Second Texas plant to convert animal waste into fuel

P.E.I. Community Energy Independence empowers local microgrids through renewable generation, battery storage, and legislative reform, enabling community-owned power, stable electricity rates, and grid-friendly distributed generation across Island communities with wind, biomass, and net metering models.

Key Points

A program enabling communities to generate and store renewable power under supportive laws and grid-friendly models.

✅ Legislative review of Electric Power and Renewable Energy Acts

✅ Community microgrids with wind, biomass, and battery storage

✅ Grid integration without raising rates via Maritime Electric

The P.E.I. government is taking steps to review energy legislation and explore new options when it comes to generating power across Island communities.

Energy Minister Steven Myers said one of those options will be identifying ways for Island communities to generate their own energy, aligning with a federal electrification study now examining how electricity can reduce or eliminate fossil fuels. 

He said the move would provide energy independence, create jobs and economic development, and save the communities on their energy bills, as seen with an electricity bill credit in Newfoundland that eased costs for consumers.

But the move will require sweeping legislative changes, that may include the merging of the Electric Power Act and the Renewable Energy Act, similar to an electricity market overhaul in Connecticut seen in other jurisdictions.  

Myers said creating energy independence should ensure a steady supply of electricity while also ensuring costs remain reasonable for P.E.I. residents, even as a Nova Scotia electricity rate hike highlights regional cost pressures.   

"We have communities that are looking to generate their own electricity for their own needs," said Myers, adding the province will not dictate what energy sources communities can invest in. 

He also said the province wants to find new community-based models that will complement existing services.

"How do we do that in a way that we don't impact the grid, that we don't impact the service that Maritime Electric is delivering, mindful of a seasonal rate backlash in New Brunswick that illustrates consumer concerns, that we don't drive up the rates for all other Islanders."

Last fall, a group of P.E.I. MLAs traveled to Samsø, a small Danish island, where they learned about renewable and sustainable energy systems being used there.

The province is looking at storage options so it can store power generated during the day to be used in the evening when electricity use is at its highest. (CBC)
Samsø produces 100 per cent of its electricity from wind and biomass, and utilities like HECO meeting renewable goals early show how quickly transitions can occur. The P.E.I. government said the Island produces 25 per cent of its electricity from wind. 

Following the trip, Myers said he was impressed by the control the island had over its energy production and would like to see if a similar model could work on P.E.I. 

Myers said the legislative review will also look at different ways to store energy on the Island. 

He said that will allow communities to sell that excess energy into the provincial electricity grid, and those revenues could be redirected into that community's priorities. 

'For the survival and the future of their community'
"This is kind of a model that we had suggested that would be in place that would allow people in their own community to produce a revenue stream for themselves that they could then turn into projects like rinks, or parks, or tennis courts or whatever it is that community thinks is the most important thing for the survival and the future of their community," said Myers. 

Energy Minister Steven Myers says creating energy independence could create a steady supply of electricity while also ensuring costs remain reasonable for P.E.I. residents. (Randy McAndrew/CBC)
The province said Maritime Electric, Summerside Electric and the P.E.I. Energy Corporation will be involved in the review, recognizing that a Nova Scotia ruling on rate-setting powers underscores regulatory limits 

Government also wants to hear from Islanders and will be accepting written submissions beginning Monday. Myers said the province is also planning to host public consultations, but because of COVID-19, those will be held virtually in mid-June.

Myers calls this a major move, one that will take time. He said he doesn't expect the legislation to be made public until the spring of 2021.

"I want to make sure we take our time and do the proper consultation."

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Manitoba Crypto Mining Electricity Pause signals a moratorium to manage grid strain, Manitoba Hydro capacity, infrastructure costs, and electricity rates, while policymakers evaluate sustainable energy demand, and planning for data centers and blockchain operations.

Key Points

A temporary halt on mining power hookups in Manitoba to assess grid impacts, protect rates, and plan sustainable use.

✅ Applies only to new service requests; existing sites unaffected

✅ Addresses grid strain, infrastructure costs, electricity rates

✅ Enables review with Manitoba Hydro for sustainable policy

The Manitoba government has temporarily suspended approving new electricity service connections for cryptocurrency mining operations, a step similar to BC Hydro's suspension seen in a neighboring province.

