内能环境

欧盟新强制碳信用披露认证规则

wed20232月15 21:51:28+00

The European Union ("EU") is coming closer to adopting mandatory rules for companies that use carbon credits.

First, the European Parliament and Council are considering for adoption a Commission for a Regulation on a Carbon Removal Certification Framework ("CRCF Regulation Proposal").

Second, the European Commission ("Commission") is in the process of adopting standards (the so-called "ESRS") for the EU's mandatory ESG reporting regime—the Corporate Sustainability Reporting Directive ("CSRD")—that will also cover disclosures on companies' use of carbon credits (including as emission offsets) and their quality.

These two regulatory initiatives are closely tied to each other. In effect, the draft ESRS that the Commission is considering for adoption require subject entities to disclose GHG removals and GHG mitigation projects financed through carbon credits.

The EU's aim of regulating carbon credits coincides with its push for carbon neutrality by 2050, and a related significant proliferation of companies publicly committing to achieve "net-zero" emissions by mid-century, which has triggered an uptick in strategic purchases of carbon credits in the voluntary carbon market ("VCM").The CRCF Regulation Proposal and the upcoming ESRS will help to expand sustainable and verified carbon removals and encourage investment in technological innovation.

Companies turning to the VCM to reach their net zero goals, and others active in the generation, trading, and use of carbon credits, will want to follow these initiatives closely. Opportunities remain for companies to express views that may shape the final contours of these regulations.

We discuss these developments and opportunities for public comment below.

Regulation for a Carbon Removal Certification Framework

The European Parliament and Council are currently considering for adoption the CRCF Regulation Proposal that the Commission presented in late November 2022.建议书载有规则监测、报告并验证欧盟/EEA内部发生的碳清除的真实性实际中,拟议方案仅用于EU/EEA中的碳清除。

CCRC规程基于四大质量标准(载运QU.A.L.ITYmniker):

/p具体地说,为了确保认证过程的透明度和可靠性,CRCF监管建议:

设置量化、额外性和长期存储需求,产品必须符合这些需求才能认证;

要求认证方法符合这些需求并授权委员会制定方法学and

requires companies to subject their certification to independent third-party verification through a certification scheme.

Thus, the CRCF Regulation Proposal would require carbon credit project developers and potential users to conduct their own assessment of the carbon removal in accordance with the "QU.A.L.ITY" principles and the methodologies prepared by the Commission and then submit that assessment for independent verification through a certification scheme.

The CRCF Regulation Proposal requires certification schemes to be recognized by the Commission. All service providers of certification schemes must submit annual records of their activities to the Commission, and communicate any attempted fraud they identify. Moreover, certification schemes may only use accredited third-party certification bodies to verify project developers' and users' carbon removal assessments. These certification bodies may only be accredited by national accreditation bodies in the EU Member States. Hence, the CRCF Regulation Proposal creates a system of accreditation similar to that of notified bodies under the EU product rules.

At this stage, it is not yet clear how carbon offsets created through carbon removal projects applying the methodologies and certificate schemes set forth under the CRCF Regulation Proposal may serve as an alternative mechanism to meet the EU's GHG emissions reduction targets.根据欧盟委员会对CRCF监管建议的解释性备忘录,部分欧盟排放交易系统(EU-ETS)收入指向创新基金,它帮助企业投资创新清洁技术 — — 包括碳清除。 CRCF监管建议与推向创新建议相匹配。然而,看来CRCF监管建议下的碳清除不易交易或服务于EU-ETS下的目的。

此外,欧盟碳清除监管努力显然与全球开发相关联。值得一提的是,2023年1月会议中,国际可持续性标准委员会确认,拟议的s/www.ifrs.org/content/dam/ifrs/meetings/2023/jansb/sb/ap4-climateISSB是国际财务报告标准基金会(IFRS)二大标准设置板之一,并负责开发IFRS可持续性披露标准草案S2要求公司披露实现公司净零目标所必要的碳抵消数,包括用户理解实体拟使用抵消的可靠性和完整性所需某些因素A carbon removal activity's compliance with the CRCF Regulation Proposal (once adopted) would likely be an important marker of credibility and integrity.

Interaction with the EU's Mandatory Carbon Credit Reporting Regime for Companies under CSRD

The draft ESRS standards that that the Commission is currently considering also include ESRS E1 on Climate Change ("ESRS E1"), which proposes a set of mandatory climate disclosures for many companies. The ESRS E1 contains two principal disclosure requirements for companies with respect to their GHG removals and GHG mitigation projects that are financed through carbon credits:

First, companies must disclose GHG removals and storage from their own operations and their upstream and downstream value chain, and report the underlying calculation assumptions and methodologies!and

Second, and most important for carbon credits and the VCM, companies must disclose the amount of GHG emission reductions or removals (in metric tonnes of CO2eq) from climate change mitigation projects that financed through any purchase of carbon credits.

In addition, the ESRS E1 also requires that:

Companies relying on carbon credits for achieving any net-zero targets explain the credibility and integrity of the carbon credits used, and whether and how its claims of GHG neutrality neither impede nor reduce the achievement of its GHG emission reduction targets;

Companies consider recognized quality standards for preparing information on carbon credits, verifiable by independent third parties, to make public reports, and to provide rules for calculation, monitoring, and verification of the project's GHG emissions;

Companies disclose information on carbon credits with a breakdown of the following items (see AG 66 for the tabular format in which companies are suggested to present information on carbon credits):

the share (percentage volume) of reduction projects and removal projects;
- the share (percentage volume) of each recognized quality standard;
- the share (percentage volume) issued from projects in the EU!
- - >
  - 和
- >/carbon清除不影响温室气体排减量努力(ESRSE1建议约90-95%温室气体排减量应来自公司自身的企业排减量)。
The draft ESRS E-1 does not reference the CRCF Regulation Proposal, but it requires companies to "apply consensus methods on accounting for GHG removals as soon as they are available." This fits with the Commission's purpose for the regulation of the certification of carbon removals—namely to increase transparency, credibility, and integrity around companies' actions to permanently remove GHG from the atmosphere.

