Recession slashed 2009 EU carbon emissions

By Reuters


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The European recession last year slashed more than 11 percent off the amount of climate-warming emissions from heavy industry, the European Union's executive said.

The EU said carbon dioxide emissions from the more than 11,000 installations regulated by its Emissions Trading Scheme fell by 11.6 percent to 1.873 billion tonnes.

Low prices also encouraged greater use of natural gas, which emits less carbon dioxide than the coal it replaced to generate electricity.

"Because of the crisis it suddenly became easier to reduce emissions," European climate commissioner Connie Hedegaard said in a statement.

"Unfortunately that also means that European business did not invest nearly as much as planned in innovation, which could harm our future ability to compete on promising markets," she added.

Discounting incomplete data from Cyprus and Liechtenstein put the 2009 drop at around 11.4 percent.

The scheme, worth an estimated $100 billion last year, caps the carbon emissions from plants and factories across 27 states, and doles out carbon permits which participants can trade.

EU carbon permit futures held steady after the news, trading at 15.35 euros a tonne US$20.60, up 25 cents or 1.7 percent.

This marked the second year in which the ETS contributed to falling emissions, and followed the three difficult years of its infancy during which too many permits to emit carbon were handed out and the scheme failed to have any impact.

Just under 82 million Kyoto Protocol carbon offsets were surrendered by EU installations last year, representing 4.3 percent of the total carbon permits turned, the EU said.

Offsets present a cheaper way for participants to meet their CO2 targets when investment in abatement proves more expensive.

Certified Emissions Reductions CERs, originated from clean energy projects in developing nations, accounted for 4.1 percent while Emissions Reduction Units ERUs, which come mainly from projects in eastern European countries, made up 0.2 percent.

Chinese CERs made up the biggest share, accounting for 52 percent of all CERs turned in. A further 21 percent came from India, 14 percent from South Korea and 9 percent from Brazil.

The remaining 4 percent originated from another 19 nations.

The Commission said the combined CER and ERU surrenders used since 2008 are only roughly 12 percent of participants' 1.4 billion tonne quota. Benchmark CER futures traded up 9 cents or 0.7 percent to 12.89 euros a tonne by 1020 GMT.

The final EU data came a week after two U.S. Senators introduced climate legislation that would kick-start an emissions trading scheme in the world's biggest economy and second largest polluter.

Democratic Senator John Kerry and independent Senator Joe Lieberman unveiled their American Power Act bill, which was quickly backed by President Barack Obama and aims to cut U.S. carbon emissions by 17 percent below 2005 levels by 2020.

The bill faces looming deadlines, with midterm elections set for November, and fierce opposition from Republicans and even some Democrats.

Governments from around the world will be watching the U.S. closely, as the fate of a new international pact to combat global warming hangs largely on Washington's actions.

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IAEA - COVID-19 and Low Carbon Electricity Lessons for the Future

Nuclear Power Resilience During COVID-19 shows low-carbon electricity supporting renewables integration with grid flexibility, reliability, and inertia, sustaining decarbonization, stable baseload, and system security while prices fell and demand dropped across markets.

 

Key Points

It shows nuclear plants providing reliable, low-carbon power and supporting grid stability despite demand declines.

✅ Low prices challenge investment; lifetime extensions are cost-effective.

✅ Nuclear provides inertia, reliability, and dispatchable capacity.

✅ Market reforms should reward flexibility and grid services.

 

The COVID-19 pandemic has transformed the operation of power systems across the globe, including European responses that many argue accelerated the transition, and offered a glimpse of a future electricity mix dominated by low carbon sources.

The performance of nuclear power, in particular, demonstrates how it can support the transition to a resilient, clean energy system well beyond the COVID-19 recovery phase, and its role in net-zero pathways is increasingly highlighted by analysts today.

Restrictions on economic and social activity during the COVID-19 outbreak have led to an unprecedented and sustained decline in demand for electricity in many countries, in the order of 10% or more relative to 2019 levels over a period of a few months, thereby creating challenging conditions for both electricity generators and system operators (Fig. 1). The recent Sustainable Recovery Report by the International Energy Agency (IEA) projects a 5% reduction in global electricity usage for the entire year 2020, with a record 5.7% decline foreseen in the United States alone. The sustainable economic recovery will be discussed at today's IEA Clean Energy Transitions Summit, where Fatih Birol's call to keep options open will be prominent as IAEA Director General Rafael Mariano Grossi participates.

