Latest / PwC's accounting podcast / Sustainability now: “Clearing the air” on GHG Protocol updates
Transcript
- 0:00SPEAKER_00: Thought leadership from PWC's national office.
- 0:10SPEAKER_03: Hello, I'm Heather Horn, PWC's U.S.
- 0:13SPEAKER_03: sustainability technical leader, and welcome back to PWC's Accounting Podcast.
- 0:19SPEAKER_03: This is Sustainability Now.
- 0:21SPEAKER_03: In today's episode, we're discussing some of the latest developments from the GHG protocol, including its broader modernization efforts, the recently issued land sector removal standard, and the new Actions and Market Instruments request for feedback and white paper.
- 0:35SPEAKER_03: That's a mouthful.
- 0:36SPEAKER_03: To help walk through these developments, I'm happy to be joined once again today by Colin Powell, PDBC Canada partner, a member of the GHG Protocol Scope 3 Technical Working Group.
- 0:47SPEAKER_03: A couple quick notes before I get started with Colin.
- 0:49SPEAKER_03: If you're listening and would like to watch our discussion, please check out the show notes for a link to the video, as well as additional sustainability reporting resources and prior episodes featuring Colin discussing developments at the GHG protocol.
- 1:02SPEAKER_03: All right.
- 1:03SPEAKER_03: Colin, so nice to have you back.
- 1:05SPEAKER_03: Thanks for having me.
- 1:06SPEAKER_03: So we have so much to talk about today.
- 1:07SPEAKER_03: We're gonna have to squeeze it in.
- 1:10SPEAKER_03: Definitely a lot going on though.
- 1:12SPEAKER_03: From your perspective, what is sort of key developments updates you think companies should be most focused on?
- 1:18SPEAKER_01: Yeah, I think I mean there's a lot of different parts, different moving parts of the protocol that's that's going on right now.
- 1:23SPEAKER_01: I think the scope two consultation closed.
- 1:26SPEAKER_01: They got 1,443 responses, I think.
- 1:29SPEAKER_01: So that's obviously, yeah, they're working through that right now.
- 1:32SPEAKER_01: And I think there's been some public comments from different corporates as well, like maybe being a bit louder about their public consultation responses.
- 1:39SPEAKER_01: So we'll see where that comes out.
- 1:41SPEAKER_01: Um, you mentioned uh the land sector removal standard, which was out at the end of January, which is really exciting, but we're we're getting a lot of feedback on the side.
- 1:50SPEAKER_03: Yes, I'm looking forward to talking about that one.
- 1:52SPEAKER_01: And then you mentioned actions and market instruments.
- 1:54SPEAKER_01: And I think the the feedback they're asking for is a lot of like, are we going down the right path here?
- 1:59SPEAKER_01: Is there something maybe we should prioritize or stop doing in that?
- 2:03SPEAKER_01: I think they're they're asking the right questions because they've only gone so far, and and I think there is a lot to comment on what they put put out.
- 2:10SPEAKER_03: All right, well, I think you just gave us an outline for the podcast.
- 2:13SPEAKER_03: Before though, call and we get started.
- 2:15SPEAKER_03: One question that I comes up often for me is that a lot of companies we're working with here in the US, and then globally, obviously, are preparing for reporting in California.
- 2:26SPEAKER_03: So obviously they're directly impacted by the GSU protocol.
- 2:30SPEAKER_03: Sometimes the question we get is that I'm an ESSRS reporter, or I'm going to be reporting under the ISSB standards, and they've specified versions of the protocol.
- 2:41SPEAKER_03: So why should I pay attention to what's going on?
- 2:45SPEAKER_03: And how do you respond to that question?
- 2:47SPEAKER_01: Yeah, it's interesting because I mean the California reg doesn't mention a specific version of the JSU protocol, but then ISSB, ESRS do mention like the exact year of the standards you're supposed to look at.
- 2:59SPEAKER_01: So I think that will be an interesting development to follow going forward.
- 3:02SPEAKER_01: And I wonder if California will put some more specificity in there just to be clear.
- 3:06SPEAKER_01: But ultimately, the big question is okay, well, if this protocol is going to change, when do I have to start adopting it?
- 3:12SPEAKER_03: Yeah.
- 3:13SPEAKER_01: Um, so the most recent date we've we've seen for a release of the standard is early 28.
- 3:18SPEAKER_01: Um, and then it remains to be seen when it will be effective after that, which is a big question, which is a question around the land sector removal standard as well.
- 3:25SPEAKER_01: So I think ultimately we're helping clients just understand what potential changes are more likely than not.
- 3:31SPEAKER_02: Yeah.
- 3:31SPEAKER_01: Um, and how to do some of those no regrets moves.
- 3:34SPEAKER_01: Yeah.
- 3:34SPEAKER_01: One of the things we're looking at a lot is that move from operational control to financial control and just getting companies just comfortable with what that looks like, working with the finance function to see what it could look like, and if there are actually any big changes.
- 3:46SPEAKER_01: I think that's probably one of the bigger ones we're getting at.
- 3:48unknown: Okay.
- 3:50SPEAKER_03: Although that one, I it's so interesting because um, so we're recording this, I guess, on May 7th, because on May 6th, the European Commission issued the draft revised ESRS, and they are now suggesting that you can use any form of organizational boundary.
- 4:06SPEAKER_03: So that is not the subject of this podcast, but it is an interesting point.
- 4:09SPEAKER_03: I guess one thing though, you know, when we're talking to, in particular, companies that are reporting under ESRS or ISSB standards, is that even if this guidance isn't going to come into effect right away for you, I think two thoughts.
- 4:24SPEAKER_03: One is it's obviously direction of travel.
- 4:27SPEAKER_02: Yeah.
- 4:27SPEAKER_03: And then also if it's addressing things for which there is no guidance, then at least to be aware of what's out there, we think is important.
- 4:36SPEAKER_03: So again, that's probably a whole other conversation.
- 4:38SPEAKER_03: But just in case that we have some of those people listening, I wanted to at least give some context before we get into it.
- 4:44SPEAKER_01: Yeah, I think, I mean, there's still like a lot of work to be done on data quality.
