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The Inflation Reduction Act of 2022: Tipping the Scale Toward Clean Energy

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The Inflation Reduction Act of 2022: Tipping the Scale Toward Clean Energy

by: Erica Lasdon | August 30, 2022

Boyertown, Pennsylvania (August 30, 2022) – Sweeping legislation signed into law this month by President Biden will allow for unprecedented investments to decarbonize the nation’s economy. The Inflation Reduction Act (IRA) earmarks the bulk of its $490 billion spending on clean energy and climate change mitigation initiatives.

Combined with other recent spending bills, the U.S. government is set to begin a period of transformative investments. The Rocky Mountain Institute, a clean energy think tank, notes that the combined bills will more than triple annual real federal spending compared with recent years, which was already elevated from levels of the 1990s and early 2000s.

While the IRA is far from perfect, advocates say it provides extraordinary opportunities for the conservation of our nation’s lands and waterways and includes significant resources for restoring wildlife habitats and forests.

The legislation is expected to reduce U.S. greenhouse gas (GHG) emissions to approximately 40%, compared to 2005-levels, by 2030. Without enactment of the IRA, the U.S. was on course to reduce its GHG emissions to only 26%, compared to 2005-levels, over this period, according to an analysis from the World Economic Forum.

For the U.S. to reach its emissions-reduction targets, it’s imperative that we begin to take action across the entire technology adoption curve. This means exploring: 

Existing technologies that are ready for market but not deployed. 
Solutions that require some further development to be market ready. 
Technologies that are only prototypes and need significant development.

Importantly, IRA resources will focus on the most hard-to-abate industrial sectors, such as electric power generation.

As widely reported, the IRA is projected to drive significant emissions reductions in the electric power sector. To a certain extent, this can lower production emissions in steel, cement, and other carbon-intensive industries. However, practical options to capture carbon from industrial processes and traditional energy production require substantial investment to help meet climate goals. The IRA addresses these challenges by creating incentives through a system of grants, loans, and tax credits, including making certain existing credits larger and more durable.

Here are a few key IRA provisions for companies and investors to be aware of:

Changes to 45Q, the existing tax credit for carbon capture and storage (CCS), make it more profitable and easier to access. Companies will be able to earn $85 for every metric ton of CO2 sequestered, rather than $50/ton previously. (The amount earned is less if the CO2 is buried during oil extraction.) The timeline is more favorable too. Previously, a company had to start building capture equipment by 2026. Now it’s 2033. The IRA also significantly lowers the minimum capture requirement.
Methane emissions are an urgent issue for many industries, as this type of emission is far more potent than carbon dioxide and hard to detect. For the oil and gas industry, investments in methane detection and a first-time federal fee on methane emissions will amplify existing initiatives within industry to tackle this problem. The IRA also funds grants, rebates, loans, and other assistance to facilities subject to the methane fee for a variety of measures, including adding or improving equipment and processes that reduce methane emissions.
Other long-term tax credits include clean hydrogen fuel development, direct-air-capture deployment, and advanced nuclear projects for heavy industry.

By driving down the cost of clean energy and other climate solutions, this approach may make it easier for companies and local governments to increase their climate ambitions. 

Regardless of your business’s sector, you will feel the impact of the IRA and related legislation. As the landscape shifts, companies and investors should factor an increasing rate of technological and systems change into their future plans.

Deep decarbonization is complex work that requires a diverse set of policy, legal, technology, and market solutions. Forthcoming investments by the U.S. government seek to put the country on a net-zero pathway. Importantly, investors and corporations have many tools available to assess their pathways to net-zero.

Since our founding, ClimeCo has been a leading transformation partner to companies, investors, and governments pursuing a low-carbon future.  As a vertically integrated sustainability solutions provider, we have enabled our clients to go beyond business as usual. By developing frontier technology- and nature-based carbon-reduction projects, transacting voluntary and compulsory environmental credits, and advising on climate risk and disclosure, our team is dedicated to implementing decarbonization pathways tailored to our clients’ specific sectors, business models, and balance sheets.

Please get in touch with us if you want to learn more about our:

Complete range of ESG Advisory solutions that help companies improve readiness and resilience in the ever-changing regulatory environment. 
Project Development capabilities around high-quality carbon projects that feature strong engagement with our project partners, local stakeholders, carbon registries, and credit buyers.
 
Environmental Credit offerings from projects we develop and projects we invest in.

