To: Mayor and Councillors of the City of Calgary, City of Beaumont, City of Cold Lake, City of Edmonton, City of Grande Prairie, City of Leduc, City of Lethbridge, City of Spruce Grove, City of St. Albert, Municipal District of Big Lakes County, Municipality of Jasper, Parkland County, Strathcona County, Town of Banff, Town of Canmore, Town of Cochrane, Town of Devon, Town of Diamond Valley, Town of Drayton Valley, Town of Hinton, Town of Innisfail, Town of Okotoks, Town of Olds, Town of Rimbey, and the Town of Stony Plain.

Executive Summary: Alberta

This report advises Alberta’s municipalities to critically reevaluate their participation in the FCM-ICLEI Partners for Climate Protection (PCP) Program and the implementation of Climate Action Plans. While these programs are marketed as progressive climate initiatives, they often impose significant financial and administrative burdens on municipalities without delivering proportional benefits.

Alberta is a net carbon sink, with its vast forests, wetlands, grasslands, and agricultural lands naturally absorbing more CO₂ than the province emits. This fact challenges the necessity and cost-effectiveness of adopting net-zero frameworks that may not align with Alberta's economic and environmental priorities. Given the province’s unique resource-based economy and focus on energy security, it is essential that climate policies reflect local needs rather than international directives.

Furthermore, Alberta’s municipalities are under no federal or provincial legal obligation to meet emissions targets set by international agreements such as the Paris Accord. Participation in the PCP program remains entirely voluntary, with no penalties for opting out. Municipal leaders should recognize that their primary responsibility is to prioritize local interests, such as economic diversification and community resilience, rather than conforming to externally driven climate agendas.

A significant concern is the financial and legal liability placed on municipalities in implementing PCP programs. ICLEI and its funding partners explicitly disclaim responsibility, leaving municipalities solely accountable for any failures or financial shortfalls. This shifts risks onto local governments and diverts valuable resources away from essential priorities such as infrastructure development, economic growth, and public safety.

Redirecting municipal resources from externally driven climate programs to local priorities—such as housing, energy availability, water management, rural-urban development, and economic diversification—will better serve Alberta’s communities and ensure long-term sustainability.

Key Recommendations:

1. Pause and Reevaluate participation in the PCP program and Climate Action Plans in the context of Alberta’s economic and environmental priorities.

2. Ensure Transparency through financial audits and public consultation on climate program costs, risks, and benefits.

3. Withdraw from the PCP Program and redirect resources to initiatives that deliver tangible, community-specific benefits.

4. Focus on Practical Environmental Stewardship by investing in pollution control, water conservation, and responsible land management, rather than costly net-zero targets.

5. Prioritize Immediate Municipal Needs, including energy security, infrastructure maintenance, and public safety, to promote sustainable economic and social development.

By emphasizing practical, locally driven solutions, Alberta’s municipalities can safeguard financial stability, support property rights, and foster growth without unnecessary external obligations.

The Alberta Municipal Government Act and Council Authority

Under the Municipal Government Act (MGA), RSA 2000, c M-26, Alberta municipal councils have the legal responsibility to govern in the best interests of their municipalities, which inherently includes serving the people who live and work in those communities.

Specifically:

• Section 153 of the MGA mandates that councillors must "consider the welfare and interests of the municipality as a whole and bring to council’s attention anything that would promote the welfare or interests of the municipality." This responsibility extends beyond infrastructure and operations to include the well-being of residents, businesses, and property owners.

• Section 201(1) confirms that councils are responsible for "developing and evaluating the policies and programs of the municipality" and for "ensuring that the powers, duties, and functions of the municipality are appropriately carried out."

• Councillors swear an Oath of Office to "diligently, faithfully, and to the best of my ability, fulfill the duties of my office."

These provisions make it clear that decision-making power rests solely with elected municipal councils—not with external consultants, third-party organizations, or administrative staff. Councils must ensure that participation in programs like ICLEI’s Partners for Climate Protection (PCP) aligns with the municipality’s financial capacity and the needs and priorities of its people.

While staff and consultants may provide advice and recommendations, their role is strictly advisory. The council alone holds the final authority to approve, modify, or reject programs like the ICLEI Partners for Climate Protection (PCP) and associated Climate Action Plans.

Given this mandate, councils must carefully evaluate whether these programs truly align with the needs of their residents or if they impose unnecessary costs and external controls that could undermine local priorities and autonomy.

