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THE SHELL LEAKS FILES — 18 OCTOBER 2026 SLF-2007-091 The Sakhalin Papers LXXXI: The Pipeline That Refuses to Die — Shell’s Gazprom Partnership, a Former Stasi Officer and the American Plans to Revive Nord Stream

Nine years after Shell helped finance Nord Stream 2, and four years after explosions crippled the Baltic pipelines, an extraordinary new chapter is unfolding. On 8 October 2026, Reuters reported discussions involving senior American and Russian figures about bringing US investors into the Nord Stream infrastructure. The reported participants included Jared Kushner, President Donald Trump’s son-in-law, and Kirill Dmitriev, a close adviser to Vladimir Putin. Germany immediately reiterated its opposition. Then, on 17 October, Russian Deputy Prime Minister Alexander Novak declared that restoring gas supplies through Nord Stream remained technically possible. Behind these developments lies a remarkable documentary trail: Shell’s original 2017 financing agreement, former East German intelligence officer Matthias Warnig’s leadership of Nord Stream 2, American sanctions, a $1.126 billion Shell write-down, Swiss restructuring proceedings and an increasingly complicated battle with European regulators.

Archive reference: SLF-2007-091
Publication date: 18 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: The Shell Leaks Files — 17 October 2026

Principal evidence: Shell’s authenticated 2017 corporate announcement; Gazprom’s contemporaneous financing announcement; Shell’s 2022 financial disclosures; US Treasury sanctions records; Financial Times and Reuters investigations; German government statements; European Commission sanctions records; and proceedings before the European Union courts.

Evidence classification: Authenticated corporate records and government decisions; attributable statements from identified officials; independently reported but unconfirmed commercial proposals; separately identified editorial commentary.

Introduction: A supposedly dead pipeline returns to the negotiating table

The previous instalment examined the financial aftermath of Nord Stream 2.

Shell had committed substantial financing to the Russian-controlled project.

Following Russia’s invasion of Ukraine, the company recognised a $1.126 billion impairment.

Nord Stream 2 never entered commercial service.

One of its two pipeline strings was damaged in the September 2022 explosions.

The operating company entered financial restructuring proceedings in Switzerland.

European sanctions created additional obstacles.

The conventional conclusion might have been that the project was finished.

Yet the evidence reveals something rather different.

Despite extraordinary financial losses, physical damage and political opposition, influential individuals continued exploring ways to revive the infrastructure.

In March 2025, the Financial Times reported a proposal involving former Nord Stream 2 chief executive Matthias Warnig and prospective American investors.

Warnig denied participating in the alleged discussions.

In October 2026, Reuters reported further discussions about potential American investment, this time involving figures associated with the highest levels of the US and Russian administrations.

The reports do not establish that an acquisition has been agreed or that the pipelines will reopen.

But they demonstrate that the possibility of commercial revival has not disappeared from international discussions.

The significance for Shell’s historical archive is that the company participated directly in the financing arrangements that made Nord Stream 2 possible.

And the original documents identify a particularly interesting individual at the centre of those arrangements.

His name was Matthias Warnig.

1. The authenticated document: Shell and Gazprom sign the financing agreement

On 24 April 2017, Shell and four other European energy companies signed financing agreements with Nord Stream 2 AG.

The other companies were Engie, OMV, Uniper and Wintershall.

The project was controlled by Gazprom.

Its estimated construction cost was €9.5 billion.

The five Western companies collectively agreed to provide financing and guarantees covering up to half that amount.

Each company’s commitment was limited to approximately €950 million.

Shell’s announcement explained that the arrangement included a €285 million long-term funding facility, with up to another €665 million available through additional financing and guarantees.

Gazprom remained the sole shareholder of Nord Stream 2 AG.

This was not a speculative press report.

It was an authenticated corporate transaction announced publicly by Shell, Gazprom and the participating European companies.

The agreement was presented as strengthening European energy security.

Its supporters believed the infrastructure would provide an important additional source of natural gas as European production declined.

Opponents argued that it would increase Europe’s dependence upon Russia and reduce Ukraine’s importance as a transit country.

Those competing positions were already well established in 2017.

Documentary sources: Shell — 2017 Corporate Press Releases, including 24 April Nord Stream 2 Agreement; Gazprom — Nord Stream 2 Financing Agreements, 24 April 2017. Uniper

The original photograph identifies the principal participants

Gazprom’s archived announcement contains photographs of the signing ceremony.

Its official captions identify senior executives from the participating companies.

Among them were Maarten Wetselaar, then a member of Shell’s Executive Committee; Alexey Miller, chairman of Gazprom’s Management Committee; and Matthias Warnig, chief executive of Nord Stream 2 AG.

The photographs provide contemporaneous confirmation that these individuals participated in the same corporate event.

They do not, by themselves, establish anything about private conversations or subsequent conduct.

But they offer a useful historical reference point.

Here was Shell, represented at a senior level, formally participating in a major Russian-controlled infrastructure project.

And Warnig was already occupying a central executive position.

Archival photograph: Nord Stream 2 financing agreement ceremony, Paris, 24 April 2017. Source: OMV’s contemporaneous corporate announcement. omv.com

2. Matthias Warnig: From East German intelligence to Russian energy

Matthias Warnig’s career is unusual even by the standards of international energy politics.

A German businessman and former officer of East Germany’s Ministry for State Security, commonly known as the Stasi, Warnig subsequently developed a substantial career in banking and Russian business.

He worked for Dresdner Bank in Russia following German reunification.

He became associated with major Russian financial and energy interests.

His relationship with Vladimir Putin has been documented extensively in international reporting.

Warnig has described meeting Putin in St Petersburg during the 1990s.

Other accounts have examined their possible connections during the final years of East Germany, when Putin served as a Soviet intelligence officer.

Those competing historical accounts should not be treated as interchangeable.

The relevant established fact is that Warnig developed a longstanding professional and personal association with Putin.

Warnig eventually became one of the most prominent executives involved in the Nord Stream projects.

He headed Nord Stream 2 AG until 2023.

His earlier Stasi service is relevant biographical history.

It does not establish that his later commercial activities involved intelligence operations or misconduct.

That distinction is important.

Nevertheless, his career illustrates the intersection of former Cold War intelligence networks, post-Soviet business relationships and European energy development.

Contemporaneous reporting: Deutsche Welle — Matthias Warnig and the Proposed Nord Stream 2 Revival, 2 March 2025. n-tv.de

3. Washington’s complicated relationship with Nord Stream 2

American opposition to Nord Stream 2 long preceded the September 2022 explosions.

Successive US administrations criticised the project.

Their concerns included European dependence on Russian gas, the strategic position of Ukraine and the geopolitical consequences of additional Russian-controlled energy infrastructure.

The issue also became connected with American legislation providing for sanctions against companies involved in the pipeline’s construction.

On 19 May 2021, the Biden administration announced sanctions-related measures concerning Nord Stream 2.

However, it also granted a waiver covering Nord Stream 2 AG, Matthias Warnig and certain company officers.

Secretary of State Antony Blinken explained that the waiver was considered consistent with American national interests at that time.

The administration continued to oppose Nord Stream 2 politically.

The waiver did not represent American endorsement of the project.

It was a decision concerning the application of sanctions.

Primary US government source: US Department of State — Nord Stream 2 and European Energy Security, 19 May 2021.

February 2022: The waiver ends

The situation changed dramatically following Russia’s escalation against Ukraine.

On 22 February 2022, Germany suspended the certification process for Nord Stream 2.

The following day, the United States imposed sanctions on Nord Stream 2 AG and Matthias Warnig.

The US Treasury’s Office of Foreign Assets Control added both to its Specially Designated Nationals list.

The restrictions affected dealings involving American persons and US jurisdiction.

The Treasury also issued a narrowly defined authorisation for winding down certain transactions.

That was not permission to operate or revive the pipeline.

The documentary record therefore establishes a significant reversal.

In May 2021, Washington waived specified sanctions against the company and its chief executive.

By February 2022, both were sanctioned.

Any future American investment proposal would have to confront that legal history.

Primary sanctions record: US Treasury — Nord Stream 2 AG and Matthias Warnig Designations, 23 February 2022.

4. Shell’s financial exposure becomes a documented loss

Shell’s position changed in the first quarter of 2022.

Following the invasion of Ukraine, the company announced its intention to withdraw from Russian ventures involving Gazprom and related businesses.

That included ending its involvement in Nord Stream 2.

Shell’s third-quarter 2022 financial announcement subsequently confirmed that the company had fully written down its Nord Stream 2 loan.

The carrying amount was $1.126 billion.

The write-down occurred in the first quarter.

That timing matters.

When explosions damaged the Nord Stream infrastructure on 26 September 2022, Shell had already recognised the impairment.

The company subsequently reported that the rupture of one Nord Stream 2 string caused no additional third-quarter financial impact on that loan.

The original accounting loss was therefore connected to Shell’s reassessment of its Russian investment, not the later physical destruction.

Shell’s authenticated financial disclosure provides the controlling evidence.

Primary Shell document: Shell plc — Third Quarter 2022 Unaudited Results, Note 8: Withdrawal from Russian Oil and Gas Activities.

An essential distinction

Shell’s financial involvement in Nord Stream 2 was through financing.

Gazprom remained the sole shareholder of Nord Stream 2 AG.

Consequently, it would be inaccurate to describe Shell as having owned 10 per cent of the operating company.

It would also be inaccurate to suggest that Shell retained an ownership stake that it could subsequently sell to American investors.

The company’s possible contractual rights as a creditor are a separate question.

As established in the previous instalment, Nord Stream 2 AG subsequently reached a restructuring agreement with creditors in Switzerland.

The precise amount, if any, eventually recovered by Shell has not been established from the documents examined.

Nor is there evidence in the material reviewed that Shell participated in the later American investment proposals.

That limitation must remain explicit.

5. November 2024: An American investor explores buying Nord Stream 2

The first important indication of American commercial interest appeared in November 2024.

The Wall Street Journal reported that American investor Stephen P. Lynch was seeking permission from the US government to bid for Nord Stream 2.

Lynch was described as an investor with extensive experience acquiring Russian-related assets.

According to the report, he had sought authorisation from the US Treasury to negotiate with sanctioned entities.

His interest arose partly from the financial difficulties facing Nord Stream 2 AG.

If the Swiss restructuring failed, the company’s assets might become available through insolvency proceedings.

Lynch reportedly believed that an acquisition could provide American investors with influence over future European gas supplies.

The proposal was therefore presented as having both commercial and strategic potential.

But there were significant uncertainties.

An auction had not necessarily been scheduled.

The required American permissions had not been established as granted.

Gazprom’s position remained central.

And Germany had not authorised operation of the pipeline.

The report established that an identifiable American investor was pursuing an opportunity.

It did not establish that an acquisition had occurred.

Contemporaneous reporting: Wall Street Journal — A Miami Financier Is Quietly Trying to Buy Nord Stream 2 Gas Pipeline, November 2024; Meduza — Summary of Stephen Lynch’s Proposed Bid, 22 November 2024.

6. March 2025: The Financial Times reports a Warnig initiative

On 2 March 2025, the Financial Times published a report that introduced another possibility.

The newspaper stated that Matthias Warnig was associated with efforts to restart Nord Stream 2 with backing from American investors.

The report relied upon individuals described as familiar with the discussions.

According to those sources, American businessmen could provide a channel to members of Donald Trump’s administration.

The proposed arrangement was reportedly being considered in the context of possible negotiations concerning the war in Ukraine and future US-Russian economic relations.

The report suggested that an American-led consortium had explored the outline of an arrangement involving Gazprom.

Such a transaction might have allowed American investors to acquire a financial interest in infrastructure originally built to transport Russian gas to Germany.

The implications were substantial.

A pipeline previously opposed by Washington might become an investment opportunity for American interests.

But the published account did not establish a completed agreement.

And there was a significant contradiction.

Warnig denied participating in the alleged discussions.

He told the Financial Times that he was not involved in discussions with American political or business representatives.

He also referred to his obligation to comply with American sanctions.

His denial was reported by German and international news organisations.

It must be included alongside the allegations.

The documentary position is therefore clear: the Financial Times reported a proposed initiative based upon confidential sources; Warnig denied the involvement attributed to him.

Neither account should be misrepresented as an uncontested finding.

Principal reporting: Financial Times — Putin Ally Pushes Deal to Restart Nord Stream 2 with US Backing, 2 March 2025; N-TV — Warnig Denies Involvement in Reported Pipeline Revival Discussions, 2 March 2025. ANSA.it

7. June 2025: Moscow says no purchase approach has been made

The Russian government’s public response introduced another complication.

On 19 June 2025, Reuters reported comments by Russian Deputy Prime Minister Alexander Novak.

Novak stated that no one had approached the Russian government about purchasing Nord Stream 2.

His remarks followed the earlier reporting about Stephen Lynch’s proposed acquisition.

They did not establish that no informal discussions existed anywhere.

But they contradicted any suggestion that the Russian government had already acknowledged a formal purchase approach.

Again, the distinction matters.

Expressions of commercial interest are not binding agreements.

Exploratory discussions are not completed negotiations.

And reporting about an investor’s intentions is not proof that Gazprom has agreed to transfer assets.

Contemporaneous source: Reuters — Russia’s Novak Says No One Has Approached Government About Buying Nord Stream 2, 19 June 2025.

8. July 2025: The European Union creates another formidable barrier

While the commercial proposals attracted attention, European regulators were moving in the opposite direction.

On 18 July 2025, the Council of the European Union adopted its eighteenth package of sanctions against Russia.

The package included a specific transaction prohibition concerning Nord Stream 1 and Nord Stream 2.

The European Commission explained that the measure was intended to prevent transactions connected with the pipelines.

The restrictions covered their completion, operation, maintenance and use.

They also addressed associated financing.

The legal framework included narrowly defined exceptions and possibilities for authorisation, including certain restructuring, compensation, legal and safety-related matters.

Those provisions should not be mistaken for permission to restart commercial gas deliveries.

The effect was significant.

Even if American investors could reach an arrangement with Gazprom, European sanctions would remain an independent obstacle.

American ownership would not automatically remove the restrictions applicable within the European Union.

Primary regulatory documents: Council of the European Union — Eighteenth Sanctions Package, 18 July 2025; European Commission — Nord Stream Transaction Ban Explained.

9. January 2026: Europe legislates to end Russian gas imports

The regulatory barriers became more substantial in January 2026.

On 26 January, the European Union formally adopted Regulation (EU) 2026/261.

The legislation established a phased prohibition on imports of Russian natural gas.

It applied to both liquefied natural gas and pipeline supplies.

The rules included transitional arrangements for qualifying existing contracts.

The general prohibition began applying on 18 March 2026, subject to those arrangements.

The final phase-out of long-term Russian pipeline gas imports was scheduled for autumn 2027.

This legislation did not concern Nord Stream alone.

It formed part of a wider European policy intended to reduce dependence upon Russian energy.

Nevertheless, its implications for Nord Stream were obvious.

The surviving Nord Stream 2 string might remain physically capable of transporting gas.

But physical capability would not overcome the applicable import restrictions.

Nor would it resolve the absence of German operational certification.

Official sources: Council of the European Union — Final Approval of Phased Russian Gas Import Ban, 26 January 2026; Regulation (EU) 2026/261 — Official Legal Record.

10. April 2026: Nord Stream 2 challenges European legislation

The operator did not accept the new legal environment without challenge.

On 27 April 2026, Nord Stream 2 AG brought proceedings before the General Court of the European Union.

The case was registered as T-264/26 — Nord Stream 2 v Parliament and Council.

The company seeks annulment of Regulation (EU) 2026/261 or, alternatively, specific provisions.

Its legal arguments include challenges concerning the regulation’s legal basis and allegations involving proportionality and property rights.

Those are the company’s arguments.

They are not established findings by the court.

The official record confirms that proceedings were commenced.

It does not establish that Nord Stream 2 has succeeded.

This is another important example of the continuing legal life of the project.