About ClimeCo

ClimeCo is a respected global advisor, transaction facilitator, trader, and developer of environmental commodity market products and related solutions. We specialize in voluntary carbon, regulated carbon, renewable energy credits, plastics credits, and regional criteria pollutant trading programs. Complimenting these programs is a team of professionals skilled in providing sustainability program management solutions and developing and financing of GHG abatement and mitigation systems.

For more information or to discuss how ClimeCo can drive value for your organization, contact us at 484.415.0501, info@climeco.com, or through our website climeco.com. Be sure to follow us on LinkedIn, Facebook, Instagram, and Twitter using our handle, @ClimeCo.

Dispatches from the Nature-Based Solutions Conference

by: Emily Romano | August 25, 2022

Site visit by ClimeCo at a reforestation project in Louisiana

Nature-based solutions (NBS) are an important part of the work we do at ClimeCo, and they are a growing sector of carbon markets. NBS are defined as actions that restore, manage, and protect natural habitats for societal benefit, including mitigation and adaptation to the effects of climate change. These activities, such as reforestation, peatland rewetting, or grassland management, have received extensive media coverage in recent years and months as they play an increasingly important role in many corporate and national climate plans. Successful NBS projects have the potential to achieve a trifecta of climate, community, and biodiversity benefits, while poorly designed projects are rightfully criticized as a step backward for climate goals, human rights, and ecosystem health.

With this context in mind, I attended the Nature-based Solutions Conference in Oxford, UK, in July 2022, hosted by researchers at the Nature-based Solutions Initiative. Held in the beautiful Oxford University Museum of Natural History, the conference attracted a wide range of researchers, policymakers, activists, NGO members, and practitioners. Sessions addressed topics such as the global status and criticisms of NBS, inclusive project governance and narratives, improved biodiversity outcomes, the economics of NBS, and applications for urban environments.

I learned a lot from the speakers, whose presentations addressed the conference’s central question: “How can we ensure that NBS support thriving human and ecological communities?” In this blog, I summarize and share the key messages I took home from this conference.

Bodleian Library, Oxford University

Key Takeaways

Concern for Low-Quality NBS

With careful planning and consideration, NBS projects can provide powerful, sustainable, and cost-effective benefits to their host communities. Unfortunately, a number of low-quality NBS projects around the world have failed in recent decades. These failures are almost always due to protocols with inadequate provisions for permanence and additionality or a lack of robust safeguards of human rights and biodiversity.

The conference explored numerous concerns surrounding low-quality NBS, primarily those voiced by Indigenous and local communities regarding projects that have caused and perpetuated human rights abuses. These include land tenure injustice, displacement of people and livelihoods, and denial of community access to natural resources. This sort of project is often characterized by a top-down design without the active participation of the local community, prioritization of western value systems, and a lack of transparency or long-term monitoring requirements. Low-quality projects often result in ecosystem failures due to inappropriate species selection or project location or the establishment of monoculture plantations without regard for local biodiversity.

An additional concern voiced at the conference was that NBS not be used in greenwashing schemes by polluters to replace decarbonization efforts. While ecosystems play an important role in climate change mitigation and adaptation, they are not capable of compensating for delayed emissions reductions in other sectors. Speakers also highlighted the moral hazard of entities from the Global North who might seek to export the responsibility and the work of decarbonization to the Global South.

These concerns are critically important for improving NBS project outcomes. The conference’s primary focus was on how to address these concerns and included many examples of current best practices from around the world.

Tradeoffs, Inclusive Project Design and Governance, and Narratives

While many NBS projects generate desirable co-benefits or “win-win” results for society and biodiversity, projects may also generate tradeoffs that create tension between competing project goals. For example, biophysical tradeoffs might occur if a project prioritizes one ecosystem service at the expense of another. Social tradeoffs might occur between stakeholders with different cultural or spiritual valuations of nature or between those with scientific knowledge and those with Indigenous knowledge. Project developers must acknowledge and mitigate these tradeoffs in partnership with local stakeholders to account for the full range of project impacts.

One strong message from the conference was the critical role that Indigenous and local community members must play in all stages of NBS projects and the importance of free, prior, and informed consent. Numerous speakers pointed out that many Indigenous groups have traditionally implemented successful NBS within their own communities, and their knowledge can fill critical gaps in scientific understanding. The inclusion of these groups from the design to the implementation to the monitoring stage of a project is not only a basic indicator of respect but can also tangibly improve project outcomes.