- 4:48SPEAKER_01: And I think that will be a big push from the like the end version of the standard is you know not forcing data quality, but exploring different ways to get there and ultimately incentivizing companies to get better data quality because that'll help your decarbonization journey at the end of the day.
- 5:02SPEAKER_01: And so, like, that is a no-regrets move.
- 5:04SPEAKER_01: Start understanding where the data is in your in your uh company, how to get it, and what you can do to actually manage it.
- 5:10SPEAKER_01: And so that that's the other side.
- 5:11SPEAKER_01: So, how do you automate your inventories?
- 5:13SPEAKER_01: How do you maybe look at third-party software that can help you actually do things easier and better?
- 5:18SPEAKER_01: How are we using AI to actually start to think about these things?
- 5:21SPEAKER_01: I think that's that's probably the the other big question we're getting is like, hey, what do I do about AI?
- 5:25SPEAKER_01: Like, I have an Excel sheet.
- 5:27SPEAKER_01: Yeah.
- 5:27SPEAKER_01: Can I use AI?
- 5:28SPEAKER_01: And so, like, I mean, we're we're starting these conversations, right?
- 5:31SPEAKER_01: Because the answer is becoming yes, um, with new models like Cloud, like they can really manage Excel files.
- 5:37SPEAKER_01: So a big question is, you know, what third-party software should I get or should I just stay with Excel?
- 5:42SPEAKER_03: Yeah, it's interesting.
- 5:43SPEAKER_03: I think again, another podcast, but obviously the data quality question is completely um standard agnostic.
- 5:51SPEAKER_03: So for all entities, that's something to focus on.
- 5:54SPEAKER_03: So, anyway, there's something here for everyone today.
- 5:56SPEAKER_03: I think we've already mentioned two more podcasts we need to have.
- 5:59SPEAKER_03: So, with that, let's get into some of the meat of it.
- 6:02SPEAKER_03: So, you mentioned the scope to public consultation.
- 6:05SPEAKER_03: PwC's response is obviously available on Viewpoint.
- 6:07SPEAKER_03: And you and I have previously talked about some of um the themes that PWC focused on in responding.
- 6:14SPEAKER_03: And uh are there any you would like to highlight again?
- 6:18SPEAKER_03: Because then I want to talk a bit more broadly about themes, if any, that we know that we're hearing from other um people who responded.
- 6:24SPEAKER_01: Yeah, I think our response, which was generally like we uh uh really admire the ambition, we we encourage the ambition, but the requirements are probably too far too soon.
- 6:34SPEAKER_01: Um I think that's pretty consistent with our clients' responses.
- 6:37SPEAKER_01: Like we I'm I'm probably putting it quite nicely uh compared to the things I've heard.
- 6:43SPEAKER_01: And so I think that's that's pretty consistent.
- 6:45SPEAKER_01: I actually haven't heard many people being like, I love this.
- 6:48SPEAKER_01: Yes, let's go.
- 6:49SPEAKER_01: Uh, and I would love to hear from those folks.
- 6:51SPEAKER_01: So just different conversations I've had in the like electricity value chain or even those who are just procuring uh electricity is just a big challenge with the implementation of this.
- 7:00SPEAKER_03: Yeah.
- 7:00SPEAKER_03: And I think one thing that impacts everything we're talking about today is complexity.
- 7:06SPEAKER_03: And I think this is where there's like a point of tension between people who are looking at this and saying, okay, but some of the way reporting is done now, there's too many gross assumptions, is actually not that accurate.
- 7:19SPEAKER_03: Um, we can do all of these things to make it more accurate.
- 7:22SPEAKER_03: And I know you're coming at it from more of a science background.
- 7:25SPEAKER_03: And then from a reporting perspective, I think thinking about the fact of level maturity of companies and people, do they have the bandwidth to deal with this?
- 7:34SPEAKER_03: And do we need some basic level of reporting first before we try to get to this level of accuracy?
- 7:41SPEAKER_03: But again, because you come from more of the scientific background, how do you do you get uncomfortable because you can really see some of the limitations in the current reporting?
- 7:52SPEAKER_03: Or do you understand like where's what where are where we're gonna be able to do that?
- 7:55SPEAKER_01: Yeah, I mean, you're actually hitting on the some of the criteria we use in the working groups to decide on changes, right?
- 8:00SPEAKER_01: Like, do the changes support uh global like climate science?
- 8:04SPEAKER_01: Are they credible within the global climate science community?
- 8:07SPEAKER_01: But then also are they feasible to implement?
- 8:09SPEAKER_01: So, I mean, it is a bit of a balance there.
- 8:10SPEAKER_01: And I and I have the same approach.
- 8:12SPEAKER_01: I'm I'm uh an engineer, I'm I'm pretty technical on these things, but I'm not going to force to the nth degree of accuracy because I know it's it's not really decision-useful information at the end of the day.
- 8:22SPEAKER_01: I think that's that's a big response we've gotten is you know, if we go and implement the the scope two standard as it is and and as far as it goes, like are we actually getting better information to decarbonize or you know, drive energy efficiency or change electricity sources?
- 8:39SPEAKER_01: Like, is that actually what's going to get us there?
- 8:41SPEAKER_01: And and I don't see that today, but um, maybe with some of the consultations, when they summarize it, we might see some new stuff come out of it.
- 8:48SPEAKER_01: Because you know, we only see it's talk to so many people.
- 8:51SPEAKER_01: Right.
- 8:51SPEAKER_03: No, it's fair.
- 8:52SPEAKER_03: And it's it is interesting because at some point, even if let's say a proposed, you know, hourly and like really hyper-local uh and that type of information would provide better results to the extent that it's not available, then you're gonna use so many assumptions that are you just better off the way you are.
- 9:11SPEAKER_03: So I think the reason I brought that up here, and I know we've talked about extensively on prior podcasts, is I think that is a perfect lead-in to our next discussion, uh, which is the land sector and removal standard.
- 9:24SPEAKER_03: And I think this is one that's been a long time coming.
- 9:28SPEAKER_03: And then when it came out, I think there were various reactions.
- 9:32SPEAKER_03: Uh, but for our listeners who have not followed this as carefully, can you just give a high-level summary of what it is?
- 9:38SPEAKER_03: And probably we should talk about who this is going to apply to, because I think it's broader than people may think.