Next Steps

The Commission is set to adopt the draft ESRS as delegated acts by mid-2023. On November 23, 2022, EFRAG sent its draft ESRS to the Commission. Once adopted, the European Parliament and Council have two months to present any objections.之后ESRS将成为强制标准,公司必须报告各种ESG影响(见即使在此后,欧盟认证框架也只有在欧盟委员会通过首个认证方法并承认首个认证机制后才能完全运行。

委员会拟议的CRCF监管建议草案目前开放公共咨询 2023

即将到来的欧盟绿色索赔规则

Tue2023年1月24日02:29:26+00

The European Commission is expected to present a Proposal for a Directive on Green Claims ("Proposed Green Claims Directive" or "the Proposal") within the next few months. Together with the Proposal for a Directive empowering consumers for the green transition through better protection against unfair practices and better information ("Consumer Empowerment Directive Proposal"), the Proposed Green Claims Directive would contribute to the EU's green transition towards a circular, climate-neutral and clean economy by creating a common methodology for the substantiation of green claims that concern the environmental footprint of products, services and companies.It would aim to reduce greenwashing and enable consumers to take informed purchasing decisions based on reliable information about the sustainability of products and traders.

If adopted, it is likely to significantly limit the environmental claims that businesses can make in the EU/EEA. Businesses may want to consider approaching the Commission to try to influence the final legislative proposal that it is expected to present by March 2023. Once the Commission presents its legislative proposal, businesses should consider proposing amendments to the European Parliament and Council.

Harmonization of the Rules on Green Claims in the EU

Currently EU law does not explicitly regulate environmental claims.万博体育app手机登录Instead, environmental claims are subject to the general rules of Directive 2005/29 on Unfair Business-to-Consumer Practices and Directive 2006/114 on Comparative Advertising. While the Commission and Member States have issued guidance interpreting these directives and their national implementation in the context of green claims, in practice there is a wide range of variations on the requirements for and enforcement against these claims among Member States. The Proposed Green Claims Directive is expected to create a harmonized set of rules on the substantiation of voluntary green claims applicable to all companies operating in the EU/EEA.

Covered Green Claims

The Proposal is expected to define green claims subject to the new rules as "any message or representation, including text, pictorial, graphic or symbolic representation (e.g., labels, brand names, company names or product names), which states or implies that a product or trader has a positive or no impact on the environment or is less damaging to the environment than other products or traders, respectively, or has improved their impact over time." The Proposal is not expected to apply to claims that cover aspects other than those related to the environment. For example, sustainability claims would only be covered if they refer to environmental sustainability (e.g., preventingbiodiversity loss).

The proposed rules are also only expected to cover voluntary claims made by companies in the context of business-to-consumer ("B2C") transactions. The rules would also not cover environmental mandatory labelling or disclosures under EU environmental rules.万博体育app手机登录For example, mandatory declarations under Proposal for Ecodesign for Sustainable Products Regulation, or the requirements under the EU Taxonomy Regulation or the Proposal for a Regulation Establishing a Union Regulatory Framework on the Certification of Carbon Removals) are out of scope.

General Rules on Green Claims

The Proposal is expected to impose general requirements on the environmental claims that companies can make that will mirror those of the existing Commission's guidance. In particular, it will require that companies:

only make environmental claims that have been substantiated through an approved methodology that meets specific criteria (see below);
do not make a positive environmental claims where a product has both a positive and negative environmental impact. Companies may communicate the positive claim only if they also communicate the negative impact in a clear and understandable way. For example, if savings in water consumption lead to a notable increase in greenhouse gas emissions or to a negative environmental impact in another stage of the life-cycle of the product (e.g., CO₂ savings at the stage of manufacturing leading to a notable increase of CO₂ emissions at the use phase), both facts should be disclosed together with the claim;
make available the information on the assessment on which the environmental claim is based, including (i) information on the product or activities of the trader subject to the claim, (ii) environmental aspects, environmental impacts or environmental performance covered by the claim, (iii) the methodology used, (iv) the underlying studies or calculations used to assess, measure and monitor the environmental impacts or aspects covered by the claim, (v) a brief explanation how improvements in environmental performance are achieved, etc. Access to this information may be provided in the form of a weblink, QR code or equivalent!万博体育app手机登录and
review the accuracy of their environmental claims (and their substantiation) at least once every five years from the date of the underlying studies or calculations. In cases where there are circumstances that may affect the accuracy of the claim (i.e., when there are updates of the scientific methodology substantiating the claim), the environmental claim should be reviewed and updated immediately.

Methodology to Substantiate Green Claims

In line with current Commission's and Member States' guidance on environmental claims, the Proposal is expected to require economic operators to duly substantiate their environmental claims on the basis of a methodology that:

is based on widely recognized scientific evidence, state of the art technical knowledge and takes into account relevant international standards. Where there is no recognized scientific method or insufficient evidence to assess environmental impacts and aspects, claims referring to such environmental impacts would not be allowed;
assesses the environmental impact throughout the whole life-cycle of the product;
takes into account: the product composition!素材制作从过程和产品使用中排出耐用性、可恢复性和生命终结性;
asesse万博体育app手机登录and
is regularly reviewed by a third party with a view to take account of technical and scientific progress and the development of relevant international standards as well as revised where necessary to reflect such progress.

The Proposal is expected to add a lengthy list of additional requirements with which the methodologies to substantiate environmental claims must comply. This is a significant departure from the previous, lighter requirements under the Commission's and Member States' green claims guidance. In this context, the Proposal links these requirements to the existing EU Product and Organization Environmental Footprint methods ("PEF" and "OEF"). Where a company complies with the Product Environmental Footprint Category Rules ("PEFCRs") for a product, the claims made on the basis of the PEFCRs are deemed compliant with the requirements of the Proposal.