Indigenous and community leaders from numerous countries, including Zambia, China, Tanzania, Peru, and the Democratic Republic of the Congo, presented case studies illustrating successful NBS outcomes in their communities. These presentations called for projects to distribute benefits equitably among community members, ensure a living wage, and create sources of long-term finance controlled by the local community. Finally, the speakers emphasized the critical importance of land tenure for Indigenous peoples.

ClimeCo meeting indigenous workers at a mangrove reforestation project in Indonesia

How to Prioritize and Adequately Represent Biodiversity

Another conference theme was the need for better metrics of biodiversity, so that progress can be adequately represented in project designs and monitoring plans. Speakers highlighted several scientific and technological advances, such as ecosystem DNA and high-resolution carbon mapping tools, which would facilitate project area prioritization and robust biodiversity assessment if implemented at scale.

However, some speakers quickly pointed out that “technology is not the solution. We are the solution.” In this vein, multiple speakers recommended that biodiversity monitoring plans utilize community monitoring approaches, including input from local and Indigenous groups regarding biodiversity metric selection.

Mangrove nursery managed and developed by the local community near the reforestation site

Creating High-Quality NBS

The conference delivered a crystal-clear message that projects that do not include robust provisions for human rights and biodiversity do not fall under the umbrella of the NBS term.

To avoid the pitfalls of low-quality projects, reputable carbon offset registries have developed meaningful standards for additionality and permanence and protocols that include protections for human rights and biodiversity. The most important feature of these protocols is that registries update them when a loophole is identified. Although these updates require months or even years to go into effect, this process allows registries to enforce ever-evolving concepts of “best practice.” For this reason, carbon offsets generated using the protocols of reputable registries, such as the Climate Action Reserve, Verra, the American Carbon Registry, and Gold Standard, are categorically distinct from low-quality offsets.

Regardless of protocol requirements, project developers are responsible for designing projects that adhere to best practices and meaningfully address the concerns of Indigenous and local stakeholders. Within the voluntary carbon market, project developers and carbon credit end-users must be able to recognize the indicators of a high-quality project and must be selective in the projects they choose to support.

ClimeCo’s NBS Approach

As offset project developers, the ClimeCo team always listens for new perspectives on best practices. We believe that NBS projects have enormous potential when they are designed carefully to empower and give voice to local communities. As sustainability advisors, we also feel a keen responsibility to help clients decarbonize wherever possible. Our ESG Advisory team provides many services essential to clients at any stage of their decarbonization journey. We encourage the use of offsets to address emission sources that are difficult or impossible to abate as a part of a larger decarbonization plan.

Most importantly, we understand there is no one-size-fits-all approach to NBS project development. We are grateful for each opportunity to earn a community’s trust and seek partners who share our accountability and responsible stewardship values.

ClimeCo’s Dr. Scott Subler observing freshly planted Bald Cypress saplings

Conclusion

I left the conference inspired by the incredible work being done worldwide to improve the implementation of NBS. ClimeCo will continue to listen and apply the guidance and feedback of the global NBS community, and I cannot wait to see the good our projects can do. ClimeCo is committed to informing you of new information discovered as we continue to explore in-depth NBS concerns. We welcome comments or questions surrounding this topic.

Anyone interested in watching conference sessions can access recordings and PDFs of presentations on the conference website (I recommend Session 4 and Session 9A). For those curious to see examples of high-quality projects, the Nature-based Solutions Initiative’s organizers directed us to their Case Study Platform, a map-based tool with over 100 examples of projects from around the world that meet the researchers’ quality standards.

About the Author

Emily Romano is a Project Manager at ClimeCo based in San Francisco. Within Project Development, she applies a background in climate, ecosystem, and soil science to her work managing NBS projects. She holds a Master of Science in Environmental Science and Policy from Northern Arizona University and a Bachelor of Science in Geology from Syracuse University.