- 9:43SPEAKER_01: Yeah, yeah.
- 9:43SPEAKER_01: So it provides a standard and approach to quantify emissions from uh things like land use change, um biogenic emissions, um, land leakage, which was one of the more controversial parts where if you cause a change in a land use, like is it actually causing displacement of food?
- 10:02SPEAKER_01: Um, and so requiring more land somewhere else uh to create that food, for example.
- 10:08SPEAKER_01: Um so so very complex um emission sources and emissions quantifications, which have have fed into this standard.
- 10:15SPEAKER_01: And now, I mean, we're seeing companies review it, and those companies are the first question is like, is this applicable to me?
- 10:21SPEAKER_01: So who is it applicable to?
- 10:23SPEAKER_01: Obviously, those in the agricultural sector.
- 10:26SPEAKER_01: So you're making food, you're making um cotton, things that go into clothes.
- 10:29SPEAKER_01: Yes.
- 10:30SPEAKER_01: Those that are obviously directly impacted by it, but uh companies who have those uh sources in their value chain as well.
- 10:37SPEAKER_01: So if I'm making clothes, if I'm a retailer, like they have significant emissions or may have significant emissions that are those emission sources, so would practically have to apply.
- 10:47SPEAKER_03: Um Although again, if I think I'm a retailer, I'm selling clothes, and I'm selling lots of clothes.
- 10:54SPEAKER_03: Trying to trace back and then think about understanding what is happening from a land use perspective.
- 11:00SPEAKER_03: I mean, it's exponentially complicated.
- 11:02SPEAKER_01: Very much so.
- 11:03SPEAKER_01: But I think you are seeing seeing some specific approaches that work for companies because especially in the retail sector, clothes, food, you maybe see a bit more of an advantage to like a lower carbon or a um uh some sort of advantage there on price.
- 11:20SPEAKER_01: Maybe other sectors you don't see this.
- 11:21SPEAKER_01: So there may be some incentives in some sectors, in some geographies, and very specific commodities where you might see benefit.
- 11:28SPEAKER_01: I think one of the better examples we've seen is um like the idea of regenerative agriculture.
- 11:33SPEAKER_01: And you see this, it's a bit of a buzzword.
- 11:35SPEAKER_01: A lot of um like customers may be like, oh, that's cool, but I don't know exactly what it is.
- 11:40SPEAKER_01: And actually, there were a few um I think cases brought in the UK, maybe one in the US, against companies using that language.
- 11:47SPEAKER_01: And this standard could actually help um like uh give an actual approach to calculating it, to showcasing it.
- 11:53SPEAKER_01: So it's that credibility it's supposed to impart.
- 11:56SPEAKER_02: Yeah.
- 11:57SPEAKER_01: Uh it's the implementation that will be a big challenge.
- 11:59SPEAKER_01: I think even understanding the data that comes out of applying the standard will be a challenge for most customers.
- 12:04SPEAKER_01: But that's the point.
- 12:05SPEAKER_01: It's it's supposed to uh give a lens of credibility to these things.
- 12:09SPEAKER_03: It's really funny the regenerative agriculture.
- 12:12SPEAKER_03: I almost started laughing literally this weekend.
- 12:14SPEAKER_03: I was in the grocery store, and I love dried coconut, and there's dried coconut, regenerative agriculture, like all over it.
- 12:23SPEAKER_03: And then all the claims on the back.
- 12:25SPEAKER_03: So I actually had to go research and say, like, is this and it actually looked fairly legitimate, but I just thought it's funny that I hadn't really focused on that term, and then I obviously it's come up a lot more.
- 12:36SPEAKER_03: And you're right, lots of claims about uh regenerative agriculture when you start buying food now.
- 12:42SPEAKER_03: So one of the things I mean, we've done a lot of so I'm starting a lot of people.
- 12:48SPEAKER_03: I think are starting from not a lot of knowledge of this particular part of DHG emissions, like electricity, you know, that's easier to get your head around.
- 12:56SPEAKER_03: But this idea of like, I have a field, I plow the field, I plant something on the field, uh, what's on the field gets harvested, like all of those activities creating emissions and how that life cycle works, I think is incredibly complicated.
- 13:11SPEAKER_03: Very much.
- 13:12SPEAKER_03: And so, what are you seeing from companies that maybe haven't focused on this as much in terms of their ability to start to understand it and to get up to speed on what's required?
- 13:21SPEAKER_01: Yeah, and I think we're we're telling companies to take it slow.
- 13:24SPEAKER_01: And so obviously look at the full spectrum of the activities that you actually do.
- 13:28SPEAKER_01: It's obviously easier for like a pure play agriculture company than a larger like investor who has maybe a lot of funds that are focused on different things.
- 13:37SPEAKER_01: And so start starting to understand does it actually apply to you, first of all?
- 13:40SPEAKER_01: And the language of the standard says, do you have significant emissions in the land use sector?
- 13:46SPEAKER_01: And so that's obviously not well defined for a lot of companies.
- 13:49SPEAKER_01: And so you kind of have to understand, you know, what that significance means to you to be able to start to do it.
- 13:54SPEAKER_01: And so obviously there's no number there, but would it benefit you because it's currently a voluntary standard to actually apply the standard and help communicate to um your although it's not voluntary for very long, yeah, for very long, for very long.
- 14:08SPEAKER_03: Because I mean, again, just for our listeners, I mean it's effective for reports issued after January 1, 2027.
- 14:16SPEAKER_03: Yeah.
- 14:16SPEAKER_03: So it's basically effective now.
- 14:18SPEAKER_01: And I guess from an assurance perspective as well, like it's creating implications there if you're in accordance with the protocol.
- 14:24SPEAKER_03: I mean, I guess if you're issuing a report between now and then.
- 14:26SPEAKER_03: So okay.
- 14:27SPEAKER_01: So Yeah, so so I mean, it could be even more, right?
- 14:30SPEAKER_01: But ultimately, like, is it important for your readers of your reports or other uh data you're putting out there to understand the emission sources there?
- 14:37SPEAKER_01: So that's like step one.
