TC Energy Corp

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive TC Energy discloses extensive detail on every aspect of its climate-policy lobbying. It names a wide array of specific measures it has engaged on, including the Canadian government’s “2030 Emissions Reduction Plan” and its component initiatives such as the “Federal Carbon Pollution Pricing System,” “Federal GHG Offset System,” “Clean Fuel Regulations,” the proposed “Oil and Gas Emissions Cap,” forthcoming “Clean Electricity Regulations,” and revisions to the federal “Oil and Gas Methane Regulations.” The company also lists provincial and U.S. policies it lobbies, for example Alberta’s “TIER” program, Ontario’s “Emissions Performance Standard,” Saskatchewan’s “Management and Reduction of GHG Act,” Quebec’s “Cap-and-Trade” programme and Bill 44, Oregon’s “Cap and Reduce Executive Order,” “Regional Haze Rule,” “Cleaner Air Oregon,” and the federal “Clean Fuel Standard,” as well as consultations on NRCan’s “Hydrogen Strategy for Canada” and CCUS policy. TC Energy is equally explicit about how and to whom it lobbies. It describes providing written submissions to Environment and Climate Change Canada, Natural Resources Canada and Finance Canada, meeting with “representatives of the Oregon DEQ,” participating in technical working groups, and advocating “through our involvement with the Northwest Gas Association” and other industry bodies such as the American Gas Association. The company notes that its environmental experts “directly engaged with government and through industry associations” and that it registers lobbyists in multiple jurisdictions, demonstrating clear disclosure of both direct and indirect mechanisms and their governmental targets. Finally, the company sets out the concrete policy outcomes it seeks. It advocates “permitting reform to accelerate the regulatory process,” supports “tax policies that incentivize early investment in clean energy systems,” seeks eligibility for infrastructure across “all three CCUS value-chain components” with credit stackability, and promotes carbon-pricing designs that “balance economic growth with GHG emission reductions” while guarding against carbon leakage. It also presses for methane-reduction rules consistent with the federal 75 % target and for pipeline-safety updates that “reduce unnecessary emissions.” This level of specificity about desired legislative and regulatory changes, together with the detailed description of mechanisms and the extensive list of policies named, demonstrates comprehensive transparency in TC Energy’s climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate TC Energy Corp’s governance and oversight processes include a Board-level Governance Committee that “oversees lobbying, political contributions, and corporate memberships” and “receives a report annually that provides information on our lobbying activities, a complete list of our political contributions and a detailed list of our corporate memberships,” demonstrating formal structures for monitoring political engagement. The company has increased transparency with the publication of its “Climate-related Lobbying Report” alongside its ESG data, and it confirms that “since the publication of the climate-related lobbying report, there has been no change to our association memberships or alignment assessment,” indicating a systematic review of indirect lobbying through trade associations. TC Energy also mandates “annual training and certification” under its Political Contributions and Activities Policy, ensuring that employees and contractors are aware of its advocacy rules. However, while the company stresses its support for “the goals of the Paris Agreement” and outlines its advocacy for policies to “reduce emissions,” it does not disclose a specific process for aligning and monitoring its direct lobbying activities against defined climate policy positions, and there is no clear explanation of how its Governance Committee or HSSE Committee assesses climate alignment of direct or indirect lobbying on an ongoing basis. We found no detailed criteria for evaluating or adjusting direct advocacy or guidelines that require climate considerations to inform each engagement, so the governance framework for comprehensive alignment of all climate-related lobbying efforts remains only partially articulated. 2