Distinguishing Avoidable vs. Unavoidable Reversal Events

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On July 7, 2023, British Columbia implemented regulatory changes through B.C. Reg. 169/2023 under the Budget Measures Implementation Act, 2023, and the Greenhouse Gas Industrial Reporting and Control Act. These amendments refine the measurement, reporting, and management of greenhouse gas emissions and carbon offsets, particularly for projects aimed at reducing emissions.

The regulation updates definitions related to emissions reductions and project emissions, specifying how these reductions will be calculated in both project plans and monitoring reports. This clarity is crucial for project proponents—those responsible for implementing emissions reduction projects—ensuring they understand how to accurately report their progress and comply with regulatory expectations. New requirements for monitoring reports mandate detailed descriptions of any events that negatively impact emissions reductions, termed “reversal events.” The regulation distinguishes between avoidable and unavoidable reversal events, influencing how project proponents are held accountable for managing their emissions.

A notable addition is the concept of “impaired project reduction,” which refers to situations where the combined total of emissions reductions and removals (such as carbon capture) falls below zero during a reporting period. The regulation specifies how to calculate these impairments, emphasizing accountability and precision in reporting. Project proponents are now required to provide comprehensive information about their projects, including any reversal events that occurred, and to assess whether these events were avoidable, offering justification for their assessments. This fosters transparency and encourages proactive management of emissions-reducing initiatives.

The updates also highlight the importance of verification in emissions reporting. Project proponents must demonstrate compliance with specified maintenance requirements to avoid penalties. If a reversal event occurs, they must clarify its cause and the extent of its impact on emissions reductions. The regulation outlines the process for retiring compliance units—essentially credits for emissions reductions—when a project experiences a reversal event, ensuring that impaired emissions reductions result in corresponding credits being retired to maintain environmental integrity. Directors are empowered to determine the appropriate amount of units to retire, reinforcing regulatory oversight.

Furthermore, the amendments provide flexibility regarding reporting periods for sequestration projects, requiring reports to cover both the current period and all previous periods, thus offering a comprehensive overview of a project’s performance over time.

The updates under B.C. Reg. 169/2023 aims to improve British Columbia’s approach to managing greenhouse gas emissions through more stringent and clear reporting requirements. By refining how emissions reductions are calculated and reported, the government promotes accountability and transparency among project proponents. 

British Columbia (169/2023) July 7, 2023