Requirements Related to Comparative Environmental Claims

The Proposal is also expected to include rules on environmental comparative claims, namely, that:

companies use the same methodology to assess the environmental impacts, aspect or performance of products or traders to which the comparison is made (e.g., where two traders make a claim on climate change, where one considered only direct impacts, whilst the other considered both their direct and indirect impacts, the results are not comparable);
data used for the substantiation of the comparative claim must be generated or sourced in an equivalent manner to ensure their comparability (e.g., choosing indicators on the same aspects but that use a different formula for quantification makes comparisons impossible, and therefore, there is a risk of misleading consumers)!and
the most significant stages along the value chain must be taken into account for all products and traders compared, etc.

If adopted, these requirements are likely to make environmental comparative advertising more challenging for companies. Product certification and testing is costly, and the proposed wording would in practice require companies to conduct head-to-head studies to be able to claim any comparative advantage. Broad, sector-wide claims based on publicly available studies would no longer be acceptable.

New Rules on Forward Looking Claims

The Proposal is also expected to introduce new strict rules on forward-looking claims (i.e., claims that suggest that a product, service or company will achieve specific environmental benefits by a certain future date).The Proposal is expected to require that claims related to the future environmental performance of a product, service or trader:

be accompanied by commitments that include milestones to be achieved within clearly specified time frames (if a target set for 2030 does not include any periodic milestones, it is impossible for stakeholders, or the trader itself, to monitor whether they are on track and what are the challenges);
indicate a baseline year for targets and the indicators reflecting performance in the baseline year and the year linked to the improvement set out in the claim (e.g., "50% reduction of greenhouse gas emissions compared to 2015" instead of "50% reduction of greenhouse gas emissions");
not include actions or targets already achieved, etc.

Enforcement and Access to Justice for third Parties

The proposal is expected to introduce new and reinforced rules on enforcement against companies making non-compliant environmental claims. Member States are expected to be required to carry out a compliance monitoring:

as part of their regular checks;
in cases where they have sufficient reason to believe that an environmental claim presents a risk of infringement of the rules, laid down in the Proposal!或
响应.

CompanyAfter receiving a notification for non-compliance, companies would only have 10 business days to provide an answer. Where a trader does not provide a timely or satisfactory answer, enforcement authorities must require the trader to correct the non-compliant claim or immediately stop its communication. The trader will have to implement the corrective actions within 30 business days.

The Proposal is also expected to allow third parties to submit complaints against non-compliant green claims before administrative authorities, and thereafter courts, if the third parties have sufficient interest or have the rights infringed. Such complains may lead to injunctive actions, including the immediate stop of the communication of the non-compliant claims.

Next Steps

The European Commission is expected to formally present its proposed Green Claims Directive by the end of March 2023. Once presented, the European Parliament and Council will consider the Proposal for adoption through the ordinary legislative procedure. This process will allow for the introduction of amendments and will take at least 18 months. As indicated above, industry should keep a close eye on the development of this proposal as the requirements it will impose will have a significant impact on the current practices.

美国政府提议规则要求主要联邦承包商披露温室气体排放并建立基于科学的减排目标

马丁列维和泰勒威廉斯 — Thu,2022年11月24日 00:32:36+00

As noted in our COP27 recap, this year's climate summit in Sharm el-Sheik involved both the historic creation of a fund to compensate countries most impacted by climate change, as well as lost opportunities to adopt more ambitious and accelerated climate mitigation commitments. Perhaps hidden between these headlines, President Biden announced an initiative with significant implications for federal contractors.Under this proposal, the United States would become the first country to require major government suppliers and contractors to set science-based emissions reduction targets aligned with the Paris Agreement. It would also require contractors to disclose their greenhouse gas (GHG) emissions and climate risks.

This initiative—the proposed Federal Supplier Climate Risks and Resilience Rule—would have wide-reaching impacts if ultimately finalized. Collectively, the proposed rule would cover about 86 percent of the federal government's supply chain GHG impacts and 86 percent of federal annual spending. To put this in perspective, in the last fiscal year alone the United States purchased $630 billion in goods and services.

The comment period for the proposed Federal Supplier Climate Risks and Resilience Rule closes on January 13, 2023.大型承包商的拟议守法要求自发布最后规则两年后启动,如果发布,可按拜顿政府为联邦承包商规定的COVID-19疫苗任务向法庭质疑该规则

spanid表示'More-8294'/span>gsa.gov/policy-structions/federal-cap-control-far#:~text=%20Federal%20Actition%20最大联邦提供商-即接受5千万美元以上年度合同的majectors-a和(3)设置科学排减目标The first and second requirements would be fulfilled through an annual climate disclosure report. Contractors receiving between $7.5 million and $50 million in annual contracts would only be required to report Scope 1 and Scope 2 emissions, and all other federal contractors would be exempt from disclosures. The proposed rule does not discuss what enforcement mechanisms—if any—could be deployed against a contractor that fails to meet its emissions reduction target.

Certain entities would be exempt from the proposal irrespective of the size of their annual contracts. For instance, tribally owned entities, higher education institutions, nonprofit research entities, state and local governments, and certain management and operating contracts figure to be exempt from the proposed emissions disclosures and science-based target requirements. Additionally, if a major contractor is considered a "small business" according to the North American Industry Classification System (NAICS) code in its System for Award Management (SAM) registration, or if it is a nonprofit organization, then it would not be required to complete an annual climate disclosure or to set science-based targets.

拟议规则将利用现有第三方标准和系统,包括与气候有关的财务披露建议工作队、CDP报告系统(原碳披露项目)和科学目标倡议标准下图概述(1)温室气体清单需求2) 年度气候披露报告和 3 基于科学目标需求.