The operating company is challenging the rules governing the very activity for which the pipeline was constructed.

Official judicial record: European Union General Court — Case T-264/26, Nord Stream 2 v Parliament and Council.

11. 8 October 2026: Reuters reports a new American-Russian initiative

The most significant recent development came on 8 October 2026.

Reuters published an investigation by John O’Donnell, Gram Slattery and David Gauthier-Villars.

The agency reported that senior American and Russian figures had discussed bringing an American investor into the Nord Stream pipelines.

Its account cited five individuals familiar with the situation.

The reported participants included Jared Kushner and Kirill Dmitriev.

Kushner is President Trump’s son-in-law and has been involved in American diplomatic efforts relating to Russia and Ukraine.

Dmitriev is a senior Russian investment official and adviser associated with President Putin.

The sources told Reuters that the possibility of American participation in Nord Stream remained under consideration.

The report described discussions involving the possible restoration of US-Russian economic relationships.

A commercial arrangement might allow American investors to benefit financially from future Russian gas exports to Europe.

But the report also contained qualifications.

It was unclear how extensively Nord Stream had been discussed during particular meetings between Kushner and Dmitriev.

The proposed commercial structure was not publicly established.

And a White House official disputed the suggestion of recent pipeline discussions.

According to Reuters, the official said there had been “no Nord Stream discussions recently.”

The same official indicated that any relevant agreements would have to involve appropriate American government authorities and benefit US interests.

That was not confirmation of an agreed transaction.

The White House response must be considered alongside the anonymous-source reporting.

Principal contemporary investigation: Reuters — US and Russia Explore Gas Sale to Europe Amid Ukraine War, 8 October 2026; English-language republication by The Moscow Times. onvista

An important distinction between the pipeline companies

The Reuters report discussed potential American involvement in the Nord Stream infrastructure more broadly.

That wording is significant.

Nord Stream 1 and Nord Stream 2 are separate corporate projects.

Nord Stream AG, the operator of Nord Stream 1, has a Gazprom majority shareholder and minority European shareholders.

Nord Stream 2 AG is wholly owned by Gazprom.

Consequently, a proposed American investment in one company would not necessarily involve acquiring an interest in the other.

Nor would it automatically resolve existing creditor claims.

The precise commercial structure contemplated in the reported discussions remains unresolved.

It would be premature to describe the proposals as an agreed American purchase of Nord Stream 2.

12. Germany’s response: The government is not seeking a restart

The German government’s reaction to the October report was unequivocal.

Reuters obtained comments from a spokeswoman for Germany’s Ministry for Economic Affairs and Energy.

She emphasised that the Nord Stream pipelines were subject to European sanctions.

Germany supported those restrictions.

The government also reiterated that reducing dependence upon Russian gas remained an important objective.

The spokeswoman explained that any operational restart would require certification from Germany’s Federal Network Agency.

Additional governmental and European regulatory processes would also be necessary.

She stated that no such process was being pursued.

That position is especially important because Nord Stream’s intended European destination is Germany.

An agreement between investors in Washington and commercial interests in Moscow would not, by itself, authorise operation of the infrastructure.

Germany’s legal and regulatory responsibilities cannot simply be bypassed through a change in ownership.

Reuters also reported opposition from other European countries, including Poland.

German political opinion was divided.

Some advocates of renewed Russian energy imports argued that commercial relations might eventually be restored.

Others warned that reopening Nord Stream could recreate the strategic vulnerabilities exposed by Russia’s invasion of Ukraine.

These competing positions remain politically important.

But the government’s official stance is a separate matter.

As of 8 October 2026, Berlin was not pursuing Nord Stream’s operational certification or revival. onvista

13. 17 October 2026: Russia says restoration remains technically possible

A further development occurred yesterday.

On 17 October 2026, the Russian business newspaper Vedomosti reported remarks by Deputy Prime Minister Alexander Novak.

Speaking in an interview broadcast by Solovyov Live, Novak said that restoring gas supplies through Nord Stream remained technically possible.

He acknowledged that three of the four pipeline strings were not operational following the September 2022 explosions.

One string survived.

According to Novak, that remaining pipeline could potentially carry gas if the necessary decisions were taken.

He also expressed the view that damaged sections could be repaired.

His comments placed responsibility for future decisions partly upon European customers and governments.

These are attributed statements by a Russian government official.

They should not be treated as an independent engineering certification.

Novak did not establish that repairs had been authorised.

He did not announce a completed American investment agreement.

Nor did his remarks remove the sanctions or regulatory obstacles identified by Germany and the European Union.

Nevertheless, the timing is notable.

Reuters had reported the American-Russian discussions on 8 October.

Nine days later, a senior Russian government official publicly reiterated the possibility of restoring deliveries through the pipeline system.

The statements are consistent with Moscow maintaining an interest in the infrastructure’s commercial future.

They do not prove that a coordinated agreement exists.

Contemporaneous Russian reporting: Vedomosti — Alexander Novak Says Nord Stream Gas Deliveries Remain Technically Possible, 17 October 2026.

14. The surviving pipeline: What would actually be required?

Nord Stream consists of four pipeline strings across the two projects.

Three were damaged in September 2022.

One Nord Stream 2 string was not ruptured.

Its original designed annual capacity was approximately 27.5 billion cubic metres of natural gas.

This creates an unusual situation.

A substantial piece of infrastructure remains beneath the Baltic Sea.

But that does not mean it is commercially available.

A revival would face several distinct obstacles.

Physical and engineering requirements: The condition of the surviving pipeline would need to be assessed and verified before operations could be authorised.

Corporate arrangements: Gazprom’s ownership position, relevant financing arrangements and any proposed investment transaction would need to be addressed.

American sanctions: Transactions involving sanctioned persons or entities could require authorisation or changes to the applicable restrictions.

European sanctions: The specific restrictions concerning Nord Stream would remain applicable unless changed or relevant authorisations were lawfully granted.

European import legislation: Regulation (EU) 2026/261 establishes restrictions on the importation of Russian natural gas.

German certification: The infrastructure would require the relevant German regulatory approvals.

Commercial arrangements: Buyers, suppliers, transportation agreements, pricing arrangements and other contractual conditions would be required.

None of these obstacles can be eliminated merely by announcing that the pipeline is physically repairable.

That is why the distinction between technical feasibility and legal commercial viability is so important.

15. Where does Shell fit into the latest developments?

Shell’s involvement belongs primarily to the earlier financing history.

The company’s role in 2017 is documented.

Its relationship with Nord Stream 2 AG was established through formal financing agreements.

Its 2022 loan impairment is documented.

Its announcement of withdrawal from Russian ventures is documented.

However, the reporting examined for this instalment does not identify Shell as a participant in the October 2026 American-Russian discussions.

Nor does it establish that Shell has agreed to finance a revival.

The presence of former Shell executives at the 2017 signing ceremony should not be confused with evidence of current involvement.

The potential rights of creditors under Nord Stream 2 AG’s restructuring arrangements must also be distinguished from ownership of the project.

In particular, the financial consequences of a possible future change in ownership cannot be determined without examining the underlying contracts.

It remains unclear whether such a transaction could produce any financial recovery relevant to Shell.

That is a legitimate question for further documentary research.

It is not an established outcome.

The archive should therefore describe Shell as an original financier of Nord Stream 2 whose disclosed loan was fully written down in 2022, rather than as a participant in the later revival proposals.

COMMENTARY: Who Would Control Europe’s Russian Gas Supply?

The reported American interest raises a question extending beyond the financial position of Nord Stream 2 AG.

What would a revived pipeline represent strategically?

The original project was developed under Gazprom’s control.

Its commercial purpose was to transport substantial quantities of Russian gas to Germany.

Western European energy companies supported its construction through financing.

The arrangement promised additional supply capacity.

But it also raised longstanding concerns concerning strategic dependence upon Russia.

Those concerns became acute following Russia’s invasion of Ukraine.

The American investment proposals introduce a different possibility.

Could an ownership or financial arrangement involving US investors provide Washington with influence over Russian gas exports to Europe?

That possibility has been raised in contemporary reporting.

Its potential advantages and disadvantages depend upon the structure of any agreement.

Supporters might argue that American participation could introduce additional oversight or commercial leverage.

Opponents might contend that changing the nationality of investors would not alter the Russian origin of the gas or remove the underlying dependency.

Other concerns could involve the distribution of revenues, European energy security and the position of Ukraine.

But all such assessments remain conditional upon a transaction that has not been established as completed.

It would be misleading to treat a speculative commercial structure as an existing geopolitical arrangement.

The danger of confusing investors with governments

There is another distinction worth preserving.

American investors are not automatically acting on behalf of the US government.

A private proposal does not necessarily represent official American policy.

Conversely, discussions involving government officials do not establish that a commercial acquisition has received final approval.

The 2024 report concerning Stephen Lynch related to an identifiable private investor.

The March 2025 Financial Times report described a possible initiative associated with Warnig, who denied the discussions attributed to him.

The October 2026 Reuters report concerned discussions reportedly involving senior American and Russian figures.

These are related developments.

They are not proof of a single continuous, coordinated operation.

Nor has the available evidence established that all the named individuals participated in one agreed plan.

A documentary history must resist the temptation to connect every reported contact into a single narrative of secret coordination.

The evidence must support the connections.

16. The remarkable 2017 photograph and the Sakhalin connection

For the Shell archive, the most revealing historical contrast may be between the photograph from April 2017 and the circumstances of October 2026.

In 2017, senior executives from Shell, Gazprom and other European energy companies publicly celebrated an agreement intended to finance a major gas pipeline.

The project was presented as commercially beneficial.

Its supporters emphasised European energy security.

The executives represented companies with substantial interests in international energy markets.

The relationships appeared sufficiently stable to justify billions of euros in commitments.

Nine years later, the landscape had changed dramatically.

Shell had withdrawn from the project.

Its loan had been fully written down.

The operating company had undergone creditor restructuring.

The pipelines had been sabotaged.

American and European sanctions restricted commercial activity.

And Germany had rejected the prospect of restarting Russian gas deliveries.

Yet individuals and organisations continued examining whether the surviving infrastructure might possess future commercial value.

The contrast is considerable.

It also brings us back to Sakhalin.

Shell’s earlier Sakhalin-2 experience demonstrated how political intervention could alter control over a major Russian energy development.

The Nord Stream experience illustrates a different but related problem.

A project supported by Western capital can become commercially unusable following changes in international political relationships.

Both cases involve Gazprom.

Both involve major Western energy interests.

Both raise questions about the long-term risks associated with international investments dependent upon government decisions.

But they must not be presented as identical.

In Sakhalin-2, Shell held an equity interest in a producing energy project.

In Nord Stream 2, Shell provided financing to a Gazprom-owned company.

The corporate rights, financial consequences and historical circumstances were different.

The common thread is the exposure of major international energy investments to political decisions that can fundamentally alter their economic value.

17. The evidence: What is established and what remains unresolved?

The documentary record supports a clear distinction between established events and contested reporting.

Established facts

Shell signed a financing agreement with Nord Stream 2 AG on 24 April 2017.

Gazprom remained the company’s sole shareholder.

Matthias Warnig was chief executive of Nord Stream 2 AG at the time.

The United States imposed sanctions on Nord Stream 2 AG and Warnig in February 2022.

Shell subsequently recognised a $1.126 billion impairment of its Nord Stream 2 loan.

The European Union adopted a specific Nord Stream transaction prohibition in July 2025.

Further EU legislation restricting Russian natural gas imports was adopted in January 2026.

Nord Stream 2 AG commenced proceedings challenging that legislation in April 2026.

Germany stated on 8 October 2026 that it was not pursuing operational certification or revival of Nord Stream.

Attributable statements and reporting

The Wall Street Journal reported Stephen Lynch’s interest in acquiring Nord Stream 2 in November 2024.

The Financial Times reported an initiative associated with Matthias Warnig in March 2025.

Warnig denied participating in the discussions attributed to him.

Reuters reported potential American investment discussions involving senior American and Russian figures on 8 October 2026.

A White House official said there had been no recent Nord Stream discussions.

Russian Deputy Prime Minister Alexander Novak stated on 17 October 2026 that restoring gas deliveries remained technically possible.

Matters not established

No completed American acquisition of Nord Stream has been verified.

No binding agreement between Gazprom and a US investor has been established.

No decision by Germany to restart the pipelines has been announced.

No general removal of the relevant European restrictions has been established.

No evidence examined for this instalment shows Shell participating in the reported revival negotiations.

The precise financial consequences for Shell of any future transaction remain unresolved.

These distinctions are not incidental.

They determine what can responsibly be said about the historical record.

Conclusion: The Pipeline That Refuses to Disappear

The Nord Stream story has become an extraordinary example of the persistence of major international energy interests.

The original infrastructure represented billions of euros in investment.

Shell and other European companies helped finance it.

The project was intended to operate for decades.

Russia’s invasion of Ukraine destroyed the political assumptions upon which much of that investment depended.

Shell recognised a substantial financial loss.

Sanctions followed.

Then came the explosions.

Yet the commercial interest did not disappear.

American investors reportedly explored acquisition opportunities.

The Financial Times reported a possible initiative involving Matthias Warnig, although he denied participating in the alleged discussions.

Reuters subsequently reported discussions involving senior American and Russian figures about potential US investment.

Germany reiterated its opposition.

And yesterday, Russia’s deputy prime minister publicly argued that the infrastructure could still be used or repaired.

The contrast is striking.

What was once promoted as a major achievement of European-Russian energy cooperation has become a contested asset at the intersection of international finance, sanctions law and diplomacy.

For Shell shareholders, the original financial consequences are documented.

For historians, the 2017 financing agreement and accompanying photographs provide an authenticated starting point.

For regulators, the challenge remains the interaction between private investment proposals and existing legal restrictions.

And for the independent Shell archive, the essential task is to preserve the evidence without overstating what it proves.

A pipeline may survive physically long after its original commercial purpose has collapsed.

But whether it can ever return to operation is a separate question.

For the moment, the evidence establishes interest, reported discussions and substantial obstacles.

It does not establish a completed revival.

Nine years after Shell signed the financing agreement, Nord Stream 2 remains unfinished business — legally, financially and politically.

PRINCIPAL DOCUMENTARY SOURCES

1. Shell — 24 April 2017

Shell’s Archived Nord Stream 2 Financing Announcement

Authenticated company document establishing the financing arrangement, original commitments and Gazprom’s ownership.

2. Gazprom — 24 April 2017

Nord Stream 2 AG and European Energy Companies Sign Financing Agreements

Contemporaneous corporate record identifying Shell, Matthias Warnig, Alexey Miller and the other participants in the signing ceremony.

3. Shell plc — 27 October 2022

Third Quarter 2022 Unaudited Results

Primary financial evidence establishing Shell’s $1.126 billion loan impairment and its withdrawal from Nord Stream 2.

4. US Department of the Treasury — 23 February 2022

Sanctions Designations Concerning Nord Stream 2 AG and Matthias Warnig

Official government record of the sanctions imposed following the termination of earlier waivers.

5. Wall Street Journal — November 2024

A Miami Financier Is Quietly Trying to Buy Nord Stream 2 Gas Pipeline

Contemporaneous investigation concerning Stephen Lynch’s proposed acquisition.

6. Financial Times — 2 March 2025

Putin Ally Pushes Deal to Restart Nord Stream 2 with US Backing

Original reporting concerning the alleged Warnig initiative.

7. N-TV — 2 March 2025

Warnig Denies Involvement in Reported Revival Discussions

German reporting recording Warnig’s denial.

8. European Commission — 18 July 2025

Eighteenth Sanctions Package, Including Nord Stream Transaction Restrictions

Official regulatory explanation of the restrictions applicable to Nord Stream.

9. Council of the European Union — 26 January 2026

Final Approval of the Phased Prohibition on Russian Gas Imports

Official record of the European Union’s Russian gas import phase-out legislation.

10. General Court of the European Union — April 2026

Case T-264/26: Nord Stream 2 AG v European Parliament and Council

Authenticated judicial record confirming the operator’s challenge to Regulation (EU) 2026/261.