State Climate Policy Trends: Action Amidst Federal Inaction

by: Wilson Fong and Braeden Larson | July 28, 2022

On June 30th, the Supreme Court ruled in the case of West Virginia vs. the U.S. Environmental Protection Agency that federal agencies, including the Environmental Protection Agency (EPA), have limited regulatory powers unless they have the explicit authority from Congress, otherwise known as the “major questions doctrine.” This decision limits the executive branch’s power to allow federal agencies to regulate significant economic and political issues. In this case, it limits the EPA’s power to regulate emissions reductions from power plants under the Clean Air Act. However, the decision made on the premises of the “major questions doctrine” will trickle down to all federal agencies’ regulatory operations that have been granted through executive power. Concerning climate change policy, this means the EPA is paralyzed from taking country-wide actions on emissions reductions until Congress gives the EPA regulatory authority. While some states have already been implementing emissions reduction regulations, this Supreme Court decision will necessitate states taking their own leadership roles in climate change policy.

States Are Taking the Lead

At the time of this writing, the U.S. Congress is split on how to address climate change: it’s either through Congress-approved regulatory action or through a neutral approach, where emissions reductions are driven by industry-led initiatives. As a result, the onus falls on the individual states to develop emission reduction frameworks that align with their political, economic, and environmental realities. There have always been states, like California, that have been at the forefront of climate action in the U.S., though there has been a recent uptick in new, state-level climate action, despite the mosaic of political and environmental positions existing throughout the U.S.

The emerging state-level approaches vary from general, all-encompassing, state-wide environmental climate action plans to more focused actions, such as those that singularly promote the build-out of carbon capture and storage (CCS). State-level climate action, through differing approaches, attempts to fill the holes in climate policy and abdication of regulatory authority at the federal level. At a high level, the key actions being taken can be broken down into four policy categories: State Action Plans, Carbon Pricing Systems, Low Carbon Products, and CCS and Class VI Well Primacy.

State Policy Categories: A Primer

To better understand the actions being taken and the implications they may have on your business, we will walk through the four policy categories below.

1. State-Wide Environmental Action Plans: State-wide environmental action plans are the overarching climate policy and strategy toolkits that can be used to reduce emissions and achieve sustainable environmental outcomes. Within these plans, states often include their climate goals, emissions reduction targets, and emissions baselines to ensure the policy and strategy toolkit is utilized to meet these targets. A typical toolkit may include a state’s environmental action plan, along with policies such as carbon pricing systems, greenhouse gas (GHG) reporting regulations, clean fuel standards, low carbon product bid-preference, energy efficiency requirements, and carbon capture and storage (CCS) deployment regulations. Multiple states have committed to environmental action plans with mid-century emissions reduction targets. Most recently, Maryland passed an environmental action plan under the Climate Solutions Now Act of 2022. Maryland has committed to being carbon neutral by 2045, with an interim goal of reducing GHG emissions by 60% by 2030, compared to 2006 emissions levels. Maryland’s Department of the Environment is required to submit a draft environmental action plan by June 30, 2023, along with the policy and strategy toolkit the state will be using to meet the 2030 and 2045 targets.

2. Carbon Pricing Systems: Carbon pricing systems are one of the most effective and efficient emissions reduction policies within the policy and strategy toolkit that are available to states. Carbon pricing systems internalize the economic cost of pollution and provide incentives to industries, governments, and individuals to reduce their carbon emissions. The two most popular systems are a carbon tax and a cap-and-trade system. A carbon tax sets a price per tonne of CO₂ emitted that is paid by all participants of the economy. A cap-and-trade system sets a cap on emissions for industries and businesses within covered sectors but allows for individual flexibility through the development of emission trading schemes. Washington state is currently finalizing its rulemaking processes for the Climate Commitment Act, which requires the enactment of a cap-and-trade program (known as cap-and-invest) on January 2023. The rulemaking includes provisions for setting the emissions cap, setting price floors and ceilings on allowances, GHG reporting, establishing emissions-intensive-trade-exposed criteria for industries vulnerable to international and inter-state trading, and establishing carbon offset usage rules.

3. Low Carbon Products: In an attempt to incentivize new technological innovation, some states have introduced and passed low carbon product procurement policies. These types of policies provide a bid preference for businesses that have reduced the embodied carbon emissions associated with producing the product. Other policies include the promotion of industrial recycling through regulation. The state of California is currently in the process of passing Senate Bill 1297 (SB 1297), which requires public agencies in the state to provide preference to low-embodied carbon building materials where feasible and cost-effective for public projects.

