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The credibility of the FQD depends on the quality and reliability of its data on GHG emissions. Not all countries provide the same quality of data and transparency, and some provide no information at all. Some of the crude oils produced by these countries have similar or higher GHG intensity than oil sands crude, but they do not report it. The Commission’s proposal rewards them for their lack of reporting by having their crude oil categorized in the lowest GHG category. As drafted, therefore, the Commission’s proposed measure penalises countries such as Canada that require transparent, independently verifiable data. Furthermore, it discourages less forthcoming countries from providing better data or becoming more transparent, and gives them an incentive to never report actual GHGs.
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