The Original Pause

The pause was initially imposed in November 2022 due to concerns that the rapid influx of cryptocurrency mining operations could place significant strain on the province's electrical grid. Manitoba Hydro, the province's primary electric utility, which has also faced legal scrutiny in the Sycamore Energy lawsuit, warned that unregulated expansion of the industry could necessitate billions of dollars in infrastructure investments, potentially driving up electricity rates for Manitobans.

The Extended Pause Offers Time for Review

The extension of the pause is meant to provide the government and Manitoba Hydro with more time to assess the situation thoroughly and develop a long-term solution addressing the challenges and opportunities presented by cryptocurrency mining, including evaluating emerging options such as modular nuclear reactors that other jurisdictions are studying. The government has stated its commitment to ensuring that the long-term impacts of the industry are understood and don't unintentionally harm other electricity customers.

What Does the Pause Mean?

The pause does not affect existing cryptocurrency operations but prevents the establishment of new ones.  It applies specifically to requests for electricity service that haven't yet resulted in agreements to construct infrastructure or supply electricity, and it comes amid regional policy shifts like Alberta ending its renewable moratorium that also affect grid planning.

Concerns About Energy Demands

Cryptocurrency mining involves running high-powered computers around the clock to solve complex mathematical problems. This process is incredibly energy-intensive. Globally, the energy consumption of cryptocurrency networks has drawn scrutiny for its environmental impact, with examples such as Iceland's mining power use illustrating the scale. In Manitoba, concern focuses on potentially straining the electrical grid and making it difficult for Manitoba Hydro to plan for future growth.

Other Jurisdictions Taking Similar Steps

Manitoba is not alone in its cautionary approach to cryptocurrency mining. Several other regions and utilities have implemented restrictions or are exploring limitations on how cryptocurrency miners can access electricity, including moves by Russia to ban mining amid power deficits. This reflects a growing awareness among policymakers about the potentially destabilizing impact this industry could have on power grids and electricity markets.

Finding a Sustainable Path Forward

Manitoba Hydro has stated that it is open to working with cryptocurrency operations but emphasizes the need to do so in a way that protects existing ratepayers and ensures a stable and reliable electricity system for all Manitobans, while recognizing market uncertainties highlighted by Alberta wind project challenges in a neighboring province. The government's extension of the pause signifies its intention to find a responsible path forward, balancing the potential for economic development with the necessity of safeguarding the province's power supply.

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Enegix Base One Green Hydrogen Plant will produce renewable hydrogen via electrolysis in Ceara, Brazil, leveraging 3.4 GW baseload renewables, offshore wind, and hydro to scale clean energy, storage, and export logistics.

Key Points

A $5.4bn Ceara, Brazil project to produce 600m kg of green hydrogen annually using 3.4 GW of baseload renewables.

✅ 3.4 GW baseload from hydro and offshore wind pipelines

✅ Targets 600m kg green hydrogen per year via electrolysis

✅ Focus on storage, transport, and export supply chains

In March, Enegix Energy announced some of the most ambitious hydrogen plans the world has ever seen. The company signed a memorandum of understanding (MOU) with the government of the Brazilian state of Ceará to build the world’s largest green hydrogen plant in the state on the country’s north-eastern coast, and the figures are staggering.

The Base One facility will produce more than 600 million kilograms of green hydrogen annually from 3.4GW of baseload renewable energy, and receive $5.4bn in investment to get the project off the ground and producing within four years.

Green hydrogen, hydrogen produced by electrolysis that is powered by renewables, has significant potential as a clean energy source. Already seeing increased usage in the transport sector, the power source boasts the energy efficiency and the environmental viability to be a cornerstone of the world’s energy mix.

Yet practical challenges have often derailed large-scale green hydrogen projects, from the inherent obstacle of requiring separate renewable power facilities to the logistical and technological challenges of storing and transporting hydrogen. Could vast investment, clever planning, and supportive governments and programs like the DOE’s hydrogen hubs initiative help Enegix to deliver on green hydrogen’s oft-touted potential?