Electricity generation from fossil fuels has been hard hit, due to relatively high operating costs compared to nuclear power and renewables, as well as simple price-setting mechanisms on electricity markets. By contrast, low-carbon electricity prevailed during these extraordinary circumstances, with the contribution of renewable electricity rising in a number of countries as analyses see renewables eclipsing coal by 2025, due to an obligation on transmission system operators to schedule and dispatch renewable electricity ahead of other generators, as well as due to favourable weather conditions.

Nuclear power generation also proved to be resilient, reliable and adaptable. The nuclear industry rapidly implemented special measures to cope with the pandemic, avoiding the need to shut down plants due to the effects of COVID-19 on the workforce or supply chains. Nuclear generators also swiftly adapted to the changed market conditions. For example, EDF Energy was able to respond to the need of the UK grid operator by curtailing sporadically the generation of its Sizewell B reactor and maintain a cost-efficient and secure electricity service for consumers.

Despite the nuclear industry's performance during the pandemic, faced with significant decreases in demand, many generators have still needed to reduce their overall output appreciably, for example in France, Sweden, Ukraine, the UK and to a lesser extent Germany (Fig. 2), even as the nuclear decline debate continues in Europe. Declining demand in France up to the end of March already contributed to a 1% drop in first quarter revenues at EDF, with nuclear output more than 9% lower than in the year before. Similarly, Russia's Rosatom experienced a significant demand contraction in April and May, contributing to an 11% decline in revenues for the first five months of the year.

Overall, the competitiveness and resilience of low carbon technologies have resulted in higher market shares for nuclear, solar and wind power in many countries since the start of lockdowns (Fig. 3), and low-emissions sources to meet demand growth over the next three years. The share of nuclear generation in South Korea rose by almost 9 percentage points during the pandemic, while in the UK, nuclear played a big part in almost eliminating coal generation for a period of two months. For the whole of 2020, the US Energy Information Administration's Short-Term Energy Outlook sees the share of nuclear generation increasing by more than one percentage point compared to 2019. In China, power production decreased during January-February 2020 by more than 8% year on year: coal power decreased by nearly 9%, hydropower by nearly 12%. Nuclear has proved more resilient with a 2% reduction only. The benefits of these higher shares of clean energy in terms of reduced emissions of greenhouse gases and other air pollutants have been on full display worldwide over the past months.

Challenges for the future

Despite the demonstrated performance of a cleaner energy system through the crisis - including the capacity of existing nuclear power plants to deliver a competitive, reliable, and low carbon electricity service when needed - both short- and long-term challenges remain.

In the shorter term, the collapse in electricity demand has accelerated recent falls in electricity prices, particularly in Europe (Fig. 4), from already economically unsustainable levels. According to Standard and Poor's Midyear Update, the large price drops in Europe result from not only COVID-19 lockdown measures but also collapsing demand due to an unusually warm winter, increased supply from renewables in a context of lower gas prices and CO2 allowances . Such low prices further exacerbate the challenging environment faced by many electricity generators, including nuclear plants. These may impede the required investments in the clean energy transition, with longer term consequences on the achievement of climate goals.

For nuclear power, maintaining and extending the operation of existing plants is essential to support and accelerate the transition to low carbon energy systems. With a supportive investment environment, a 10-20 year lifetime extension can be realized at an average cost of US $30-40/MW*h, making it among the most cost-effective low-carbon options, while also maintaining dispatchable capacity and lowering the overall cost of the clean energy transition. The IEA Sustainable Recovery report indicates that without such extensions 40% of the nuclear fleet in developed economies may be retired within a decade, adding around US$ 80 billion per year to electricity bills. The IEA note the potential for nuclear plant maintenance and extension programmes to support recovery measures by generating significant economic activity and employment.

The need for flexibility

New nuclear power projects can provide similar economic and environmental benefits and applications beyond electricity, but will be all the more challenging to finance without strong policy support and more substantive power market reforms, including improved frameworks for remunerating reliability, flexibility and other services. The need for flexibility in electricity generation and system operation - a trend accelerated by the crisis - will increasingly characterize future energy systems over the medium to longer term.