11. Reuters — 8 October 2026

US and Russia Explore Gas Sale to Europe Amid Ukraine War, Say Sources

The principal contemporary investigation concerning reported American-Russian discussions, together with the relevant White House and German government responses.

12. Vedomosti — 17 October 2026

Russian Deputy Prime Minister Alexander Novak on the Possibility of Restoring Nord Stream Deliveries

Contemporaneous Russian reporting of the latest statements concerning the physical infrastructure.

DOCUMENTARY EVIDENCE AND LEGAL DISCLAIMER

This instalment draws upon authenticated corporate announcements, official regulatory documents, financial disclosures, judicial records and identified contemporaneous journalism.

The 2017 financing agreement, Shell’s 2022 impairment and the cited sanctions and legislative measures are established documentary facts.

Accounts of prospective American investment are attributed to the publications and sources that reported them.

Matthias Warnig’s denial is expressly acknowledged.

Statements attributed to government officials are distinguished from independently verified conclusions.

No allegation is made that Shell participated in undisclosed negotiations to revive Nord Stream.

No allegation is made that any person mentioned in this article engaged in unlawful conduct in connection with the reported investment proposals.

No completed American acquisition or operational restart has been established.

The discussion of political and commercial implications is editorial analysis, not a finding of misconduct.

The website’s general disclaimer also applies.

NEXT IN THE SHELL LEAKS FILES SLF-2007-092 — The Sakhalin Papers LXXXII: Gazprom’s Pipeline Takes Europe to Court — The Energy Charter Treaty, Secretive Arbitration and the Battle Over Billions

The next instalment will examine a legal development that may be even more consequential than the reported American investment proposals.

Nord Stream 2 AG has not confined its efforts to commercial negotiations.

It has also pursued legal proceedings against the European Union.

The disputes reach back to 2019.

They concern European gas-market legislation, international investment protections and the legal consequences of restrictions on Nord Stream.

A particularly revealing authenticated document is Procedural Order No. 18, issued on 22 October 2025 in proceedings administered by the Permanent Court of Arbitration.

The order records a disagreement between Nord Stream 2 AG and the European Union over whether sanctions restrictions created unacceptable risks for the arbitration itself.

Nord Stream 2 argued that the restrictions could affect participants in the proceedings.

The European Commission disputed that interpretation.

The arbitral tribunal ultimately suspended the proceedings pending clarification of the relevant risks.

The document reveals a remarkable situation.

A company controlling infrastructure built to transport Russian gas was challenging European legislation, while arguing that other European sanctions could interfere with its ability to pursue the legal case.

The next instalment will reconstruct that dispute from the actual procedural orders, European court records and the original legislative instruments.

It will also examine the earlier General Court judgment concerning the European gas directive and the later actions challenging sanctions and import restrictions.

Primary documentary starting point: Nord Stream 2 AG v European Union — Procedural Order No. 18, 22 October 2025.

The central question will be whether an international energy investment can generate enforceable compensation rights when subsequent political and regulatory developments undermine its commercial purpose.

For Shell shareholders, the wider historical lesson is significant.

The contracts may have been signed years ago. The financial losses may already have been recognised. But the legal consequences can continue for decades.

The Sakhalin Papers continue.

THE SHELL LEAKS FILES — 18 OCTOBER 2026 was first posted on October 18, 2026 at 7:05 pm.
©2018 "Royal Dutch Shell Plc .com". Use of this feed is for personal non-commercial use only. If you are not reading this article in your feed reader, then the site is guilty of copyright infringement. Please contact me at john@shellnews.net

A listing of 28 news and opinion articles we found interesting and shared on social media during the past week: Sun, October 11, 2026 thru Sat, October 17, 2026. Stories we promoted this week, by category:

Climate Science and Research (6 items)

• Fingerprint Evidence for Human Effects on Climate: Advances After the 2009 Endangerment Finding Academic report finds obvious human effects on climate behavior and formally discredits a July 2025 report published by the US Department of Energy, Earth's Future, Benjamin Santer, Susan Solomon, David Thompson, Qiang Fu, Gabriele Hegerl, Sep 12, 2026.
• Fired Government Scientists Are Finding New Ways to Spread the Word on Climate Change Donald Trump’s administration fired scientists working on the next National Climate Assessment. They’re finding new ways to publish their research Rolling Stone, Thor Benson, Oct 12, 2026.
• Thousands of handwritten records reveal scale of warming in the Congo Congo Basin weather records have been poorly represented in climate assessments; to fill this gap scientists have digitized thousands of handwritten weather records, revealing significant warming in the region. Yale Environment 360, Yale Environment 360 staff, Oct 12, 2026.
• Big if True: New Paper Finds Doubling in Planet`s Rate of Warming A new paper suggests that the rate of warming of Earth's climate is higher than previously thought, but the final and best answer may depend on past El Niño effects. This is Not Cool, greenman3610, Oct 12, 2026.
• Skeptical Science New Research for Week #42 2026 Skeptical Science's latest weekly climate research survey. Skeptical Science, Doug Bostrom & Marc Kodack, Oct 15, 2026.
• Climate Overshoot Needs a New Generation of Researchers | Opinion Professor Yohe argues that dealing with the aftermath of climate overshoot will require a deep pool of scientific talent, and assembling that resource should begin now. Newsweek, Gary Yohe, Oct 15, 2026.

Climate Policy and Politics (5 items)

• SEC Issues Warning to Investment Firms That Challenged ExxonMobil The commission issued a rare “report of investigation” into the largest asset managers and state pension funds, part of a broader campaign to curb investor activism on climate risks. Inside Climate News, By Nicholas Kusnetz, Oct 09, 2026.
• Carbon Accounting May Be the Most Important Climate Fight You've Never Heard About Carbon accounting is a vital climate mitigation tool but the details are devilish. TIME, Justin Worland, Oct 09, 2026.
• IPCC is under pressure to delay publication of key global climate report AR7 report was scheduled for 2028 in time for Cop33 summit but some petro-states and major developing countries want to postpone it The Guardian, Fiona Harvey, Oct 13, 2026.
• Trump just effectively killed a popular solar energy program for rural America Solar panels can be an economic lifeline for farmers. Now they're going to be a lot harder to build. Grist, Frida Garza, Oct 16, 2026.
• Under US pressure, World Bank says it will back gas "where appropriate" The US wants the World Bank to expand its gas support while climate campaigners are pushing for it to end – its head spoke this week of limited backing for the fossil fuel Climate Home News, Joe Lo, Oct 16, 2026.

Climate Change Impacts (4 items)

• How climate change worsened Hurricane Isaias Climate Central says climate-warmed Gulf waters made Isaias’s winds 7 mph stronger than than otherwise, resulting in over a doubling of the hurricane’s damages because of exponential rise in damage with winds. Yale Climate Connections, Jeff Masters, Oct 10, 2026.
• Thwaites Glacier could contribute twice as much sea-level rise as previously projected Phys.org, University of California, Irvine, Oct 13, 2026.
• What finance can tell us about the `twin crises` of climate change and biodiversity loss Yale SOM’s Stefano Giglio explains how the two environmental threats can amplify each other—and why understanding those interactions matters for the economy. Yale Insights, Ted O’Callahan, Oct 14, 2026.
• How the quirky puffin became a symbol of the climate crisis - and hope In an extract from his new book, the nature historian explains how technology could help the seabird survive The Guardian, Stephen Moss, Oct 17, 2026.

Climate Education and Communication (3 items)

• Your Climate Shadow You can grow your climate shadow without guilt. Climate Trunk, John Lang, Oct 11, 2026.
• How AI chatbots may be talking people out of climate action Across 28,800 prompts, models were 7.5 times more likely to advise “stay the course” than “change,” even when the status quo is anti-climate. Anthropocene, Sarah DeWeerdt, Oct 13, 2026.
• US voters want more action on global heating. Why are Democrats and Republicans staying silent? Polls show that Democrats and Republicans in battleground states want to hear more from candidates about the climate crisis The Guardian, Oliver Milman, Oct 16, 2026.

Miscellaneous (3 items)

• From Bad to Better Bill McKibben reflects on our new ability to directly confront the climate problem we've created, at its roots. The Crucial Years, Bill McKibben, Oct 09, 2026.
• 2026 SkS Weekly Climate Change & Global Warming News Roundup #41 A listing of 28 news and opinion articles we found interesting and shared on social media during the past week: Sun, October 4, 2026 thru Sat, October 10, 2026. Skeptical Science, Bärbel Winkler & Doug Bostrom, Oct 11, 2026.
• Just what damage can the emissions from a new fossil fuel facility cause? A new tool has estimates From crop failures to coral bleaching, a new tool developed by climate scientists aims to predict in detail the impacts of each megatonne of carbon emissions The Guardian, Nick Evershed, Oct 15, 2026.

Public Misunderstandings about Climate Solutions (2 items)

• Fact brief - Does onshore wind power need subsidies to compete with fossil fuels? Recent inflation, rising interest rates, and trade barriers have increased costs across all energy generation technologies, but onshore wind is still cheaper than fossil fuel plants and does not require subsidization to operate. Skeptical Science, Sue Bin Park, Oct 13, 2026.
• Exxon scientist says the company knew its algae biofuel ads were BS In newly reported deposition testimony, a company scientist calls Exxon’s claims “patently false”—and says he warned them before they went public. Heated, Emily Atkin, Oct 14, 2026.

Climate Law and Justice (1 item)

• How climate and health science is turning international law into action Following a historic ICJ ruling, climate science and international law are converging to turn state duty into binding policy. The Independent, wellcome staff, Oct 13, 2026.

Climate Change Mitigation and Adaptation (1 item)

• Will AI be good or bad for the climate? Here`s what the latest evidence on energy use suggests The Conversation, Francesco Grillo, Oct 12, 2026.

Geoengineering (1 item)

• Why We Should(n't) Geoengineer Our Planet Adam Levy and Ella Gilbert discuss regional geoengineering. ClimateAdam on Youtube, Adam Levy, Oct 17, 2026.

Health Aspects of Climate Change (1 item)

• Climate Change Is Increasing Simultaneous Exposure to Heat Waves and Wildfire Smoke Heat and wildfire smoke are dangerous on their own. A new study says more people are facing both at once. Inside Climate News, Katie Surma, Oct 14, 2026.

Public Misunderstandings about Climate Science (1 item)

• Five types of disinformation - and how to spot red flags that trigger climate inaction The Conversation, Mark Maslin, Oct 15, 2026.

If you happen upon high quality climate-science and/or climate-myth busting articles from reliable sources while surfing the web, please feel free to submit them via this Google form so that we may share them widely. Thanks!

IT IS OFTEN said that hindsight is 20/20. Coroner’s inquests are, by their nature, exercises in hindsight. We look backwards after someone has died, reconstructing timelines and events, examining decisions and systems, hearing from families, eyewitnesses, and experts, ultimately asking what happened, and why? Coroner’s inquests are open to the public, live-streamed but never recorded. They cannot make any findings of blame, liability, or legal culpability. These measures are taken to encourage transparency and clarity, with a goal to fundamentally understand the root causes contributing to a death, so a jury of the public can make recommendations that may prevent another death of a similar nature.

Over the past several years, I have had the difficult privilege of serving as an expert witness in coroner’s inquests examining the deaths of Indigenous people in Ontario, including Don Mamakwa and Roland McKay who experienced medical emergencies while in the custody of the Thunder Bay Police; Luke Moore, Lorraine Shaganash, Lizzie Sutherland, Mark Ferris and Douglas Taylor – five members of Constance Lake First Nation, who died during a catastrophic outbreak of blastomycosis (a rare fungal infection); and, most recently, 24-year-old Heather Winterstein, from Six Nations, who died of septic shock after repeatedly seeking emergency medical care. 

Coroner’s inquests provide a window into how Indigenous people on Turtle Island access and receive healthcare. Each time we look backwards and are shocked by what we find. But increasingly, we must question whether hindsight is the right direction. What happens when we look forward instead?

If we know that a population has poorer access to healthcare, less adequate housing and infrastructure, structural poverty, greater exposure to systemic violence, less control over the socioeconomic and political systems affecting their lives, and persistently worse health outcomes – and we reproduce these conditions generation after generation – how useful can our hindsight really be?

Premeditation is as powerful as hindsight.

Premeditation does not mean that every health disparity we see today is deliberately engineered for harm by providers. It means that the discriminatory structures that created these conditions were deliberately designed for these outcomes, the consequences have been documented for generations, and their continuation makes the disparities they produce increasingly foreseeable.

The Malignant Narrative and Medical Violence

This year, 2026, the Indian Act turned 150 years old. For over 150 years, Indigenous health outcomes in Canada have been shaped not by accident or oversight, but by design. At the center of this design is what can be understood as “the Malignant Narrative”: a church-sanctioned dehumanization and devaluation of Indigenous people, legally enforced by colonial officials. This narrative framed Indigenous people not only as inferior to European settlers, but as non-human and therefore effectively non-existent, with no more claim to land, rights, or privilege than the animals that roamed the forests. 

The foundation of this narrative is legislative. The Indian Act consolidated extraordinary state control over First Nation identity, land, and governance. Residential schools, forced relocation, land dispossession, child apprehension, and jurisdictional fragmentation formed parts of the same colonial architecture. The Indian Act did not merely regulate Indigenous life, but it constructed a system of control that fundamentally altered the social determinants of health. It continues to structure how Indigenous people access, receive, and/or are denied healthcare today. 

At what point does a pattern of disparities become so persistent, so reproducible, and so well documented that we stop calling the outcome unexpected? The system isn’t broken; it was built this way.

The Malignant Narrative is the colonial story that precedes Indigenous people into every institution, from criminal justice to education to healthcare to employment. It positions Indigenous people as less credible, less deserving of compassion and care, less compliant. Indigenous people are simply stereotypes, reinforced by the narrative, told over and over through time. 

A Coroner’s inquest can be an investigation into this architecture that is now recognized as medical violence. Indigenous people have been subjected to neglect, abuse, experimentation, forced interventions, and systemic under-servicing. While contemporary discourse often frames these harms as historical, the underlying logic has not disappeared. We have seen this Malignant Narrative institutionalized in modern healthcare settings through predictable patterns of higher disease burden, inadequate access to care, dismissal, delayed diagnosis, inadequate pain management, and premature discharge. It influences who we believe, whose pain we take seriously, whose behaviour requires explanation, and tends to assign personal responsibility for structural challenges. Ultimately, it influences who receives the benefit of our clinical curiosity, and who we protect from the consequences of our unconscious bias and assumptions. 

One of the most dangerous features of the Malignant Narrative is that it is self-reinforcing. The system produces the conditions and then pathologizes Indigenous people for living within them. We see the normalization of disbelief whereby Indigenous patients’ reports of pain or illness are minimized. We see diagnostic hesitation where symptoms are attributed to stereotypes rather than investigated. We see triage decisions that systematically deprioritize Indigenous lives. We see a normalization of expected outcomes: Indigenous people are sicker and we are not shocked by increasing disparities in life expectancy. 

Poverty becomes irresponsibility. Difficulty accessing healthcare becomes “non-compliance”. Unmet needs become “frequent fliers”. Substance use becomes a diagnosis rather than a risk factor, and mistrust of institutions becomes “unwillingness to engage”. These are not isolated realities, they are patterned outcomes of a system that continues to operate within the Malignant Narrative. The consequences of colonialism become evidence for the stereotypes that colonialism created. 

Medical violence today rarely presents as overt abuse. It is more often expressed through structured neglect, a form of harm produced when systems consistently fail to respond appropriately to the needs of Indigenous patients. 

This system operates with a nearly insurmountable inertia.

The Constance Lake Blastomycosis Inquest

My work at the Constance Lake First Nation inquest made this painfully clear. I was retained by the Office of the Chief Coroner as an independent expert following the deaths of five community members during the 2021-22 blastomycosis outbreak. My mandate was not to determine whether individual physicians met the standard of care, nor to provide expertise on blastomycosis. I was asked to examine how stereotyping, unconscious bias and systemic racism can affect Indigenous peoples’ access to and receipt of healthcare, particularly during an infectious-disease outbreak.