Legal Context: International, Federal, and Provincial Requirements

1. The Paris Agreement

• The Paris Agreement is a non-binding international treaty that commits federal governments, not municipalities, to greenhouse gas (GHG) reduction targets.

• Alberta municipalities are under no legal obligation to align their policies with the Paris Agreement or participate in ICLEI programs.

2. Federal Legislation — Canadian Net-Zero Emissions Accountability Act

• The Canadian Net-Zero Emissions Accountability Act requires the federal government to achieve net-zero emissions by 2050.

• This legislation does not impose mandates on municipal governments regarding emissions reduction policies. 2

3. Alberta’s Provincial Climate Policies

• Alberta’s Emissions Management and Climate Resilience Act (EMCRA) focuses on regulating industrial emissions but does not impose net-zero targets on municipalities. 3

• The Technology Innovation and Emissions Reduction (TIER) Regulation applies exclusively to large industrial emitters and does not mandate municipal participation in net-zero programs. 4

Liability Waivers and What They Mean for Municipalities

Although ICLEI, the Federation of Canadian Municipalities (FCM), and the Government of Canada fund and administer programs such as PCP, these organizations have explicitly disclaimed liability for the outcomes or impacts of municipal participation [5].

Key Disclaimer (PCP Webpage):

• “This project was carried out with assistance from the Green Municipal Fund[6], a Fund financed by the Government of Canada and administered by the Federation of Canadian Municipalities, and from ICLEI – Local Governments for Sustainability (Management) Inc. Notwithstanding this support, the views expressed are the personal views of the authors, and ICLEI Canada, the Federation of Canadian Municipalities, and the Government of Canada accept no responsibility for them.”

What Does This Mean for Ontario Municipalities?

1. Voluntary Adoption: Programs modeled after PCP milestones are voluntary, and municipalities can opt out without facing legal penalties.

2. No External Accountability: ICLEI, FCM, and the Government of Canada have waived responsibility for any financial losses, policy failures, or legal disputes arising from participation.

3. Local Risk: Municipalities bear full legal and financial accountability for any cost overruns, compliance challenges, or policy impacts associated with their climate plans.

4. Financial Uncertainty: While programs may include grant funding, municipalities must cover long-term costs for implementation, monitoring, and reporting—often millions of dollars—without guarantees of success or protection from liability.

Data Collection Concerns

The Climate Action Plan requires extensive data collection at both the corporate (municipal operations) and community levels. These data collection requirements, outlined in the PCP Milestone One Protocol Handbook [8], are repeated annually or biannually and include:

Corporate Data Collection Requirements:

• Tracking energy consumption from all sources, including non-CO₂-emitting sources.

• Recording electricity usage for all municipal lighting annually.

• Monitoring energy consumption for water and wastewater facilities.

• Reporting fuel sources and emissions from all municipal buildings and facilities.

• Conducting waste audits to categorize and measure all waste materials, from food waste to electronics.

• Calculating the methane potential of landfill waste and assessing decay rates annually.

• Collecting data on fuel usage for all municipal fleet vehicles, including public transit and staff commuting patterns.

Community-Wide Data Collection Requirements:

• Emissions from residential, commercial, and industrial buildings, including fuel and electricity consumption.

• Fuel sales data and kilometers traveled by all vehicle types, public transit, and private transportation within the county.

• Monitoring emissions from industrial processes and wastewater treatment.

• Detailed solid waste data, including livestock counts and methane potential.

These requirements represent a significant administrative burden and raise serious ethical and privacy concerns, such as:

• Infringement on privacy: Residents and businesses may not be aware that their energy and waste habits are being tracked, leading to potential distrust in local government.

• Data security risks: Sensitive information is often managed by third-party organizations such as ICLEI, raising concerns about data breaches and potential misuse.

• Profit-driven motives: Data collected is often used to market "green energy" products, benefiting corporate interests rather than prioritizing genuine environmental stewardship.

This level of surveillance and data harvesting could be seen as disproportionate where local environmental initiatives can be achieved without such invasive measures.

PCP Cost Projections

Participation in the PCP program is often marketed as a low-cost initiative; however, significant hidden costs exist [7]. These financial demands disproportionately burden rural and smaller municipalities with recurring expenses tied to externally driven objectives.