Looking further ahead, while generators and system operators successfully responded to the crisis, the observed decline in fossil fuel generation draws attention to additional grid stability challenges likely to emerge further into the energy transition. Heavy rotating steam and gas turbines provide mechanical inertia to an electricity system, thereby maintaining its balance. Replacing these capacities with variable renewables may result in greater instability, poorer power quality and increased incidence of blackouts. Large nuclear power plants along with other technologies can fill this role, alleviating the risk of supply disruptions in fully decarbonized electricity systems.

The challenges created by COVID-19 have also brought into focus the need to ensure resilience is built-in to future energy systems to cope with a broader range of external shocks, including more variable and extreme weather patterns expected from climate change.

The performance of nuclear power during the crisis provides a timely reminder of its ongoing contribution and future potential in creating a more sustainable, reliable, low carbon energy system.

Data sources for electricity demand, generation and prices: European Network of Transmission System Operators for Electricity (Europe), Ukrenergo National Power Company (Ukraine), Power System Operation Corporation (India), Korea Power Exchange (South Korea), Operador Nacional do Sistema Eletrico (Brazil), Independent Electricity System Operator (Ontario, Canada), EIA (USA). Data cover 1 January to May/June.

 

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Summerland solar power project will provide electricity

Summerland Solar+Storage Project brings renewable energy to a municipal utility with photovoltaic panels and battery storage, generating 1,200 megawatts from 3,200 panels on Cartwright Mountain to boost grid resilience and local clean power.

 

Key Points

A municipal solar PV and battery system enabling Summerland Power to self-generate electricity on Cartwright Mountain.

✅ 3,200 panels, 20-year batteries, 35-year panel lifespan

✅ Estimated $7M cost, $6M in grants, utility reserve funding

✅ Site near grid lines; 2-year timeline with 18-month lead

 

A proposed solar energy project, to be constructed on municipally-owned property on Cartwright Mountain, will allow Summerland Power to produce some of its own electricity, similar to how Summerside's wind power supplies a large share locally.

On Monday evening, municipal staff described the Solar+Storage project, aligning with insights from renewable power developers that combining resources yields better projects.

The project will include around 3,200 solar panels and storage batteries, giving Summerland Power the ability to generate 1,200 megawatts of electrical power.

This is the amount of energy used by 100 homes over the course of a year.

The solar panels have an estimated life expectancy of 35 years, while the batteries have a life expectancy of 20 years.

“It’s a really big step for a small utility like ours,” said Tami Rothery, sustainability/alternative energy coordinator for Summerland. “We’re looking forward to moving towards a bright, sunny energy future.”

She said the price of solar panels has been dropping, with lower-cost solar contracts reported in Alberta, and the quality and efficiency of the panels has increased in recent years.

The total cost of the project is around $7 million, with $6 million to come from grant funding and the remainder to come from the municipality’s electrical utility reserve fund, while policy changes such as Nova Scotia's solar charge delay illustrate evolving market conditions.

The site, a former public works yard and storage area, was selected from 108 parcels of land considered by the municipality.

She said the site, vacant since the 1970s, is close to main electrical lines and will not be highly visible once the panels are in place, much like unobtrusive rooftop solar arrays in urban settings.

Access to the site is restricted, resulting in natural security to the solar installation.

Jeremy Storvold, general manager of Summerland’s electrical utility, said the site is 2.5 kilometres from the Prairie Valley electrical substation and close to the existing public works yard.

However, some in the audience on Monday questioned the location of the proposed solar installation, suggesting the site would be better suited for affordable housing in the community.

The timeline for the project calls for roughly two years before the work will be completed, since there is an 18-month lead time in order to receive good quality solar panels, reflecting the surge in Alberta's solar growth that is straining supply chains.

 

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BC Hydro completes major milestone on Site C transmission line work

Site C 500 kV transmission lines strengthen the BC Hydro grid, linking the new substation and Peace Canyon via a 75 kilometre right-of-way to deliver clean energy, with 400 towers built and both circuits energized.

 

Key Points

High-voltage lines connecting Site C substation to the BC Hydro grid, delivering clean energy via Peace Canyon.

✅ Two 75 km circuits between Site C and Peace Canyon

✅ Connect new 500 kV substation to BC Hydro grid

✅ Over 400 towers built along existing right-of-way

 

The second and final 500 kilovolt, 75 kilometre transmission line on the Site C project, which has faced stability questions in recent years, has been completed and energized.