清单将在连续12个月期间编目排放,结束时间不超过清单编全前12个月实体可使用环境保护局简化排量

万博体育app手机登录信息披露必须同TCFD建议保持一致,除范围1和2外,还必须包括CLE3排放清单。报告还必须描述实体的气候风险评估过程和通过该过程识别的任何风险。建议规则目前设想承包商通过完成CDP

确定与TCFD匹配的CDP

Science-Based Target Requirement

As noted above, major contractors would be required to develop science-based targets. The Federal Register notice for the proposed rule defines a science-based target as "a target for reducing GHG emissions that is in line with reductions that the latest climate science deems necessary to meet the goals of the Paris Agreement to limit global warming to well below 2 °C above pre-industrial levels and pursue efforts to limit warming to 1.5 °C." According to the proposed rule, these targets must be validated by SBTi and be made publicly available. Though only applying to major contractors, it is estimated that these targets would address 64 percent of federal government spending and approximately 69 percent of supply chain GHG impacts.

II.Related Federal Sustainability Initiatives

The proposed rule fits within two larger Biden Administration initiatives. The first is the President's Federal Sustainability Plan, which we previously summarized in another blog entry. That plan sets a number of goals, including: 100% carbon-free electricity by 2030, and net-zero emissions in federal government procurements by 2050. To achieve the net-zero-emissions procurement goal, the government previously announced a "Buy Clean Task Force" to prioritize the procurement of low-carbon building materials, such as steel and concrete. The proposed Federal Supplier Climate Risks and Resilience Rule furthers net-zero procurement by requiring 85 percent of the emissions associated with the Federal supply chain to set net-zero targets and disclose their emissions.

The second initiative is a "comprehensive, government-wide strategy to measure, disclose, manage, and mitigate the systemic risks" of climate change. Within this bucket, the Biden Administration points to the Department of Labor's proposal to remove barriers to the consideration of climate risks and other environmental, social and governance factors by ERISA plan fiduciaries!证券交易委员会待定study climate-related risks to the financial system.

[1] Scope 1 emissions include GHG emissions from sources that are owned or controlled by the reporting company.

[2] Scope 2 emissions include GHG emissions associated with the generation of electricity, heating and cooling, or steam, when these are purchased or acquired for the reporting company's own consumption but occur at sources owned or controlled by another entity.

[3] Scope 3 emissions are a consequence of the operations of the reporting entity but occur at sources other than those owned or controlled by the entity.

COP 27重点:融资取中心阶段

托马斯·赖利 — wed2022年11月9日2.30:38+00

p对齐=scenter@p>justday11月8日是“国家元首和政府首脑高层次段”的第二天,重点是他们的演讲和声明egeneral损耗和损害快速成为本次COP关键争议点并预示比去年格拉斯哥更紧张的会议这个问题一直在上移日程,最近极端气候事件增加了围绕这个题目的感知紧迫性,对脆弱国家来说尤其如此。

spanid='more-8226'/span>

马拉维、佛得角、苏里南、巴巴多斯和帕劳领导人都表示需要增加损失和破坏资金,而联合国秘书长则呼吁创建新的“气候团结协议”,富国在其中从财政上帮助较穷国家。

表示美国愿意讨论损失与损害问题, 并期望两年对话达成任何承诺。

Meanhy尽管如此,迄今认捐的数额仍然相对微不足道。同时,欧盟呼吁“全球北区”承诺全球南区气候融资,同时指出欧盟在为每年1,000亿美元的适应基金捐款方面正在发挥自己的作用。相关地,爱尔兰总统确认爱尔兰对气候司法融资的贡献将超出其现有承诺,新西兰宣布为发展中国家因气候变化影响而损失土地和资源建立气候基金。

所有这一切都是在Nicholas Stern新报告(英国和埃及政府委托编写)的背景下实现的,该报告显示发展中国家迫切需要气候融资减缓和适应《报告》的结论是,它需要每年2万亿美元投资,以满足除中国以外的世界发展中经济体的需要。对公司很重要的是,报告承认资金不能单从政府提供,而应该从国际金融机构(IFIs)和私营部门提供。

其他开发s:

UK >The new Partnership will almost double the scale of the original program from USD 12 billion to USD 23 billion in funding and include countries accounting for almost 60 percent of global GDP, such as Australia, Canada, the U.S., France, Germany, Japan, Kenya, among others.

France announced a doubling of its domestic decarbonization budget from EUR 5 to EUR 10 billion to help heavy industry in France decarbonize.

A UN group that was set up to crack down on greenwashing of net zero pledges has called for "red lines" to stop support for new fossil fuel exploration and overuses of carbon offsets.集团报告得到了联合国秘书长的全力支持。

the U.S.hrefss/www.ft.com/content/827e012-5374-4676-860e-b860b6ccf5收益再为新清洁能源项目供资. /duvalu https://public.wmo.int/en/earwarsforall>plan

Contractors有机会帮助形状ESG需求

Sarah Schuler — Tue2021年12月14日

Addressing climate change has been a priority for President Biden since his first day in office. On December 8, 2021, President Biden continued that focus by issuing Executive Order (EO) 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, which includes a number of requirements directed at introducing sustainability to federal acquisitions.

This most recent EO announces an administration policy to achieve net-zero emissions from federal procurement by 2050 and comes on the heels of the public comment period extension to January 13, 2022 in response to EO 14030, Climate-Related Financial Risk. Although the administration will likely be rolling out additional sustainability requirements in the coming months, contractors currently have an opportunity to help shape an initial requirement that may end up effectively establishing an environmental, social, and governance or "ESG" reporting requirement.具体地说,联邦获取管理委员会正征求公众评论,以考虑修改联邦获取规则:

>>要求主要的联邦供应商公开披露温室气体排放和气候相关金融风险并设定科学减排目标和

sp样式='pdate-left:40px;'>>确保主要联邦机构采购最大限度地降低气候变化风险,包括要求在采购决策中考虑温室气体排放的社会成本,并在适当可行时优先选择温室气体排放社会成本较低的供应商的标书和建议。

政府当前提案类似于机构一级最近的活动,与美国Securities and Exchange Commission ("SEC") announcing an "all-agency approach" in response to investor demand for ESG-related information. The SEC is also seeking public comment in an effort to determine whether current climate change disclosures adequately inform investors and as of December 7, 2021 has received 5,867 comments.

In light of the rapidly evolving scope, demands, and attention placed on board and management accountability for sustainable business practices, Covington's multidisciplinary ESG and Sustainability team created an ESG and Sustainability Toolkit as an entry point for analysis, understanding, and tailored advice on this wide ranging topic.