4. Carbon Capture and Storage, and Class VI Well Primacy: While perhaps the most inequitable policy category due to the availability of geological storage in different states, CCS regulations have the potential to lead to the greatest emissions reductions through the geological storage or utilization of industrial CO₂. Storing CO₂ in the Earth is predicated by the need for a Class VI well permit, which is issued by the EPA (federal jurisdiction). Class VI wells are used to inject CO₂ into deep rock formations. In an effort to support the build out of CCS in the U.S., the EPA has created a process to transfer permitting authority to states, thereby reducing administrative burden and improving efficiency. The current Class VI well landscape across the U.S. is fragmented due to the varied control over carbon sequestration rights, or ‘primacy’ over Class VI wells. Primacy identifies whether the Federal or State Government has enforcement authority over Class VI wells permitting. The vast majority of Class VI wells are under the direction of the U.S. EPA and follow a lengthy application process. As companies increasingly discuss and mobilize resources for CCS, the administrative burden on the U.S. EPA grows in parallel. The U.S. EPA lacks the staff and resource capacity necessary to take on a large number of Class VI well applications, which are necessary to sequester CO₂ in deep saline aquifers. For this reason, while states are developing regulations and action plans for CCS deployment and sequestration, they are also active in the primary enforcement application process with the U.S. EPA to take primacy over regulating Class VI wells within their state. To receive primacy over Class VI wells, the state must align its standards with the EPA. Class VI primacy is an enabling action that will support the rapid and widespread deployment of CCS throughout the United States.

Conclusion

In the absence of federal authority on climate change regulation, 24 states and the District of Columbia are establishing emissions reduction targets and implementing a plethora of emission reduction initiatives. While one of the most effective policies for reducing emissions is a carbon pricing system, the adoption of regulated carbon markets in the U.S. has been slow.

As states contemplate policy action to reduce the effects of climate change, it elevates the growing need for support of different technological, industrial, and nature-based policy solutions. With properly designed policies, states can support the deployment of CCS solutions and increase acceptance and demand for low carbon products, both of which have significant emission reduction potential.

ClimeCo has vast experience in a wide array of emission reduction initiatives and actively monitors developments throughout the U.S. Please contact us if you want to learn more about our Policy Team’s complete range of services that help companies improve readiness and resilience in the ever-changing regulatory environment.

Update Note: On July 27th, Senator Joe Manchin (D-WV) and Senate Majority Leader Chuck Schumer (D-NY) announced a deal to pass a budget reconciliation bill that would include $369 billion in spending towards climate and energy policies. Most of the incentives from this package are long-term tax credits, which include relief for clean hydrogen fuel development, direct-air-capture deployment, and advanced nuclear projects for heavy industry. Other tax credits are provided for renewable projects in the energy economy, new EV purchases, and residential retrofits for heating, cooling, and power. However, this announcement, as it stands, continues a federal trend to take a bottom-up approach to climate change, which leaves the states taking the regulatory lead on climate change.

About the Authors

Wilson Fong is an Associate on ClimeCo’s Sustainability, Policy, and Advisory team, based in Calgary, Alberta. Wilson collaborates with corporate clients to navigate the complexities of carbon markets, model their carbon position, and advise them on emission reduction strategies. He holds a Master of Global Business and Master of Science in International Business from the University of Victoria and Montpellier Business School.

Braeden Larson is a Policy Analyst on ClimeCo’s Sustainability, Policy, and Advisory team, based in Calgary, Alberta. Braeden supports the tracking and analysis of carbon policies throughout North America. He holds a Master of Public Policy from the University of Calgary and a Bachelor of Arts (Honours) with a major in Politics from Acadia University.

The ABCs of Proxy Voting and Its Role in ESG

by: Erica Lasdon | April 26, 2022

What is Proxy Voting?

Proxy voting is the primary means for shareholders to communicate their views about a company’s management. At most public U.S. companies, shareholders can vote annually to elect board members and approve executive compensation packages and other strategic proposals put forward by the company. This voting peaks from April through June, when most annual corporate meetings occur.

For decades, U.S.-based public corporations have also faced shareholder proposals at a company’s annual meeting. They are proposed by shareholders who meet minimum holding requirements set by the U.S. Securities and Exchange Commission (SEC). Resolutions tend to focus on a single, concrete call to action, such as issuing a report or establishing explicit board oversight for Environmental, Social, and Governance (ESG) issues relevant to the company. Rules require that the proposals be high-level and do not overstep management territory.