With this milestone, the work to connect the new Site C substation to the BC Hydro grid, amid treaty rights litigation that has at times shaped schedules, is complete. Once the Site C project begins generating electricity, much like when the Maritime Link first power flowed between Newfoundland and Nova Scotia, the transmission lines will help deliver clean energy to the rest of the province.

The two 75 kilometre transmission lines run along an existing right-of-way between Site C and the Peace Canyon generating station, a route that has seen community concerns from some northerners. The project’s first 500 kilovolt, 75 kilometre transmission line – along with the Site C substation – were both completed and energized in the fall of 2020.

BC Hydro awarded the Site C transmission line construction contract to Allteck Line Contractors Inc. (now Allteck Limited Partnership) in 2018. Since construction started on this part of the project in summer 2018, crews have built more than 400 towers and strung lines, even as other interties like the Manitoba-Minnesota line have faced scheduling uncertainty, over a total of 150 kilometres.

The two transmission lines are a major component of the Site C project, comparable to initiatives such as the New England Clean Power Link in scale, which also consists of the new 500 kilovolt substation and expanding the existing Peace Canyon 500 kilovolt gas-insulated switchgear to incorporate the two new 500 kilovolt transmission line terminals.

Work to complete three other 500 kilovolt transmission lines that will span one kilometre between the Site C generating station and Site C substation, similar to milestones on the Maritime Link project, is still underway. This work is expected to be complete in 2023.

 

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British Columbia Halts Further Expansion of Self-Driving Vehicles

BC Autonomous Vehicle Ban freezes new driverless testing and deployment as BC develops a regulatory framework, prioritizing safety, liability clarity, and road sharing with pedestrians and cyclists while existing pilot projects continue.

 

Key Points

A moratorium pausing new driverless testing until a safety-first regulatory framework and clear liability rules exist.

✅ Freezes new AV testing and deployment provincewide

✅ Current pilot shuttles continue under existing approvals

✅ Focus on safety, liability, and road-user integration

 

British Columbia has halted the expansion of fully autonomous vehicles on its roads. The province has announced it will not approve any new applications for testing or deployment of vehicles that operate without a human driver until it develops a new regulatory framework, even as it expands EV charging across the province.


Safety Concerns and Public Questions

The decision follows concerns about the safety of self-driving vehicles and questions about who would be liable in the event of an accident. The BC government emphasizes the need for robust regulations to ensure that self-driving cars and trucks can safely share the road with traditional vehicles, pedestrians, and cyclists, and to plan for infrastructure and power supply challenges associated with electrified fleets.

"We want to make sure that British Columbians are safe on our roads, and that means putting the proper safety guidelines in place," said Rob Fleming, Minister of Transportation and Infrastructure. "As technology evolves, we're committed to developing a comprehensive framework to address the issues surrounding self-driving technology."


What Does the Ban Mean?

The ban does not affect current pilot projects involving self-driving vehicles that already operate in BC, such as limited shuttle services and segments of the province's Electric Highway that support charging and operations.


Industry Reaction

The response from industry players working on autonomous vehicle technology has been mixed, amid warnings of a potential EV demand bottleneck as adoption ramps up. While some acknowledge the need for clear regulations, others express concern that the ban could stifle innovation in the province.

"We understand the government's desire to ensure safety, but a blanket ban risks putting British Columbia behind in the development of this important technology," says a spokesperson for a self-driving vehicle start-up.


Debate Over Self-Driving Technology

The BC ban highlights a larger debate about the future of autonomous vehicles. While proponents point to potential benefits such as improved safety, reduced traffic congestion, and increased accessibility, and national policies like Canada's EV goals aim to accelerate adoption, critics raise concerns about liability, potential job losses in the transportation sector, and the ability of self-driving technology to handle complex driving situations.


BC Not Alone

British Columbia is not the only jurisdiction grappling with the regulation of self-driving vehicles. Several other provinces and states in both Canada and the U.S. are also working to develop clear legal and regulatory frameworks for this rapidly evolving technology, even as studies suggest B.C. may need to double its power output to fully electrify road transport.


The Road Ahead

The path forward for fully autonomous vehicles in BC depends on the government's ability to create a regulatory framework that balances safety considerations with fostering innovation, and align with clean-fuel investments like the province's hydrogen project to support zero-emission mobility.  When and how that framework will materialize remains unclear, leaving the future of self-driving cars in the province temporarily uncertain.