What I encountered was not a simple story. The evidence showed many healthcare workers making extraordinary efforts in the midst of an unprecedented catastrophe. It also showed many community members repeatedly seeking medical attention as they became sicker, while others remained at home as they became increasingly ill before seeking help, reluctant to engage with a system that has harmed them. And, we saw the significant barrier to accessing higher levels of hospital care for critically ill patients. 

This outbreak asked us to look at what happens inside a system whose very architecture is deeply inequitable – no matter how hard working or caring those working inside it are. This outbreak asked us why there are no hospitals on-reserve anywhere in Ontario? Why are the vast majority of healthcare resources hoarded in non-Indigenous communities? The inquest gave insight into how jurisdictional fragmentation further entrenches harm, and the division of responsibility between federal and provincial governments creates gaps in care that Indigenous patients are forced to navigate, often at great personal cost. 

Don Mamakwa, Roland McKay and Heather Winterstein

Unmet needs are not only an outcome of geography. Unmet needs continue to profoundly impact First Nation people off-reserve. Don Mamakwa, Roland McKay, and Heather Winterstein all passed away off-reserve, in urban settings where high-level hospital access existed. The availability of healthcare does not always translate into access to care, and we can understand this by understanding bias.

Bias arises from early and repeated exposure to cultural stereotypes. Bias shapes our patterns of thinking, functioning as mental short cuts that influence perception, judgement, and behaviour. Much of our biases are unconscious attitudes and associations that are activated automatically, without deliberate attention or awareness. Research shows that biases develop very early in life, including racial bias. Children as young as three years old recognize and internalize racial stereotypes through cultural conditioning. And unfortunately in Canada, stereotypes rooted in Anti-Indigenous racism are rampant, often involving substance use, mental health, intelligence, criminality, hygiene, and poor parenting. 

Although stereotypes are not rational nor evidence-based, they exert powerful effects on cognition, impacting how information is noticed, how it is interpreted, and how decisions are made. This is how the Malignant Narrative is manifest. It is a pattern where racist assumptions, beliefs, biases, and stereotypes take over how people perceive and interact with Indigenous people. 

Don Mamakwa and Roland McKay were both Oji-Cree men who were arrested by police on suspicion of public intoxication, three years apart in Thunder Bay. Each man was placed in a locked jail cell, where they would ultimately die from treatable medical illness that had been mis-attributed to intoxication. For Don, a bystander had called 911 to report a man “passed out” on the church steps. Police and EMS arrived on scene and quickly determined he was intoxicated, taking him to a locked jail cell. In reality, Don was suffering from Diabetic Ketoacidosis, sepsis, and alcohol use disorder, but the medical emergency was not recognized. One expert in the inquest stated that Don would have had a, “97% of surviving if he had been brought to the hospital rather than a jail cell”. 

Here, the Malignant Narrative was profoundly impactful. From the moment 911 was called to the heartwrenching deaths recorded on jail cell surveillance cameras, stereotypes and assumptions appeared to be deeply ingrained across so many interactions. They were both unable to access medical care because the door was literally locked. 

For Heather Winterstein, the door was not locked, but neither was it open. Heather was a 24 year old Cayuga woman who repeatedly sought care in hospital over a two day period before she collapsed and died in the waiting room of a St. Catharine’s Hospital Emergency Department. She asked for help, and as she progressively deteriorated in plain sight, help was not provided. She had been given a diagnosis of “social issues”. The Coroner’s jury found that Heather Winterstein died of septic shock, due to sepsis (infection) with delayed treatment. They classified the manner of death as Accidental, not natural. Her family’s lawyer, Rachel Gardiner said, “there is nothing natural about being ignored to death”. 

Bias does not require a clinician to consciously believe that an Indigenous life matters less. It can operate far more subtly. A stereotype consciously or unconsciously creates an attribution: “Don is drunk”, or, “Heather has social issues”. This attribution becomes an anchor which is then used as the lens through which we process all information. Confirmation bias reinforces the original interpretations and clinical curiosity narrows. Bias can change what we believe we are seeing. In practice it can directly influence triage acuity, the thoroughness of an examination, diagnostic reasoning, and the willingness to initiate investigation or treatment – resulting in delayed recognition of serious illness and preventable harm. 

Anti-Indigenous racism is a patient-safety issue.

This is where one of the most basic tools in medicine can become a powerful anti-bias intervention: the differential diagnosis. A risk factor is not a diagnosis, substance use does not explain diabetic ketoacidosis, mental illness does not explain sepsis. Using a clear differential diagnosis can protect a patient from the consequences of our assumptions, forcing us to ask “what does not fit” and “Why is this person getting worse?” A differential diagnosis provides a circuit breaker from the momentum of the Malignant Narrative. 

The Future of Ontario’s Coroner’s Inquest System

There is another lesson I have taken from this work. We cannot prevent what we refuse to examine. This makes the future of Ontario’s Coroner’s Inquest system deeply important. The purpose is fact finding, public accountability, and prevention. Ontario is now considering significant changes to that system in relation to correctional institutions, replacing mandatory inquests for non-natural deaths in police custody with coroner-led annual reviews. This would result in the loss of public hearings, examinations and cross-examinations of evidence, participation of families and organizations with relevant expertise, community juries, and the transparency that accompanies an open proceeding.

Those concerns extend beyond correctional institutions. For Indigenous people, public inquests have repeatedly provided something our healthcare and justice systems too often fail to provide elsewhere: a forum in which a death can be understood not only as an individual event, but within the systems surrounding it.

I have watched that process happen. I have seen inquests provide the platform for deaths of Indigenous people to be examined alongside healthcare infrastructure, jurisdiction, geography, racism, trust, and Indigenous governance. They create a public record, allowing evidence to be tested and families to hear what happened. They bring experts, institutions, and communities into the same room, and critically, they ask a jury of ordinary people not simply, “why did this person die?” but, “what should change so another person does not die this way?”

Inquests are imperfect. Their recommendations are not binding; the Office of the Chief Coroner itself notes that it cannot compel organizations to implement them. But the answer to recommendations that are insufficiently implemented cannot be less accountability, it must be more.

This brings me back to hindsight. Mamakwa and McKay, Luke Moore, Lorraine Shaganash, Lizzie Sutherland, Mark Ferris, and Douglas Taylor, and Heather Winterstein.These are different people, different communities, different medical circumstances, and different institutions.

All raised the questions: Who is to be believed? Whose knowledge carries authority? Whose behaviour is pathologized? Whose suffering generates urgency? And, who gets to decide what happens next?

Inquests allow us to look backward and see these patterns. The danger is that Canada has become extraordinarily practiced at looking backward and being surprised. We have documented Indigenous disparities exceptionally well, now the harder task is acting on what makes these disparities so predictable.

Citation:

Shoush, Suzanne. “The Malignant Narrative: Coroner’s Inquests and Clinical Harm” Yellowhead Institute. Oct 20 2026. https://yellowheadinstitute.org/2026/the-malignant-narrative-coroners-inquests-and-clinical-harm/

Beadwork by Jamaica Cass

 

The post The Malignant Narrative: Coroner’s Inquests and Clinical Harm appeared first on Yellowhead Institute.

A new report from WWF highlights how we still have time to protect global biodiversity. While the decline in biodiversity worldwide shows no sign of slowing, according to a new WWF report, the organization believes that nature recovery is still within reach.

“Nature underpins our economies…It’s our life support system,” says Kirsten Schuijt, Director General of WWF International. But it “continues to be degraded at an alarming scale.”

The new Living Planet Report, which covers more than 35,000 populations and 5,700 species of mammals, birds, fish, reptiles, and amphibians, shows that not all regions are affected evenly.

Biodiversity decline is highest in Latin America and the Caribbean, followed by the African continent. But Andrew Terry, the Chief Conservation Officer for the Zoological Society of London, is careful to note that the results don’t mean regions like North America and Europe haven’t seen significant population decline. Rather, the biggest drop-off took place before 1970, when scientists established a baseline to measure against.

WWF points to food and agriculture systems as the largest cause of habitat loss and degradation. They’re also a major contributor to the climate crisis and the overexploitation of species. Together, these make the sector the leading driver of biodiversity decline.

“Habitat loss driven by agriculture is a threat to over 80 percent of all threatened terrestrial bird and mammal species,” Rebecca Shaw, Lead Author of the report and WWF’s Chief Scientist, tells Food Tank. “Overfishing is the leading cause of biodiversity loss in marine ecosystems and water extraction for agriculture.” She also adds that polluted runoff is responsible for 50 percent of all freshwater biodiversity loss.

But WWF still finds reason to remain hopeful. “Nature can rebound especially when we work together,” Schuijt says.

The report highlights the green sea turtle—they became the first marine turtle to ever be downgraded on a conservation list. After 50 years of collaborative efforts spanning 80 countries, it has been recategorized, moving from an Endangered species to one of Least Concern.

Atlantic and Pacific bluefin tuna are another example. Decades of overfishing brought populations to the brink of collapse. But concerted efforts to protect and replenish stocks mean that neither is considered threatened today.

“Targeted conservation action works, and it works really well, but it can’t overcome the threats to nature alone,” says Shaw. She argues that lessons from these projects can be taken and applied to address the root causes of biodiversity loss and drive systems change.

To reach a positive tipping point in food and agriculture systems, WWF argues that change is needed in three major areas. They call for the wide-scale adoption of nature-positive farming practices, a shift to healthy and sustainable diets, and a reduction in food loss and waste.

These changes “could have a dramatic impact on decreasing biodiversity loss,” Shaw tells Food Tank. “At the same time, it would also have extraordinary human health and economic benefits. The potential is huge.”

The transition to renewable energy sources must also continue to accelerate, the report states. Meanwhile funding must flow away from systems that harm ecosystems and toward those that regenerate them.

To make this transformation possible, WWF believes it is essential to uplift bright spots that prove efforts pay off.

“Hope is not an abstract thing. It’s based in science,” Schuijt says. And as long as people believe change is possible, she is adamant people will be willing to act —an attitude that is particularly important for the next generation. “Young people need to feel they can still contribute to a better future.”

Articles like the one you just read are made possible through the generosity of Food Tank members. Can we please count on you to be part of our growing movement? Become a member today by clicking here.

Photo courtesy of Shelley Pauls, Unsplash

The post WWF Shows Turning the Tide on Biodiversity Loss Is Still Possible appeared first on Food Tank.

When one of the nation’s biggest investor-owned utilities, Pacific Gas and Electric, wanted to replace Merrian Borgeson’s aging gas service line in Berkeley, California, she asked the company not to do it.

Borgeson, who is the California policy director for climate and energy at the nonprofit Natural Resources Defense Council, explained that the repair wasn’t necessary: She was in the process of fully electrifying her home and would be replacing her stove — the only gas appliance left in the house — with an induction version during an upcoming kitchen remodel. At that point, she planned to request that the gas line be shut off.

But PG&E told her it couldn’t wait. That week, the utility dug up her yard and swapped in a new pipe to send gas from the distribution main line to her home.

Borgeson wasn’t charged for the service — at least not directly. The upgrade, which in PG&E’s service area typically costs $20,000 to $30,000, plus interest and operation and maintenance costs, gets paid for by all gas customers over the life of the infrastructure.

A few years later, the new pipe sits unused in the ground.

Courtesy of RMI

“Now, I have no gas in my house,” Borgeson said. ​“But the customers all around me are paying for that pipeline for the next 50 years.”

Soon, Californians will have the choice that Borgeson did not.

A new law, the Home Energy Choice Act (Assembly Bill 2313), will require utilities to give households scheduled for a service line replacement the option of getting the new line or taking a financial incentive potentially worth several thousand dollars to get off gas instead. Crucially, the incentive to switch to all-electric equipment, such as a heat pump, induction range, and heat-pump water heater, will be less than the cost to replace the line, resulting in savings that will be shared among all gas customers.

The law ​“sends a very clear message that California is no longer going to invest millions of dollars in gas infrastructure without considering the future,” said Borgeson, who advocated for the bill. ​“It’s this huge signal of where the state is headed.”

The Natural Resources Defense Council has calculated that PG&E’s gas customers could save a total of $20 million if the utility gave 1,000 households a $17,500 incentive apiece rather than replacing their service lines. For context, PG&E replaces about 15,000 service lines annually.

Read Next The Northeast’s reliance on heating oil is turning into a crisis Tik Root

If similar programs were instituted across the country, the savings could rival Biden-era investments in home electrification. Utilities spend upward of $7 billion per year on service line replacements, according to clean energy nonprofit RMI. 

The policy will help push the state closer to its goal of a carbon-neutral economy by 2045; however, the version that passed was less ambitious than what was introduced, according to Brandon García, California director at industry association Advanced Energy United. Revisions included programs being capped at 1% of a utility’s customers and the law expiring Jan. 1, 2035, though it could be renewed before then.

“AB 2313 was a very difficult bill to get through the Legislature, so I’m very excited that it will soon give Californians the opportunity to decide what energy is powering their home and provide financial support if they choose to transition away from natural gas,” Assemblymember Marc Berman, who authored the bill, said by email. ​“When homeowners opt to electrify, the utility avoids additional investments in fossil fuel infrastructure that will eventually become a stranded asset, and this saves all ratepayers money long-term.”

Utilities San Diego Gas and Electric and SoCalGas opposed the bill, arguing that it would result in an unfair cost shift: As some customers stop using gas, those remaining could be left bearing outsized costs to maintain the system. While that is an issue writ large for the transition off of fossil fuels, and one the state needs to address, this law ​“is instead about trying to encourage people to leave at the exact time when they are saving money for everyone else by leaving,” said Kiki Velez, equitable gas transition lead at the Natural Resources Defense Council.

With the new legislation, California becomes the third jurisdiction to authorize the pipeline replacement alternative approach — and the first to do so statewide. In 2024, New York utility Con Edison launched its initiative, the Energy Exchange Program, which offers eligible households up to $20,000 to electrify. Other New York utilities are following suit, Velez said. And in July, the Colorado Public Utilities Commission authorized Xcel Energy to create a similar program, which she expects could launch within a few months.

Read Next A new report just busted another myth about heat pumps Matt Simon

In California, the next step is for the Public Utilities Commission to create a detailed framework for utilities to follow, including incentive levels, with larger amounts for customers in disadvantaged communities. Then utilities will have until January 1, 2028, for their individual proposed programs to be approved.

One yet-to-be-determined detail is how much notice utilities will give residents whose pipes they want to replace. ​“I think the worst case is you don’t hear about [the incentive] until the last minute,” Borgeson said. RMI recommends utilities alert residents one to five years ahead — at the point when it is scheduling the service line replacements.

Other states are looking to emulate California with bills of their own, Velez said, pointing to Illinois, Maryland, Minnesota, Oregon, and Washington. ​“Folks are already reaching out a lot about how they can bring it to their state,” she said.

In California, the bigger electrification incentives for disadvantaged communities will provide a much-needed boost to clean energy equity, García noted. ​“As someone who grew up in those kinds of neighborhoods as a low-income person, I want to make sure that everyone has access to [all-electric] technology.”

This story was originally published by Grist with the headline A new gas line or cash to electrify? California lets households choose. on Oct 18, 2026.

Updated: South Australia unveils project proposals totalling 13 GW of new wind and solar which it says can underpin the next phase of green industry development.

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THE SHELL LEAKS FILES — 17 OCTOBER 2026 SLF-2007-090 The Sakhalin Papers LXXX: Who Pays for a Dead Pipeline? Shell’s $1.126 Billion Loss, a €579 Million Insurance Defeat and the Battle Over Nord Stream’s Financial Remains

Four years after explosions devastated the Nord Stream pipelines, the financial consequences continue to work their way through European courts. A remarkable judgment delivered by London’s High Court on 6 July 2026 rejected a €579 million insurance claim arising from the destruction of Nord Stream 1. In Switzerland, the operator of Nord Stream 2 has survived threatened bankruptcy through a court-approved agreement with creditors, including the Western energy companies that helped finance its construction. Meanwhile, a German court has refused to allow the pipeline operators to join the criminal prosecution arising from the sabotage as additional complainants. For Shell shareholders, these developments raise an important question: what became of the company’s $1.126 billion Nord Stream 2 financing exposure, written down months before the explosions?