Estimated Costs for PCP Participation and Implementation

Milestone/Initiative

Estimated Cost Range*

Baseline Emissions Inventory

$10,000–$50,000

Emissions Reduction Targets

$5,000–$25,000

Local Action Plan Development

$20,000–100,000

Implement Action Plan

$50,000–1,000,000+

Monitor and Report Results

$10,000–50,000 annually

Municipal Fleet Upgrades

$500,000–5,000,000+

EV Charging Stations

$100,000–1,000,000+

Municipal Building Upgrades

Smart City Technology

$1,000,000–10,000,000+

$500,000–5,000,000+

Circular Economy Initiatives

$1,000,000–10,000,000+

15-Minute City Model

$5,000,000–50,000,000+

Active Transportation Networks

$1,000,000–20,000,000+

Urban Densification

$5,000,000–100,000,000+

Total Cost Range:

• Modest Implementation: $8.2 million

• Comprehensive Implementation: $212 million+

These conservative estimates underscore the financial burden imposed by PCP participation and Climate Action Plan implementation. A thorough cost analysis of the program expenditures to date and anticipated future costs is essential.

Alberta’s CO₂ Emissions and Carbon Sequestration Capacity

Provincial Emissions

Alberta has a population of approximately 4.8 million residents as of 2024.7 Using Canada’s average per capita emissions of 14.2 tonnes of CO₂ per year, Alberta’s gross emissions are calculated as follows:

• 4.8 million residents × 14.2 tonnes of CO₂ per resident per year = 68.16 million tonnes of CO₂ annually

Thus, Alberta’s gross annual CO₂ emissions for the population are approximately 68.16 million tonnes.

The Government of Alberta states their current emissions are 269.9 million tonnes, which would include their industrial and resource sector.

Alberta’s Carbon Sequestration Capacity

Net-zero programs often overlook natural carbon sinks, failing to recognize the substantial role that Alberta’s ecosystems play in absorbing carbon dioxide. These programs apply a one-size-fits-all approach, disregarding the unique contributions of forests, wetlands, peatlands, and agricultural lands in mitigating CO₂ emissions.

Alberta’s ecosystems naturally absorb vast amounts of CO₂, far exceeding the province’s annual emissions. The estimated carbon sequestration by ecosystem type is as follows:

• Forests – Alberta’s boreal forests cover approximately 38 million hectares, absorbing an estimated 10 tonnes of CO₂ per hectare annually, totaling 380 million tonnes of CO₂ absorbed each year.8.

• Wetlands – Wetlands span about 14.36 million hectares, sequestering roughly 1.8 tonnes of CO₂ per hectare annually, totaling 25.8 million tonnes of CO₂ absorbed annually.9

• Peatlands – Alberta’s peatlands cover approximately 5.8 million hectares, providing long-term carbon storage through slow organic accumulation. These ecosystems are estimated to store hundreds of millions of tonnes of carbon over centuries. 10

• Agricultural Lands and Grasslands – Alberta’s agricultural soils and grasslands cover approximately 20 million hectares, contributing to carbon sequestration through soil health practices and vegetation cover, with an estimated 15 tonnes of CO₂ per hectare annually, totaling 300 million tonnes of CO₂ absorbed annually. 11

Net CO₂ Balance

Based on emissions estimates:

• Alberta’s total emissions: 269.9 million tonnes (including industrial and resource sectors)

• Total CO₂ sequestered: 705.8 million tonnes

Net Balance Calculation:

705.8 million tonnes (sequestered) - 269.9 million tonnes (emissions) = -435.9 million tonnes annually

Even under the highest emission estimate of 269.9 million tonnes, Alberta remains a significant net carbon sink, absorbing approximately 435.9 million tonnes more CO₂ than it emits each year; with additional potential contributions from other ecosystems such as alpine tundra and shrublands that could further enhance carbon sequestration. This substantial carbon sequestration capacity underscores the misalignment between costly net-zero policies and Alberta's existing environmental strengths.

Key Takeaway

Alberta’s natural environment already surpasses emissions levels through its extensive carbon sequestration capabilities. Consequently, imposing additional regulatory burdens through global net-zero targets is unnecessary and does not align with Alberta's environmental realities. Instead, policies should focus on enhancing and maintaining Alberta’s natural carbon sinks to further strengthen its position as a global environmental leader.

Note: The sequestration rates and areas are estimates based on available data and may vary with different management practices and environmental conditions. KICLEI Canada is available to collaborate with provincial and municipal GIS departments to refine these calculations using exact data for ecosystem coverage.

Redirecting Resources to Local Priorities: Alberta

Given Alberta’s vast natural carbon sinks and resource-based economy, continued participation in programs focused on net-zero targets diverts critical resources away from pressing local issues that fall under municipal jurisdiction. Alberta’s municipalities must prioritize their unique local needs rather than aligning with externally driven climate initiatives that may not serve the best interests of their communities.