 

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Senate Democrats push for passage of energy-related tax incentives

Senate Renewable Energy Tax Credits face Finance Committee scrutiny, with Democrats urging action on tax extenders, clean energy incentives, and climate policy, while Republicans cite prior wins in wind, biodiesel, and EV credits.

 

Key Points

Legislative incentives debated in the Senate Finance Committee to extend and align clean energy tax benefits.

✅ Democrats press hearings and action on energy tax policy

✅ Focus on clean energy, EVs, wind, biodiesel, and resilience

✅ Grassley cites prior extenders; disputes push for bigger subsidies

 

A group of 27 Democratic senators is calling for action in the Senate Finance Committee on extending energy-related tax credits and examining new tax proposals, especially those that incentivize renewable energy projects and align with FERC action on aggregated DERs across the grid.

Sen. Ron Wyden, D-Ore., the ranking Democrat on the Senate Finance Committee, who recently introduced a wildfire-resilient grid bill with Sen. Merkley, led the group of Democrats in writing a letter Tuesday to Sen. Charles Grassley, R-Iowa, who chairs the committee.

“Despite numerous opportunities, including in the recent tax extenders package, the Finance Committee has failed to take action on the dozens of energy tax proposals pending before it,” they wrote. “It is critical that the Committee move to address these issues in a timely manner, along with much needed policy changes that heed warnings on regulatory rollbacks to combat the damage and growing dangers caused by global climate change.”

The number of Americans ages 65 and over is projected to nearly double by 2060. And most would prefer to age in place and hiresenior caregivers if needed.

They pointed out that the Senate Finance Committee hasn’t held a single hearing on energy tax policy during the previous congressional term, and has yet to hold one in the current one.

“The sole energy tax-related recommendation of the Committee’s temporary policy task forces was ignored in the tax extender legislation passed in December 2019, along with nearly all proposals put forward in members’ legislation this Congress,” they wrote. “This Committee must fulfill its role in examining members’ energy tax proposals and in bolstering our nation’s efforts to combat climate change, including a clean electricity standard approach that sets firm targets.”

They noted that In 2019, the global average temperature was the second highest ever recorded and the past decade was the hottest ever. The lawmakers pointed to raging wildfires and increased flooding in the western part of the U.S., as well as challenges in California’s power system during the transition, causing unprecedented destruction over the past several years. They called for tax incentives for renewable energy to help combat climate change.

“Gaps in the tax code have disadvantaged complementary technologies that could improve climate resiliency and provide additional emissions reductions,” they wrote. “While power sector emissions continue to decrease, emissions from transportation, heavy industry and agriculture have stayed level or increased over the past 10 years, even amid $5 gas not spurring a green shift in consumer behavior. The United States is not on pace to meet its international climate commitments, to say nothing of the reductions necessary to stave off the worst potential outcomes of global warming.”

Grassley reacted to the letter, noting that he had worked to get tax extenders legislation passed, even as some states consider bans on clean energy use by utilities. "I begged Democrats for a year to help me get an extenders package passed, about half of which were green energy policies, so this rings hollow," he said in a statement Tuesday. "We wouldn’t have a wind energy credit or a biodiesel credit but for me, let alone an extension of either. Democrats were holding up these green energy provisions in an attempt to get a big expansion of taxpayer subsidies for rich Tesla owners."

 

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LNG powered with electricity could be boon for B.C.'s independent power producers

B.C. LNG Electrification embeds clean hydro and wind power into low-emission liquefied natural gas, cutting carbon intensity, enabling coal displacement in Asia, and opening grid-scale demand for independent power producers and ITMO-based climate accounting.

 

Key Points

Powering LNG with clean electricity cuts carbon intensity, displaces coal, and grows demand for B.C.'s clean power.

✅ Electric-drive LNG cuts emissions intensity by up to 80%.

✅ Creates major grid load, boosting B.C. independent power producers.

✅ Enables ITMO crediting when coal displacement is verified.

 

B.C. has abundant clean power – if only there was a way to ship those electrons across the sea to help coal-dependent countries reduce their emissions, and even regionally, Alberta–B.C. grid link benefits could help move surplus power domestically.