Brazilian billions
The Base One project is exceptional not only for its huge scale, but the timing of its construction, with demand for hydrogen set to increase dramatically over the next few decades. Figures from Wood Mackenzie suggest that hydrogen could account for 1.4 billion tonnes of energy demand by 2050, one-tenth of the world’s supply, with green hydrogen set to be the majority of this figure.

Yet considering that, prior to the announcement of the Enegix project, global green hydrogen capacity was just 94MW, advances in offshore green hydrogen and the development of a project of this size and scope could scale up the role of green hydrogen by orders of magnitude.

“We really need to [advance clean energy] without any emissions on a completely clean, carbon neutral and net-zero framework, and so we needed access to a large amount of green energy projects,” explains Wesley Cooke, founder and CEO of Enegix, a goal aligned with analyses that zero-emissions electricity by 2035 is possible, discussing the motivation behind the vast project.

With these ambitious goals in mind, the company needed to find a region with a particular combination of political will and environmental traits to enable such a project to take off.

“When we looked at all of these key things: pipeline for renewables, access to water, cost of renewables, and appetite for renewables, Brazil really stood out to us,” Cooke continues. “The state of Ceará, that we’ve got an MOU with the government in at the moment, ticks all of these boxes.”

Ceará’s own clean energy plans align with Enegix’s, at least in terms of their ambition and desire for short-term development. Last October, the state announced that it plans to add 5GW of new offshore wind capacity in the next five years. With BI Energia alone providing $2.5bn in investment for its 1.2GW Camocim wind facility, there is significant financial muscle behind these lofty ambitions.

“One thing I should add is that Brazil is very blessed when it comes to baseload renewables,” says Cooke. “They have an incredibly high percentage of their country-wide energy that comes from renewable sources and a lot of this is in part due to the vast hydro schemes that they have for hydro dams. Not a lot of countries have that, and specifically when you’re trying to produce hydrogen, having access to vast amounts of renewables [is vital].”

Changing perceptions and tackling challenges
This combination of vast investment and integration with the existing renewable power infrastructure of Ceará could have cultural impacts too. The combination of state support for and private investment in clean energy offsets many of the narratives emerging from Brazil concerning its energy policies and environmental protections, even as debates over clean energy's trade-offs persist in Brazil and beyond, from the infamous Brumadinho disaster to widespread allegations of illegal deforestation and gold mining.

“I can’t speak for the whole of Brazil, but if we look at Ceará specifically, and even from what we’ve seen from a federal government standpoint, they have been talking about a hydrogen roadmap for Brazil for quite some time now,” says Cooke, highlighting the state’s long-standing support for green hydrogen. “I think we came in at the perfect time with a very solid plan for what we wanted to do, [and] we’ve had nothing but great cooperation, and even further than just cooperation, excitement around the MOU.”

This narrative shift could help overcome one of the key challenges facing many hydrogen projects, the idea that its practical difficulties render it fundamentally unsuitable for baseload power generation. By establishing a large-scale green hydrogen facility in a country that has recently struggled to present itself as one that is invested in renewables, the Base One facility could be the ultimate proof that such clean hydrogen projects are viable.

Nevertheless, practical challenges remain, as is the case with any energy project of this scale. Cooke mentions a number of solutions to two of the obstacles facing hydrogen production around the world: renewable energy storage and transportation of the material.

“We were looking at compressed hydrogen via specialised tankers [and] we were looking at liquefied hydrogen, [as] you have to get liquefied hydrogen very cool to around -253°, and you can use 30% to 40% of your total energy that you started with just to get it down to that temperature,” Cooke explains.

“The other aspect is that if you’re transporting this internationally, you really have to think about the supply chain. If you land in a country like Indonesia, that’s wonderful, but how do you get it from Indonesia to the customers that need it? What is the supply chain? What does that look like? Does it exist today?”

The future of green hydrogen
These practical challenges present something of a chicken and egg problem for the future of green hydrogen: considerable up-front investment is required for functions such as storage and transport, but the difficulties of these functions can scare off investors and make such investments uncommon.

Yet with the world’s environmental situation increasingly dire, more dramatic, and indeed risky, moves are needed to alter its energy mix, and Enegix is one company taking responsibility and accepting these risks.

