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Sustainability now: Balancing GHG scope 2 ambition and practicality · PwC's accounting podcast

0:00
SPEAKER_00: Thought leadership from PWC's national office.
0:10
SPEAKER_05: Hello, I'm Heather Horn, PWC's U.S.
0:13
SPEAKER_05: Sustainability Technical Leader, and welcome back to PWC's Accounting Podcast.
0:18
SPEAKER_05: This is Sustainability Now.
0:20
SPEAKER_05: In today's episode, we're revisiting the GHG Protocol's first major updates.
0:24
SPEAKER_05: It's a public consultation on the scope two guidance, which closed for comment on January 30th.
0:29
SPEAKER_05: To walk through the latest, I'm happy to be joined again today by Colin Powell, PWC Canada partner and a member of the GHG Protocol Scope 3 Technical Working Group.
0:39
SPEAKER_05: A couple quick notes before we get started.
0:41
SPEAKER_05: If you're listening and would like to watch this episode, check out the show notes for a link to the video, as well as other resources on GHG reporting, including two prior episodes with Colin, as well as a recent episode with Paul Munter, a member of the Independent Standards Board at the GHG Protocol, which is covering the modernization of the GHG standards, including the scope two guidance.
1:02
SPEAKER_05: All right, with that, let's get started.
1:04
SPEAKER_05: Colin, welcome back.
1:05
SPEAKER_05: So nice to have you back in New York.
1:07
SPEAKER_01: Thanks for having me.
1:08
SPEAKER_05: All right, so scope two consultation, which you know I have personal interest in.
1:12
SPEAKER_05: Um, it was released in uh October of last year, and there were over 180 questions, which I think was quite intimidating, and 60-day comment period.
1:22
SPEAKER_05: And um, I think probably the first welcome thing that happened was that the GHG protocol, I think, heard the feedback and they actually extended the comment period.
1:31
SPEAKER_05: So comments were originally supposed to be due December 19th and then moved to January 30th.
1:36
SPEAKER_05: So huge difference.
1:37
SPEAKER_05: And I think hopefully something we'll see for future standards.
1:41
SPEAKER_05: Yeah, so we can talk about that maybe for a moment.
1:44
SPEAKER_05: But I wanted to talk a bit today about some of PWC's points of view.
1:48
SPEAKER_05: But before we do that, just to rehe um help our audience re-level set, can you just cover some of the major things that were proposed?
1:56
SPEAKER_01: Sure.
1:56
SPEAKER_01: So there's probably three big buckets of changes.
1:59
SPEAKER_01: Um, one on the location-based emission factors, basically changing the hierarchy of emission factors to be more precise.
2:05
SPEAKER_01: So they just want more granularity, getting closer to the geography associated with the grid you're procuring, um, more time granularity, so trying to get to an hourly emission factor, um, and then using hourly consumption data all of if available.
2:20
SPEAKER_01: Um on the market-based side, so ultimately moving towards a different emission factor hierarchy as well.
2:26
SPEAKER_01: Um, so trying to get more reflective of what's actually being uh the renewables on the grid.
2:31
SPEAKER_01: Um, and then also the big headline is like hourly matching, and so requiring on an hourly basis the matching of market-based instruments.
2:39
SPEAKER_01: Um and then also just um the the legacy um exemptions they've proposed on if you have an existing contract for Rex, for example, um, you can maintain that contract.
2:48
SPEAKER_01: So there was some big like groundbreaking changes.
2:52
SPEAKER_01: So it is welcome that they extended the time period for for uh consultations.
2:57
SPEAKER_01: Um, but interesting, like how how it sees how it flushes out ultimately.
3:01
SPEAKER_05: Yeah, and also, I mean, to your point, I personally think this is one of the most complicated areas of GHG accounting.
3:06
SPEAKER_05: And it's the first one that we've seen the new standards.
3:09
SPEAKER_05: So, again, definitely um interest or is really good.
3:13
SPEAKER_05: They gave us more time.
3:14
SPEAKER_05: And I do want to talk about PwC's points of view, and in particular, this Fiora quiz view on your point of view, um, and I can share mine.
3:21
SPEAKER_05: But maybe before we do that, I know you've been talking to a lot of companies, and I think what's of a lot of interest to our viewers and listeners is understanding points of view sort of should um overall.
3:32
SPEAKER_05: So, what are some of the things that you're hearing?
3:34
SPEAKER_01: Yeah, it's interesting.
3:35
SPEAKER_01: I think I've had like 40 conversations on this for now.
3:38
SPEAKER_01: Um, one of the like the first interesting thing is that a lot of our clients didn't know the public consultation was open.
3:44
unknown: Oh, okay.
3:45
SPEAKER_01: And so, like, the first thing that we should say is like, I think the protocol needs to be a bit louder on these things.
3:51
SPEAKER_01: Um, but once our clients went into the the like the questions, yeah, it was just very bewildering ultimately.
3:58
SPEAKER_01: It's like, how do I respond?
3:59
SPEAKER_01: Yeah, there's so many questions here.
4:01
SPEAKER_01: Like, why do I have to go into the detail about everything that maybe doesn't matter to me?
4:05
SPEAKER_01: So I think some flexibility on the the responses probably could have helped um get some get some answers.
4:12
SPEAKER_01: Um, and then on those answers, we saw like a lot of my client base didn't actually respond individually.
4:18
SPEAKER_01: Yes, but they're looking to respond on like the sector basis.
4:21
SPEAKER_01: So like the banking industry, the insurance industry all will respond, but individual responses were probably not going to be um that prevalent in the in the answers.
4:30
SPEAKER_05: Yeah, I mean it's interesting on that point.
4:32
SPEAKER_05: I think we've seen that with a lot of other comment letters as well.
4:35
SPEAKER_05: And even I remember with the SEC climate proposed rule, which obviously is as now stayed, um, that we did also see a lot of sectors responding versus individuals.