- 14:38SPEAKER_01: But then because there's so many buckets within the standard itself, so there's land use change, there's land emissions, there's biogenic removals, and there's another section on technological removals, uh, both of those removal pieces are optional, but they provide different avenues for reporting on the activities that you may have in your value chain.
- 14:55SPEAKER_01: Um, they're providing methodologies that may have been in existence for a while, but are now like codified within the standard.
- 15:01SPEAKER_01: So they are providing that approach, but ultimately it's like, does this apply to me?
- 15:04SPEAKER_01: Yes, no.
- 15:05SPEAKER_01: Is it significant?
- 15:06SPEAKER_01: Yes, no.
- 15:07SPEAKER_01: And then how do I actually report on it?
- 15:10SPEAKER_01: The the bigger challenge, I think, is the data is just not available at the granularity that is being ultimately recommended in the standard.
- 15:18SPEAKER_01: There will be a lot of estimates over the next couple of years while we're waiting for maybe more precise data on a on a geographical level or an activity level, like a technological level.
- 15:28SPEAKER_01: So there's still going to be a lot of room for estimates over the next couple of years as you see companies adopt it because it's it's gonna be in effect and built into some regulations as well.
- 15:38SPEAKER_03: Yeah, and I mean, again, this standard deserves its own podcast.
- 15:42SPEAKER_03: We will give it its own podcast.
- 15:44SPEAKER_03: But one question maybe to touch on there is you mentioned the fact that the removals guidance uh is optional.
- 15:51SPEAKER_03: However, it's not optional if you're reporting removals.
- 15:54SPEAKER_02: Yeah, yeah, yeah.
- 15:55SPEAKER_03: So again, if a company is wanting to report removals, then that's important.
- 16:00SPEAKER_03: What if, though, I'm buying, for example, offsets?
- 16:02SPEAKER_01: Yeah.
- 16:03SPEAKER_03: Then does this come into play?
- 16:04SPEAKER_01: Or no, we're still Well, I mean, it depends on the type of offset.
- 16:08SPEAKER_01: And I think this was maybe a bit of a precursor to more of the actions and market instruments stuff we'll talk about a bit later.
- 16:14SPEAKER_01: And so it does apply.
- 16:15SPEAKER_01: It's just the procurement of removals within your value chain is now like a the it has a place ultimately.
- 16:23SPEAKER_01: So where do they sit in your value chain?
- 16:25SPEAKER_01: How do you actually report on them?
- 16:26SPEAKER_01: What constitutes a removal and what doesn't constitute a removal.
- 16:29SPEAKER_01: Um, those are the prescriptions that are available to you.
- 16:33SPEAKER_01: Whether how you buy it, what you buy, where it sits, like is is not going to be fully prescribed in the standard itself.
- 16:40SPEAKER_03: Yeah.
- 16:40SPEAKER_03: And I think one key point, and maybe it will be a bit confusing to listeners or viewers, is that the first thing we talked about with scope two and its complexity, that is a proposal.
- 16:51SPEAKER_02: Yeah.
- 16:52SPEAKER_03: This is not a proposal.
- 16:54SPEAKER_03: This is actual guidance that if you're reporting in accordance with the protocol, you need to follow.
- 16:58SPEAKER_03: And so for companies, you know, you're working with a lot of different companies, um, many of whom probably have been doing some reporting in the space, but many of whom have not, how do you recommend that you even get started with the standard?
- 17:12SPEAKER_03: Call you besides that.
- 17:14SPEAKER_01: Yeah.
- 17:15SPEAKER_01: But it is that it's like starting to, is it applying to me, first of all?
- 17:18SPEAKER_01: Like, what is significant?
- 17:19SPEAKER_01: Do I have significant emissions?
- 17:20SPEAKER_01: And I think even in an in a non-land sector removals environment, uh like in your inventory, you should have a good understanding of where your emissions or sources are coming from.
- 17:30SPEAKER_01: Um, so if there are a lot of land-based emissions, are you um, you know, dairy farming, meat farming, like for cattle?
- 17:38SPEAKER_01: Like these are on land.
- 17:39SPEAKER_01: So typically, if they're a big bulk of your emissions, you're going to have emissions in this source or in this, in this standard.
- 17:45SPEAKER_01: There are also emission sources that sit within a previously like uh fulsome inventory that will actually be moved to a land sector removal standard.
- 17:54SPEAKER_01: So things like uh CH4 from cattle, like those things are actually will actually sit in your land management emissions and your livestock emissions that so they were previously in your normal inventory, and now there is a place for them in the land sector removal standard.
- 18:06SPEAKER_01: So I think understanding that complexity is probably step one.
- 18:10SPEAKER_01: And then you have to dive into the calculations if you haven't done them before.
- 18:13SPEAKER_01: So, yeah, if if you're calculating emissions from cattle, for example, you may have done those calculations before.
- 18:18SPEAKER_01: They just now sit in a different bucket.
- 18:20SPEAKER_01: And so it is a fairly decent like mapping exercise, understanding what sectors you're working in, um, and then kind of digging into the data that you actually have to calculate it.
- 18:30SPEAKER_03: And then how about, for example, real estate developers, if you are buying uh land and now you're converting it by putting buildings and things?
- 18:38SPEAKER_03: So that type of activity is also in scope?
- 18:41SPEAKER_01: Land use change.
- 18:42SPEAKER_01: Um going back 20 years to understand the impacts of that.
- 18:45SPEAKER_01: That is the standard number.
- 18:47SPEAKER_01: Um, it is there, but again, it's like, is that significant to you?
- 18:50SPEAKER_01: Are you doing uh a significant amount of like green field um building?
- 18:56SPEAKER_01: And in that 20 years, has there been land use change that has would actually impact you as like the the owner of that uh that land?
- 19:03SPEAKER_01: So it's it's a good question.
- 19:05SPEAKER_01: I think you're probably not gonna see that much activity in the real estate space yet, but it certainly could be a significant activity uh for those for those players.
- 19:12SPEAKER_03: So two follow-on questions to that then, because you know, when you mentioned this sort of um green field, yeah, but what about if you're dealing with the more brown field development?
- 19:21SPEAKER_03: So now you're taking a former industrial side or otherwise, and then you're converting it, then can you is that become positive?
- 19:28SPEAKER_03: Or how does that actually work then if you're actually pr going to put in place something that will absorb more carbon versus its current state?