“We need to have the renewables to match the dirty fuel types,” Cooke says. “This [investment] will really come from the decisions that are being made right now by large-scale companies, multi-billion-euro-per-year revenue companies, committing to building out large scale factories in Europe and Asia, to support PEM [hydrolysis].”

This idea of large-scale green hydrogen is also highly ambitious, considering the current state of the energy source. The International Renewable Energy Agency reports that around 95% of hydrogen comes from fossil fuels, so hydrogen has a long ways to go to clean up its own carbon footprint before going on to displace fossil fuel-driven industries.

Yet this displacement is exactly what Enegix is targeting. Cooke notes that the ultimate goal of Enegix is not simply to increase hydrogen production for use in a single industry, such as clean vehicles. Instead, the idea is to develop green hydrogen infrastructure to the point where it can replace coal and oil as a source of baseload power, leapfrogging other renewables to form the bedrock of the world’s future energy mix.

“The problem with [renewable] baseload is that they’re intermittent; the wind’s not always blowing and the sun’s not always shining and batteries are still very expensive, although that is changing. When you put those projects together and look at the levelised cost of energy, this creates a chasm, really, for baseload.

“And for us, this is really where we believe that hydrogen needs to be thought of in more detail and this is what we’re really evangelising about at the moment.”

A more hydrogen-reliant energy mix could also bring social benefits, with Cooke suggesting that the same traits that make hydrogen unwieldy in countries with established energy infrastructures could make hydrogen more practically viable in other parts of the world.

“When you look at emerging markets and developing markets at the moment, the power infrastructure in some cases can be quite messy,” Cooke says. “You’ve got the potential for either paying for the power or extending your transmission grid, but rarely being able to do both of those.

“I think being able to do that last mile piece, utilising liquid organic hydrogen carrier as an energy vector that’s very cost-effective, very scalable, non-toxic, and non-flammable; [you can] get that power where you need it.

“We believe hydrogen has the potential to be very cost-effective at scale, supporting a vision of cheap, abundant electricity over time, but also very modular and usable in many different use cases.”

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Hydro One investment risk reflects Ontario government influence, board shakeup, Avista acquisition uncertainty, regulatory hearings, dividend growth prospects, and utility M&A moves in Peterborough, with stock volatility since the 2015 IPO.

Key Points

Hydro One investment risk stems from political control, governance turnover, regulatory outcomes, and uncertain M&A.

✅ Ontario retains near-50% stake, affecting autonomy and policy risk

✅ Board overhaul and CEO exit create governance uncertainty

✅ Avista deal, OEB hearings, local utility M&A drive outcomes

Hydro One may be only half-owned by the province on Ontario but that’s enough to cause uncertainty about the company’s future, thus making for an investment risk, says Douglas Kee of Leon Frazer & Associates.

Since its IPO in November of 2015, Hydro One has seen its share of ups and downs, including a Q2 profit decline earlier this year, mostly downs at this point. Currently trading at $19.87, the stock has lost 11 per cent of its value in 2018 and 12 per cent over the last 12 months, despite a one-time gain boosting Q2 profit that followed a court ruling.

This year has been a turbulent one, to say the least, as newly elected Ontario premier Doug Ford made good this summer on his campaign promise re Hydro One by forcing the resignation of the company’s 14-person board of directors along with the retirement of its chief executive, an event that saw Hydro One shares fall amid the turmoil. An interim CEO has been found and a new 10-person board and chairman put in place, but Kee says it’s unclear what impact the shakeup will ultimately have, other than delaying a promising-looking deal to purchase US utility Avista Corp, with the companies moving to ask the U.S. regulator to reconsider the order.

Douglas Kee’s take on Hydro One stock

“We looked at Hydro One a couple of times two years ago and just decided that with the Ontario government’s still owning a big chunk of the company … there are other public companies where you get the same kind of yield, the same kind of dividend growth, so we just avoided it,” says Kee, managing director and chief investment officer with Leon Frazer & Associates, to BNN Bloomberg.

“The old board versus the new board, I’m not sure that there’s much of an improvement. It was politics more than anything,” he says. “The unfortunate part is that the acquisition they were making in the United States is kind of on hold for now. The regulatory procedures have gone ahead but they are worried, and I guess the new board has to make a decision whether to go ahead with it or not.”