As part of an effort to reduce federal supply chain emissions, President Biden additionally ordered the General Services Administration to "track disclosure of greenhouse gas emissions, emissions reduction targets, climate risk, and other sustainability-related actions by major Federal suppliers, based on information and data collected through supplier disclosure" of greenhouse gas emissions (as discussed in consideration (i) above).

With new reporting, tracking, and emissions reduction targets potentially on the horizon, federal contractors should consider taking the opportunity to shape aspects of new requirements, such as the preferred method of tracking and reporting emissions data, including how to evaluate the social cost of such greenhouse gases. For example, there would be a number of ways to measure the "social cost" of greenhouse gas emissions, which is generally an estimate of the monetized damages associated with incremental increases in greenhouse gas emissions. As re-established under EO 13990, the Interagency Working Group on the Social Cost of Greenhouse Gases published interim estimates of the social cost of carbon, methane, and nitrous oxide in February 2021 that reflect one method for evaluating emissions data that could ultimately inform requirements imposed on contractors. Although a coalition of states is currently challenging the administration's use of social cost estimates to calculate regulatory costs and benefits under EO 13990,[1] the notice of public comment for EO 14030 still includes the social cost of greenhouse gases as one potential factor when considering greenhouse gas emissions in federal procurement decisions.

Comments may be submitted on the following questions on or before January 13, 2022 for FAR Case 2021-016 at https://www.regulations.gov/document/FAR-2021-0016-0001:

How can greenhouse gas emissions, including the social cost of greenhouse gases, best be qualitatively and quantitatively considered in Federal procurement decisions, both domestic and overseas?
什么可用并受尊重方法测量所购或租产品或所服务生命周期中的温室气体排放?
联邦政府通过国内外采购决策可如何考虑和尽量减少与气候有关的金融风险?
贵组织将如何提供温室气体排放数据供建议和/或合同性能使用?
联邦政府应如何验证温室气体排放报告?
政府应如何优先接受国内外供应商的标书或建议书,以最有效实现减少温室气体排放或降低温室气体排放社会成本?
采购决策中考虑温室气体社会成本对小企业产生什么影响? 小企业包括处境不利小企业、妇女拥有小企业、服务性残疾老企业和历史利用不足商业区小企业FAR理事会应如何最优化地将目标与确保小企业机会的努力相匹配?

号2:21-cv-0107La.提交4月22,2021.

格拉斯哥COP26报告:评估联合国气候会议

加里S古济市 — Frii2021年11月19日

As the United Nations Climate Change Conference of the Parties ("COP") in Glasgow has drawn to a close, with seemingly mixed messages and a somewhat ambiguous conclusion, it is worth reflecting on the overall trajectory of the climate issue, societal expectations, and the accomplishments that — with time — Glasgow is likely to represent. COP26 highlighted the fragility of the planet, as well as the fragility of the global consensus-based United Nations approach to protecting it. It highlighted the sweep of global climate-induced challenges and the scale of transformation needed to address them. With rising temperatures has come a rising global focus on climate and a far greater set of emerging societal expectations for meaningful responses by government and the private sector. Despite the risk that the global agreement forged in Glasgow is seen by climate activists as all talk and no action — what they referred to as "blah, blah, blah" — I believe that a number of features will endure as important accomplishments.

Representatives from 197 nations, businesses, hundreds of civil society organizations, scientists, educators, media, and climate activists — you name it — all converged on Glasgow to shine a global spotlight on the climate crisis. The Conference had some 40,000 registered participants. With just a few thousand of those involved in the negotiations themselves, the rest converged around elevating climate understanding, climate solutions, and climate action. And still tens of thousands of others converged to protest and lend their voices to the climate debate.期望因Covid-19延迟一年以及美国返回巴黎气候进程而提高但这些期望都集中在依赖实现每一项结果一致性的联合国谈判进程上。

尽管Covid云下集合和大批与会者所构成挑战,但缔约方会议在某些方面组织得比以往更好。它不再完全是一个国际谈判,而更多地是一个通信机制,以凝聚世界对雄心气候行动需求的看法United Nations进程启动全球领导人峰会,有120位国家元首参加It featured inspiring statements from governmental and societal leaders, such as Sir David Attenborough. The Summit then flowed into the overall COP, which had a thematic organization for each day of the conference, by which it highlighted actions or the sweep and scale of climate impacts in a more coherent fashion than ever before — spanning from energy, finance, transport, cities and the built environment, science and innovation, nature, gender, youth, and adaptation to and loss and damage from climate change. And the overall gathering encapsulated a heightened global focus on climate as a defining generational issue in a way that has never happened before.

The World Rallied Around the Urgency Shown By the Evolving Climate Science

The defining element of the Glasgow considerations was the acceptance of a far sharper sense of climate science findings around the scale and urgency of emissions reductions needed to stabilize the earth's climate and prevent catastrophic consequences. Every aspect of the discussions was judged by the context the new climate science shows.

Leading up to the COP, the UN's authoritative science body, the Intergovernmental Panel on Climate Change ("IPCC"), had issued two reports — one in 2018 focused on the imperative of holding global average temperature rise to 1.5 degrees Centigrade, and one in the Summer of 2021 highlighting the "overwhelming" evidence of climate change. The reports showed that a rise in global temperature to 2 degrees would lead to catastrophic results in both the frequency and severity of climate-induced events and global changes. The reports found the science of human-induced impacts "unequivocal" and noted that global temperatures had already risen by 1.1 degrees over pre-industrial levels — demonstrating how limited the remaining carbon budget is — and that climate adverse effects were widespread, rapid, and intensifying.The report further found that urgent action is needed to cut emissions by 45% by 2030 and achieve net zero emissions by 2050 in order to maintain a sustainable trajectory.

