Resilient LLP (formerly DeMarco Allan LLP)
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DT Vollmer

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Canada Growth Fund Announces First Transaction under CCfD and Offtake Mandate

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Canada Growth Fund (CGF) today announced that it has completed its first transaction under its mandate to use nearly half of its $15B budget for carbon contracts for difference (CCfDs) and offtake agreements. CGF is the federal agency (a subsidiary of Canada Development Investment Corporation) with a mandate to “build a portfolio of investments that catalyze substantial private sector investment in Canadian businesses and projects to help transform and grow Canada’s economy at speed and scale on the path to net-zero.” PSP Investments acts as the investment manager for CGF through a wholly-owned subsidiary. Via a hybrid security, CGF has agreed to invest $200M in Entropy Inc., a Calgary-based developer of carbon capture and sequestration (CCS) projects. Alongside the investment, CGF and Entropy have entered into a “carbon credit offtake commitment” agreement (CCO) whereby CGF has committed to purchase up to 9M tonnes (up to 600K tonnes per annum (tpa) over a 15-year term) of TIER or equivalent carbon credits from Entropy projects. The initial project to benefit from the CCO is intended to be the Advantage Glacier Phase 2 project, drawing up to 185K tpa at an initial price of $86.50 per tonne, for a total of approximately 2.8M tonnes over the 15-year term. Upon successful deployment of the initial 600K tpa of CCO, CGF may make available a further 400K tpa of CCOs for additional Entropy CCS projects in Canada. This initial transaction notably appears to be in the form of an offtake agreement, rather than a contract for difference. The Globe and Mail reported that other project proponents, including larger oil and gas producers and members of the cement and chemical industries, have been attempting to negotiate contracts with the CGF at rates higher than the initial price of $86.50 per tonne agreed in this initial transaction. For further information or to…

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UNEP Releases 2023 Emissions Gap Report

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The United Nations Environment Programme (UNEP) recently published its annual emissions gap report: Emission Gap Report 2023: Broken Record (the Report). The Report provides an assessment of the gap between pledged and actual greenhouse gas (GHG) emissions reductions and the reductions required to align with the long-term temperature goal of the Paris Agreement and is published annually in the lead-up to the UN Climate Change Conference. COP 28, set to start Thursday in Dubai, will mark the conclusion of the first Global Stocktake under the Paris Agreement, which is very likely to acknowledge that current Nationally Determined Contributions (NDCs) are insufficient to achieve the goals of the Paris Agreement. The UNEP Report highlights the need for immediate implementation of solutions to the emissions problem. Article 6 of the Paris Agreement represents a viable mechanism to channel capital at the levels required in the time available. The Public Policy Forum, together with Resilient LLP and the International Emissions Trading Association, released a report last week titled The Missing Article: How to get Canada back in the game on Article 6. This bulletin briefly summarizes the key findings of the Report. The emissions gap in 2030 remains high. The Report indicates that current unconditional NDCs result in a 14 GtCO2e gap for a 2°C goal and a 22 GtCO2e gap for the 1.5°C goal. Full implementation of unconditional and conditional NDCs would reduce these estimates by 3 GtCO2e.   Figure: GHG emissions under different scenarios and the emissions gap in 2030 and 2035 Source: UNEP, Emissions Gap Report 2023, Figure 4.2   Likelihood of limiting warming to 1.5°C remains low. The Report found that there is only a 14% likelihood of limiting warming to 1.5°C and that current policies are likely to see temperature rise by 3°C compared to pre-industrial levels. However, implementing all unconditional and conditional pledges by 2030…

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Public Policy Forum Publishes Article 6 Report

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We are pleased to announce the release of an Article 6 report published by Public Policy Forum, authored by Lisa DeMarco (Resilient LLP), Katie Sullivan (IETA), and Steve MacDonald (+SM). The report, entitled The Missing Article: How to Get Canada Back in the Game on Article 6, is available now on PPF’s website and sets out a pathway for Canada to maximize the opportunity and minimize the cost of energy transition through Article 6.