“Their transmissions side is coming up for regulatory hearings next year, which could be difficult in Ontario,” says Kee. “The offset to that is that there are a lot of municipal distributions systems in Ontario that may be sold — they bought one in Peterborough recently, which was a good deal for them. There may be more of that coming too.”

Last month, Hydro One reached an agreement with the City of Peterborough to buy its Peterborough Distribution utility which serves about 37,000 customers for $105 million. Another deal to purchase Orillia Power Distribution Corp for $41 million has been cancelled after an appeal to the Ontario Energy Board was denied in late August. Hydro One’s sought-after Avista Corp acquisition is reported to be worth $7 billion.

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Ontario CDM Programs expand energy efficiency, demand response, and DER incentives via IESO's Save on Energy, cutting peak demand, lowering bills, and supporting electrification, retrofits, and LED lighting to meet Ontario's growing electricity needs.

Key Points

Ontario CDM Programs are IESO incentives that cut peak demand and energy use via demand response, retrofits and DERs.

✅ Delivered by IESO's Save on Energy to reduce peak demand

✅ Incentives for demand response, retrofits, LEDs, and DER solutions

✅ Help homes, businesses, and greenhouses lower bills and emissions

Ontario will be making available four new and expanded energy-efficiency programs, also known as Conservation and Demand Management (CDM) programs, to ensure a reliable, affordable, and clean electricity system, including ultra-low overnight pricing options to power the province, drive electrification and support strong economic growth. As there will be a need for additional electricity capacity in Ontario beginning in 2025, and continuing through the decade, CDM programs are among the fastest and most cost-effective ways of meeting electricity system needs.

Conservation and Demand Management

The Ontario government launched the 2021-2024 CDM Framework on January 1, 2021. The framework focuses on cost-effectively meeting the needs of Ontario’s electricity system, including by focusing on the achievement of provincial peak demand reductions and initiatives such as extended off-peak electricity rates, as well as on targeted approaches to address regional and/or local electricity system needs.

CDM programs are delivered by the Independent Electricity System Operator (IESO), which implemented staff lockdown measures during COVID-19, through the Save on Energy brand. These programs address electricity system needs and help consumers reduce their electricity consumption to lower their bills. CDM programs and incentives are available for homeowners, small businesses, large businesses, and contractors, and First Nations communities.

New and Expanded Programs

The four new and expanded CDM programs will include:

A new Residential Demand Response Program for homes with existing central air conditioning and smart thermostats to help deliver peak demand reductions. Households who meet the criteria could voluntarily enroll in this program and, alongside protections like disconnection moratoriums for residential customers, be paid an incentive in return for the IESO being able to reduce their cooling load on a select number of summer afternoons to reduce peak demand. There are an estimated 600,000 smart thermostats installed in Ontario.
Targeted support for greenhouses in Southwest Ontario, including incentives to install LED lighting, non-lighting measures or behind-the-meter distributed energy resources (DER), such as combined solar generation and battery storage.
Enhancements to the Save On Energy Retrofit Program for business, municipalities, institutional and industrial consumers to include custom energy-efficiency projects. Examples of potential projects could include chiller and other HVAC upgrades for a local arena, building automation and air handling systems for a hospital, or building envelope upgrades for a local business.
Enhancements to the Local Initiatives Program to reduce barriers to participation and to add flexibility for incentives for DER solutions.
It is the government’s intention that the new and expanded CDM programs will be available to eligible electricity customers beginning in Spring 2023.

The IESO estimates that the new program offers will deliver total provincial peak electricity demand savings of 285 megawatts (MW) and annual energy savings of 1.1 terawatt hours (TWh) by 2025, reflecting pandemic-era electricity usage shifts across Ontario. Savings will persist beyond 2025 with a total reduction in system costs by approximately $650 million over the lifetime of the measures, and will support economic recovery, as seen with electricity relief during COVID-19 measures, decarbonization and energy cost management for homes and businesses.

These enhancements will have a particular impact in Southwest Ontario, with regional peak demand savings of 225 MW, helping to alleviate electricity system constraints in the region and foster economic development, supported by stable electricity pricing for industrial and commercial companies in Ontario.