- 19:37SPEAKER_01: Yeah, I think it goes to a few of the other worlds we're living in around restoration and nature-based solutions.
- 19:42SPEAKER_01: So it is possible, certainly.
- 19:44SPEAKER_01: I think the the challenge will be your data availability on that in that sense.
- 19:48SPEAKER_01: And so we're actually seeing uh Google Maps being used as a good source of previous land use.
- 19:53SPEAKER_01: Oh, very interesting.
- 19:54SPEAKER_01: I mean, because there's it's been around for more than 20 years.
- 19:57SPEAKER_03: Yeah, yeah.
- 19:58SPEAKER_01: So I mean, if you just scroll back through the timeline, you can actually see what's been going on there.
- 20:02SPEAKER_01: And so we have seen some companies where they think that is a significant um emission source, use Google Maps as a source to understand like what is the actual change.
- 20:10SPEAKER_01: And so, yeah, it can be a uh loss of emissions or a release of emissions or um uh a removal uh could be, as long as it's within the rules of the removal.
- 20:19SPEAKER_03: Yeah, right, right.
- 20:20SPEAKER_03: And so that's really understanding that.
- 20:22SPEAKER_03: And then maybe a related question is that notably, you do not mention forestry.
- 20:27SPEAKER_03: And I think in some ways, forestry is one of the easiest things for people to understand.
- 20:31SPEAKER_03: You had a forest, we all hopefully know that that is absorbing carbon.
- 20:36SPEAKER_03: You cut down the forest and do something else, yeah, but that's not in the standard.
- 20:40SPEAKER_03: And so, can you just give a little context why and then what we expect to come on that?
- 20:45SPEAKER_01: Because I mean, it is as simple as we can think about it.
- 20:48SPEAKER_01: The the calculations, the approach are not so simple.
- 20:51SPEAKER_01: And so it was always seen as a bit of a separate part of the the uh the standard.
- 20:56SPEAKER_01: And ultimately, to not get into too much of the the dramatic details, like they couldn't arrive at a particular standard they were all happy with.
- 21:03SPEAKER_01: And so it it ultimately has gotten gone back to the drawing board.
- 21:06SPEAKER_01: They say they're still working on it.
- 21:08SPEAKER_01: Um, and I don't and I don't know the exact uh timeline.
- 21:12SPEAKER_01: So I think that will come out soon.
- 21:14SPEAKER_01: But it was a bit of a disappointment when uh it was released at the end of January.
- 21:18SPEAKER_03: Yeah, very interesting.
- 21:19SPEAKER_03: All right, well, again, more to come on that, but to the extent, if you're um, like I already said at least once, if you're listening and this could impact you, then start paying attention.
- 21:28SPEAKER_03: Uh all right, let's move on then to even I'd say less developed proposal than the scope two.
- 21:35SPEAKER_03: So we kind of went in interesting order on in these topics, but more chronological order.
- 21:40SPEAKER_03: Um, so we, as I mentioned at the outset, we did we have seen a white paper and basically request for comment from the fourth technical working group, the Actions and Market Instruments uh working group on some proposals of what that could look like in the future, sort of going beyond um location based emissions reporting.
- 22:00SPEAKER_03: Interesting proposal.
- 22:01SPEAKER_03: Very quick comment period.
- 22:03SPEAKER_03: It's going to end May 31st.
- 22:05SPEAKER_03: So if you're interested, you want to weigh in now.
- 22:08SPEAKER_03: And you know, companies will have a chance to weigh in later, but this seems like a really important time to talk about direction.
- 22:13SPEAKER_02: Yeah.
- 22:14SPEAKER_03: But before we get into some thoughts on it, can you just give a high level of what is being, I guess, proposed?
- 22:21SPEAKER_03: It's not really being proposed, but what's being discussed.
- 22:23SPEAKER_01: Yeah, the concept.
- 22:24SPEAKER_01: And that's basically what's been put out.
- 22:26SPEAKER_01: And the comments or the ask for comment is pretty brief.
- 22:30SPEAKER_01: And I think that's a good one.
- 22:31SPEAKER_01: Like it's straightforward.
- 22:32SPEAKER_01: Yes.
- 22:32SPEAKER_01: So we'll talk a little bit.
- 22:33SPEAKER_03: Yeah, do you agree?
- 22:34SPEAKER_03: Do you not agree?
- 22:34SPEAKER_03: Yeah.
- 22:35SPEAKER_01: It's a nice question.
- 22:37SPEAKER_01: So ultimately, you would you have your normal GHE inventory.
- 22:40SPEAKER_01: They're calling it a physical GHE inventory.
- 22:42SPEAKER_01: This is your scope one, two, three.
- 22:44SPEAKER_01: Then the proposed approach for a whatever actions and market instrument, multi-impact statement, the name is to be defined in the future.
- 22:54SPEAKER_01: And so one would have a market-based instrument inventory or market-based inventory.
- 22:59SPEAKER_01: Again, that name is subject to change.
- 23:00SPEAKER_01: But this is where now your current market-based scope two will sit, but it will also include a market-based scope one and putting quotes around that, market-based scope three.
- 23:09SPEAKER_01: And so any market-based instruments that you procure in, say, uh renewable natural gas contracts may sit in your uh market-based scope one.
- 23:17SPEAKER_01: Or if there's market-based instruments procured in your value chain, they can be then reflected in your scope three.
- 23:23SPEAKER_01: So that those things are pretty um straightforward, I think.
- 23:26SPEAKER_01: They don't need a ton of explanation, but there's a lot of issues, there's a lot of details.
- 23:30SPEAKER_01: Yeah.
- 23:31SPEAKER_01: But but we know what market-based scope two is.
- 23:33SPEAKER_01: And so just say that exists in scope one.
- 23:36SPEAKER_01: Um the other pieces, so there's two other pieces.
- 23:39SPEAKER_01: One is um impacts.
- 23:40SPEAKER_01: And so you're looking at GHG impacts, whether it's within a sector, uh, within your specific geography, or outside your value chain.
- 23:48SPEAKER_01: So this could be when you're maybe procuring offsets in a totally different region, in a totally different project that's not related to anything you do, you're just buying offsets.