4:46
SPEAKER_03: Yeah.
4:46
SPEAKER_05: But back to your point about the fact they were conf that it was hard to respond, confused.
4:50
SPEAKER_05: I mean, one thing we really noted is it almost was like trying to drive certain responses, and they didn't ask some questions we would have liked them to have asked.
4:59
SPEAKER_05: And so it sounds like we're not the only ones that observed that.
5:02
SPEAKER_01: It's a little leading the witness.
5:03
SPEAKER_01: Yeah.
5:04
SPEAKER_01: And that also made some of my clients step back and be like, well, is this am I going to be heard in this consultation?
5:10
SPEAKER_02: Yes.
5:10
SPEAKER_01: Um, so so that I think that's been one of the frustrations.
5:13
SPEAKER_01: But I think the changes themselves, right?
5:15
SPEAKER_01: Like them walking through, maybe some of them don't understand all the nuance.
5:20
SPEAKER_01: And so it was helpful to have these conversations, and I would urge all of us to have these conversations.
5:24
SPEAKER_02: Yes, yes.
5:25
SPEAKER_01: Um, because it's pretty in the weeds, and a lot of like uh client-based, like there's probably one or two people who are actually dealing with these calculations, but it does flow up through the decision um matrix of aligning on exactly approaches and then disclosures.
5:39
SPEAKER_01: And so I think that like the detail in the changes was important, but it maybe wasn't explained the best.
5:46
SPEAKER_05: Yeah, yeah.
5:47
SPEAKER_05: I felt like the explanations were rather brief, considering the significance of, and I think something you and I have talked about before, and our regular listeners know, like I come from the power and utilities industry, and I still was confused by some of what was being proposed.
6:02
SPEAKER_05: And so I just feel like for someone who is either not deep in the industry, not deep in G, it's really hard to even understand what the potential implications are of some of these changes.
6:13
SPEAKER_01: Yeah, and I think that's what it is.
6:14
SPEAKER_01: There's a bit of frustration in there of like, okay, well, I don't know exactly what's going on, so I don't really know what to do about it.
6:19
SPEAKER_01: Yeah.
6:20
SPEAKER_01: Um, and so I think there was a lot of just yeah, frustration with the extreme changes that they saw and and a lot of, you know, what's what's the point?
6:29
SPEAKER_01: Why do I have to go do this?
6:31
SPEAKER_01: And how is this going to help me say decarbonize or choose better suppliers for XYZ?
6:37
SPEAKER_01: Like I think there was a sense of, you know, is this too much too fast?
6:41
SPEAKER_01: I think that aligns with the PWC view generally too.
6:44
SPEAKER_01: Um, but a lot of frustration with, you know, why?
6:47
SPEAKER_05: Yeah.
6:47
SPEAKER_05: So it's an interesting point, and maybe this is a broader question, but do you think that's something we may see then for the other proposals that maybe they won't go as far, or it's hard to say.
7:01
SPEAKER_01: It's hard to say.
7:02
SPEAKER_01: I mean, just having been involved so deeply in the scope three one, I'm seeing them go farther than I think that they should.
7:08
SPEAKER_03: Yeah.
7:08
SPEAKER_01: Um, I am but one voice in these working groups.
7:11
SPEAKER_01: Um, so I I think they'll probably aim to push the limit a little bit.
7:16
SPEAKER_01: Maybe the expectation is that public consultation will bring it back, um, or that there'll be some decisions like maybe pushed out to the next round of revisions.
7:24
SPEAKER_05: Yes.
7:25
SPEAKER_01: They've committed to doing this every five years.
7:27
SPEAKER_01: Probably not.
7:28
SPEAKER_05: Big commitment.
7:29
SPEAKER_01: Probably not to like the full scale they're doing now, because it's been like 20 years since the corporate standards have been changed.
7:34
SPEAKER_01: But um the five-year program, I think, permits them some like, okay, let's wait to change this, uh, or let's pick this up in another year, or maybe it just needs more time.
7:44
SPEAKER_05: Yeah, let technology catch up, like whatever the case may be, practice development more.
7:49
SPEAKER_05: Yeah, that that makes sense.
7:51
SPEAKER_05: So if we think about our uh consultation that we submitted, and we definitely did not answer all 180 questions, but we answered a lot of them.
8:00
SPEAKER_05: Uh, and it is available on Viewpoint, I I encourage our listeners to check it out.
8:05
SPEAKER_05: But what are some of the big themes you would say that we saw when we looked at the uh proposal?
8:11
SPEAKER_01: Yeah, I think I mean generally we support the ambition, right?
8:13
SPEAKER_01: Like the idea of it all is very much aligned with our thinking.
8:19
SPEAKER_01: Um, I think one of the big challenges is just implementation feasibility, data availability, right?
8:24
SPEAKER_01: Like the the push on granularity for location-based emission factors, like that data is just not available.
8:30
SPEAKER_01: Um, and so the the requirement of it all, like the shall of it all, is just, you know, why are we forcing companies to do this when they may actually have to prove that they can't do it to an auditor, for example, right?
8:41
SPEAKER_01: Like, so there is, you know, that's the key term that comes keeps coming back from the client is like this seems like a lot of work.
8:47
SPEAKER_01: This seems a lot of a lot of burden for for what am I getting out of it?
8:51
SPEAKER_03: Yeah.
8:51
SPEAKER_01: Um, so I think that's like that feasibility and data availability piece is is one of them.
8:56
SPEAKER_05: Yeah.
8:56
SPEAKER_05: I think it's uh one of the comments in our letter uh that I particularly think is tallying is that you know, you go from right now for one location, you probably have one emission factor and then the electricity.
9:10
SPEAKER_05: So basically two numbers you're multiplying, and then I guess global warming potential.
9:14
SPEAKER_05: And then now if you go to hourly, you've got 9,000 almost data points plus then all of the electricity and this like an exponential amount of data.