While non-binding, these proposals have been an important mechanism for interested investors to drive attention to ESG issues. Over the years, vote totals have risen out of the single digits for ESG resolutions. Still, many filed resolutions are withdrawn before being sent out for a broader shareholder vote. This entire process has formed the backbone for more active engagement between shareholders and company management. It has built a body of voluntary disclosure from companies that forms the basis for much of what we currently understand about material ESG business issues.

Long-term ESG Proxy Trends

Examining the trends in proxy voting is a powerful way to understand the general market views on corporate ESG practices. The overall trends are unmistakable and steady. The following charts¹ give a clear sense of how this process has driven the adoption of ESG in recent decades.

What to Expect in 2022

The 2021 proxy season featured record support for proposals on environmental and social (E&S) issues and continued strong support for governance proposals, especially at midsized and smaller companies. It also saw growing opposition to director elections. Part of this trend is explained by the increasing support by institutional investors such as BlackRock and State Street for ESG resolutions and against directors presiding over perceived inadequate climate or diversity oversight. These investors are also increasingly open to supporting dissident board nominees, potentially signaling a new phase in shareholder activism connected to longer-range strategic concerns about climate and/or diversity.

This shift in voting practices is likely to continue in the upcoming 2022 proxy season. What is creating this shift?

In general, institutional investors are moving more quickly to vote against companies, many shedding their more cautious approaches in past years, which showed deference to corporate management recommendations on resolutions. Large investors like BlackRock and State Street demonstrate this approach by signaling intent in annual public letters to vote against companies that lag on issues like climate and diversity.

Similarly, the proxy advisory services that provide influential analysis and recommendations to investors also signal ESG policy changes annually. Both ISS and Glass Lewis have signaled a more active ESG voting approach, especially on efforts to increase board oversight of crucial ESG issues like climate and diversity.²

We can perhaps get the clearest view of ESG during the 2022 season by looking at the leading edge of shareholder action, the investors filing the resolutions. The annual Proxy Preview published by three active groups (As You Sow, Sustainable Investments Institute, and Proxy Impact) highlights leading trends and gives specific details about pending resolutions. In March 2022, there were 529 filed resolutions, up 20% from 2021. The pie chart³ below shows the ESG topics at play this year:

In his introductory letter to this year’s Proxy Preview, As You Sow CEO, Andy Behar, draws these three main messages from 2022 resolution proponents:

1) Climate change affects each company and its supply chain, employees, and customers. Every company must cut emissions in half by 2030, and leading companies are already on the way.

2) Racial justice, gender equality, diversity, and equity are critical for talent retention and recruitment. Companies are starting to act by using clear metrics to quantify the problem and inform action.

3) Political Spending has become riskier in the era of polarized politics. Some companies restrict spending while others are challenged to explain incongruent corporate policies and political spending.

What Should Companies do to Prepare?

Public companies now have a clear obligation to provide disclosure on key ESG topics, driven by this market expectation. Corporate boards should ensure they are prepared to provide proper oversight of ESG topics and may be asked to participate in shareholder engagement more actively than in the past. Management teams should ensure that they get forward-looking information on significant ESG developments to efficiently allocate corporate resources towards necessary improvements.

What About Private Companies?

Private companies and investors in the private markets do not face the direct challenge of a shareholder resolution or proxy vote concern about director elections or other corporate-backed proposals. However, proxy season trends offer a useful window into expectations private market participants face on other fronts. Increasingly, requests for similar ESG information are expected as a part of other types of corporate financing. Private equity investors, banks, and other capital providers also seek to understand how large and small firms manage their most relevant ESG issues.

There are no public records of proposals or votes and less pressure to report on ESG issues publicly. Still, surveys of investors and other participants in private markets show a similar rising tide of interest in understanding relevant ESG issues. Private companies and investors can use many of the same tools as public market peers and can sometimes find customized guidance for their asset class.

Conclusion

As companies and investors face questions from stakeholders about their strategy on climate change and other ESG issues, ClimeCo is here to develop solutions that fit your needs. For more information or to discuss how ClimeCo can drive value for your organization, contact us at info@climeco.com.