- 23:57SPEAKER_01: So that would be just completely outside of your uh outside of your value chain.
- 24:00SPEAKER_01: So there's different options for calculating about that.
- 24:02SPEAKER_01: This is also where avoided emissions might sit.
- 24:05SPEAKER_01: Um, they're proposing it based on products that you sell.
- 24:08SPEAKER_01: Um, so all these things are GHG impacts because of something you did.
- 24:13SPEAKER_01: So it's like a consequential uh approach.
- 24:16SPEAKER_01: And then there's a fourth piece, which is non-GHG indicators.
- 24:19SPEAKER_01: So this could be anything else you want to track that may have climate-related impacts.
- 24:23SPEAKER_01: Some of the examples that we've seen is like percent spend on low carbon uh cement, for example.
- 24:29SPEAKER_01: So this could be something that would actually reduce your greenhouse gas inventory, but a different metric is just a bit easier to understand is you know, things like percent spend or things like that.
- 24:39SPEAKER_01: So it is not GHG emissions, but it could be things that impact GHE emissions.
- 24:44SPEAKER_03: So there's a lot of additional reporting.
- 24:46SPEAKER_03: I guess before you dig into the individual statements, what problem is this trying to solve?
- 24:52SPEAKER_01: Yeah, I uh the original problem I did like we saw that it was trying to solve was that market-based piece for scope one and scope three, because I mean, you were getting questions.
- 25:01SPEAKER_01: We were everyone, I was asking these questions.
- 25:04SPEAKER_01: So it does it did stem from the original um request for uh changes to the GHC protocol and we're like questions of how to reflect biomethane certificates.
- 25:14SPEAKER_01: You know, what if uh my value chain partner uh has done a bunch of offsets and can I actually use them in my scope three?
- 25:21SPEAKER_01: So those are very normal questions.
- 25:23SPEAKER_01: And I think that's where that market-based inventory comes into play.
- 25:27SPEAKER_01: The other two, um, it is a bit of a question.
- 25:30SPEAKER_01: I think like avoided emissions have never really had a home.
- 25:32SPEAKER_01: Well, they don't have a home in the GSU protocol.
- 25:35SPEAKER_01: Um, they are not of the same accounting procedure, there's no real standard methodology.
- 25:40SPEAKER_01: And so I I this could be a question of like the protocol was asked to do something with them, yeah, and they're putting it in here.
- 25:47SPEAKER_01: I think those broader impacts beyond your own value chain, things like that, are very interesting topics.
- 25:52SPEAKER_01: And so I think it could just be like, well, here's where it will sit if we were to um get a company to if a company wanted to disclose on them.
- 26:00SPEAKER_03: So I have so many questions, but I think starting with maybe market-based, because this is something that actually they asked about also, or they didn't necessarily ask about in the scope two letter, but I mean, clearly they asked questions about the market-based method.
- 26:13SPEAKER_03: And one of the comments we made there is that we think it's important because it's important to many companies, it's not important to all companies.
- 26:20SPEAKER_03: So that in uh PwC's view, that that should not be required.
- 26:25SPEAKER_03: Yeah.
- 26:26SPEAKER_03: So when we step back and look at these three additional statements, is there any um proposal in terms of would they be required, would they not be required, or that's something that's still open?
- 26:35SPEAKER_01: I think it's still to be defined.
- 26:37SPEAKER_01: Um, but the the sense is that it would still be optional.
- 26:40SPEAKER_01: Um, because again, there this is more of a disclosure piece, and that's the interesting part here in that I don't think they could make these things uh mandatory anyway.
- 26:49SPEAKER_02: Yeah.
- 26:50SPEAKER_01: Uh, but it like the reading between the lines and understanding what's happening in the working group, it does seem they're leaning towards these are optional parts of uh a disclosure under the GSU protocol.
- 26:58SPEAKER_03: Yeah, which is interesting because right now in scope two, market-based is not optional.
- 27:04SPEAKER_03: So more, it's very interesting more to come.
- 27:06SPEAKER_03: So let's dig in then to the impact statement.
- 27:09SPEAKER_03: Uh, because again, in the scope two uh consultation, they briefly touched on it, and at the same time, they did put out this consequential accounting uh request for comment or um comment letter processor, whatever terminology.
- 27:24SPEAKER_03: But in any event, um as you look at this impact statement, what are companies focused on and in terms of positive, negative?
- 27:34SPEAKER_01: I think it's more like why?
- 27:36SPEAKER_01: Yeah, yeah.
- 27:37SPEAKER_01: Like, what am I supposed to do with this?
- 27:39SPEAKER_01: Um, do I have to report on it?
- 27:41SPEAKER_01: Do I have to calculate things in every single bucket?
- 27:44SPEAKER_01: Because there are different um spheres of influence, which they include in that in that proposed multi-impact statement.
- 27:50SPEAKER_01: Um, and so I think that that's probably the first question is like, what is this?
- 27:54SPEAKER_01: And what do I have to do with this?
- 27:56SPEAKER_01: And is this mandatory?
- 27:57SPEAKER_01: So I think there's been a, you know, we're getting a little bit of standard fatigue at this moment.
- 28:02SPEAKER_01: So it does seem like a lot at one point.
- 28:05SPEAKER_01: Um, I I think that probably would have benefited from a comment from the protocol of saying, like, this is going to be optional, like this is, you know, this is not as strict as we want, as we might seem.
- 28:14SPEAKER_01: Yeah.
- 28:15SPEAKER_01: So I think that's the first question.
- 28:17SPEAKER_01: This a lot of the comments we've gotten back is like the part on avoided emissions, like, should this be sitting next to a JC inventory?
- 28:24SPEAKER_01: Because I think that's been a broader question.
- 28:26SPEAKER_01: Some companies call avoided emissions scope four.
- 28:29SPEAKER_01: Yes.
- 28:30SPEAKER_01: That imparts credibility to the to the approach.
- 28:32SPEAKER_01: So I think that was, you know, when when we talk to clients on this, it's often like, okay, we see that as avoided emissions.
- 28:38SPEAKER_01: Is the protocol going to put out a standard for calculating avoided emissions?
- 28:41SPEAKER_01: And the answer we've gotten is no.