9:24
SPEAKER_05: And so, you know, when you're talking to clients, what are they saying from feasibility?
9:28
SPEAKER_05: Just data management, put aside availability, but data management.
9:32
SPEAKER_01: Yeah, we have some global banking clients with like branches all over the world.
9:35
SPEAKER_01: And so now you have to do 9,000 of those calculations times hours.
9:40
SPEAKER_01: Like is it is just not feasible with their current systems.
9:43
SPEAKER_01: Um, but also the data is just not there for their utility provider and the emission factors aren't there because the government isn't providing them or the provider of the emission factors.
9:51
SPEAKER_01: So I think like all of those things combined is just, you know, why are we going so so far without a consideration for feasibility?
9:59
SPEAKER_03: Yeah.
10:00
SPEAKER_01: That is, I mean, that's one of the decision-making criteria that is used.
10:03
SPEAKER_01: Um, and I think that is like because I introduced them to a lot of our clients.
10:06
SPEAKER_01: Like, here are the five things we consider as we make changes to the protocol.
10:10
SPEAKER_01: And oftentimes the question is, okay, well, how closely was that feasibility one considered there?
10:15
SPEAKER_05: Right.
10:16
SPEAKER_05: Yeah.
10:16
SPEAKER_05: Yeah.
10:17
SPEAKER_05: No, that makes sense.
10:18
SPEAKER_05: Any other themes you want to highlight?
10:20
SPEAKER_01: Or I have some questions otherwise.
10:22
SPEAKER_01: I think like the the one thing I really enjoyed about our response is the market-based um issue.
10:28
SPEAKER_01: And so, you know, the market-based calculation, there are there are a lot of changes um to the admission factor hierarchy.
10:34
SPEAKER_01: Some we generally agree with, pending more information, like the standard supply service, um, changing from uh like a fossil fuel only factor.
10:44
SPEAKER_01: Like the idea is is good.
10:46
SPEAKER_01: I think the devil is in the details, and that's that's generally our comment is like support, but we need more information here.
10:52
SPEAKER_01: I think our our ask for an alternative disclosure um to market-based, which more aligns with IFRSS2, of you know, basically disclose how you're how you're managing your contractual instruments for for energy, is more aligned with what a lot of our clients would would want to do.
11:08
SPEAKER_01: Yes.
11:09
SPEAKER_01: Um, and I support that because mostly from an interoperability perspective, which again is another one of the decision-making criteria.
11:15
SPEAKER_01: So it I think it is a good flag from us, not to like pat ourselves on the back, but I think it is a good approach that could be better leveraged and better um showcase the intention behind these things.
11:24
SPEAKER_05: Yeah.
11:24
SPEAKER_05: And I think though this is a really interesting point because they didn't even ask.
11:29
SPEAKER_03: Yeah.
11:30
SPEAKER_05: And we had to find a place to stick that in our letter.
11:33
SPEAKER_05: And but if you go back and look at the feedback for the 2023 consultation, that was highlighted as a point.
11:39
SPEAKER_05: So it almost felt what's interesting to me.
11:43
SPEAKER_05: Interoperability is supposed to be important, feasibility, and you know, this prior feedback, and it just felt a bit like it was disregarded because I didn't even ask because this is something you wanted, and so, or if if people wanted.
11:54
SPEAKER_05: And so who, I guess, ultimately, I know the technical working group advised, but who is the one that's saying this is what we're going to ask questions about?
12:04
SPEAKER_01: Yeah, the scope is guided by the secretariat ultimately, because that's it was meant to be that compendium of feedback that was in the initial um initial outreach.
12:14
SPEAKER_01: And so I think they're shaping the conversation and the working groups are responding to that scope.
12:20
SPEAKER_02: Yeah.
12:20
SPEAKER_01: Um, there is like that back and forth with the independent standards board, um, but ultimately they're not going to push us in a different direction.
12:26
SPEAKER_01: They're just going to respond to the existing scope.
12:28
SPEAKER_01: And so I'm not sure if you know it was ever raised, okay, well, is there an alternative to market-based?
12:33
SPEAKER_01: I think it was just like, okay, we have location-based and we have market-based.
12:37
SPEAKER_01: Yeah.
12:37
SPEAKER_01: Now let's go down this path.
12:39
SPEAKER_01: But it, I mean, this ultimately the response that we gave is an alternative to market-based.
12:43
SPEAKER_01: Um, you could consider it your market-based disclosure.
12:46
SPEAKER_05: Yeah.
12:46
SPEAKER_05: And I mean, do you think this is a key point?
12:48
SPEAKER_05: Because even as we were discussing our feedback, there are, and I want to make sure we recognize here, a lot of companies that market-based is very important.
12:57
SPEAKER_05: They're using it to manage their emissions.
12:59
SPEAKER_05: They it they're setting targets, goals, otherwise.
13:02
SPEAKER_05: And so for those companies who want to take, don't want to take it away.
13:06
SPEAKER_05: Um, but if you are a company that's not managing that way, or maybe you're located in a very green location, then yes, let's do this alternative.
13:14
SPEAKER_05: So I think it'll be interesting if we're going to be a lone voice, or if others will even think to give that type of feedback given the way the questions were written.
13:25
SPEAKER_01: We had like a lot of my clients have said, you know, that's really interesting.
13:28
SPEAKER_01: Can you show me an example and of of what like an IFRSS2 disclosure would look like?
13:32
SPEAKER_01: And PwC Global's report is actually a really good example.
13:36
SPEAKER_01: It's like maybe three paragraphs is the disclosure next to the location-based um scope two, right?
13:42
SPEAKER_01: And so they're often like, oh, okay, I get it, but I also get the benefit of doing the market based.
13:47
SPEAKER_01: But I would love the option of doing that.
13:49
SPEAKER_05: Yes, yes.