Natural gas that is liquefied using clean hydro and wind power and then exported would be, in a sense, a way of embedding B.C.’s low emission electricity in another form of energy, and, alongside the Canada–Germany clean energy pact, part of a broader export strategy.

Given the increased demand that could come from an LNG industry – especially one that moves towards greater electrification and, as the IEA net-zero electricity report notes, broader system demand – poses some potentially big opportunities for B.C.’s clean energy independent power sector, as those attending the Clean Energy Association of BC's annual at the Generate conference heard recently.

At a session on LNG electrification, delegates were told that LNG produced in B.C. with electricity could have some significant environmental benefits.

Given how much power an LNG plant that uses electric drive consumes, an electrified LNG industry could also pose some significant opportunities for independent power producers – a sector that had the wind taken out of its sails with the sanctioning of the Site C dam project.

Only one LNG plant being built in B.C. – Woodfibre LNG – will use electric drive to produce LNG, although the companies behind Kitimat LNG have changed their original design plans, and now plan to use electric drive drive as well.

Even small LNG plants that use electric drive require a lot of power.

“We’re talking about a lot of power, since it’s one of the biggest consumers you can connect to a grid,” said Sven Demmig, head of project development for Siemens.

Most LNG plants still burn natural gas to drive the liquefaction process – a choice that intersects with climate policy and electricity grids in Canada. They typically generate 0.35 tonnes of CO2e per tonne of LNG produced.

Because it will use electric drive, LNG produced by Woodfibre LNG will have an emissions intensity that is 80% less than LNG produced in the Gulf of Mexico, said Woodfibre president David Keane.

In B.C., the benchmark for GHG intensities for LNG plants has been set at 0.16 tonnes of CO2e per tonne of LNG. Above that, LNG producers would need to pay higher carbon taxes than those that are below the benchmark.

The LNG Canada plant has an intensity of 0.15 tonnes og CO2e per tonne of LNG. Woodfibre LNG will have an emissions intensity of just 0.059, thanks to electric drive.

“So we will be significantly less than any operating facility in the world,” Keane said.

Keane said Sinopec has recently estimated that it expects China’s demand for natural gas to grow by 82% by 2030.

“So China will, in fact, get its gas supply,” Keane said. “The question is: where will that supply come from?

“For every tonne of LNG that’s being produced today in the United States -- and tonne of LNG that we’re not producing in Canada -- we’re seeing about 10 million tonnes of carbon leakage every single year.”

The first Canadian company to produce LNG that ended up in China is FortisBC. Small independent operators have been buying LNG from FortisBC’s Tilbury Island plant and shipping to China in ISO containers on container ships.

David Bennett, director of communications for FortisBC, said those shipments are traced to industries in China that are, indeed, using LNG instead of coal power now.

“We know where those shipping containers are going,” he said. “They’re actually going to displace coal in factories in China.”

Verifying what the LNG is used for is important, if Canadian producers want to claim any kind of climate credit. LNG shipped to Japan or South Korea to displace nuclear power, for example, would actually result in a net increase in GHGs. But used to displace coal, the emissions reductions can be significant, since natural gas produces about half the CO2 that coal does.

The problem for LNG producers here is B.C.’s emissions reduction targets as they stand today. Even LNG produced with electricity will produce some GHGs. The fact that LNG that could dramatically reduce GHGs in other countries, if it displaces coal power, does not count in B.C.’s carbon accounting.

Under the Paris Agreement, countries agree to set their own reduction targets, and, for Canada, cleaning up Canada’s electricity remains critical to meeting climate pledges, but don’t typically get to claim any reductions that might result outside their own country.

Canada is exploring the use of Internationally Transferred Mitigation Outcomes (ITMO) under the Under the Paris Agreement to allow Canada to claim some of the GHG reductions that result in other countries, like China, through the export of Canadian LNG.

“For example, if I were producing 4 million tonnes of greenhouse gas emissions in B.C. and I was selling 100% of my LNG to China, and I can verify that they’re replacing coal…they would have a reduction of about 60 or million tonnes of greenhouse gas emissions,” Keane said.

“So if they’re buying 4 million tonnes of emissions from us, under these ITMOs, then they have net reduction of 56 million tonnes, we’d have a net increase of zero.”

But even if China and Canada agreed to such a trading arrangement, the United Nations still hasn’t decided just how the rules around ITMOs will work.

 

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