Here are some recent resources offering guidance on many of the topics discussed above:

Resource	Author	Useful for
Materiality Finder	SASB	Investors/companies looking to identify material ESG issues by industry
A Climate Disclosure Framework for Small and Medium-Sized Enterprises	CDP	Investors/companies looking to establish climate disclosure for smaller companies
Audited Financial Statements and Climate-Related Risk Considerations	Center for Audit Quality	Audit Committees looking to build climate literacy
Technical Note: Reporting on Transition Plans	CDP	Investors/companies looking to develop transition plans from current disclosure
Guidance on Diversity Disclosures and Practices	State Street Global Advisors	Investors/companies looking to establish or enhance diversity disclosure
Navigating the Risks of Corporate Political Spending	Center for Political Accountability	Investors/companies looking to establish or enhance political spending oversight

[1] “The Long View: US Proxy Voting Trends on E&S Issues from 2000 to 2018,” Kosmas Papadopoulos, Managing Editor, ISS Analytics, published on 1/31/2019 at the Harvard Law School Forum on Corporate Governance.

[2] “Heads Up for the 2022 Proxy Season,” Weil, Gotshal & Manges LLP, 12/22/21, https://governance.weil.com/latest-thinking/heads-up-for-the-2022-proxy-season-iss-and-glass-lewis-release-voting-policy-updates-for-2022.

[3] Proxy Preview 2022, p.5, available at https://www.proxypreview.org/.

About the Author

Erica Lasdon is Sr. Director, Capital Markets on ClimeCo’s Sustainability, Policy, and Advisory team based in Washington DC. Erica specializes in applying ESG to financial company operations, with deep expertise in engagement, proxy voting, and investment functions across a wide range of asset classes. Erica holds a B.S. in Biology and a B.A. in History from the University of California, San Diego and served on the development team for the Sustainability Accounting Standards Board’s Level II exam for the inaugural FSA credential.

What Is The Role Of Renewable Electricity In Corporate Sustainability?

by: Garrett Keraga | March 28, 2022

In 2022, it seems that we’ve reached a crescendo of pressure from regulators, investors, customers, peers, and other stakeholders pushing companies along a sustainable path. Things that were once considered exceptional – such as pledging to reach net-zero carbon emissions or using 100% renewable electricity – have quickly become necessities for many companies to keep up with their peers. When we look back at the sustainability landscape over the last few years, it’s easy to see how this sudden boom of ESG has led to some confusion.

As companies enhance their ESG strategy and commit to public-facing initiatives, it becomes crucial to understand how different interventions factor into their corporate carbon accounting. How can carbon offsets be used? Where can companies account for renewable energy? What projects can be undertaken to decarbonize? And ultimately, which of these efforts should be prioritized in an ESG strategy? Companies need to be able to answer these questions and communicate their strategy effectively to stakeholders. In this blog, we explain the role renewable electricity has in corporate sustainability.

How does renewable electricity factor into corporate carbon accounting?

Renewable electricity is often one of the first levers considered when creating a corporate ESG strategy, and the global transition to clean energy is accelerating every year. Bloomberg reported that global renewable energy investment grew by 6.5% in 2021 to a new record of $366 billion. For companies, switching to renewable electricity can be just part of a decarbonization strategy, or specific goals around renewable electricity consumption can be set, such as those set through RE100. When companies plan out renewable electricity adoption, there’s a lot to decipher.

First, companies need to understand how to account for renewable electricity in their carbon footprint. For this, as with all carbon accounting questions, companies will want to reference the Greenhouse Gas (GHG) Protocol, and here specifically – the Scope 2 Guidance. Scope 2 covers indirect emissions from purchased electricity and other purchased energy – basically, the emissions created by the generator of that electricity when the generator is not operated by the company conducting the carbon inventory. For most companies, this refers primarily to electricity from the grid.

Location-based Accounting: Within Scope 2, one option is to account for electricity emissions with a location-based emission factor, where reporting entities use an emission factor based on local grid mix to determine their emissions. This doesn’t allow for contractual instruments, such as Renewable Energy Credits (RECs), to be used to switch generation attributes and lower emissions.

Market-based Accounting: However, the other option – market-based accounting – allows for consumer choices in energy generation and contractual instruments to be reflected in the emission factor. In other words, continuous contracts with a supplier to use a renewable generation, or one-time REC purchases, can be accounted for in the market-based approach. Companies that are considering building renewable electricity into their ESG strategy should utilize a market-based carbon accounting approach for Scope 2.

What renewable electricity options are available to companies?

