The attached document contains the Business Council of British Columbia’s commentary and recommendations on the Climate Leadership Team October 2015 Report.

British Columbia has carved out a unique response to the issue of climate change and remains a recognized leader in the use and implementation of carbon pricing. The actions taken and the achievements to date provide an opportunity to take stock and carefully consider the next stage in climate policy development amid a changing Canadian policy and political environment.

We see no need for BC to rush to implement significant new measures separate from the policies likely to be pursued by the recently elected federal government – which is committed to stronger climate action than its predecessor. At this juncture, there is a risk that BC could further undermine competitiveness by continuing to layer on additional costs for trade-exposed industries that are already grappling with the steepest carbon tax and among the highest fossil fuel costs in North America. BC should be pragmatic and outward-looking in its approach to managing greenhouse gas emissions. It is time to shift away from a “made-in-BC strategy” and to put more emphasis on working collaboratively in a pan-Canadian context. Climate change can only be addressed through collective action.

Recommendations

Appendix 1 to this submission contains responses to the thematic policy areas covered in the CLT Report, including both affirmation of positive elements and critiques of other CLT proposals. The Business Council also offers three new recommendations. Each would require collaboration with industry and other governments while enabling BC to continue to show leadership across Canada. These new recommendations are:

• Develop a competitiveness lens that, inter alia, is based on the principle that CO2e charges are the same regardless of production process, plan or emissions history of the country/region of origin or facility.
• Complete work on definitions for energy-intensive, trade-exposed industries. Such definitions should recognize BC’s existing relatively low carbon energy system.
• Champion the reinstatement of Class 27 accelerated depreciation under the federal Income Tax Act. This would provide a powerful tool for incentivizing investment in new technologies and processes across the full spectrum of industrial sectors in Canada.