- 28:43SPEAKER_01: And so it's what are we supposed to do with this, these buckets?
- 28:46SPEAKER_01: How do we calculate them?
- 28:47SPEAKER_01: Is there going to be methodologies?
- 28:48SPEAKER_01: Is there going to be guidance?
- 28:49SPEAKER_01: And I mean, it is just a discussion paper at this point, but it does, you know, it raises many, many questions of like, what are we doing here?
- 28:57SPEAKER_03: Yeah, yeah.
- 28:57SPEAKER_03: It makes sense.
- 28:58SPEAKER_03: And then how about the last statement, which I think the reactions I've heard is okay, it's why is the GHG protocol putting out guidance for reporting non-GHG emissions that does not seem to be in their wheelhouse.
- 29:13SPEAKER_03: So I don't know if you've heard similar.
- 29:15SPEAKER_01: Well, I mean, one of the questions is should we even do this?
- 29:17SPEAKER_01: Yeah.
- 29:18SPEAKER_01: Which is a fair question.
- 29:19SPEAKER_01: Um, yeah, the guidance, I mean, or or the client comments we've had on this is basically like, what am I actually supposed to put in here?
- 29:26SPEAKER_01: Do I have to put in something?
- 29:27SPEAKER_01: Yeah.
- 29:28SPEAKER_01: Is there going to be sector-specific guidance?
- 29:30SPEAKER_01: And my response is like, you actually may have these KPIs already.
- 29:34SPEAKER_01: You may be tracking these things like percent spend on low carbon cement.
- 29:39SPEAKER_01: Like you may be doing that, but it doesn't mean that you have to put it in some specific disclosure.
- 29:44SPEAKER_01: If it's important to you and it's important to your stakeholders, you can disclose on this regardless of it being in this statement.
- 29:50SPEAKER_01: But they're just trying to put a place for these things so that I think this is the idea.
- 29:55SPEAKER_01: A reader can be, okay, all of this is in one bucket.
- 29:57SPEAKER_01: I know where to find all these information in a report.
- 30:00SPEAKER_01: But again, it goes to the the intention behind the GHG protocol.
- 30:04SPEAKER_01: Is it a like disclosure standard or is it an accounting standard?
- 30:07SPEAKER_01: And I think that's the balance that they're going to have to manage, and especially when they get these comments, but I thought that that might be a bit of a theme.
- 30:14SPEAKER_03: Yeah, and I do think that goes to you know, having some standardized measurement for some of these could be helpful.
- 30:21SPEAKER_03: I guess the counter argument, though, and this is something you and I have talked about, is given the number of open questions that we have on scope one, two, and three, and given all the work that's being done right now by the other technical working groups to change those standards, do standard setters, prepares and uh users have the bandwidth to even understand all these changes?
- 30:44SPEAKER_03: And wouldn't the energy be better focused elsewhere?
- 30:48SPEAKER_01: Yeah.
- 30:48SPEAKER_01: I mean, I think the answer is yes.
- 30:50SPEAKER_01: Uh, because there's a lot going on, as I said, standard fatigue.
- 30:53SPEAKER_01: And so introducing a whole nother three extra concepts on top of the normal changes that will come down as part of the protocol.
- 31:00SPEAKER_01: Like it is a lot to deal with.
- 31:02SPEAKER_01: I mean, the counter to that is you might as well do it all in one go.
- 31:06SPEAKER_01: But as opposed to having like a 10-year period where everything's changing.
- 31:11SPEAKER_01: Um, but I but I think like a key message to the protocol would likely be to prioritize efforts.
- 31:16SPEAKER_01: Um, like my personal view is I do think that market-based piece is a is a good thing to work through.
- 31:21SPEAKER_03: Yes, because there are so many questions.
- 31:23SPEAKER_03: I agree.
- 31:23SPEAKER_01: And if that's an approach that a company chooses to take for its decarbonization efforts, I think they should have like a standardized way of um displaying and disclosing on it.
- 31:33SPEAKER_01: I think that probably should take precedent over the other um two sides of the standard or or the the multi-impact statement, however it ends up being.
- 31:41SPEAKER_01: Um, but again, it is that like, do we have bandwidth to deal with?
- 31:44SPEAKER_01: Does the protocol have bandwidth to deal with this?
- 31:47SPEAKER_01: Um prioritizing efforts to make sure that we're still like on track for decarbonization and supporting companies' disclosures, I think is an important key piece.
- 31:54SPEAKER_03: Yeah, and I think in particular, people would rather, I think, see new guidance sooner on just the location-based method.
- 32:03SPEAKER_03: But I I agree with your points on market-based that definitely is coming, needs to be coming soon.
- 32:08SPEAKER_03: Yeah.
- 32:08SPEAKER_03: So I guess maybe to before we wrap things up then, any headlines from your own technical working group that you would share?
- 32:17SPEAKER_03: I mean, I guess you don't own the perspective, but just to be clear, the one that you are on, the go three.
- 32:22SPEAKER_01: We're actually dealing with category 10 and 11 right now in uh use of soul products, processing of sold products, reverse.
- 32:28SPEAKER_01: Um, and there's a lot of good, sticky questions that are coming out of it.
- 32:32SPEAKER_01: Um, I think I talked about this on a previous podcast of just like, you know, on use of soul products, how far do you go down the value chain if you make uh a piston that goes into a car or it goes into a motor that then goes into a car?
- 32:45SPEAKER_01: How far do you go down the value chain to calculate um use of soul products?
- 32:49SPEAKER_03: Especially because you might not know after you the first sale where it's going.
- 32:53SPEAKER_01: Yeah.
- 32:54SPEAKER_01: And it's it's it's a very technical conversation, actually a very productive conversation.
- 32:59SPEAKER_01: Um, nothing has been really resolved yet.
- 33:01SPEAKER_01: It's actually been a few meetings, but it there's a lot to talk about.
- 33:04SPEAKER_03: Yeah.
- 33:05SPEAKER_01: Um, and so like that that um integration of physical parts into another physical thing is different than me making uh methanol that goes into plastics, right?
- 33:15SPEAKER_01: The methanol doesn't exist anymore as that same chemical.
- 33:18SPEAKER_01: And so do you treat those things differently?
- 33:20SPEAKER_01: Because the piston is still a piston in a car.