Option 1: RECs are a common entry point for companies starting to use renewable electricity. RECs represent a certified unit of electricity production from a generator. RECs must be retired on behalf of a specific entity, and once retired, that electricity generation cannot be accounted for elsewhere. RECs are often third-party-certified by entities such as Green-e® Energy. As more RECs are retired, the remaining grid mix, called the “residual mix” gets dirtier, further incentivizing companies to adopt renewable electricity. RECs can be simply purchased in bulk and used to switch a company’s entire electricity consumption to renewable sources each year. Similarly, companies can work with utilities to opt into low-carbon energy contracts, which often work by providing RECs to the purchaser. However, some critics argue that purchasing renewable electricity through RECs stunts companies’ impact on increasing the total amount of renewable electricity on the grid. Companies will also often seek to move beyond RECs to avoid the annual expenditure and price uncertainty in their renewable electricity supply.

Option 2: Onsite generation is another choice for companies, especially those that own property and/or their facilities. Rooftop solar is one popular example. Onsite generation can also occur in leased or rented spaces through collaboration with landlords. This strategy is most often employed in facilities or properties where a company has a long-term lease and plans to stay in a particular location for the foreseeable future. Companies should note that they can only take credit for renewable electricity that is generated onsite if they use power directly from their system or retire RECs generated by their systems on their own behalf. If RECs are sold, that company cannot take credit for the renewable electricity it produced on its site.

Option 3: Many companies who don’t have the assets to invest in onsite renewables opt instead to pursue a Power Purchase Agreement (PPA). In a low-carbon PPA, companies will pay a third-party to develop and maintain a renewable electricity system and sell that energy physically or in the form of credits back to the company. When credits are sold back to the company, but the electricity itself is consumed elsewhere or sold to the grid, these agreements are called Virtual Power Purchase Agreements (VPPAs). Typically, companies will size a PPA based on their energy consumption and will often develop a project along with other interested companies.

In all of these cases, renewable electricity can be accounted for in a company’s carbon footprint, as long as the company uses the market-based approach for Scope 2 accounting and retires the renewable generation credits on their behalf or directly consumes renewable electricity.

Source: GHG Protocol Scope 2 Guidance (linked above)

“Additionality” in renewable electricity – is it an effective or appropriate metric?

In the world of carbon offsets and project development, “additionality” is a strict qualifier that assesses whether a project was caused by intervention above and beyond regulation. To be additional, it must be determined that a project would not have happened without the intervention of the entity supporting the project. When evaluating what type of renewable electricity strategy to pursue, companies tend to ask themselves about additionality and whether they are supporting a new project – through a PPA, for example. But is this term really applicable to renewable electricity?

Ultimately, additionality isn’t a term that should be used to discuss renewable electricity. The GHG Protocol Scope 2 Guidance advises that “Offset additionality criteria are not fundamental to, or largely compatible with, the underlying rules for market-based scope 2 accounting and allocation.” Additionality is used to qualify projects that are an improvement over a baseline. For example, in carbon offset projects, what is being measured is a change in avoided GHG emissions from a theoretical baseline without intervention. In renewable electricity, direct energy use attributes are being claimed rather than separation from a baseline. It’s also a challenge to determine what is really “in addition” to regulation in the world of renewable electricity. On top of that, there are more aspects of additionality as used in project development, like proving that technology isn’t commonplace, which aren’t useful to apply to renewable electricity.

That said, companies may still face criticism if it’s perceived that they aren’t doing enough to support the development of new renewable electricity sources. Voluntary programs can be developed to address this concern, but for now, companies should stray away from the term “additionality” to avoid making a false claim. In the words of the GHG Protocol Scope 2 Guidance “Maximizing the speed and efficacy of voluntary initiatives in driving new low-carbon development is an important, complex, dynamic, and evolving process for program implementers, regulators, and participants.”. Supporting development of new renewable assets is an ongoing challenge that companies can help accelerate as they increase demand for renewable electricity.

Creating a corporate renewable electricity strategy

As companies face the challenge of adopting renewable electricity and developing a robust plan to meet stakeholder demands, ClimeCo is here to develop a strategy that is right for you. For more information or to discuss how ClimeCo can drive value for your organization, contact us at info@climeco.com.

About the Author

Garrett Keraga is a Manager on ClimeCo’s Sustainability, Policy, and Advisory team based in Burlington, Vermont. His sustainability work has included greenhouse gas accounting, carbon abatement planning, ESG strategy development, and disclosure advisory. He has worked with a large variety of industries, both across consumer-facing and industrial clients. Garrett holds a Bachelor of Science in Mechanical Engineering from the University of Vermont.

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