The IPCC findings were characterized by UN Secretary General António Guterres as a "code red for humanity." They became the touchstone for judging the adequacy of country pledges and private sector net zero commitments. In addition to the scale of the emissions reductions, the need for an accelerated pace of change also became far clearer and a widely accepted expectation. The notion that we are now in a "decisive decade" to get on the right emissions trajectory was embraced by the COP process. Going into the COP, various assessments, such as from the International Energy Agency, showed that existing country emissions reduction commitments would lead to a global temperature rise of 2.8 degrees by the end of the century. Those pledges covered less than 20 per cent of the gap in emissions reductions needed to be closed by 2030 to keep a 1.5 degree path within reach. According to a number of projections, the plethora of new commitments announced at the COP would, if delivered in full, lower the rise to somewhere between 1.8 and 1.9 degrees. The UN noted that the actual nationally determined contributions ("NDCs") submitted by participating nations would result in an unsustainable global temperature rise of 2.4 degrees.

At the end of the day, the overall agreement reached by 197 countries — including new emissions reductions announcements, the move to more regular revision of national commitments, transparency requirements around that process, and the development of rules for the global carbon markets — at bottom kept alive the possibility of limiting global temperature rise to 1.5 degrees by the end of the century and essentially transformed that temperature target into the new object of the UN process.虽然1.8度和1.5度之间的差值似乎不大,但实际上它代表着减轻气候变化最大破坏性影响的实质性差值。广泛报道的争议涉及是否逐步停用煤炭和化石燃料补贴,发展中国家是否有足够的气候资金,以及是否向受影响国家提供补偿“损耗和损害”抑制了对协议的热度。尽管如此,正如缔约方会议主席Alok Sharma得出的结论, “我们现在可以可信地说我们已经保住1.5度。But, its pulse is weak and it will only survive if we keep our promises and translate commitments into rapid action."

Paired with these science targets was a far more prominent voice given to the moral underpinnings to the proceedings that focused on the inequity created because the most vulnerable nations to climate impacts are those who have contributed least to the emissions causing such impacts, and a palpable sense of obligation to future generations. The IPCC report drove home the concept that the COP process is not some future exercise with distant impacts, but that the delegates were poised to address an urgent crisis of the here and now.

The Paris Climate Framework Survived the Absence, and Accommodated the Return, of the United States as an Active Participant

The nations of the world remained committed to the UN Climate Framework Convention's goal of "the stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system" even in the absence of U.S.巴黎气候协议自下而上承诺框架由每个国家根据自身环境确定,体现了应对这一全球挑战的共同全球承诺,没有美国则保持稳定和适切性participation, and the reaffirmation of that framework may be one of Glasgow's greatest accomplishments.

The Paris balance had achieved a "bottom-up" system of emissions reduction commitments that flexibly accommodates the circumstances of individual countries, yet one that does not allow so much flexibility that there is no realistic hope of actually bettering the climate situation by addressing emissions mitigation, adaptation to the already locked-in effects of climate change, and assistance for climate-impacted developing nations. Paris provided a solution and a directional sense of its goals, even as it admitted that its trajectory may need to grow more stringent over time, informed by meaningful science. Glasgow refined that process with a commitment by the parties to revisit their NDCs in one year rather than five and with enhanced transparency around individual country goals and their implementation. This process preserves the possibility that the collective emissions reduction actions are calibrated to avoid the worst climatic impacts.

The durability of the Paris structure was aided, to be sure, by the promise of new technology, which could allow for countries to enhance their emission reduction commitments through cost effective wind, solar, energy efficiency, and electric vehicle technologies — technologies that were still only on the verge in Paris — making a clean energy transformation that is consistent with the Paris climate goals today seem like an attainable objective.

When the United States did return to the negotiating table, it brought with it an ambitious NDC — pledging to achieve a 50-52 percent reduction from 2005 levels in economy-wide net greenhouse gas pollution by 2030, to achieve 100 percent carbon pollution-free electricity by 2035, and net zero emissions no later than 2050. It also brought a bevy of other actions to instill more confidence in its commitment.This included leadership in assembling a global methane reduction coalition by which more than 100 countries agreed to cut emissions to tackle this highly potent short-acting greenhouse gas by 2030, a "first movers" technology coalition, as well as a series of whole-of-government financial and regulatory initiatives.

While the Biden Administration would have liked to have had its actions backed up by climate legislation, particularly power plant incentives and a range of clean energy tax credits in the reconciliation bill, it made a strong case nonetheless about the comprehensive approach it is taking to prioritizing climate outcomes across the government, whether that be in the financial sector, energy, or transportation. And the United States demonstrated ambition in its diplomacy, reaching a surprise commitment with China to work collaboratively across a range of areas to keep alive the prospects for achieving 1.5 degrees. President Biden's address to the COP was complemented by a widely praised speech by former President Obama speaking directly to youth climate activists who had taken to the streets during the COP, as well as by Congressional leadership.

The Global Focus on the Climate Crisis Puts a New Spotlight on the Importance of Business Solutions and the Business Opportunities Around Climate — Subject to Ever Greater and More Intensive Scrutiny

The first week of the COP brought a breathtaking series of collaborative public and private sector announcements to achieve carbon emissions reductions. In many ways, these commitments seem almost as significant in accomplishing a clean energy transformation as the text of the UN agreement itself.

In addition to the methane pledge, leaders from over 120 countries, representing about 90 percent of the world's forests, pledged to halt and reverse deforestation by 2030. Hundreds of financial firms, operating through the Glasgow Financial Alliance for Net Zero (GFANZ), committed over $130 trillion of private capital — representing 40 percent of global financial assets — to transforming the economy for net zero.Various combinations of development organizations and private sector capabilities identified a range of opportunities they will pursue for investments in particular developing nation economies, such as in efforts to stem coal use in South Africa. Nearly 30 national governments, joined by cities, states, major automotive manufacturers, fleet owners, and investors, signed the Glasgow Declaration on Zero-Emission Cars and Vans to end the sale of internal combustion engines by 2035 in leading markets, and by 2040 worldwide. Other transportation commitments touched on heavy duty vehicle electrification, green shipping, and enhancing the deployment of sustainable aviation fuels.