Archive reference: SLF-2007-090
Publication date: 17 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-089 — The Sakhalin Papers LXXIX, 16 October 2026

Principal documentary sources: Shell plc’s 2022 financial disclosures; Nord Stream AG v Lloyd’s Insurance Company SA & Anor [2026] EWHC 1685 (Comm); Cantonal Court of Zug proceedings EN 2022 2; Hanseatic Higher Regional Court of Hamburg proceedings 3 St 2/26; European Union regulatory and judicial records.

Evidence classification: Authenticated corporate financial disclosures; published judicial findings; documented restructuring proceedings; established regulatory decisions; contested allegations concerning responsibility for sabotage; separately identified editorial analysis.

Introduction: The explosions were only the beginning of the financial story

The previous instalment examined the criminal investigation into the explosions that destroyed three of the four Nord Stream pipeline strings on 26 September 2022.

The German prosecution has now reached the trial stage.

On 14 October 2026, a former Ukrainian military officer appeared before the Hanseatic Higher Regional Court in Hamburg.

German prosecutors allege that the defendant participated in an operation organised by Ukrainian military personnel acting on instructions from Ukrainian state authorities.

The allegations are contested, Ukraine denies responsibility, and the defendant remains presumed innocent.

But criminal responsibility is only one part of the Nord Stream story.

There is also the matter of the money.

The pipelines represented investments of approximately €17 billion between the two projects.

Nord Stream 1 had operated commercially for years.

Nord Stream 2 was completed but never entered commercial service.

Shell was one of five Western European energy companies that financed Nord Stream 2.

When Russia invaded Ukraine in February 2022, the commercial assumptions underpinning that investment collapsed.

Shell recognised a $1.126 billion write-down in the first quarter of 2022.

Other lenders faced their own financial consequences.

The Nord Stream 2 operating company subsequently entered restructuring proceedings in Switzerland.

Following the explosions, the operators also confronted enormous repair costs.

One operator sought compensation from insurers.

The resulting litigation produced a striking outcome.

A London court concluded that the pipeline damage was excluded from insurance cover because of its connection to the Russia–Ukraine war — without deciding who carried out the explosions.

That judgment is central to today’s instalment.

1. Two pipelines, two companies and two very different financial positions

Understanding the financial aftermath requires distinguishing Nord Stream 1 from Nord Stream 2.

Although the pipelines followed broadly similar routes beneath the Baltic Sea, they were operated by separate companies.

Nord Stream AG, the operator of Nord Stream 1, is a Swiss company in which a Gazprom entity holds a controlling 51 per cent interest.

Its other shareholders are European energy companies.

Nord Stream 1 began commercial operations in 2011, with its second pipeline entering service in 2012.

It subsequently transported substantial volumes of Russian natural gas to Germany.

Nord Stream 2 AG, by contrast, is wholly owned by Gazprom.

Shell did not hold an equity interest in Nord Stream 2 AG.

Its involvement was through the provision of financing and associated commitments.

That distinction matters.

A shareholder owns part of a company and participates in its residual economic value.

A lender has contractual rights relating to the repayment of financing.

Those rights may become subject to restructuring, insolvency proceedings, sanctions and negotiated settlements.

The two positions have different legal consequences.

Shell’s financing exposure therefore cannot simply be treated as a shareholding in Nord Stream 2.

Nor should financial losses affecting Nord Stream 1 automatically be attributed to Shell.

These distinctions are confirmed by Shell’s disclosures and the ownership information recorded in the July 2026 English High Court judgment. Case Law

The financing arrangement

Nord Stream 2 was estimated to cost approximately €9.5 billion.

Gazprom was to provide approximately half the financing.

The remaining portion was supported by five Western European energy companies:

• Shell
• Uniper
• Wintershall Dea
• OMV
• Engie

Each committed financing of up to approximately 10 per cent of the project’s total cost.

The arrangement was commercially significant.

Gazprom controlled the company.

But Western European energy businesses helped finance the infrastructure necessary to transport Russian gas directly to Germany.

The financing model reflected expectations that substantial volumes of Russian natural gas would continue flowing into European markets for years.

Those expectations were eventually overtaken by political events.

2. Shell’s authenticated financial disclosure: $1.126 billion written down

The clearest evidence concerning Shell’s financial position appears in its third-quarter 2022 results.

The company confirmed that it had reassessed the recoverability of its Nord Stream 2 loan following its decision to withdraw from Russian activities.

That reassessment resulted in the complete write-down of the loan’s carrying amount.

The figure was $1,126 million.

Shell recognised the charge in the first quarter of 2022.

It was therefore recorded before the September explosions.

Shell’s subsequent disclosure made the distinction explicit.

The company acknowledged that one of the two Nord Stream 2 pipeline strings had ruptured on 26 September.

It nevertheless reported that the rupture produced no additional financial impact in the third quarter because the loan had already been fully written down.

This is a particularly important piece of documentary evidence.

It means that Shell had already recognised the loss in its accounts as a consequence of the changed circumstances surrounding its Russian business.

The explosions were a later event.

They did not cause the original impairment.

Primary source: Shell plc — Third Quarter 2022 Unaudited Results, Note 8. Investegate

What a write-down does — and does not — establish

The accounting treatment requires careful interpretation.

A write-down recognises a reduction in the carrying value of an asset.

It does not necessarily mean that every contractual right associated with that asset has ceased to exist.

Nor does it prove that no future recovery could ever occur.

A lender may retain legal claims even after the corresponding financial asset has been impaired.

Any subsequent recovery would require appropriate accounting treatment.

The public documents examined for this instalment establish Shell’s $1.126 billion impairment.

They do not establish that Shell subsequently recovered that amount.

Equally, the impairment should not automatically be equated with a separately verified total cash payment of precisely $1.126 billion.

For the historical record, the accurate description is that Shell fully wrote down its reported Nord Stream 2 loan carrying amount of $1.126 billion.

That distinction becomes especially relevant when examining the later Swiss creditor settlement.

3. May 2022: The Nord Stream 2 operator enters Swiss restructuring proceedings

Nord Stream 2 AG was incorporated in Switzerland.

Consequently, its financial difficulties became a matter for the Swiss courts.

On 10 May 2022, the company obtained an initial moratorium protecting it while possible restructuring arrangements were considered.

The proceedings took place before the Cantonal Court of Zug.

The court appointed Transliq AG to supervise aspects of the process.

A Swiss composition moratorium allows a financially distressed company time to seek an arrangement with creditors.

Such an arrangement may involve extensions of payment deadlines, negotiated compromises or partial debt waivers.

It does not automatically mean that the company has been liquidated.

Indeed, the purpose may be to avoid bankruptcy.

This distinction was important in Nord Stream 2’s case.

The company possessed expensive physical infrastructure.

But its anticipated commercial revenue had disappeared.

Germany had suspended the certification process.

The United States had imposed sanctions.

Nord Stream 2 had not begun supplying gas.

The company’s financial problem was therefore not merely that it had suffered physical damage.

Its commercial purpose had become uncertain.

And these difficulties arose before the September 2022 explosions.

4. January 2025: The Swiss court approaches the limits of restructuring

The restructuring proceedings continued for an unusually prolonged period.

By January 2025, Nord Stream 2 AG had received repeated extensions of its creditor protection arrangements.

On 9 January 2025, the Cantonal Court of Zug issued an important decision.

It exceptionally extended the company’s definitive composition moratorium until 9 May 2025.

However, the court imposed conditions.

Nord Stream 2 AG was required to satisfy the claims of its smaller creditors within the specified period.

The court warned that bankruptcy would follow if the requirements were not met.

Transliq AG remained involved as the administrator.

The arrangement demonstrated the seriousness of the company’s financial position.

The operator possessed a completed pipeline system originally intended to generate substantial revenues.

Yet it was struggling to meet obligations to relatively small creditors.

These included contractors and other businesses involved in the project.

Some were located in Germany.

The contrast was striking.

A multibillion-euro international energy project had reached the point where relatively modest outstanding debts became central to its continued corporate existence.

Authenticated court record: Cantonal Court of Zug — Nord Stream 2 AG, Proceedings EN 2022 2. Zug

5. May 2025: A settlement with creditors averts bankruptcy

A major development occurred in spring 2025.

Nord Stream 2 AG reached an agreement with its creditors on 30 April.

On 9 May 2025, the Cantonal Court of Zug approved the composition agreement.

The court described the arrangement as a Dividendenvergleich — a composition arrangement involving payments to creditors.

The original decision was subject to appeal.

However, on 3 June 2025, the court confirmed that its approval had become enforceable.

Contemporaneous reporting identified Shell, Uniper, Wintershall Dea, OMV and Engie among the principal Western European creditors involved in the settlement.

The agreement allowed the company to avoid bankruptcy.

That was an important result.

But avoiding bankruptcy was not equivalent to restoring the commercial viability of Nord Stream 2.

Nor did it establish that the financing companies had recovered their original investments.

The full economic terms applicable to Shell have not been established from the public documents examined for this instalment.

It would therefore be inappropriate to state a specific recovery amount.

The settlement demonstrates that the company’s financial affairs were being reorganised.

It does not establish that Shell’s previously recognised loss was reversed. Energie und Management

September 2025: Smaller creditors receive another extension

The creditor arrangements continued to require attention.

On 8 September 2025, Reuters reported that the Swiss court had extended the deadline for satisfying smaller creditors until 9 February 2026.

The earlier deadline had been 9 September 2025.

The extension reflected continuing implementation issues under the approved settlement.

The available public reporting does not establish the detailed outcome of every creditor’s claim after that subsequent deadline.

For the Shell archive, the essential distinction is between the court’s approval of a restructuring agreement and documentary proof of the amounts ultimately recovered by individual creditors.

Those are not the same thing.

Contemporaneous reporting: Reuters — Swiss Court Extends Nord Stream 2 Creditor Deadline, 8 September 2025.

6. A separate battle begins in London: Nord Stream 1 claims against insurers

While Nord Stream 2’s creditor arrangements were being addressed in Switzerland, another financial dispute developed in England.

This involved Nord Stream AG, the operator of Nord Stream 1.

It was not Shell’s Nord Stream 2 financing claim.

The company sought approximately €579 million from insurers following the September 2022 explosions.

The defendants included Lloyd’s Insurance Company S.A. and Arch Insurance (EU) DAC, acting in representative capacities for subscribing insurers.

The litigation concerned insurance policies covering the two Nord Stream 1 pipelines.

The insurers disputed liability.

Their principal argument relied upon exclusions concerning war and certain governmental acts.

The proceedings eventually reached a substantial trial in the Commercial Court.

Expert evidence was presented concerning geopolitics, insurance market practices, explosives, materials science, subsea operations and repairs.

The dispute was therefore far more than an argument about the physical cost of replacing damaged pipe.

It required the court to determine whether the loss fell within the insurance cover at all.

Primary court record: Nord Stream AG v Lloyd’s Insurance Company SA & Anor — [2026] EWHC 1685 (Comm).

7. The extraordinary insurance question: Must the court identify the saboteurs?

At the centre of the dispute was the relationship between the explosions and Russia’s war against Ukraine.

Nord Stream AG sought compensation for deliberate destruction of its infrastructure.

The insurers argued that the policy exclusions applied.

The central legal issue was whether the damage was sufficiently connected with the war to fall outside the insurance cover.

This created an unusual difficulty.

No criminal court had yet established who was responsible for the explosions.

Different accounts attributed possible responsibility to Ukraine, Russia or the United States.

The insurers nevertheless argued that identifying a particular perpetrator was unnecessary.

Their case was that, on the range of possible perpetrators considered in the proceedings, the attacks were connected to the war.

The court examined expert evidence concerning the possible motives of state and non-state actors.

The analysis included possible Ukrainian state involvement, Ukrainian actors operating outside direct state control, Russian involvement and American involvement.

These possibilities were considered for the purpose of interpreting the insurance policies.

They were not findings that those governments or individuals had carried out the attacks.

That distinction is fundamental.

The English court was determining an insurance dispute, not conducting a criminal prosecution for sabotage.

8. 6 July 2026: Nord Stream loses its €579 million insurance claim

On 6 July 2026, Dame Clare Moulder delivered judgment in the Commercial Court.

The decision is recorded as:

Nord Stream AG v Lloyd’s Insurance Company SA & Anor [2026] EWHC 1685 (Comm)

The court found that the relevant policy exclusion applied.

In substance, the judge concluded that the damage was sufficiently connected with the Russia–Ukraine war to fall within the contractual war exclusion.

That conclusion did not require a finding identifying the perpetrators.

The judgment also considered a separate area of damage, described as the Dent, affecting one of the Nord Stream 1 lines.

The court concluded on the balance of probabilities that this damage had been caused by an explosive device as part of the same attack.

It rejected the alternative explanation involving a dropped anchor.

The result was that the relevant damage fell outside the insurance cover.

The court therefore dismissed Nord Stream AG’s claim.

An important further detail appears near the end of the judgment.

Because the judge had decided the case on liability, she did not need to determine the precise amount that would otherwise have been recoverable.

Consequently, the judgment should not be described as judicial confirmation that repairs would necessarily cost €579 million.

That was the approximate insurance claim.

The court’s decisive finding concerned coverage.

The operator had suffered damage, but the insurers were not liable to indemnify it under the policies considered.Case Law

The judgment did not establish who destroyed the pipelines

This distinction deserves particular emphasis.

The July 2026 judgment did not establish that Ukraine organised the sabotage.

Nor did it establish responsibility on the part of Russia or the United States.

The court assessed possible causal connections between the war and the attacks for the limited purpose of interpreting the insurance exclusion.

The subsequent German criminal trial involves different legal questions and different standards of proof.

The English civil judgment cannot properly be converted into a finding of criminal responsibility.

That would misrepresent the decision.

An appeal remains possible

The insurance litigation may not be over.

On 17 July 2026, the High Court refused Nord Stream AG permission to appeal.

The company was nevertheless entitled to seek permission directly from the Court of Appeal.

A legal analysis published on 9 October 2026 reported that its application remained pending.

Accordingly, the July judgment is an important existing decision, but the possibility of appellate proceedings must be recognised.

The financial position could change if the judgment is successfully challenged.

As of the latest verified reporting examined for this instalment, no appellate reversal has been established. theinsurer.com

9. September 2026: German courts reject the pipeline operators’ applications

Another important decision followed in Germany.

On 30 September 2026, the Hanseatic Higher Regional Court in Hamburg considered applications by Nord Stream AG and Nord Stream 2 AG to participate as additional complainants in the criminal proceedings.

The court rejected both applications.

Its public explanation, issued on 2 October, is particularly revealing.

The companies argued that the destruction had caused severe economic consequences.

The court acknowledged that the estimated costs of restoring the pipelines ran into hundreds of millions of euros.

However, it compared those estimates with the original investment costs.

The investments had amounted to approximately €7.4 billion for Nord Stream 1 and €9.5 billion for Nord Stream 2.

The judges concluded that the repair estimates, viewed in that context, did not establish the exceptional circumstances necessary for the companies to participate under the relevant criminal procedural provision.

The court also distinguished physical damage from wider commercial consequences.

Some of the operators’ financial difficulties arose from political decisions taken in response to Russia’s invasion of Ukraine.

Those consequences could not simply be attributed to the explosions.

This was an important legal distinction.

The ruling did not establish that the pipelines had suffered insignificant damage.

Nor did it determine that the operators lacked possible civil claims.

Rather, it concerned their procedural entitlement to join the criminal prosecution.

Authenticated court statement: Hanseatic Higher Regional Court — Nord Stream Applications Rejected, 2 October 2026.