13:50
SPEAKER_05: And again, I think you made this point.
13:51
SPEAKER_05: If you're an IFRS reporter or um, you know, you're you're following those standards, then that means you're having to create the market base just for the reporting with the protocol.
14:01
SPEAKER_05: So yes, interesting.
14:03
SPEAKER_05: Uh we talked a little bit about data availability, but other anything else you wanted to touch on there?
14:08
SPEAKER_05: Well, data management, but let's just talk a bit about the availability.
14:12
SPEAKER_01: I think, yeah, the from utility perspective, like no company is getting hourly data.
14:17
SPEAKER_01: Um, you often may get data fixed in future periods.
14:21
SPEAKER_01: So you're gonna get it like ultimately uh rectified.
14:24
SPEAKER_01: And so you're never really getting real-time data from a utility.
14:28
SPEAKER_01: So a lot of clients are just like, how is this ever gonna happen?
14:31
SPEAKER_01: Is this gonna happen in 10 years?
14:33
SPEAKER_01: And so I think that again, just the recognition that that this isn't possible right now, and a lot of the approaches aren't available.
14:39
SPEAKER_05: Yeah.
14:40
SPEAKER_05: Well, and I think put aside the utility because someone at some level has that data and it's to share it.
14:47
SPEAKER_05: But emission factors right now, I mean, most companies are using one or two year old emission factors that are annual, and then they want to go to hourly.
14:55
SPEAKER_05: Like, how about monthly?
14:56
SPEAKER_05: Or you know, it feels like that's where I felt like they were really missing.
15:00
SPEAKER_05: There's no middle, there wasn't a lot of middle ground proposed.
15:03
SPEAKER_01: Yeah, and I think that's where you're gonna see, you're not gonna see much change in the disclosure if this stays as it is, because the the data is just not there.
15:11
SPEAKER_01: No one's gonna have emission factors for that for that level.
15:13
SPEAKER_05: So they're just gonna disclose they can't do what well exactly.
15:16
SPEAKER_01: And so are we requiring that?
15:18
SPEAKER_01: Like and now everyone's gonna have a disclosure that says, like, oops, I'm sorry we can't do this, and then have that for the next 10 years.
15:24
SPEAKER_01: Like, and so that I think that's the undue burden a little bit of um companies just being like, How how far do I have to go on this?
15:31
SPEAKER_01: And we've had a lot of people say to us, like, are or ask me, like, am I worried that this may push people away from the protocol?
15:38
SPEAKER_05: I have heard that same question.
15:40
SPEAKER_05: I mean, how are you responding?
15:41
SPEAKER_01: Generally, like, well, it is still the standard for corporate accounting um overall for GHGs, and it is now embedded in a lot of the regulations, whether it's um IFRSS2 or you know, in California, it's it is the the accounting standard.
15:56
SPEAKER_01: So uh it is going to be around for a while.
15:59
SPEAKER_01: I think, and the also the fact that this isn't final yet is another uh stipulation.
16:04
SPEAKER_01: Yeah.
16:05
SPEAKER_01: But there are other GHG accounting programs that are popping up um for different reasons and for different utilities.
16:11
SPEAKER_01: But um I am saying like it is currently the approach, it will likely be the approach for the for the foreseeable future.
16:19
SPEAKER_01: Um, but this that's why public consultation and being uh aware of the changes is so important right now.
16:25
SPEAKER_05: Yeah.
16:25
SPEAKER_05: So we we've talked about sort of the hourly data, data availability.
16:29
SPEAKER_05: One thing with the market base, you highlighted briefly.
16:33
SPEAKER_05: So, first of all, it's different between location and market base.
16:36
SPEAKER_05: Also, market base contemplates this hourly matching of your uh recs or your uh renewable attributes.
16:44
SPEAKER_05: And then if you can't, then you're gonna use these what are load profiles.
16:47
SPEAKER_05: So can you just explain for people what that is and then maybe the challenges associated with it?
16:53
SPEAKER_01: Sure.
16:53
SPEAKER_01: So if you do have an asset, um you probably know how the energy use or electricity use changes throughout the day or the week or the month, depending on what your actual like profile is, what you're doing.
17:04
SPEAKER_01: Um and so you could put that on a monthly, daily um consumption and just model it out as a distribution.
17:11
SPEAKER_01: So you might have less uh electricity consumption in the morning, more during the day, and then less at night.
17:17
SPEAKER_01: And so you could actually just apply that to any asset.
17:20
SPEAKER_01: But again, it's prescribing an accuracy that's probably not really there or giving the the like perception of accuracy.
17:28
SPEAKER_02: Yes.
17:29
SPEAKER_02: Yes.
17:30
SPEAKER_01: And then you're matching that with a market-based instrument.
17:32
SPEAKER_01: Yeah.
17:33
SPEAKER_01: And so it it's giving a lot of more information ultimately, but is that decision useful information?
17:39
SPEAKER_01: Or is it just a lot of work to model a bunch of assets, load profiles, yeah, and then and then apply an emission factor?
17:45
SPEAKER_05: Or uh I guess one point maybe we should touch on though, because we've talked a bit of the data's not available, and I agree with you on the perception of accuracy.
17:54
SPEAKER_05: I do think it's fair to say that there are some companies, especially large util um electricity users, that are managing at an hourly basis, that are making sure the utility is giving them hourly information.
18:06
SPEAKER_05: And in fact, they're co-locating with clean resources.
18:10
SPEAKER_05: So maybe we should at least touch on the fact that we're talking about a big picture, but there are this subset of companies that actually this does make sense for.
18:19
SPEAKER_05: So I don't know if your perspective on that.
18:21
SPEAKER_01: No, it's true.
18:21
SPEAKER_01: And you see the biggest consumers of electricity, you're seeing the data centers, you're seeing a lot of the big tech players like already be able to do this.
