The Ground Rules for Effective OBAs: Principles for Addressing Carbon-Pricing Competitiveness Concerns through the Use of Output-Based Allocations


  • Sarah Dobson University of Calgary
  • G. Kent Fellows University of Calgary
  • Trevor Tombe University of Calgary
  • Jennifer Winter University of Calgary



The federal government’s decision to impose a minimum national price on carbon emissions has the potential to make certain businesses in the country less competitive. Specifically, there are emissions-intensive and trade-exposed industries across Canada that compete against producers from other jurisdictions where governments do not put a price on carbon. For these industries, the obligation to pay a carbon price creates a competitive disadvantage. Specifically, these businesses will face higher costs and may encounter a loss of market share to international competitors from jurisdictions that lack the same emission-control measures. That not only hurts Canadian businesses, it could also negate any emissions reductions that carbon pricing in Canada achieves on a global scale. The federal government has opted to protect such emissions-intensive, tradeexposed businesses using subsidies called output-based allocations (OBAs). This is the same system that Alberta is introducing through its forthcoming Carbon Competiveness Regulation. It also shares certain similarities with cap-and-trade programs, such as those in Ontario and Quebec, which provide free allocations of emissions permits to certain firms. OBAs are a desirable complementary policy to a carbon price as they maintain the incentive for producers to invest in production methods and facilities that are less emissions intensive. So while producers are still, nevertheless, subsidized to offset the tax burden of the carbon price, they will, under an OBA system, see greater benefits the more they work to reduce their emissions intensity. Still, to function most effectively and most efficiently, an OBA policy should follow certain key principles. The most critical principle in the design of an OBA policy is ensuring that OBAs are allocated to facilities independent of their individual emission levels, and allocated equally (on a per unit basis) to facilities producing the same product. One of the major flaws with Alberta’s current Specified Gas Emitters Regulation (SGER) is that it does not follow this principle. Rather, subsidies under SGER are allocated based on a facility’s historical emissions intensity. As a result, more generous subsidies are given to those facilities that are “dirtier” (that is, those with higher emissions intensities) than to “cleaner” facilities with lower emission intensities. Secondly, it is important for a well-designed OBA policy to have transparent costs. Including a clear accounting of OBAs in government finance reports will ensure the public is fully aware of the revenues being directed to the subsidies. Thirdly, OBAs for different facilities are best allocated using a classification system based on the product being produced, and not using more conventional industry-classification codes. Commonly used conventional industry classifications—for example, conventional oil and natural gas extraction—group together facilities that produce distinct products and compete in different markets. Consequently, this classification will not recognize the various levels of emissions intensity and trade exposure within an industry. This will result in some facilities receiving more OBAs than they should and others receiving less than they should. Finally, a well-designed OBA system should seek to be as administratively efficient as possible with minimal implementation costs imposed on government and businesses. It is important to recognize that the federal carbon price and OBAs are a new policy and that many large emitting facilities have been making investment decisions based on a previous regulatory environment. Therefore, a compromise approach may be to initially provide an output subsidy based on a facility’s past emissions intensity (as Alberta has historically done under its SGER system) and then to transition gradually to the optimal OBA system over time.


Adkins, Liwayway, Richard Garbaccio, Mun Ho, Eric Moore and Richard Morgenstern. 2012. “Carbon Pricing with Output-Based Subsidies: Impacts on US Industries over Multiple Time Frames.” National Center for Environmental Economics Working Paper 12-03. May.

Beale, Elizabeth, Dale Beugin, Bev Dahlby, Don Drummond, Nancy Olewiler and Christopher Ragan. 2015. “Provincial Carbon Pricing and Competitiveness Pressures.” Ecofiscal Commission Research Report, November 18.

Bohringer, Christoph, Brita Bye, Taran Fæhn and Knut Einar Rosendahl. 2017. “Outputbased rebating of carbon taxes in a neighbour’s backyard: Competitiveness, leakage, and welfare.” Canadian Journal of Economics 50 (2): 426-455.

Dion, Jason. 2017. “Explaining Output-Based Allocations (OBAs).” Ecofiscal Commission blog. May 24. Available from

Environment and Climate Change Canada. 2016. Technical Update to Environment and Climate Change Canada’s Social Cost of Greenhouse Gas Estimates. March. Available from

--- 2016. “Government of Canada Announces Pan-Canadian Pricing on Carbon Pollution.” News Release. October 3. Available from

--- 2017. Facility Greenhouse Gas Emissions Reporting Program - Overview of Reported 2015 Emissions. April 13. Available from asp?lang=En&n=8044859A-1.

--- 2017. National Inventory Report 1990–2015: Greenhouse Gas Sources and Sinks in Canada. April 13. Available from asp?lang=En&n=83A34A7A-1.

--- 2017. Technical Paper on the Federal Carbon Pricing Backstop. Last modified June 9. Available from technical-paper-federal-carbon-pricing-backstop.html.

Fellows, G. Kent and Sarah Dobson. 2017. “Embodied Emissions in Inputs and Outputs: A ‘Value Added’ Approach to National Emissions Accounting,” Canadian Public Policy 43 (2): 140-164.

Fischer, Carolyn and Alan K. Fox. 2007. “Output-based allocation of emissions permits for mitigating tax and trade interactions.” Land Economics 83 (4): 575-599.

Government of Alberta. 2012. Technical Guidance for Completing Specified Gas Baseline Emission Intensity Applications. July. Available from climate-change/guidelines-legislation/specified-gas-emitters-regulation/documents/ GuideSpecifiedGasEmissionApplication-2012.pdf.

Government of Alberta. n.d. “Output-based Allocation System Engagement.” Accessed June 25, 2017.

Goulder, Lawrence and Andrew Schein. 2013. “Carbon taxes versus cap and trade: a critical review,” Climate Change Economics 4 (3) [28 pages].

Gray, Wayne B. and Gilbert E. Metcalf. 2017. “Carbon Tax Competitiveness Concerns: Assessing a Best Practices Carbon Credit.” Resources for the Future Discussion Paper 17-10, February.

Leach, Andrew, Angela Adams, Stephanie Cairns, Linda Coady and Gordon Lambert. 2015. Climate Leadership Report to Minister, Government of Alberta. November. Available from

Leach, Andrew and Trevor Tombe. 2016. “Power Play: The Termination of Alberta’s PPAs,” The School of Public Policy Communique 8 (11), August.

McCrank, Neil and Alan M. Ross. 2015. “Temperature check: Alberta makes big move on carbon emissions.” Financial Post, June 25. Available from http://business.financialpost. com/fp-comment/temperature-check-alberta-makes-big-move-on-carbon-emissions.

NASA. 2017. Global Climate Change. Accessed June 25, 2017.






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