offset	
  Project	
  Developers	
  Version	
  4.0	  –	
  Specified	
  Gas	  Emitters	
  Regulation.	
  Available	
  at:	
  esrd.alberta.ca	
  25 	
  AESRD	
  2013.	
  Section	
  3.3.6	
  -­‐	
  Technical	
  Guidance	
  for	
  Offset	
  Project	
  Developers	
  Version	
  4.0	  –	
  Specified	
  Gas	  Emitters	
  Regulation.	
  Available	
  at:	  http://esrd.alberta.ca/focus/alberta-­‐and-­‐climate-­‐change/regulating-­‐greenhouse-­‐gas-­‐emissions/alberta-­‐based-­‐offset-­‐credit-­‐system/offset-­‐credit-­‐system-­‐protocols/documents/TechnicalGuideOffsetProject-­‐Feb2013.pdf	
  26 	
  SGER139/2007	
  See	
  generally	
  Part	  3	
  Section	
  11	
  
27 	
  SGER139/2007.	
  See	
  generally	
  Part	  3,	
  Section	
  18	
  
28 	
  SGER139/2007.	
  See	
  generally	
  Part	  	  6,	
  Section	
  27	
  
29 	
  SGER139/2007.	
  Part	  6,	
  Section	
  28,	  Article	
  2(a)	
  and	
  2(b)	
  30 	
  AESRD,	
  2014.	
  Alberta	
  and	
  Climate	
  Change.	
  	
  Available	
  at:	
  esrd.alberta.ca	
  31 	
  Government	
  of	
  Alberta,	
  2014.	
  One	  Simple	  Act..	
  Available	
  at:	
  onesimpleact.alberta.ca	
  32 	
  AESRD,	
  2010.	
  Climate	
  Change	
  Adaptation	
  Framework	
  Manual,	
  Published	
  April	
  1	
  2010.	
  Available	
  at:	
  esrd.alberta.ca	
  33 AESRD,	
  2014.	
  “implementing	
  Carbon	  Capture	
  and	
  Storage”	
  Available	
  at:	
  esrd.alberta.ca	
  34 	
  CCEMC,	
  Alberta	
  Innovates	  Bio	  Solutions,	
  2013.	
  	
  Media	
  Release.	
  Published	
  January	
  29,	  2013.	
  Available	
  at:	
  albertainnovates.ca	
  35 	
  AESRD,	
  2014.	
  Climate	
  Change	
  Emissions	
  Management	  	
  Fund.	
  Available	
  at:esrd.alberta.ca	
  36 	
  AESRD,	
  2014.	
  Greenhouse	  Gas	
  Reduction	
  Program.	
  Available	
  at:	
  esrd.alberta.ca	
  37 	
  CCEMC,	
  2014.	
  Global	
  Challenges	
  Local	
  Solutions.	
  Pg.	
  32.	  Available	
  at:	
  ccemc.ca	
  Page 11 of 11