18:28
SPEAKER_01: Right.
18:28
SPEAKER_01: And they're definitely pushing the market on this.
18:30
SPEAKER_01: And um, you you see just their scale is what's allowing them at the to do this.
18:36
SPEAKER_01: But you see, like most medium-sized companies will never get the scale to be able to procure on an hourly basis.
18:43
SPEAKER_01: Um, but the idea is correct.
18:45
SPEAKER_01: Like you're you shouldn't be procuring solar power at night to match your nighttime consumption, right?
18:51
SPEAKER_01: It's just not possible.
18:52
SPEAKER_05: Right.
18:52
SPEAKER_01: Um, but you don't have the scale to do that.
18:54
SPEAKER_01: It may drive up the price of that market-based instrument.
18:57
SPEAKER_01: And so, what does it actually do to the market when you're when you're um applying these like strong requirements?
19:02
SPEAKER_05: Yeah.
19:03
SPEAKER_05: So I have two follow-up on that though.
19:05
SPEAKER_05: So then for the first thing is so for those companies that actually this does make sense for, then how do you feel or what did the firm say about, okay, well, can you make it optional to do this more refined reporting?
19:19
SPEAKER_05: So I think what's your perspective on that?
19:21
SPEAKER_01: I think if that's the objective, right?
19:22
SPEAKER_01: Because it does actually match like your consumption, it's matching the the carbon intensity to actually get to zero.
19:29
SPEAKER_01: So if that is the objective of that company's decarbonization strategy, absolutely welcome that.
19:34
SPEAKER_01: I think that's an ambition thing.
19:35
SPEAKER_02: Yes.
19:36
SPEAKER_01: Um, but to require it really does push it in a direction that I think is not so um, it's not driving the like real intention of decarbonization.
19:44
SPEAKER_01: Yeah.
19:45
SPEAKER_01: Um, like PwC UK, I think is is trying to get to hourly matching already.
19:50
SPEAKER_01: And that is like a bit of a stretch, I think.
19:52
SPEAKER_01: Um, but you see the biggest companies actually start to do this, and um it's important, but not everyone can do it.
19:58
SPEAKER_01: Yeah.
19:59
SPEAKER_05: Well, and I think you said something important there.
20:01
SPEAKER_05: It's like if it's your ambition or this is how you're managing, then yes, then you should.
20:05
SPEAKER_05: But for someone else, it just becomes a bit meaningless.
20:09
SPEAKER_05: But I think the other thing with the market-based time, we've talked about the hourly, but actually, there's also a lot here on location.
20:15
SPEAKER_05: Yeah.
20:16
SPEAKER_05: And so one of the key points is that they're proposing that your um the offsets need to be in the same location, and the location could be pretty narrowly defined.
20:26
SPEAKER_05: So there's a lot of views on this, some of which that's important because it's a better reflection of reality, other views that that's gonna stifle developments.
20:35
SPEAKER_05: So I guess what's your view, Colin?
20:37
SPEAKER_01: Yeah, I mean, it's kind of taking it to the level where it was always probably intended to be.
20:42
SPEAKER_01: Like they're always trying to procure um or or generate projects, additional renewable projects in the market that you're operating.
20:49
SPEAKER_01: As the the problem was that the protocol never really like well defined what the same market was.
20:54
SPEAKER_01: And so now they're going to the like saying, here is what same market is.
20:57
SPEAKER_01: Um, there's a lot of prescription in that too.
20:59
SPEAKER_01: You know, there's a discussion of the like them, the protocol naming the markets, naming the exact markets you have to be in, and like who's going to maintain that list?
21:08
SPEAKER_01: Oh, I have but the concept of it is is fair in that the the electricity that you're generating from a renewable energy project should actually meet, be able to get to the the consumption that you're trying to match it with.
21:22
SPEAKER_01: It's a lot of our clients are saying, and I think this happens in a lot of regulated markets, like you know, I'm from Canada.
21:27
SPEAKER_01: There's probably only one jurisdiction where you could build a PPA.
21:31
SPEAKER_01: Yeah.
21:31
SPEAKER_01: And so that jurisdiction is certainly not meeting most of the other population centers in Canada.
21:36
SPEAKER_01: So a lot of companies are like, well, what am I supposed to do?
21:38
SPEAKER_01: I I can't match a lot of my consumption.
21:42
SPEAKER_01: Um, and often companies were relying on a different definition of the same market to be quite expensive.
21:49
SPEAKER_01: Um, and now it pushes it to be quite narrow.
21:51
SPEAKER_01: And so I'm I'm getting a lot of concern of like, okay, well, you know, is this gonna put a chill on the market?
21:56
SPEAKER_01: Is this gonna change the market dynamics?
21:58
SPEAKER_01: Is this gonna increase the price?
21:59
SPEAKER_01: Yeah.
22:00
SPEAKER_01: Yes.
22:00
SPEAKER_01: Um so I think that's a real concern.
22:02
SPEAKER_01: Um and so actually like the devil again, devil's in the details on this, how far do they actually want to go?
22:08
SPEAKER_01: Because it may shut down a lot of markets.
22:10
SPEAKER_05: Yeah, and I think so.
22:11
SPEAKER_05: We have talked previously about they came out with another proposal at the same time.
22:16
SPEAKER_05: And that's really much more focused on is what you're doing actually going to reduce consumption?
22:22
SPEAKER_05: And I think this plays in.
22:24
SPEAKER_05: So, for example, you're located in California.
22:26
SPEAKER_05: Well, is building a new solar plant in California actually going to reduce emissions net?
22:31
SPEAKER_05: Yeah.
22:32
SPEAKER_05: Maybe, maybe not.
22:32
SPEAKER_05: And that's where the other proposal is important.
22:35
SPEAKER_05: So, how do you see those fitting together and or are they even going to be considered together?
22:40
SPEAKER_01: This is what we have flagged internally of like they have to actually be considered together.