In Canada, municipalities operate under the authority of provincial and territorial governments, which delegate specific responsibilities. While responsibilities may vary slightly by province, the core municipal responsibilities in Alberta generally include:

• Housing Availability: Addressing rising costs and availability challenges to ensure safe, accessible housing for all residents. Municipalities must protect property rights and resist over-regulation of rural lands that displace people and limit economic opportunities in smaller communities. Alberta’s municipalities should focus on policies that support affordable housing solutions tailored to local demographics and workforce needs.

• Energy Security: Ensuring affordable and reliable energy sources to support households, businesses, and critical infrastructure. Alberta, as a leader in energy production, must prioritize local energy security, including expanding natural gas infrastructure, supporting energy diversification, and resisting externally imposed energy restrictions that could hinder economic growth.

• Land Use Planning and Development: Ensuring balanced growth that supports both urban and rural communities while preserving Alberta's unique landscape and economy. Municipalities should resist centralized "sustainable development" policies that disproportionately favor urban centers at the expense of small towns, rural communities, and agricultural operations.

• Infrastructure Maintenance and Expansion: Investing in the upkeep and development of essential infrastructure such as roads, bridges, water, and wastewater systems to support economic growth and quality of life. Alberta’s municipalities must prioritize practical, cost-effective solutions that meet the needs of their residents without unnecessary external constraints.

• Transportation Networks: Providing efficient and accessible transportation options that serve residents and businesses alike. Municipalities should avoid restrictive policies that discourage private vehicle use or impose costly public transit initiatives that do not align with Alberta's geographic realities and reliance on personal and commercial vehicles.

• Emergency Services and Public Safety: Supporting police, fire, and paramedic services to enhance community safety, emergency preparedness, and disaster response, including mental health support services and rural emergency response capabilities.

• Waste Management: Overseeing efficient waste collection, recycling, and disposal programs that promote environmental stewardship while being cost-effective and locally driven. Municipalities must resist externally driven mandates that add unnecessary costs or reduce local autonomy in waste management practices.

• Parks and Recreation: Maintaining and expanding green spaces, recreational facilities, and community programs to support active and healthy lifestyles, with an emphasis on local decision-making and sustainable land management practices that reflect Alberta’s cultural values and lifestyle.

• Economic Development: Promoting job creation, investment, and industry growth to sustain vibrant and resilient communities. Local governments must prioritize organic growth, entrepreneurship, and support for small businesses rather than catering to global investors or large corporations that do not contribute to long-term community sustainability.

• Public Health and Social Services: Collaborating with health agencies and social service providers to address community well-being, ensuring access to healthcare, mental health services, and social programs tailored to Alberta’s diverse population.

• Government Accountability: Strengthening transparency, fiscal responsibility, and public trust by ensuring that financial resources are directed toward local priorities and essential services rather than costly international programs that fall outside municipal jurisdiction.

Alberta’s municipal governments must focus on these core responsibilities to best serve their communities and avoid diverting funds toward global initiatives such as climate action programs that impose additional financial burdens and limit local autonomy. Redirecting resources toward these pressing local needs will ensure that municipalities remain resilient, self-sufficient, and responsive to the unique challenges and opportunities within Alberta’s dynamic economic landscape.

This approach avoids imposing costly net-zero policies that are misaligned with Alberta's existing natural carbon advantage and the immediate concerns of its citizens.

Recommendations: Alberta

1. Pause and Reevaluate the PCP Program and Climate Action Plans:

   • Conduct a comprehensive review of the PCP program and climate action initiatives, including thorough public consultation, to ensure they align with Alberta’s local economic priorities, environmental realities, and financial capacities.

   • Assess the cost-effectiveness and feasibility of continuing with the milestone-based framework, considering Alberta’s vast natural carbon sinks and energy sector contributions.

2. Improve Transparency and Accountability:

   • Disclose all costs already incurred under the PCP program and climate action plans, including consultant fees, data collection expenses, and long-term financial obligations to taxpayers.

   • Conduct a detailed financial audit of climate-related spending to evaluate its impact on municipal budgets and ensure responsible resource allocation.

   • Engage residents, businesses, and stakeholders in meaningful public consultations to foster trust and ensure transparency in decision-making processes.

3. Withdraw from the PCP Program and Halt Climate Action Plan Implementation:

   • Immediately withdraw from the ICLEI Partners for Climate Protection (PCP) program or similar milestone-based frameworks to prevent the imposition of externally driven policies that do not reflect Alberta’s economic strengths and environmental realities.