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U.S. and China Release Sunnylands Statement Ahead of COP 28

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The United States and China announced renewed commitment to enhance cooperation to address the climate crisis in the Sunnylands Statement released on November 14, 2023 (the Statement). Both countries indicated their commitment to the effective implementation of the UNFCCC and the Paris Agreement, including the Glasgow Climate Pact and the Sharm el-Sheikh Implementation Plan, and to further the effective and sustained implementation of the U.S.-China Joint Statement Addressing the Climate Crisis and the U.S.-China Joint Glasgow Declaration on Enhancing Climate Action in the 2020s. This bulletin provides key details of the new and renewed commitments in the Statement. COP 28. The countries indicated that the consensus Global Stocktake decision expected to come out of COP 28 should, among other things: reflect that substantially more ambition and implementation on action and support will be needed to achieve the Paris Agreement’s goals; send signals with respect to the energy transition (renewable energy, coal/oil/gas), carbon sinks including forests, non-CO2 greenhouse gases (GHGs) including methane, and low-carbon technologies; encourage economy-wide 2035 Nationally Determined Contributions (NDCs) covering all GHGs; note the expectation of developed countries that the $100B climate finance goal will be met in 2023; welcome the recommendations of the Transitional Committee with respect to establishing funding arrangements to address loss and damage, including the establishment of a fund; and emphasize the important role of international cooperation. 2035 NDCs. The U.S. and China both affirmed that their 2035 NDCs under the Paris Agreement will be economy-wide, include all GHGs, and reflect emission reductions aligned with the Paris Agreement temperature goals. Energy Transition. The Statement provides important commitments related to the energy transition, including: support for the G20 Leaders Declaration to pursue efforts to triple renewable energy capacity globally by 2030 and sufficiently accelerate renewable energy deployment through 2030 from 2020 levels to accelerate the…

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Supervisory Body Publishes Recommendations for Methodologies and Removals Under Article 6.4 of the Paris Agreement

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The Article 6.4 Supervisory Body (SB) has published guidance on activities involving removals under the Article 6.4 mechanism of the Paris Agreement (the Removals Guidance). The SB also published recommendations on the requirements for the development and assessment of Article 6.4 mechanism methodologies (the Methodology Requirements). Both recommendations will be presented for consideration and adoption by the Parties to the Paris Agreement (CMA) at COP 28 starting later this month in Dubai, UAE. This bulletin highlights key information, guidance, and requirements provided by the SB in both the Removals Guidance and the Methodology Requirements. Removals Guidance Recommendation The Removals Guidance defines removals as the outcomes of processes to remove GHGs from the atmosphere through anthropogenic activities and destroy or durably store them. Requirements. The Removals Guidance provides the following requirements for activities involving removals under the Article 6.4 mechanism: Monitoring. Activity participants must monitor removals through appropriate application of quantification and estimation based on field measurements, remote sensing, measurement through instrumentation, and/or modelling. Post-crediting period monitoring, reporting, and remediation of reversals. Activity participants must undertake monitoring, reporting, verification, and remediation measures during the post-crediting monitoring period to confirm the continued existence of removals and to address any reversals of removals for which 6.4 carbon credits (6.4ERs) were issued during the active crediting period(s). The SB noted that 6.4ERs will not be issued for removals generated after the last active crediting period, including during the post-crediting monitoring period. Reporting. Activity participants must prepare monitoring reports after implementing monitoring operations and methods. These reports are to be prepared without a gap between two successive monitoring periods. The SB noted that methodologies will contain provisions specifying the minimum frequency of monitoring report submission, commensurate with the degree and nature of the risk of reversals. Accounting for removals. Removals eligible for crediting must exceed the applicable baseline determined in accordance with the Methodology Requirements and will be…

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