Glasgow in many ways represents a shift in focus from a governmental initiative to a recognition that the scale and pace of the energy and societal transformation and response demanded by climate change necessarily will require swift and credible action by the private sector as well. As one Chief Executive Officer put it, the concept of a "climate-advantaged" company has taken hold, where sustainability has been transformed from a "nice to have" effort being done on the side, to a vital consideration at the center of business strategy, and where such companies can benefit from a substantial value premium. As one of the UN's High Level Climate Champions put it: "Net zero has gone from extreme to mainstream."

Of course, with the proliferation of net zero pledges comes an increasing level of skepticism about the credibility of those commitments and the ability to deliver on them in the long run. In the ramp up to the COP, the IPCC focus on the more stringent and nearer term emissions reductions meant that the Science Based Targets Initiative formally revised its goals for net zero corporate commitments to align with the new 1.5 degree IPCC target and issued a new standard for evaluating company emission reduction offerings. Along these same lines, the so-called "Under 2 Coalition," representing commitments by some 60 percent of world's economy, is recasting itself as the "Net Zero Coalition."

Likewise, the UN Secretary General, at the Opening to the World Leaders Summit portion of the COP and prompted by developing nation and activist concerns over the credibility of emissions reduction commitments, characterized "a deficit of credibility and a surplus of confusion over emissions reductions and net zero targets, with different meanings and different metrics." The Secretary General therefore announced that he will "establish a Group of Experts to propose clear standards to measure and analyze net zero commitments from non-state actors." The Secretary General reiterated his intent to establish a high level group for this purpose at the conclusion of the COP as well. These will likely complement a range of emerging national financial sector and ESG transparency requirements, including the announcement of the formation of a new International Sustainability Standards Board, along with other Paris Climate Agreement provisions, particularly the new carbon market rules.

Indeed, youth activists expressed particular concern over the pace and credibility of emissions reduction commitments, stating quite simply that "we don't believe you" and urging the business community to "prove them wrong." This skepticism was heightened by the overall context of the final COP debate around the failure to honor in a timely way climate finance commitments of $100 billion per year to affected developing countries, the absence of a clear loss and damage compensation commitment, and the somewhat relaxed treatment of fossil fuels, particularly the insistence by some nations to preserve an ongoing role for coal.

Just as there will be these formal processes to help refine net zero expectations, there no doubt also will be enhanced activist group scrutiny of company pledges and climate impacts. Companies will be called to task to demonstrate what they are doing to implement their net zero commitments.This scrutiny is likely to be even more acute given the inability of the formal negotiating process to achieve a level of ambition through country NDCs that will reach the 1.5 degree target or deliver in the short term the climate finance commitments for the developing world and the credibility gap that this outcome may perpetuate. As France's former Climate Ambassador and the key architect of the Paris Climate Agreement, Laurence Tubiana, put it, "Greenwashing is the new climate denial." Climate accountability in many ways will be the new currency.

We Can Expect More Focus on Climate Commitments Going Forward

Building on the Paris accord, the agreement follows the pattern of existing domestic environmental laws in recognizing that it may not be a perfect solution, in and of itself, and that the science will continue to evolve.But those frameworks recognize that it is critical to get started on the emissions reduction process even if the target may be revised in the future. Similar to the Clean Air Act's five year review provision for fundamental health-based pollutants, Glasgow acknowledges the need to calibrate future emissions reductions based on new science more frequently and with greater transparency to assess the success of country measures in meeting the emissions targets, and that there is a fierce urgency of the now being expressed by climate advocates that should inform those evaluations. While the global community has demonstrated that it can, in essence, walk and chew gum at the same time, the question this time is whether it can do so while running.That will be tested starting next year with submissions to the next COP.

Implementation of the various COP26 pledges will be a critical piece of the equation. The test will continue to be how to turn commitments into action for this decade. As the UN Secretary General indicated, "COP27 begins today." In some ways, Glasgow represents a sharper focus on science-aligned plans — by governments and business and in the face of a new global climate consciousness — to maintain climate stability, and the focus will now shift to the implementation and refinement of those commitments. For companies, growing global climate consciousness and risks and opportunities posed by the energy transformation present a new post-Glasgow dynamic necessitating climate engagement, but requiring a credible approach in doing so.

苏格兰政府水力行动计划草案

托马斯·赖利和托莫斯·格里菲思 — Thu,2021年11月18日

sup>th/sup>2021年11月10日sup>sth/supsss目的是苏格兰到2030年能生产5GW氢和2045年能生产25GW氢span/ps苏格兰政府确认迫切需要改变,表示实现这些气候变化目标需要前所未有的速度。

苏格兰政府热切地确保现有(碳氢化合物)部门就业者得到再技能和再生部门提供的机会,可再生能源价格可承受苏格兰水电部门将在支持这一过渡方面发挥重要作用,计划要求苏格兰政府评估如何为碳密集部门工人创建长期“技能保证”。Plan还突显苏格兰成为欧洲低成本氢矿生产者的潜力苏格兰政府将在2022年能源策略和公正过渡计划中更详细地说明其方法。

Funding

This money will fund FEED studies for large-scale renewable Hydrogen production projects with a view to making full investment decisions later in the decade.

The Scottish Government wants to use the £100m fund as a means to accelerate as many projects as possible from pilot stage to large scale commercial and has hypothecated £10m to prioritise innovation and research through the creation of the Scottish Hydrogen Innovation Fund, which will be launched early in 2022.

The remaining £80m of the EETF will fund the development of carbon capture, utilization and storage technologies – suggesting that the Scottish Government views blue Hydrogen as an important element of its Hydrogen revolution.

Timeline

The Plan sets out detailed action points until the end of 2026.苏格兰政府期望到2026年大规模氢生产基础设施到位,与大规模碳捕获存储相联(super>CCS )以及岸上和近海风开发。

计划还提出了2045至2045年Hydrugen经济路径图苏格兰的目标是到2035年实现100%可再生电运营,同时增加向英国和欧洲其他地区的氢输出量In the 2040s, the Scottish Government aims to have capacity to produce 25 GW of Hydrogen and to be established as an enduring and reliable exporter of Hydrogen to Europe.