- 33:23SPEAKER_01: Right.
- 33:23SPEAKER_01: Uh and so are they different approaches?
- 33:25SPEAKER_01: And then it's on the particle to say, do we have to provide use cases for everything, or do we push some things to the guidance to be able to like actually implement it?
- 33:33SPEAKER_01: So I think these are like good questions to start having.
- 33:37SPEAKER_01: The big fear I have, and a lot of people have raised this in the working group, is it is it adding too much complexity to to the standard, like the calculations?
- 33:45SPEAKER_01: And so do you go, do you do you end up just going so far that it's too much?
- 33:50SPEAKER_01: Yeah, it's too much.
- 33:51SPEAKER_01: And so I think a lot of us are raising our hands like take a step back.
- 33:55SPEAKER_01: Is this important right now?
- 33:56SPEAKER_01: Like, is this gonna help decarbonize?
- 33:58SPEAKER_01: Is it gonna help um companies standardize their disclosures and they're on DHG emissions?
- 34:03SPEAKER_01: So that is like my big fear in some of these things.
- 34:06SPEAKER_01: Um, and I think that's why it's really important for companies to be able to like track the progress and just understand what's going on.
- 34:14SPEAKER_01: And like we've talked to a lot of clients on this.
- 34:16SPEAKER_01: I'm trying to get a lot of voices in the room.
- 34:18SPEAKER_01: Um, but ultimately, yeah, that's it's it's an exciting time, certainly, but a big fear is like, are we going too in the weeds on this stuff?
- 34:26SPEAKER_03: Wow, yeah.
- 34:27SPEAKER_01: This is an engineer who like loves precision and accuracy, but like so you know it's really important.
- 34:31SPEAKER_03: That is why you're saying reading between the lines.
- 34:34SPEAKER_03: Yeah, yeah, yeah.
- 34:35SPEAKER_03: So then with all of this, so much, and we've only skimmed the surface today.
- 34:40SPEAKER_03: What are you recommending to companies then?
- 34:42SPEAKER_03: We kind of started here, but let's loop back there.
- 34:45SPEAKER_01: Yeah, I think like data will always be this piece.
- 34:48SPEAKER_01: Like, do you have the data?
- 34:49SPEAKER_01: What does it look like?
- 34:50SPEAKER_01: Is it good data quality?
- 34:51SPEAKER_01: And so I think no matter where the protocol goes, there will be ultimately a need for better quality data as we start to decarbonize, as we start to manage emissions, energy, and things like that.
- 35:01SPEAKER_01: So, like, no regrets move on understanding what data is available in an organization, how to move it faster, how to get it quicker, and how to manage it and understand like what AI can do with it.
- 35:11SPEAKER_01: Um, that is a big question around inventories.
- 35:13SPEAKER_01: Can AI do a big can AI do my inventory for me?
- 35:16SPEAKER_01: Like, probably not today in a in a more like complex organization, but I think getting ready for that automation and AI uh conversation is a really good one to have now.
- 35:26SPEAKER_01: Um, because it'll it'll also support, especially on the automation piece, is just future changes to the inventory.
- 35:31SPEAKER_01: So like data quality, understanding how automation can help you.
- 35:34SPEAKER_01: Um and I think on the decarbonization side is like they, you know, they all go hand in hand.
- 35:38SPEAKER_01: And so really focusing on um the cost of things and and cost of energy and being able to understand exactly the data or the the amount of energy you're using in these things, that goes to a data quality piece.
- 35:49SPEAKER_01: So like they all come hand in hand around decarbonization.
- 35:52SPEAKER_03: Yeah, it's interesting too, though, is I'm reflecting on these different topics.
- 35:56SPEAKER_03: It also seems like if I'm a company that's go through category 11 is very important, that's I should be paying attention to those discussions.
- 36:04SPEAKER_03: Yeah, maybe electricity is a really important metric for you.
- 36:08SPEAKER_03: You should pay attention to that.
- 36:10SPEAKER_03: And so I guess instead of trying to, okay, I have to keep up with all of this, what are your largest sources of emissions?
- 36:16SPEAKER_03: And then can you at least key in on those discussions so you can understand what could be coming and weigh in when the time's appropriate if you don't agree with what's being proposed?
- 36:25SPEAKER_01: Yeah, and I think try to weigh in a bit earlier, though, because there are always avenues to engage.
- 36:29SPEAKER_01: Um, you know, there's a lot of people on those working groups.
- 36:32SPEAKER_01: And so I think that is a key piece of just understanding where the working groups are in their process.
- 36:37SPEAKER_01: Um, admittedly, the protocol isn't like the website's not great for downloading information.
- 36:42SPEAKER_03: But it has a lot of information.
- 36:44SPEAKER_01: It's a lot of information.
- 36:45SPEAKER_01: Uh, actually, one of our staff built an agent to read all of the Wow Yeah, and so it was actually really good.
- 36:51SPEAKER_01: Uh just to summarize some of the information and put it in one spot.
- 36:54SPEAKER_01: Yeah.
- 36:54SPEAKER_01: Like just a it was actually quite a simple agent to just download the information from the protocol and segment it and just give summaries.
- 37:01SPEAKER_01: So a company could do that if they wanted to.
- 37:03SPEAKER_01: Yeah.
- 37:03SPEAKER_01: Or come to come to me, come to us just to ask questions.
- 37:06SPEAKER_01: But I think yeah, focusing on the the key changes that could be coming out of your key emission source is a really good idea.
- 37:11SPEAKER_03: All right.
- 37:12SPEAKER_03: Well, Colin, as always, such a pleasure to talk to you.
- 37:14SPEAKER_03: I'm sure I'll see you again in the next few months.
- 37:17SPEAKER_03: But uh, thanks so much for joining me today.
- 37:18SPEAKER_02: Thanks for having me.
- 37:19SPEAKER_03: All right, and to our viewers and listeners, thank you as well for joining us.
- 37:23SPEAKER_03: Please check out the show notes to hear about other or to see other episodes between me and Colin.
- 37:28SPEAKER_03: And then as always, please subscribe to our newsletter and to this podcast to stay up to date on the latest developments.
- 37:34SPEAKER_03: Thanks again.
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