22:45
SPEAKER_01: Yeah.
22:45
SPEAKER_01: Um, it almost like it's another criteria, um, just the avoided emissions piece and misunderstanding the emissions quantification there.
22:52
SPEAKER_01: Because that is fundamentally the like the flip side of the deliverability piece, right?
22:56
SPEAKER_01: Like you're gonna build a lot of renewables in Texas, but Texas already has a lot of wind on the grid, but that electricity can never get to any other grid because Texas is isolated.
23:06
SPEAKER_05: And then they might need to build other like gas plants to have grid stability.
23:12
SPEAKER_05: So I mean it's a real challenge.
23:13
SPEAKER_01: And I don't think and they've considered them separately, like in the consultations are considered separately.
23:18
SPEAKER_01: The interplay isn't considered, they're not asking questions on them like together.
23:22
SPEAKER_01: And so I I think this is something that will come up.
23:24
SPEAKER_01: Yes.
23:25
SPEAKER_01: Um, in and I I wonder if there'll be um just some considerations of how to fit them together.
23:31
SPEAKER_05: Yeah.
23:31
SPEAKER_05: Well, and I guess to that point, there's uh there was a very small handful of questions that didn't even, I don't think, deserve their own subheading, which I was sad to see about would you give an alternative metric?
23:43
SPEAKER_05: So if they go down this path of saying it has to be this very look close location, well, what if you do invest somewhere else?
23:50
SPEAKER_05: And uh most of our listeners will know Marchin Olawinski.
23:53
SPEAKER_05: So Marcin's from Poland, and he and I kept looking at the map of Poland, which is like coal, really coal.
23:58
SPEAKER_05: So we kept saying, well, what if I do build a solar plant in Poland, but I'm in California?
24:04
SPEAKER_05: You know, how can I take credit for that?
24:06
SPEAKER_05: So do you think those types of proposals will have any legs if they stick with this path on uh the market base?
24:13
SPEAKER_01: It's it's high potential.
24:14
SPEAKER_01: I think there's like a lot more openness to these types of arrangements because I think you see even um like in SBTI or when they're talking about beyond the value chain, and there's a bit more of an openness and a recognition that a lot of the decarbonization may not take place in exactly your value chain, but you're still making it happen.
24:31
SPEAKER_01: And so is that such a bad thing in that like you're almost relying too much on the on the accounting system that we have to drive decarbonization that you lose the point of decarbonization.
24:41
SPEAKER_01: Yes.
24:42
SPEAKER_01: Um so I hope so.
24:43
SPEAKER_01: I think and those I think I'm very much welcome of those considerations.
24:47
SPEAKER_01: You see it in the SBTI scope three guidance or the scope three standard as well as like what alternative metrics are you can you use to track decarbonization?
24:54
SPEAKER_01: Yeah.
24:54
SPEAKER_01: So hopefully.
24:56
SPEAKER_05: Yeah.
24:56
SPEAKER_05: But I think it's interesting, Colin, because you mentioned the fact that it's very prescriptive in the standard and a few places of like these markets this, these markets that.
25:04
SPEAKER_05: And I think it highlights then that this is incredibly complex.
25:11
SPEAKER_05: The way electricity operates worldwide is incredibly complex.
25:15
SPEAKER_05: There's a huge number of challenges and pros, cons of different approaches, and there's a lot of differences.
25:22
SPEAKER_05: So designing one set of accounting standards that's trying to fit all of them, I think that's something we talked about a lot because in our working group, you know, there's people from and are internal, yeah, people from all over the world, and like, well, that might be good for you, but that does not work for us.
25:36
SPEAKER_05: And so, how is the GHG protocol or the the working groups thinking about those regional or even smaller differences?
25:45
SPEAKER_01: It's meant to be put into that uh feasibility decision-making criteria, like the equitable and adoptable piece of that, um, in that a company that operates in the US versus Poland, for example, should should be able to apply the protocol the same way.
25:58
SPEAKER_02: Yeah.
25:58
SPEAKER_01: Um, and so it it is an ask, and I think we have this ask often is like this should be a framework.
26:03
SPEAKER_01: It shouldn't be so prescriptive.
26:05
SPEAKER_01: Yes.
26:05
SPEAKER_01: Um, and that is a lot of our comments in there is like maybe we should just build out the framework for these things.
26:10
SPEAKER_01: And and that's what the scope two quality criteria generally is.
26:12
SPEAKER_01: Yes.
26:13
SPEAKER_01: Right.
26:13
SPEAKER_01: Should be able to go through step by step and say yes, yes, yes, no.
26:17
SPEAKER_01: Um, and so that's still there.
26:19
SPEAKER_01: I think what they've done is just provide a lot more prescription in those criteria.
26:23
SPEAKER_01: And so it almost takes you out of the framework.
26:26
SPEAKER_02: Yes.
26:26
SPEAKER_01: If they're giving you like in this region, you have to use this thing, yes, um, it takes you away from it.
26:32
SPEAKER_01: So I wonder if in the public consultation you'll see some softening of that.
26:35
SPEAKER_01: Um, and not meant to like soften the intention of the decarbonization, but just drive it from a framework perspective, allow it to be more equitably applied, um, and and hopefully like support the intention at the end of the day.
26:47
SPEAKER_05: Yeah.
26:47
SPEAKER_05: And again, it's like if we had a perfectly global electricity system and all these the real problems were solved, then the reporting would be easy.
26:58
SPEAKER_05: But that's not the case.
26:59
SPEAKER_05: So yeah.
27:00
SPEAKER_05: So I think your comment though is a good lead-in.
27:03
SPEAKER_05: There's exemptions proposed and you know, size-based exemptions.
27:08
SPEAKER_05: So this size in this location.
27:11
SPEAKER_05: Honestly, I thought they were a little complicated.
27:13
SPEAKER_05: And I have some other views about them.