10. The Hamburg court draws a boundary around the criminal proceedings

The German court’s explanation went further.

It emphasised that the criminal proceedings were concerned with the alleged acts and responsibility of the defendant.

They were not intended to provide a comprehensive investigation into every possible financial consequence of the explosions.

Nor were they designed to identify every potential defendant in future compensation proceedings.

The court specifically referred to the limits of using criminal proceedings to develop the factual and legal basis for possible reparations claims by the Russian Federation against Ukraine.

That observation is striking.

It shows that the judges recognised the wider geopolitical and financial questions surrounding the case.

But they were unwilling to turn the criminal trial into a general inquiry covering all those matters.

The court also indicated that civil law provided possible avenues for pursuing financial claims.

The operators were therefore not necessarily deprived of every opportunity to seek compensation.

They had been refused a particular form of participation in the criminal case.

The ruling illustrates why different legal proceedings must be kept separate.

A criminal prosecution determines individual criminal responsibility.

An insurance action determines contractual coverage.

A civil compensation claim may involve different questions of loss, causation and liability.

And an insolvency or restructuring proceeding concerns the treatment of creditors.

The same physical event can produce all four types of proceeding.

But their outcomes are not interchangeable. justiz.hamburg.de

11. A further development: The European Union moves to end Russian gas imports

While the pipeline operators continued their financial and legal struggles, the wider regulatory environment changed again.

On 26 January 2026, the Council of the European Union formally adopted legislation establishing a phased prohibition on imports of Russian natural gas.

The measure covers pipeline gas and liquefied natural gas.

It entered into force in February 2026, with restrictions beginning to apply in March and transitional arrangements for existing contracts.

Under the legislation, long-term Russian pipeline gas imports are scheduled to end in autumn 2027.

The regulation forms part of the European Union’s efforts to reduce dependence on Russian energy following the invasion of Ukraine.

For Nord Stream 2, the implications are potentially substantial.

The pipeline had already been completed without entering commercial service.

One string had been ruptured in the explosions.

The surviving string had not provided an authorised commercial route for Russian gas supplies to Germany.

Now, additional European legislation was being introduced to prohibit the relevant imports.

Even repairing the damaged infrastructure would therefore not resolve all the barriers to commercial operation.

Physical functionality is only one requirement.

Certification, sanctions, import restrictions and commercial agreements also matter.

Official regulatory source: Council of the European Union — Russian Gas Imports: Final Approval of Stepwise Ban, 26 January 2026.

12. April 2026: Nord Stream 2 challenges the European Union

The legislative development produced another court case.

On 27 April 2026, Nord Stream 2 AG brought proceedings against the European Parliament and the Council of the European Union.

The application was registered as Case T-264/26.

The company’s action challenges Regulation (EU) 2026/261.

According to the published notice of proceedings, Nord Stream 2 seeks annulment of the regulation or, alternatively, specified provisions.

Its arguments include allegations that the measure was adopted on an incorrect legal basis, that it breaches proportionality and that it infringes property rights.

These are the applicant’s legal arguments.

They are not findings of the EU courts.

The action demonstrates that Nord Stream 2’s legal and commercial future remains contested.

The operator is not merely dealing with the physical consequences of the explosions.

It is challenging legislation affecting the possibility of importing Russian gas.

The proceedings also reinforce the distinction between owning infrastructure and possessing a commercially usable asset.

A pipeline may remain physically present beneath the Baltic Sea while its anticipated business model is constrained by regulatory decisions.

Official judicial record: Official Journal of the European Union — Case T-264/26, Nord Stream 2 v Parliament and Council.

13. What has become of Shell’s money?

The central question for Shell shareholders remains difficult to answer completely from the public records.

Several matters are established.

Shell committed financing to Nord Stream 2.

Its reported loan carrying amount was $1.126 billion when it was fully written down in the first quarter of 2022.

The explosions occurred subsequently.

Nord Stream 2 AG entered Swiss creditor-protection proceedings.

A composition agreement with creditors was approved in May 2025 and became enforceable.

Shell was identified among the Western European financing companies involved.

But the documents examined do not establish the precise amount, if any, ultimately recovered by Shell under the settlement.

Nor do they establish that the original $1.126 billion write-down was subsequently reversed.

It would therefore be misleading to announce that Shell recovered its money.

It would be equally misleading to claim that every possible recovery right was extinguished simply because the asset had been written down.

The unresolved documentary question is narrower.

What financial entitlement did Shell retain under the Swiss restructuring agreement, and what payments, if any, did it subsequently receive?

Answering that question conclusively would require additional evidence.

Potentially relevant records include the complete composition agreement, associated creditor arrangements and later Shell financial disclosures.

Without those documents, the archive should record the established impairment and restructuring events while leaving the precise recovery position unresolved.

COMMENTARY: Billions Invested, Commercial Assumptions Destroyed

The financial history of Nord Stream provides a remarkable demonstration of the risks arising when large energy investments depend upon international political relationships.

Nord Stream 2 was built to carry Russian natural gas directly to Germany.

Western energy companies helped finance it.

Construction was completed in September 2021.

At that point, the project had overcome substantial technical difficulties and years of political opposition.

But the underlying commercial proposition remained dependent upon government decisions.

Germany had to authorise its operation.

The infrastructure required an acceptable international regulatory environment.

Gas sales depended upon continuing commercial relationships between Russia and European customers.

Those conditions deteriorated dramatically after Russia invaded Ukraine.

Shell announced its withdrawal and wrote down the loan.

The operator entered restructuring proceedings.

Then the explosions occurred.

The insurance litigation added another consequence.

In London, an approximately €579 million claim failed because the court concluded that the damage fell within the contractual war exclusion.

The Swiss restructuring demonstrated that creditors and the operating company had to negotiate over obligations arising from a project that had lost its anticipated revenue stream.

And the European Union’s subsequent legislation introduced still further restrictions.

The financial consequences therefore arose through several distinct mechanisms.

There was the collapse of commercial expectations.

There were sanctions and regulatory constraints.

There was the physical destruction of infrastructure.

There were disputes over insurance coverage.

And there were negotiations about outstanding debts.

These mechanisms should not be merged into one undifferentiated loss.

A project can fail without being physically destroyed

One of the most important lessons is that a pipeline can lose much of its commercial usefulness while remaining substantially intact.

Nord Stream 2 demonstrated this before the September 2022 explosions.

Shell’s impairment was recorded while the pipeline infrastructure still existed.

Germany had already suspended certification.

The project could not deliver its intended commercial benefits.

This does not establish that construction of Nord Stream 2 was necessarily irrational when the original investment decisions were made.

Commercial judgments must be examined in the circumstances in which they occurred.

But it does demonstrate the importance of assessing political and regulatory risks alongside engineering and financial considerations.

For shareholders, the relevant question is whether those risks were understood and appropriately reflected in investment decisions.

That question cannot be answered solely by examining the eventual loss.

It requires contemporary records of the decisions themselves.

14. The Sakhalin connection: When political power overtakes commercial ownership

This collection began by examining Shell’s experience in Sakhalin.

The company’s difficulties with the Sakhalin-2 project included Russian regulatory intervention and the eventual transfer of controlling ownership to Gazprom.

Years later, the deterioration of relations between Russia and Western governments created a different form of exposure.

In Sakhalin, Shell had been an equity participant.

In Nord Stream 2, it was a financier.

The two arrangements involved different rights and obligations.

Nevertheless, both projects illustrate how political decisions can fundamentally alter the economics of major international energy investments.

The comparison is particularly relevant because Shell’s third-quarter 2022 disclosures addressed both investments.

The company reported a substantial impairment associated with Sakhalin-2.

It also reported the complete write-down of its Nord Stream 2 loan.

Both occurred as part of its reassessment of Russian operations following the invasion of Ukraine.

The financial circumstances were not identical.

But they formed part of the same wider corporate withdrawal.

The Nord Stream records therefore belong within the broader Sakhalin collection.

They help explain how Shell’s long commercial relationship with Russia evolved into a succession of losses, disputes and unresolved legal questions.

The Sakhalin Papers are not simply a history of one oil and gas development. They have become a documentary examination of Shell’s wider relationship with Russian political power and its consequences.

15. Evidence assessment: Established facts, judicial findings and unresolved questions

The documentary record now permits several conclusions.

Established corporate facts: Shell financed Nord Stream 2 and reported a $1.126 billion loan write-down in the first quarter of 2022. The September explosions caused no additional third-quarter impairment of that loan.

Established Swiss proceedings: Nord Stream 2 AG entered creditor-protection proceedings. A composition agreement was approved in May 2025 and subsequently became enforceable.

Established English judicial finding: On 6 July 2026, the Commercial Court held that the relevant damage to Nord Stream 1 fell within the insurance policies’ war exclusion. The court did not decide who committed the sabotage.

Established German judicial decision: The Hanseatic Higher Regional Court refused the pipeline operators permission to participate as additional complainants in the criminal trial under the relevant procedural provision.

Established European regulatory development: The European Union adopted legislation phasing out imports of Russian natural gas. Nord Stream 2 AG has brought legal proceedings challenging that legislation.

Unresolved financial question: The publicly examined documents do not establish the precise amount Shell may have recovered under the Nord Stream 2 creditor agreement.

Unresolved criminal question: The identity and criminal responsibility of those who carried out the explosions remain matters for the relevant criminal proceedings.

These distinctions are essential.

They prevent financial accounting figures from being mistaken for compensation awards.

They prevent civil insurance findings from being presented as criminal verdicts.

And they prevent the existence of a restructuring agreement from being treated as proof of full repayment.

Conclusion: The Pipes Were Built, the Money Was Committed — and the Legal Battles Continue

Nord Stream 2 was intended to strengthen the commercial relationship between Russia and European energy markets.

Instead, it became one of the most visible casualties of the political collapse of that relationship.

Shell committed substantial financing.

It subsequently wrote down $1.126 billion.

The operating company entered restructuring proceedings.

The pipelines were sabotaged.

Nord Stream 1’s operator sought substantial compensation from insurers.

The English High Court rejected that insurance claim under a war exclusion.

German judges refused the pipeline operators’ applications to participate as additional complainants in the sabotage prosecution.

And Nord Stream 2 is now pursuing separate litigation against European Union legislation restricting Russian gas imports.

The financial consequences are substantial.

But the documentary record does not support the proposition that every loss arose from the explosions.

In Shell’s case, the recognised loan impairment preceded them.

That distinction may be the most important financial fact in the entire Nord Stream chronology.

The commercial project had already failed to deliver its intended purpose before the physical infrastructure was attacked.

What remains is an extraordinary network of financial obligations, judicial proceedings, regulatory restrictions and unanswered questions.

The English insurance judgment shows that even substantial physical damage does not necessarily produce an insurance recovery.

The Swiss restructuring demonstrates that major creditors may have to negotiate over their financial entitlements when a project loses its revenue-generating purpose.

And the continuing European litigation illustrates how the legal consequences of major energy investments can survive long after their original commercial assumptions have collapsed.

For Shell shareholders, Nord Stream 2 provides a substantial historical case study in geopolitical investment risk.

For the independent archive, it provides another example of why authenticated documents must remain at the centre of the account.

The financial loss is documented.

The restructuring is documented.

The court decisions are documented.

The precise outcome of Shell’s creditor entitlement remains to be established.

That is where the evidence leads — and where the historical record must presently stop.

PRINCIPAL DOCUMENTARY SOURCES

1. Shell plc — Third Quarter 2022 Unaudited Results

Original Corporate Financial Disclosure

Authenticated company record confirming the $1.126 billion Nord Stream 2 loan impairment and establishing that the pipeline rupture created no additional third-quarter impairment.

2. High Court of England and Wales — 6 July 2026

Nord Stream AG v Lloyd’s Insurance Company SA & Anor [2026] EWHC 1685 (Comm) — Full Judgment

The principal judicial record concerning the Nord Stream 1 insurance dispute, the contractual war exclusion and the court’s findings.

3. Brick Court Chambers — 6 July 2026

Nord Stream: €579 Million Insurance Claim Dismissed by Commercial Court

Contemporaneous legal analysis from counsel’s chambers summarising the insurance litigation and its outcome.

4. Cantonal Court of Zug — Proceedings EN 2022 2

Official Swiss Court Record of Nord Stream 2 Restructuring Proceedings

Primary judicial source recording the moratorium extensions, approval of the creditor agreement and confirmation that the agreement became enforceable.

5. Reuters — 8 September 2025

Swiss Court Extends Nord Stream 2 Deadline for Smaller Creditors

Contemporaneous reporting on the extension of payment deadlines under the Swiss creditor settlement.

6. Hanseatic Higher Regional Court — 2 October 2026

Nord Stream Operators Refused Additional Complainant Status

Authenticated German court statement explaining the procedural decision, estimated repair costs and distinction between physical damage and broader economic consequences.

7. Council of the European Union — 26 January 2026

Official Announcement of the Phased Prohibition on Russian Gas Imports

Primary regulatory source concerning the European Union’s decision to phase out Russian natural gas imports.

8. Official Journal of the European Union — 15 June 2026

Case T-264/26: Nord Stream 2 AG v European Parliament and Council

Official notice of proceedings challenging Regulation (EU) 2026/261.

9. Kennedys — 9 October 2026

Nord Stream: War Exclusions and Indirect Causation

Recent legal commentary examining the English insurance judgment and recording that an application for permission to appeal remained pending.

DOCUMENTARY EVIDENCE AND LEGAL DISCLAIMER

This instalment is based upon authenticated corporate financial disclosures, published court judgments, official judicial announcements, regulatory records and identified contemporaneous reporting.

The English insurance judgment concerns Nord Stream AG and Nord Stream 1. It should not be confused with Shell’s financing exposure to Nord Stream 2 AG.

The Swiss composition agreement establishes that a creditor arrangement was approved. The precise financial treatment of Shell’s individual claim has not been independently established from the complete agreement.

The German court decision concerning additional complainant status does not determine the merits of possible separate civil claims.

The pending German criminal proceedings have not resulted in a final conviction establishing responsibility for the Nord Stream explosions.

The European Union proceedings brought by Nord Stream 2 AG remain legal claims, not findings that the legislation is invalid.

Editorial commentary is distinguished from the documentary findings.

The website’s general disclaimer also applies.

NEXT IN THE SHELL LEAKS FILES SLF-2007-091 — The Sakhalin Papers LXXXI: The Pipeline That Refuses to Die — Nord Stream 2, the Former Stasi Officer, American Investors and the Battle to Reopen Russia’s Gas Route to Europe

The pipelines were completed.

Three of their four strings were ruptured.

Shell wrote down more than a billion dollars.

The Nord Stream 2 operator came close to bankruptcy.

The European Union adopted legislation intended to end Russian natural gas imports.

Yet the story did not end.

In March 2025, the Financial Times reported an extraordinary development.

Matthias Warnig, the former East German intelligence officer and longstanding associate of Vladimir Putin who had previously headed Nord Stream 2 AG, was reportedly involved in efforts to revive the pipeline project.

The proposals involved possible American investors.

The reported discussions contemplated arrangements that could potentially bring an American commercial interest into the ownership or operation of the infrastructure.

The plans were highly controversial.

They also remained dependent upon overcoming formidable political, legal and regulatory obstacles.

The reports did not establish that any such transaction had been completed.

Nevertheless, they revealed that some influential participants had not abandoned the possibility of reviving Nord Stream.

Contemporaneous reporting: Financial Times — Putin Ally Pushes Deal to Restart Nord Stream 2 with US Backing, 2 March 2025.

The next instalment will examine Warnig’s historical role, the reported American interest and the documentary evidence concerning efforts to revive the pipeline.

It will also investigate the obstacles created by European energy legislation and the company’s continuing legal challenges.

And it will ask a question that brings the wider Russian energy history back into focus.

How did an energy project financed by Western companies, controlled by Gazprom and opposed by successive American administrations become the subject of reported proposals involving American investors?

The answer may reveal another unexpected chapter in the long and complicated history of Shell, Gazprom and European energy politics.

The Sakhalin Papers continue.