The overall savings from this CDM programming will result in an estimated three million tonnes of greenhouse gas emissions reductions over the lifetime of the energy-efficiency measures to help achieve Ontario’s climate targets and protect the environment for the future.

The IESO will be updating the CDM Framework Program Plan, which provides a detailed breakdown of program budgets and energy savings and peak demand targets expected to be achieved.

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Nova Scotia Cap-and-Trade Program joins Western Climate Initiative to leverage emissions trading IT systems, track allowances, and manage compliance, while setting in-province caps, carbon pricing signals, and third-party verified reporting for industrial and fuel suppliers.

Key Points

A provincial emissions trading system using WCI services to cap GHGs, track allowances, and enforce verified compliance.

✅ Uses WCI IT system to manage allowances and registry

✅ Initial trading limited to in-province participants

✅ Third-party verification and annual reporting deadlines

Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program, with Hydro-Québec's U.S. sales highlighting cross-border dynamics. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

#google#

Nova Scotia is yet to set targets for its new cap and trade regime to reduce greenhouse gases, but the province announced Monday that it has joined the Western Climate Initiative Inc. -- a non-profit corporation formed to provide administrative and technical services to states and provinces with emissions trading programs.

Environment Minister Iain Rankin said joining the initiative would allow the province to use its IT system to manage and track its new cap and trade program.

Rankin said the province can join without trading greenhouse gas emission allowances with other jurisdictions -- California, Quebec, and Ontario are currently linked through the program. Nova Scotia currently has no plans to trade outside the province as it works on emissions caps Rankin said will be ready sometime in June.

"By keeping our system internal it ensures that our greenhouse gas reductions are happening within our province," said Rankin. "But we do have that opportunity (to join) and if there are new entrants or we need more access to credits then that may shift our strategy."

The use of the system will cost Nova Scotia about US$314,000 for 2018-19, with an annual cost in subsequent years of about US$228,000 or more, if the province requests modifications.

"If we were to do something like that internally we would have to build a full database and hire more people, so this was an obvious choice for us," said Rankin.

Nova Scotia has already met the national reduction target of 30 per cent below 2005 levels and says it's on track to have 40 per cent of electricity generation from renewables by 2020, underscoring how cleaning up Canada's electricity supports climate pledges.

Stephen Thomas, energy campaign coordinator for the Ecology Action Centre, called the province's move an "important small step," stressing the importance of using the same administrative rules as the other jurisdictions involved.

But Thomas said Nova Scotia should go further and trade emissions with California, Quebec, and Ontario, and also put a price on carbon by auctioning credits as they do.

Thomas said Nova Scotia's system stands to be volatile because of the smaller number of participants -- about 20 including Nova Scotia Power, Northern Pulp, Lafarge, and large oil and gasoline companies such as ExxonMobil, Imperial and Irving.

"It's very likely to favour Nova Scotia Power as the largest single emitter with the most credits to sell here, and that would change if we had a linked system, at a time when Canada will need more electricity to hit net-zero according to the IEA," Thomas said.

He said it's important to have a linked system and a regional approach in Atlantic Canada, which has more emissions per person and more emissions per GDP than places like Ontario, Quebec and California, and where policies like Newfoundland's rate reduction plan can influence electricity strategy.

"Reducing emissions, because we are so emissions-intensive here, is a little bit cheaper," said Thomas. "So it's possible that Ontario, Quebec and California could pay Nova Scotia to reduce its emissions."

Under its program, Nova Scotia requires industrial facilities generating 50,000 tonnes or more of greenhouse gas emissions per year to report emissions.

Regulations also cover petroleum product suppliers that import or produce 200 litres of fuel or more per year for consumption and natural gas distributors whose products produce at least 10,000 tonnes of greenhouse gas emissions a year.

Companies were to have reported to the Environment Department by May 1 but Rankin said the deadline has been pushed back to June 1, a deadline that was to be followed in subsequent years in any event. Reports must be verified by a third party by Sept. 1 every year.

The Liberal government passed enabling legislation for cap and trade last fall.

As for the upcoming emissions caps, Rankin isn't tipping the province's hand yet, even as B.C.'s 2050 targets face a shortfall in some forecasts.

"Those caps will recognize the investments that have already been made and therefore will be the most cost-effective program that we can put together to meet the federal requirement," he said.

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