27:14
SPEAKER_05: But what's your reaction to those?
27:16
SPEAKER_05: And what did PwC say?
27:18
SPEAKER_01: Yeah, I mean, generally we oppose the like specific size or or other, because I think the other one was um the SRS size of company restrictions.
27:26
SPEAKER_01: And so we generally don't support those, I think, in any standard.
27:30
SPEAKER_01: It's just again, it should be fallback on a framework.
27:32
SPEAKER_01: Um, there should be optionality or non-optionality.
27:35
SPEAKER_01: Like and I mean, one question that always comes up to me is like, who's deciding on that number?
27:40
SPEAKER_01: Like, do they put out a number every year and then said if you're above it, you gotta do this, if you're below, like yeah.
27:45
SPEAKER_01: So so that was one of the things.
27:46
SPEAKER_01: And I think that's popped up a few times is like the the secretariat has often taken on some of these things and saying, we will like hold this list and update it annually.
27:56
SPEAKER_01: And so I think some of those things just need to go away at the end of the day.
28:00
SPEAKER_01: Yeah.
28:00
SPEAKER_01: Um, again, rely back on the framework piece.
28:03
SPEAKER_01: Um, I don't I don't agree there should be any exemptions here.
28:06
SPEAKER_01: I think it just falls back on optionality.
28:08
SPEAKER_05: Yeah, and I think this is where in PWC's letter, we talk about the concept of reasonable, supportable information without undue cost or effort.
28:16
SPEAKER_05: And so for our listeners that do ESRS, the IFRS sustainability disclosure standards, like those concepts, I think it matches what you're saying.
28:25
SPEAKER_05: It's a framework.
28:26
SPEAKER_05: You're not saying, okay, well, in this location, you have this much power.
28:29
SPEAKER_05: So do this, this other location, this.
28:31
SPEAKER_05: And then what if your location is going up and down?
28:33
SPEAKER_05: So it just seems more realistic.
28:35
SPEAKER_05: But did you hear from your clients on this?
28:38
SPEAKER_01: I think generally they've just been like, I think this is going to go away.
28:41
SPEAKER_01: Okay.
28:42
SPEAKER_01: So there hasn't been a lot of like, will I be under or above?
28:45
SPEAKER_01: Because I think the discussion is like, I don't think that the protocol will end up having a number on these things.
28:51
SPEAKER_05: No, it's so I think so.
28:53
SPEAKER_01: It's like almost an expectation that it will be softened.
28:55
SPEAKER_01: Yeah, okay.
28:56
SPEAKER_05: That makes sense.
28:57
SPEAKER_01: Which I mean, at the end of the day, that that that seems kind of bad to me that you know the protocol's putting out things that that some of our clients think, oh, that's not going to stick around.
29:06
SPEAKER_01: That's too far-fetched to like stay.
29:08
SPEAKER_01: And so that is a bit of a red flag to me.
29:10
SPEAKER_01: Um, and and that good in indication that things may be a little too far, too fast.
29:15
SPEAKER_05: Yes, yes.
29:17
SPEAKER_05: So another thing that I know we spent time debating is around these so-called legacy clauses.
29:23
SPEAKER_05: I think from an accounting point of view, we might call this more grandfathering.
29:26
SPEAKER_05: And this is the idea we're putting new standards in place, but if you have existing contracts, you could you can continue to account for them.
29:35
SPEAKER_05: There's a lot of pros and cons.
29:36
SPEAKER_05: So can you highlight a few of those and then maybe give a point of view?
29:39
SPEAKER_01: Yeah, I mean, and sometimes these off-take agreements are long-term, 10 to 15 years, just to make them economical.
29:45
SPEAKER_01: And so I do think it makes sense that there's this exemption or grandfathering.
29:50
SPEAKER_01: Um, and that was a lot of the questions that I got from my clients is just like, hey, I'm actually in a contract right now.
29:56
SPEAKER_01: Yeah.
29:56
SPEAKER_01: Um, can I maintain this?
29:57
SPEAKER_01: And and seems like they're going to keep that, and then we support that.
30:00
SPEAKER_01: Yes.
30:01
SPEAKER_01: I think, you know, part of the cons is that you're just you're having then two dual systems for reporting, and and I don't know exactly how how a company would do that.
30:09
SPEAKER_01: How would we then audit it as well?
30:11
SPEAKER_01: Um, so it creates some challenges of just like a transition that may be a bit longer than you would hope, especially if you have a longer off-take agreement.
30:19
SPEAKER_05: Yeah, some of these are like 20 years long.
30:21
SPEAKER_01: So I think that's probably gonna be the the implementation challenge here, and then how it shows up in a report.
30:26
SPEAKER_01: Um, is it an asterisk or is it a bit more detailed than that?
30:30
SPEAKER_05: Yeah, but I think to your point, there's real economic consequences then if you were to say, oh, well, this contract did qualify, and then oh, sorry, no more.
30:40
SPEAKER_05: Yeah, and then what's the company supposed to do in that situation?
30:44
SPEAKER_05: Yeah.
30:44
SPEAKER_01: And they're making long-term bets on this.
30:46
SPEAKER_05: Yeah.
30:46
SPEAKER_05: So hopefully, at least for now, we think there's, I mean, the fact of assuming in there, I think it's a good indication they're thinking.
30:53
SPEAKER_01: Yeah, for sure.
30:54
SPEAKER_05: So I think those are my key ones I wanted to ask, but anything else that stood out to you you want to make sure we talk about?
31:00
SPEAKER_01: I think like, you know, there there are next steps here.
31:03
SPEAKER_01: The protocol takes these, uh, this work back.
31:05
SPEAKER_01: Um essentially, like they run through the scope of work again with those questions with the comments in mind.
31:10
SPEAKER_01: And so, like, you know, is there general consensus that we're in the right path or are there any big red flags that we have to go revisit?