   • Cease further development and implementation of climate action plans to avoid additional financial commitments and regulatory burdens that may undermine Alberta’s economic resilience and energy independence.

   • Redirect municipal resources to locally driven initiatives that provide tangible benefits to residents and businesses, fostering self-reliance and economic growth.

4. Prioritize Local Environmental Stewardship and Practical Solutions:

   • Focus on protecting Alberta’s natural carbon sinks—forests, wetlands, grasslands, and agricultural lands—that contribute to the province’s environmental sustainability without the need for costly net-zero policies.

   • Develop cost-effective, locally controlled programs to improve pollution prevention, water conservation, and responsible land management that align with Alberta’s industrial and agricultural landscape.

   • Implement practical environmental initiatives that enhance natural carbon sequestration and environmental resilience without excessive reliance on data collection or costly “green” technologies that do not align with Alberta’s needs.

   • Strengthen infrastructure resilience and emergency preparedness to mitigate risks from natural disasters and ensure community safety.

5. Address Immediate Municipal Priorities:

   • Housing: Reduce unnecessary regulations and streamline approvals to increase access to affordable housing while protecting property rights and supporting balanced urban and rural development.

   • Energy Security: Invest in affordable and reliable energy infrastructure, leveraging Alberta’s abundant natural resources to support communities and businesses.

   • Economic Development: Encourage local job creation, small business growth, and support for Alberta’s industries to sustain long-term prosperity and community resilience.

   • Public Safety and Community Services: Enhance emergency response capabilities, policing, and fire services to ensure the safety and well-being of all residents.

   • Government Accountability: Promote fiscal responsibility, transparency, and prudent financial management to uphold public confidence in municipal governance.

Conclusion

Alberta's municipalities have no legal obligation to participate in costly climate programs like the PCP. Local governments should prioritize community needs, fiscal responsibility, and practical environmental solutions over externally driven net-zero policies.

We respectfully request the councils to reevaluate climate policies, prioritize transparency, and safeguard the interests of its residents.

Sincerely,
Maggie Braun, KICLEI Canada, info@kiclei.ca
Concerned Residents and Stakeholders of Alberta

References

References

1. Municipal Government Act (MGA), RSA 2000, c M-26. Government of Alberta. Available at: https://www.qp.alberta.ca/documents/Acts/m26.pdf

2. Canadian Net-Zero Emissions Accountability Act. Government of Canada. Available at: https://www.canada.ca/en/services/environment/conservation/climate-change/net-zero-emissions-2050.html

3. Emissions Management and Climate Resilience Act (EMCRA), SA 2003, c E-7.8. Government of Alberta. Available at: https://www.qp.alberta.ca/documents/Acts/e07p8.pdf

4. Technology Innovation and Emissions Reduction (TIER) Regulation. Government of Alberta. Available at: https://www.alberta.ca/technology-innovation-and-emissions-reduction-regulation.aspx

5. Partners for Climate Protection (PCP) Program Disclaimer. ICLEI – Local Governments for Sustainability. Available at: https://www.pcp-ppc.ca/

6. Cost Breakdown for Municipalities Participating in the PCP Program and Climate Action Plans. KICLEI Canada. Available at: https://kiclei.substack.com/p/cost-breakdown-for-municipalities

7. Statistics Canada. Alberta’s Estimated Population (2024). Available at: https://www150.statcan.gc.ca/

8. Alberta’s Forest Coverage. Alberta Wilderness Association – Boreal Forest. Alberta’s Boreal Forest covers approximately 381,046 square kilometres (38 million hectares). Available at: https://albertawilderness.ca/issues/wildlands/forests/boreal-forest/

9. Alberta’s Wetlands. Alberta Wilderness Association – Wetlands. Wetlands cover approximately 143,628 square kilometres (14.36 million hectares). Available at: https://albertawilderness.ca/wetlands-for-a-sustainable-environment/

10. Alberta’s Peatlands. Government of Alberta – Peatland Resource. Peatlands cover approximately 58,000 km² (5.8 million hectares). Available at: https://open.alberta.ca/dataset/a3866d2b-d28c-40fb-ac84-eec270e936d0

11. Alberta’s Agricultural Lands and Grasslands. Alberta Wilderness Association – Grasslands. Alberta’s Grasslands Natural Region covers approximately 20 million hectares. Available at: https://albertawilderness.ca/issues/wildlands/areas-of-concern/majorville/