Underlying Themes

Strategic Scotland – the Plan stresses Scotland's ideal position – due to its location, infrastructure, skilled workforce and natural resources – to grow its Hydrogen industry and become a world-leader in the Hydrogen sector.
Private Sector Diversification – the Plan notes the opportunity that Hydrogen offers for existing energy companies not only to diversify their offer, but also to reduce their carbon emissions.
Regional Approach – the Plan reinforces the importance of Scotland's key regional hubs, in particular Orkney and Shetland, for potential growth in the Hydrogen industry.Aberdeen City is already deemed to be a Hydrogen hub in this regard, and the aim is for the initial public investment in these hubs to facilitate more significant private investment.
Collaboration – the Plan sets out a collaborative approach to developing Scottish Hydrogen for export, particularly with Germany and other Northern European nations.

Relationship Between Hydrogen and Other Renewable Energy Sources

Although the Plan is not explicit on this point, it acknowledges that initial low-carbon Hydrogen infrastructure will pave the way for establishing the transportation and storage infrastructure to support a green Hydrogen economy in Scotland.

The Plan acknowledges that a strong renewables sector is essential to the development of Hydrogen projects.计划指出岸风部门支持小型和大型可再生水力项目的重要性,但承认该部门需要进一步投资。

离岸风部门更先进Successful bidders in the July 2021 leasing round will be announced in early 2022, and August 2021's leasing round had the specific objective of constructing offshore wind farms to decarbonise oil and gas infrastructure operations, support oil and gas-field decommissioning, and use excess generation to create Hydrogen.

Key Goals

The Plan set out six key goals:

Drive Scotland's Hydrogen production capability to meet an ambition of 5 GW of renewable and low-carbon Hydrogen by 2030 and 25 GW by 2045.
Address current barriers to the uptake of green and low-carbon Hydrogen, including high production costs.
Support the growth of Regional Hydrogen Energy Hubs.
Encourage demand for Hydrogen by supporting Hydrogen use and developing supply chain capability and export potential.
Secure broad economic benefit from public sector and private sector support for development of regional Hydrogen production and use.
Encourage the development of a strong Hydrogen sector in Scotland which supports a just transition to net zero.

II. ACTION PLAN

The Plan sets out six key challenges to be overcome during the next five years.

Scaling Up Hydrogen Production in Scotland

To unlock Scotland's potential to meet its ambitious targets for Hydrogen production, barriers such as regulation, planning laws or infrastructure constraints will need to be addressed.The Plan therefore commits the Scottish Government to a review of existing legislation, regulation and standards, to identify and remove potential barriers to the growth of the Hydrogen industry.

In order to improve understanding of the likely role to be played by Hydrogen in the domestic and global markets, the Scottish Government aims to establish the expected cost-trajectory for renewable Hydrogen up to 2045.

The Scottish Government will work with its counterpart in Whitehall to establish a UK Hydrogen Standard, and until this is established, the Scottish Government will only grant funding to Hydrogen projects with capture rates of at least 90%.将不向COsub>2 排放不减量的新Hydgen网站提供资金。

促进开发国内市场

促进国内Hydrogen市场增长、规模经济和技术进步是关键交通产业被视为可能高氢需求行业。

Scottland政府会邀请能源密集制造厂商申请苏格兰工业能源变换基金赠款支持深度去碳化项目新的工业开发无阻碳排放将不符合苏格兰政府供资计划的资格。In the transport sector, the Scottish Government will establish a consortium for implementation of the Plan.

In the heating sector, the Scottish Government will support SGN (formerly known as Scotia Gas Networks), in converting elements of its network to Hydrogen, but only where doing so is consistent with keeping options open and limiting consumer costs.

Finally, the Scottish Government notes the urgency of amendments to existing UK-wide regulations to support the role of Hydrogen in the gas grid, to support Hydrogen blending and to maximize the volumes of renewable Hydrogen available in the energy system as quickly as possible.

Maximising the Benefits of Integrating Hydrogen into the Scottish Energy System

The Plan notes that converting renewable energy into Hydrogen provides new routes to market and may well change the investment proposition for new and existing renewables investors.

The Scottish Government believes that a key way to maximize the benefits of Hydrogen integration is to work with the UK government, Ofgem and the energy network sector to ensure that regulation rewards Hydrogen projects appropriately.关键行动点是建立氢流交通配送基础支持苏格兰氢流输出目标。

授权苏格兰供应链和工作队伍增长和过渡

计划强调技能投资,包括提高工人技能并重新培训工人进入Hypgen部门。Hypgen工商开发服务将旨在促进产业和学术研究之间的协作。

Establishing并加强国际伙伴关系和市场

企业机构将特别支持Scot2Ger项目,目的是到2024年向德国消费者提供苏格兰生产的可再生氢计划指出必须确保苏格兰氢流国际输出不存在法律或监管障碍,苏格兰氢流行业国际内向投资也不存在障碍。

Scottish Development国际外联方案将与280家被确定为苏格兰氢流行业外国直接投资潜在目标的国际公司积极接触将寻求与德国、比利时、荷兰、丹麦、加拿大、澳大利亚、日本和法国的关键协作。

加强创新和研究一个新的苏格兰氢创新网络将促进苏格兰氢创新资产间增强协作并避免研究重复苏格兰政府支持苏格兰通过清洁氢欧洲合作伙伴关系申请欧盟资助,并启动150k英磅研究电话支持苏格兰和德国学术应用研究所之间的合作

英国净零策略

托马斯·赖利 — Frii,2021年10月22日12:55:52+00

j/pspanid='More-7639's/span/p>NZS聚焦8个关键领域并按领域划分优先级和政策:

1>PowerSection

The focus is on domestically-generated renewable electricity to create a power system based on a mix of renewables, new nuclear power stations, flexible storage, gas with CCS and hydrogen.