THE SHELL LEAKS FILES — 17 OCTOBER 2026 was first posted on October 17, 2026 at 11:25 pm.
©2018 "Royal Dutch Shell Plc .com". Use of this feed is for personal non-commercial use only. If you are not reading this article in your feed reader, then the site is guilty of copyright infringement. Please contact me at john@shellnews.net

The nation’s largest union of registered nurses issued the following statement, in response to the federal government’s raid on Rep. Ilhan Omar’s home, confiscating her possessions, and reports of attempting to strip her of her citizenship.

In January 1966, a South African ship caught fire at sea. In port in Bristol, England, after firefighters pried open the smoking container, the conflagration spread and burned for five days. A little over a month later, a Liberian steamship caught fire near Rotterdam, ignited a storage area with barrels of petrol and sank. The month after that, a Danish ship caught fire off Long Beach, California, injuring three firefighters, killing a longshoreman and causing over a million dollars in estimated damages.

The culprit in each fire was fishmeal, a dark yellow powder made by drying and pulverizing fish that, if left untreated, is known for spontaneously combusting as it decays and oxidizes. 

Tied to at least 90 ship and plant fires from the 1950s through the 1970s, fishmeal’s combustibility was a serious worry for seafarers, insurers and dock workers, according to a sweep of historical news coverage by The Outlaw Ocean Project, a news organization in Washington, D.C.

In 1967, American feed producer Cargill announced a solution: ethoxyquin. 

A crew abandons ship as the SS South America burns in Rotterdam in 1966.​ Sepia Times, NY Daily News, Evers, Joost / Anefo​

A fire retardant previously used to keep rubber tires from drying out and applied as a preservative on fruits and alfalfa, production of the antioxidant was soon ramped up. 

“Antioxidant treatment has made bulk handling an easy matter,” the director of the Canadian Department of Fisheries told an industry publication in 1966, arguing it should be required for fishmeal shipments. 

The chemical was highly effective. By the 1970s, press-reported fires dropped sharply—from a typical 16 ship fires a year, according to the Liverpool Underwriters Association, to five. 

By 1976, the U.S. Coast Guard imposed mandatory ethoxyquin treatment on fishmeal shipments, and three years later, the United Nations body that oversees maritime activity recommended fishmeal be treated with it “to prevent spontaneous combustion.” 

But there was a problem: Ethoxyquin is a carcinogen. 

“Toxic effects had been observed in laboratory animals fed high concentrations of ethoxyquin,” said a 1969 paper by U.N. food and agriculture authorities.

87 fires in fishmeal cargoes, plants, and warehouses, 1950–1978. The Outlaw Ocean Project

As its use in animal feeds and aquaculture grew, a 1987 study by British researchers found the chemical “caused severe damage” and had a potentially “carcinogenic effect” in rats. In 2015, the European Food Safety Authority said an impurity within ethoxyquin, known as p-phenetidine, was capable of causing mutations in genetic material. 

There is a lack of scientific consensus on whether it is safe to eat farmed seafood raised on feed treated with ethoxyquin, but some countries have considered the risk to be high enough to justify banning or limiting the use of the chemical. In 2017, the European Commission suspended authorization for its use in animal feed across the European Union.

Today, ethoxyquin has been banned in the U.K. and by members of the European Economic Area, including Norway, Iceland, and Liechtenstein. But ethoxyquin, within limits, is still permitted in animal feed in Australia, Japan, South Korea, and the U.S.

With more than half of the seafood eaten worldwide now coming from fish farms, and with the majority of such species fed fishmeal and fish oil, studying the chemicals added to feed is critical for understanding the possible contamination of our global food supply.

Although ethoxyquin is not banned in the U.S., it has been at the center of a half-dozen lawsuits, typically involving claims of false advertising. Some lawsuits targeted seafood companies for marketing their products as “sustainable” even though they contained ethoxyquin, while others highlighted the potential risks that the additive poses to the environment. 

Fishmeal production at an Exalmar plant in Peru spans from unloading fresh catch through processing and bagging the final powdered product. Growing health concerns over substances like ethoxyquin are fueling debate about the future of additive use in the global fishmeal industry. Credit: Pesquera Exalmar

In 2022, a New York resident brought a class-action lawsuit against Aldi Inc., a German supermarket chain with stores in the U.S., alleging its Atlantic salmon products were falsely labeled as “sustainable” due to “environmentally destructive” practices. The complaint cited the EU’s ban on the chemical and a study linking ethoxyquin to mortality and deformations in fish and crustaceans, noting the chemical “poses a risk for aquatic life.” The case was settled out of court. 

The same year, a New York and a California resident jointly sued Gorton’s Inc., a seafood company, for labeling its frozen tilapia as “sustainably sourced” despite containing ethoxyquin. This lawsuit also cited the “risk for aquatic life” and the European Union’s ban, and was settled out of court.

In Canada, the country’s Food Inspection Agency requires feeds containing ethoxyquin to carry a label declaring that it meets the legal limits, but the agency does not specify how it tests for the chemical in feeds. Inspectors also do not check whether ethoxyquin ends up in the seafood itself, according to the agency’s latest food inspection report from 2022. 

And a 2024 audit of the Canadian agency by the EU found it completed only about 40 percent of its planned inspections, citing “systematic and significant under-delivery” in terms of testing seafood products.

Read Next Marine protected areas aren’t as protected as you think Joseph Winters

Cargill said in a statement that it has assessed alternative antioxidants since 2005 and no longer uses ethoxyquin in its global salmon feed business or in any market where ethoxyquin is not authorized for use in aquafeed. The company also noted that it did not develop ethoxyquin. Globally, producers and feed makers have also increasingly shifted to alternatives, including natural additives such as rosemary extract and vitamin E compounds.

“More and more destinations are not accepting ethoxyquin, starting with our local Peruvian market,” said James Frank, managing director of the Peruvian fishmeal company MSICeres, during a 2022 webinar. He added that 100 percent of Peru’s fishmeal exports to Europe, Canada, the U.S. and Australia are now ethoxyquin-free, a shift also seen among companies in the U.K. and Norway. 

The most popular alternative to ethoxyquin is now butylated hydroxyanisole, or BHA, favored for its lower costs and strong antioxidant properties compared with fully natural additives. But like the chemical it aims to supplant, BHA has its own significant health risks, according to researchers. 

The U.S. National Toxicology Program identified BHA as “reasonably anticipated to be a human carcinogen” as early as 1991, and Japanese researchers found it caused malignant tumors in laboratory rats in 2008.

In February, the U.S. Food and Drug Administration announced it was reassessing the safety of the substance as a food additive. 

To address the world’s insatiable hunger for seafood, the aquaculture industry will continue to expand. Perhaps there’ll be a shift away from carnivorous fish, or a replacement will be found for fishmeal. But for now, the aquaculture and fishmeal industries find themselves in a perilous loop: pivoting from deadly ship fires to a carcinogenic fire retardant, and then to yet another one.

This story is part of an investigation conducted by an international team of journalists based at The Outlaw Ocean Project. Read the other stories here.

This story was originally published by Grist with the headline The fire retardant in the seafood chain on Oct 17, 2026.

Australian developer snaps up portfolio of operating and developing wind and solar projects as a major European player decides to focus on its core markets.

The post One of Australia’s largest wind and solar portfolios sold as European developer retreats to core markets appeared first on Renew Economy.

16 October 2026 | RoyalDutchShellPlc.com

Shell has obtained permission from Canadian securities regulators to dispense with certain Canadian oil and gas reserves reporting requirements, following its multibillion-dollar acquisition of ARC Resources. Instead, the company will continue using its American securities reporting framework, subject to conditions that include filing the relevant disclosures in Canada. The decision may be a legitimate administrative accommodation for an international company already subject to extensive reporting obligations. But it also raises an important question about the information available to Canadian investors. For Shell, whose 2004 reserves scandal involved the overstatement of 4.47 billion barrels of oil equivalent, any change to reserves reporting deserves careful examination.

A regulatory announcement with a significant history

On 16 October 2026, Shell plc announced that it had received exemptive relief from Canadian securities regulatory authorities concerning future Canadian filings.

The announcement followed Shell’s acquisition of ARC Resources Ltd., completed on 2 September 2026.

That transaction made Shell a reporting issuer under Canadian securities legislation, creating additional obligations to provide ongoing financial and other disclosures.

One of those obligations concerned Canada’s National Instrument 51-101, known as Standards of Disclosure for Oil and Gas Activities.

Shell has now received permission not to comply with specified requirements under that instrument, provided it satisfies the conditions imposed by Canadian regulators.

Instead, Shell may provide oil and gas disclosures prepared under its existing American reporting framework.

The company must also make the relevant disclosures available through Canada’s SEDAR+ filing system.

Shell describes the decision as relief from overlapping regulatory requirements.

There is no suggestion in its announcement that the company has been excused from reporting its oil and gas reserves altogether.

Nor does the announcement establish that Canadian regulators have waived Shell’s broader securities-law obligations.

Nevertheless, the development is worth examining because reserves information is central to the valuation of an oil and gas company.

And in Shell’s case, the historical significance is considerable.

Original announcement: Shell receives exemptive relief from Canadian securities regulatory authorities regarding future Canadian filings — 16 October 2026

Why Shell suddenly became subject to Canadian reporting requirements

The immediate cause was Shell’s acquisition of ARC Resources, a major Canadian oil and gas producer.

ARC’s operations were concentrated in British Columbia and Alberta, including the Montney formation.

The Montney is one of Canada’s most important natural gas and liquids-producing regions.

Shell announced completion of the transaction on 2 September 2026.

According to its corporate announcement, the acquisition added approximately 370,000 barrels of oil equivalent per dayto Shell’s production portfolio.

The transaction was structured as a combination of cash and Shell shares.

Former ARC shareholders became entitled to receive CAD $8.20 in cash and 0.40247 Shell ordinary shares for each ARC share.

Shell valued the equity consideration at approximately US$13.9 billion at completion.

Including assumed net debt and leases, the enterprise value was approximately US$16.5 billion.

The acquisition was intended to strengthen Shell’s Canadian upstream business, particularly its exposure to natural gas and liquids production.

Shell’s chief executive, Wael Sawan, described the transaction as an opportunity to expand the company’s production portfolio and generate additional cash flow.

From a commercial perspective, the acquisition was substantial.

From a regulatory perspective, it also changed Shell’s position.

Because of the transaction, Shell became subject to Canadian reporting obligations that did not necessarily duplicate the requirements applicable to its existing international securities filings.

That created the basis for its application for exemptive relief.

Corporate source: Shell completes acquisition of ARC Resources — 2 September 2026

What exactly have Canadian regulators exempted Shell from?

The exemption concerns National Instrument 51-101.

This instrument establishes requirements for oil and gas disclosure by reporting issuers subject to Canadian securities law.

It addresses the reporting of reserves data and related information.

Under the normal Canadian framework, companies subject to the instrument may be required to provide annual reserves statements and associated evaluations and governance disclosures.

These include prescribed reporting forms.

Shell’s announcement specifically identifies Form 51-101F1, the Statement of Reserves Data and Other Oil and Gas Information.

It also refers to related forms and disclosure requirements.

Under the decision, Shell will no longer be required to prepare those particular Canadian filings as part of its annual reporting, provided the relevant conditions remain satisfied.

Instead, the company may use disclosures prepared in accordance with applicable American securities requirements.

Shell identified the US Securities and Exchange Commission, the Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002 and New York Stock Exchange rules among the applicable reporting framework.

That is a significant distinction.

The exemption permits substitution of an established international disclosure framework.

It does not grant a general licence to withhold reserves information.

The company’s announcement also states that the relevant American oil and gas disclosures must be filed with Canadian securities regulators through SEDAR+ as soon as practicable after they are filed with the SEC.

In short, Shell will not have to produce the same Canadian-specific reserves reporting package, but it remains required to provide the relevant American disclosures in Canada.

The question for shareholders is what differences, if any, that substitution makes to the information available.

An important additional detail: The regulator’s register refers to two instruments

The Alberta Securities Commission’s official exemption-order register records a decision concerning Shell plc dated 14 October 2026.

The entry identifies the decision as a dual decision involving two Canadian instruments:

• National Instrument 51-101 — Standards of Disclosure for Oil and Gas Activities.
• National Instrument 52-109 — Certification of Disclosure in Issuers’ Annual and Interim Filings.

This second reference deserves attention.

NI 52-109 concerns management certifications associated with financial reporting and disclosure controls.

Shell’s 16 October announcement focuses upon the oil and gas reserves reporting relief.

It does not provide the same detailed explanation of the NI 52-109 reference appearing in the regulator’s register.

Consequently, it would be premature to conclude that Shell has received any particular additional certification exemption without examining the operative decision and its conditions.

The register establishes that the second instrument is associated with the decision.

It does not, by itself, establish the precise scope of the relief under that instrument.

This is a matter that merits further documentary examination.

It also illustrates why the original regulator’s order is important.

Corporate announcements explain decisions from the company’s perspective.

The formal regulatory instrument establishes exactly what the authorities have authorised.

Canadian and American reserves reporting are not identical

Canada and the United States have well-developed systems for reporting oil and gas reserves.

Both are designed to provide useful information to investors.

However, their requirements are not identical.

Canada’s NI 51-101 framework is associated with the Canadian Oil and Gas Evaluation Handbook.

It provides a prescribed structure for reporting reserves and related oil and gas information.

Canadian disclosure commonly includes proved and probable reserves categories, as well as associated economic evaluations, subject to the applicable requirements.

The Canadian framework also places particular emphasis upon qualified reserves evaluators or auditors and management responsibilities for the reported information.

The SEC has its own definitions and disclosure rules.

Its mandatory proved reserves reporting framework includes specific requirements concerning reasonable certainty, economic producibility, pricing assumptions and other technical matters.

The SEC also permits or requires additional information in particular circumstances.

As a result, two companies with similar underlying assets might present reserves information differently depending upon the regulatory framework used.

This does not automatically make one framework more reliable than the other.

Nor does it mean that an SEC-reporting company necessarily supplies less information overall.

The issue is comparability.

For Canadian investors accustomed to NI 51-101 disclosures, the substitution of SEC reporting may alter the format, categories or assumptions used in the information they receive.

Investors must therefore understand the standards applied rather than simply comparing headline reserves figures.

For a company as large and geographically diversified as Shell, using a consistent international reporting framework may also avoid unnecessary duplication and conflicting presentations.

There is a legitimate administrative rationale for that approach.

The appropriate question is whether investors continue to receive sufficient, comprehensible and reliable information.

The historical shadow: Shell’s 2004 reserves scandal

Any discussion of Shell and reserves reporting inevitably recalls the events of 2004.

On 9 January 2004, the Royal Dutch/Shell Group announced that approximately 3.9 billion barrels of oil equivalent previously classified as proved reserves would have to be removed from that category.

Further reviews increased the amount.

By the completion of the regulatory process, the overstatement amounted to 4.47 billion barrels of oil equivalent.

That represented approximately 23 per cent of the proved reserves reported in Shell’s 2002 Form 20-F.

The disclosure caused an international corporate crisis.

Investors learned that Shell had previously overstated a fundamental indicator of its future production potential.

Senior management changes followed.

The company undertook extensive reviews of its reserves reporting procedures.

Regulators in the United States and the United Kingdom investigated.

The affair became one of the most serious corporate governance controversies in Shell’s modern history.

What the SEC actually found

On 24 August 2004, the US Securities and Exchange Commission announced settlement of enforcement proceedings involving Royal Dutch Petroleum Company and The Shell Transport and Trading Company.

The SEC’s findings were extensive.

According to the Commission, Shell had overstated proved hydrocarbon reserves in its 2002 Form 20-F by approximately 4.47 billion barrels of oil equivalent.

The SEC also found that Shell had overstated the standardised measure of future cash flows associated with the reserves by approximately $6.6 billion.

The regulator examined the company’s reserves reporting over several years.

It found deficiencies in internal controls and reporting procedures.

