Is Alberta about to hit its oil sands emissions cap?

By Lethbridge Herald on January 20, 2026.

Lennie Kaplan

TROY MEDIA

New federal emissions projections show Alberta’s oil sands are on track to hit or exceed the province’s legislated 100-megatonne emissions cap within the next decade, forcing the Alberta government to choose between enforcing the cap or following through on its plan to sharply expand oil production.

Environment and Climate Change Canada (ECCC) recently released greenhouse gas (GHG) emissions projections through 2035 showing absolute oil sands emissions rising from 89 megatonnes (Mt) in 2023 to 95 Mt in 2035 under policies already in place, and from 89 Mt to 92 Mt over the same period if governments implement additional measures they have already announced.

These projections bring oil sands emissions closer to Alberta’s legislated limit of 100 Mt. The limit was set in Alberta law in 2016 as a hard cap on annual oil sands emissions and could prompt the Smith government to raise or repeal it.

Those emissions projections are driven by ECCC estimates of oil sands production, excluding upgrading, of 4.325 million barrels a day in 2035 under current policies and 4.342 million barrels a day with additional announced measures.

Based on publicly available modelling information, ECCC’s emissions projections do not appear to include the Pathways Alliance’s estimated 22 megatonnes in emissions reductions by 2030. Oil sands carbon capture, utilization and storage production is projected to rise from 245,300 barrels a day in 2023 to 300,200 barrels a day in 2035 under current policies, and to 306,300 barrels a day with additional announced measures. Pathways has yet to reach a final investment decision and may not ultimately meet its 22-megatonne reduction target by 2030.

Compounding that uncertainty, the new oil sands emission levels also do not reflect the Smith government’s commitment to double Alberta’s oil production by 2035. Since January 2025, the Smith government has been talking about doubling provincial oil production, largely from the oil sands, to six million barrels a day by 2030 and eight million barrels a day by 2035.

However, it appears that no comprehensive, publicly released emissions forecasting and analysis has been conducted on how this commitment would affect future oil sands emissions levels in Alberta, even with the 100-megatonne emissions limit approaching.

To assess what that could mean in practice, I estimated, based on publicly available production and emissions data, in an earlier guest column, that scaling up Alberta oil sands production from 3.1 million barrels a day in 2023 to 7.5 million barrels a day in 2035, and netting out annual GHG emissions reductions from Pathways, oil sands sector emissions in Alberta would reach 101.7 Mt in 2030 and 111.6 Mt in 2035. The legislated oil sands emissions limit of 100 Mt annually could be breached as early as 2030.

The credibility of Alberta’s climate and energy policy framework depends on whether legislated limits are treated as binding constraints or effectively as political placeholders. Investors, regulators and the public rely on clear signals about how governments intend to balance production growth with emissions obligations. Allowing emissions to drift toward or beyond a statutory cap without a clear plan risks undermining confidence in Alberta’s policy regime and creating uncertainty about future regulatory changes.

That uncertainty carries economic consequences, particularly for long-term, capital-intensive oil sands projects that depend on predictable rules.

With the commitment to double oil production by 2035, the Alberta government will need to decide whether to raise or repeal its oil sands emissions limit. The Smith government has a responsibility to inform Albertans about what it intends to do.

Lennie Kaplan is a former senior manager in the fiscal and economic policy division of Alberta’s Ministry of Treasury Board and Finance, where, among other duties, he examined best practices in fiscal frameworks, program reviews and savings strategies for non-renewable resource revenues. In 2012, he won a Corporate Values Award in TB&F for his work on Alberta’s fiscal framework review. In 2019, he served as executive director to the MacKinnon Panel on Alberta’s finances—a government-appointed panel tasked with reviewing Alberta’s spending and recommending reforms.