The SEC also addressed Shell’s reserves replacement ratio, a performance indicator closely watched by energy-sector investors.

The regulator concluded that the misstatements had created an inaccurate picture of Shell’s reserves replacement performance.

The financial consequences included a $120 million US civil penalty.

The companies settled without admitting or denying the SEC’s substantive findings.

Shell also undertook additional compliance measures.

The regulatory record is particularly important because it is not merely retrospective criticism from opponents of the company.

It is an authenticated enforcement record issued by the American securities regulator.

Primary historical source: US Securities and Exchange Commission — Royal Dutch Petroleum Company and Shell Transport Pay $120 Million to Settle Reserves Fraud Case, 24 August 2004

A second regulator also intervened

The UK Financial Services Authority also took enforcement action over Shell’s reserves reporting.

The British regulator imposed a substantial financial penalty and criticised the company’s disclosure practices.

The combined regulatory proceedings exposed weaknesses in the governance of a multinational oil company operating through an unusually complicated corporate structure.

The events contributed to fundamental changes in Shell’s organisation and management.

In 2005, the former dual-parent Royal Dutch/Shell structure was replaced by Royal Dutch Shell plc.

The 2004 reserves scandal was not the sole cause of that restructuring.

But it was a central part of the corporate governance crisis that preceded it.

For shareholders, the scandal illustrated a fundamental principle.

Reserves disclosure is not simply a technical exercise performed by petroleum engineers. It is a central component of corporate financial accountability.

Why reserves matter so much

An oil company’s reported reserves influence how investors assess its future.

They help inform expectations concerning production, revenues, cash flow and the economic life of assets.

Reserves reporting also affects assessments of whether a company is replacing the oil and gas it produces.

A company may report substantial current profits while facing long-term difficulties if it cannot replace depleted reserves economically.

That makes the distinction between discovered resources, contingent resources and proved reserves especially important.

Not every quantity of hydrocarbons believed to exist underground qualifies as proved reserves.

Classification depends upon technical, economic and regulatory criteria.

Prices, development plans, production rights and other assumptions can affect reported quantities.

When those estimates are materially misstated, investors may receive an inaccurate impression of the company’s future prospects.

That was one of the central lessons of Shell’s 2004 crisis.

COMMENTARY: An Administrative Exemption — But a Legitimate Shareholder Question

It would be wrong to portray the Canadian decision as evidence that Shell is concealing reserves information.

The available documents do not support that allegation.

There is also a straightforward argument in favour of the exemption.

Shell is an international company already subject to substantial securities reporting requirements.

Producing an additional Canadian reserves reporting package could impose costs without necessarily providing equivalent additional value.

Canadian regulators are entitled to consider whether an alternative disclosure framework provides adequate investor protection.

That appears to be the purpose of the arrangement Shell has announced.

However, shareholders also have legitimate reasons to examine what changes.

The relevant questions are practical.

Does the SEC framework provide all the categories of reserves information that Canadian investors would otherwise have received?

Are the valuation assumptions comparable?

Will reserve estimates relating to the newly acquired ARC assets be sufficiently transparent?

Are independent technical assessments required or disclosed to the same extent?

Will Canadian investors be able to locate and understand the relevant information without navigating several international reporting systems?

And what conditions must Shell continue satisfying to retain the exemption?

These questions do not imply wrongdoing.

They concern the effectiveness of disclosure.

The 2004 scandal is relevant history, not evidence of present misconduct

The temptation to connect Shell’s 2004 scandal directly with today’s exemption must be resisted.

The historical scandal involved material overstatements and regulatory findings concerning disclosure failures.

The present decision concerns permission to substitute one reporting framework for another.

They are not equivalent events.

No evidence examined for this article establishes that Shell’s current reserves are misstated.

No evidence establishes that the Canadian regulators have granted the exemption because of any improper influence.

No evidence establishes that Shell sought the exemption to conceal information from shareholders.

The historical connection is relevant because it demonstrates why accurate reserves reporting matters.

It does not justify treating the present regulatory decision as suspicious by default.

A credible independent archive must preserve that distinction.

The significance of the ARC acquisition

The scale of Shell’s acquisition of ARC Resources makes the issue commercially important.

The transaction added substantial production from Canadian assets.

It increased Shell’s exposure to North American gas and liquids.

It also brought former ARC shareholders into Shell’s shareholder base.

Those investors may have been accustomed to examining ARC’s disclosures under Canadian securities rules.

They will now need to assess Shell’s disclosures within a much larger international reporting framework.

The acquired Canadian assets will form part of Shell’s global portfolio.

Consequently, information previously available in a dedicated Canadian producer’s reporting may appear in a different structure or level of aggregation.

This does not necessarily mean investors will receive less reliable information.

But it makes the accessibility and comparability of information particularly important.

Shell’s decision to continue filing the relevant American disclosures through SEDAR+ is therefore an important protection.

The practical value of that protection will depend upon what information is actually provided and how readily investors can interpret it.

A question for Canadian regulators

The Alberta Securities Commission has publicly identified the exemption decision.

Shell has announced its principal effect.

The remaining task is to examine the complete decision and determine the exact conditions attached.

That examination should clarify the scope of relief under NI 51-101.

It should also establish the meaning of the NI 52-109 reference appearing in the regulator’s register.

The difference between a regulator’s formal decision and a company’s summary of that decision should not be overlooked.

For shareholders, the operative document matters.

It is the document that defines what Shell may do, what obligations continue and what circumstances could affect the exemption.

There is no indication that the authorities acted improperly.

The relevant question is whether the regulatory arrangement provides sufficiently clear and comparable disclosure for investors in Canada and elsewhere.

That is a legitimate subject for independent examination.

Conclusion: A Twenty-Two-Year Reminder of Why Reserves Transparency Matters

Shell’s Canadian exemption appears to arise from an identifiable administrative problem.

The company acquired a major Canadian oil and gas producer.

That acquisition created additional Canadian reporting obligations.

Shell applied for relief from certain requirements that overlap with its existing American reporting framework.

Canadian regulators granted the requested relief, subject to conditions.

The company must continue to provide relevant disclosures through SEDAR+.

On the available evidence, this is a reporting accommodation, not an exemption from securities accountability.

Nevertheless, it deserves attention.

Oil and gas reserves are central to the financial evaluation of energy companies.

Different reporting systems can produce different presentations of technically complex information.

And Shell has a documented history demonstrating the potentially serious consequences of inaccurate reserves disclosures.

In 2004, the SEC found that Shell had overstated proved reserves by 4.47 billion barrels of oil equivalent.

The resulting scandal damaged investor confidence and led to major regulatory penalties.

Twenty-two years later, that history remains relevant to the importance of rigorous and transparent reserves reporting.

It does not establish that anything improper has occurred in Canada.

But it does justify a continuing interest in how Shell reports the reserves underlying its substantial international operations.

The Canadian authorities have granted Shell regulatory flexibility. The essential shareholder question is whether the resulting disclosures will continue to provide investors with clear, reliable and comparable information.

That is the standard against which the exemption should ultimately be assessed.

Principal Documentary Sources

1. Shell plc — 16 October 2026

Shell Receives Exemptive Relief from Canadian Securities Regulatory Authorities Regarding Future Canadian Filings

The original company announcement identifying the relief from NI 51-101 requirements and the continuing requirement to file relevant US disclosures on SEDAR+.

2. Alberta Securities Commission — 14 October 2026

Official Exemption Orders Register

Primary regulator’s register identifying Shell’s decision and the references to NI 51-101 and NI 52-109. The complete operative decision should be consulted for the detailed conditions.

3. Shell plc — 2 September 2026

Shell Completes Acquisition of ARC Resources

Authenticated corporate announcement confirming the transaction, production volumes and acquisition consideration.

4. ARC Resources — 2 September 2026

ARC Resources Announces Closing of Acquisition by Shell plc

Independent corporate confirmation of the acquisition structure and completion.

5. US Securities and Exchange Commission — 24 August 2004

SEC Enforcement Announcement Concerning Shell’s Overstatement of Proved Reserves

Authenticated regulatory record establishing the 4.47 billion barrels of oil equivalent overstatement, deficiencies identified by the SEC and the $120 million penalty.

6. US Securities and Exchange Commission — Litigation Release No. 18844

Royal Dutch Petroleum Company and Shell Transport — SEC Litigation Release

Formal litigation record describing the settlement, applicable findings and additional compliance measures.

7. Shell — Historical Corporate Disclosure

Shell’s 2004 Reserves Review and Corporate Governance Measures — SEC-Filed Announcement

Contemporaneous company material documenting reserves reviews, management changes and remedial measures.

Editorial and Legal Disclaimer

This article is based upon Shell’s 16 October 2026 announcement, the Alberta Securities Commission’s public register, corporate acquisition records and authenticated historical SEC enforcement documents.

The Canadian exemption is an established regulatory decision. Its detailed conditions should be understood by reference to the complete operative document.

The regulator’s register identifies NI 52-109 alongside NI 51-101. The precise significance of the additional reference has not been independently established from the full decision.

The historical 2004 reserves scandal is presented as documented corporate history, not as evidence of present misconduct.

No allegation is made that Shell’s current reserves disclosures are false, misleading or incomplete, or that Canadian regulators acted improperly.

Editorial analysis is identified separately from established facts.

The website’s general disclaimer also applies.

Shell Wins Canadian Reserves Disclosure Exemption — Twenty-Two Years After the Scandal That Shook Investor Confidence was first posted on October 16, 2026 at 11:54 pm.
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CRA Meeting

The October 16 meeting is canceled. Too much pre-election activity and not enough rail activity. The next meeting will be November 6. The agenda and link will be sent to the mail list. If you need the link, email admin@climaterailalliance.org.

Caltrain, the San Francisco – San Jose – Gilroy commuter rail agency tried a new radical approach to declining ridership. When commuter rail service began in the US, well over 160 years ago, the majority of suburban dwellers traveled into the central city in the morning and left in the evening, Monday through Friday. Commuter rail service was structured for exactly those people. A very large percentage of people traveling to or from suburban areas are not traveling for a 9-5 job in the central city. Some people see the response to the decline as less service. Caltrain took the opposite approach.

Metra, the Chicago area commuter rail agency is purchasing eight to 16 battery-electric trains. The trains will use the Beverly branch of the Chicago-Blue Island route. This route is perfect for this type of train. Stations are about four blocks apart. There is a limited amount of parking; it’s mostly walk-up or bus transfer passengers. They will be in service in 2028. The purchase is part of Metra’s plan to convert from 9 to 5er commuter railroad to all day regional service.

On Friday, September 25, SeaPort air published a full page press release/advertisement in “businesswire:” ““Billions in New Trains, Same Slow Route: Boeing Field Air Service SeaPort Airlines is Making New Amtrak Trains Obsolete.”” Here is our response to that propaganda piece.

The UP-NS merger application is live at Surface Transportation Board. CRA opposes this merger. There are many ways in which this merger will have a bad outcome. Wall Street activist investors will be thrilled, however. Our colleagues at Solutionary Rail and Public Rail Now have an ongoing campaign that allows comments on the merger to be made anonymously to Surface Transportation Board.

Amtrak is exploring a corporate restructuring, intending to improve service. There is detailed information on Amtrak’s website. Deadline for feedback is Oct. 30, 2026.

This coming election day, Colorado will be voting an a ballot measure to provide a dedicated funding source for rail passenger service. In a Trains.com article, former Federal Railroad Administration Administrator Amit Bose and former US Department of Transportation General Counsel John Putnam promote the Colorado program as model for the next generation of passenger rail. A successful dedicated measure depends upon demonstrating that the proposed program will work. Colorado has done the homework with successful light rail and commuter service in the Denver region, laying solid groundwork for this next step.

The 2027 Washington State Legislative Session is about to begin. CRA, along with the other members of the Rail Can’t Wait Coalition have developed our Legislative Priorities for Washington, the list of things that rail transportation needs that we would like legislators to fund and enable.

The New Cascades Airo sets started service between Vancouver BC and Eugene OR on October 30. Trains will be introduced as they arrive from testing. Right now, you can see and ride them on Trains 503 and 508 between Seattle and Eugene and trains 516 and 519 between Portland and Vancouver BC.

CRA joined Solutionary Rail, Duwamish River Community Coalition, Reconnect South Park, and Georgetown Community Council in a comment letter responding to the 2026 Washington State draft Freight System Plan. The plan was effectively a plan for trucking. It contained almost no reference to rail at all, about which we commented at length.

Registered nurses at MedStar Franklin Square Medical Center in Baltimore, Md. voted on whether to join National Nurses Organizing Committee/National Nurses United in an election held on Oct. 14 and 15, 2026. The results were inconclusive at the end of the night, with challenged ballots still to be resolved.

A massive 244-tonne transformer has completed a 2,165 km road trip to the site of Australia's biggest solar project.

The post A massive 244-tonne transformer completes 2,165 km road trip to Australia’s largest solar project appeared first on Renew Economy.

A new rule recently released by the Trump Administration would give political appointees new powers to cancel funding agreements at will for a huge number of federal programs, including some USDA funding that goes directly to farmers.

The post Proposed Rule Threatens Farmer Funding and Undermines USDA Programs appeared first on RAFI.

Typical bills climb by over $100 a month as data centers demand more energy

RICHMOND, VA — Dominion Energy’s newly filed 2026 Integrated Resource Plan (IRP) update projects that the utility’s carbon pollution will more than double compared to last year’s plan while customer bills climb steadily for the next two decades. Under the IRP’s “preferred path” that the company submitted to Virginia’s State Corporation Commission (SCC), a typical residential bill for 1,000 kilowatt-hours would rise from $180.31 to $283.65 a month – an increase of more than $100 – as Dominion pursues nearly 9,000 megawatts of new gas-fired generation and six small modular nuclear reactors to meet a demand forecast driven in large part by new data centers. The company estimates its preferred plan will cost $91.5 billion, costs that will be passed on to customers through their electric rates.

Dominion’s preferred plan ignores state requirements on at least three accounts. While the update increases planned solar and battery storage over last year’s plan, the battery targets fall well short of recent statutory requirements (SB 448 / HB 895, 2026). Dominion’s calculations do not appear to square with Regional Greenhouse Gas Initiative requirements targeting zero tons of greenhouse gas emissions from large power plants by 2045. In addition, Dominion’s preferred path would keep its fossil fuel plants running past 2045, the date by which the Virginia Clean Economy Act (VCEA) requires them to close. Dominion now forecasts demand rising 2.8% a year, up from 2.5% in last year’s update, and expects its preferred path to emit 47 million metric tons of carbon dioxide in 2046 – up from 21.8 million in last year’s plan.

Victoria Higgins, Virginia Director of Chesapeake Climate Action Network (CCAN), issued the following statement:

“With every new energy plan, Dominion gives up a little more on the planet and jacks up rates a little higher to serve data centers. Now, as Dominion awaits a decision on NextEra’s proposed acquisition, it plans to double its pollution while the typical family’s bill climbs by more than $100 a month. 

Communities will see this plan for what it really is: a blueprint for billions of dollars in new gas plants to chase Big Tech’s appetite for power. The SCC must hold Dominion to the clean energy laws on the books, and Virginia leaders must rein in data center growth before it drains all of our natural resources, further punishes the poor and destroys the middle class.”

In July 2025, the SCC directed Dominion to model at least one scenario fully aligned with the VCEA, including the scheduled retirement of its fossil fuel plants. Dominion’s update sets that path aside in favor of a preferred plan that keeps gas burning. The preferred plan’s gas buildout does not even count the roughly 5 Gigawatts of gas plants Dominion has already proposed in Chesterfield and Cumberland counties. The update arrives as Dominion and NextEra seek state approval for a proposed merger that would create the largest regulated utility monopoly in the world.

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Chesapeake Climate Action Network is the first grassroots organization dedicated exclusively to raising awareness about the impacts and solutions associated with global warming in the Chesapeake Bay region. Founded in 2002, CCAN has been at the center of the fight for clean energy and wise climate policy in Maryland, Virginia, and Washington, DC.

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