31:17
SPEAKER_01: And then it's it's almost like back to the drawing board with the working group and it goes back to the independent standards board.
31:22
SPEAKER_01: So, again, it's not the final say.
31:24
SPEAKER_01: There's a lot more to come.
31:25
SPEAKER_01: Um, I will say the one thing that um that will come out of this is like it's likely the the the actual standard will probably shift a few months.
31:33
SPEAKER_05: I was gonna ask you about that.
31:35
SPEAKER_01: Well, there's a few reasons.
31:36
SPEAKER_01: Not and it's not just on the scope too, it's mostly because of the ISO relationship we're hearing.
31:40
SPEAKER_01: Um, because of the relationship with the ISO and and GSH protocol secretariat, is that ISO is gonna have a bit more say and and input into the process because it didn't exist when this process started.
31:52
SPEAKER_01: And so I think it was just like finding the right place for this.
31:54
SPEAKER_01: Um and I mean the market-based approach doesn't exist in the ISO standard, um, but it's likely that there's going to be some sort of discussion.
32:01
SPEAKER_01: So, more from a broader like corporate standard, scope three perspective is that the ISO relationship will now shift things a little bit, probably to give them more time to respond.
32:11
SPEAKER_05: So, for our listeners that either didn't fully understand the agreement that was announced or that weren't maybe didn't see it, can you just explain what is this relationship, new relationship between, well, first of what ISO is, and then the relationship between the two?
32:25
SPEAKER_01: So ISO is the international standards organization.
32:27
SPEAKER_01: They have standards for a lot of different things, not just the environment uh or or climate change, um, but there is an existing like corporate accounting standard within ISO, ISO 14064.
32:37
SPEAKER_01: Um, it is slightly different than the GSU protocol.
32:40
SPEAKER_01: So the GSU protocol was built on the ISO standard.
32:42
SPEAKER_01: The GSU protocol expanded a lot of things, um, added a lot more um like prescription in that.
32:48
SPEAKER_02: Yes.
32:49
SPEAKER_01: Um and so the relationship that was announced uh later last year in 2025 ultimately was a um you know a sharing of responsibilities, a you know, not too different standards for corporate accounting anymore.
33:01
SPEAKER_01: And so part of the relationship is now to co-build these standards.
33:06
SPEAKER_01: Um, just the the timing of the relationship didn't work out with the timing of the initial revisions, and so this is now like almost an insertion of the ISO relationship.
33:15
SPEAKER_01: Um, the the other thing that they're going to be building side by side, and they've already started this process, is a product carbon footprint accounting standard.
33:22
SPEAKER_01: So that will be done like in parallel together.
33:24
SPEAKER_01: Um, whereas this is a bit more, okay.
33:26
SPEAKER_01: Well, now we have the relationship, let's let's work together on aligning on the standard.
33:30
SPEAKER_05: So is the expectation then that we the ISO standalone standard will not exist once this process is complete with updating the GHG protocol standards?
33:40
SPEAKER_01: We haven't been told that yet.
33:41
SPEAKER_01: That's a very good question.
33:42
SPEAKER_01: Um, and I've asked this question in the meetings.
33:45
SPEAKER_01: I think they're still working through a lot of the details.
33:47
SPEAKER_01: Yes.
33:47
SPEAKER_01: Their first meeting, their first working group meeting, I think was um mid-January.
33:52
SPEAKER_01: And so that was just like, okay, here's how we're gonna do all this over the next X while.
33:57
SPEAKER_01: So I don't think they have all the answers yet, is the other thing.
33:59
SPEAKER_01: Yes.
34:00
SPEAKER_01: Um, but ultimately co-branded standards is the idea, um, working on them together, uh, making sure they align with the other suites of standards that are out there.
34:07
SPEAKER_05: So then maybe the next obvious question, um, for those of you familiar with the ISO standards, you have to pay for them.
34:12
SPEAKER_03: Yeah, yeah.
34:13
SPEAKER_05: And you have to pay per use or per user.
34:17
SPEAKER_05: So if you and I would each need our own license.
34:20
SPEAKER_05: So would the plan, I mean, do we have any idea then how that will impact the fact that obviously this whole point of these standards, they're free, they're widely accessible, they even talk about free in a bit of characters.
34:33
SPEAKER_05: So yeah, so do we have any sense for that?
34:35
SPEAKER_01: I haven't heard.
34:36
SPEAKER_01: I expect them to keep it free because that would be um that wouldn't help.
34:42
SPEAKER_01: Yeah.
34:42
SPEAKER_01: Um, but again, I don't I don't have the exact answer.
34:44
SPEAKER_01: Yeah, yeah.
34:45
SPEAKER_05: All right, well, it should be very interesting to come then.
34:47
SPEAKER_05: Actually, it's funny because um that makes sense about the relationship.
34:51
SPEAKER_05: I thought you were gonna say because of this complexity, it's just making it that much harder to get through this because so we already knew there was going to be more questions asked about scope two, but if they're getting all this feedback, if we were talking about the ISSB or um even like FREG with the ESRS, a lot of times when you get this much feedback, there's an idea that you would need to re-expose for public comment.
35:17
SPEAKER_05: Right.
35:17
SPEAKER_05: Do we have any sense if there would be a similar view here?
35:21
SPEAKER_01: I haven't seen like the exact time I expect it to happen.
35:25
SPEAKER_01: Yes.
35:25
SPEAKER_01: Because the expectation is that for the corporate standard and the scope three, um, we're looking at end of year now for like the public consult.
35:32
SPEAKER_01: Oh, so even later than well, it's because of the ISO integration.
35:36
SPEAKER_01: And I I don't want to say it's bad.
35:37
SPEAKER_01: Like they should have their theorem, they're working together, they have a relationship.
35:43
SPEAKER_05: To have one.
35:44
SPEAKER_05: I mean, this is a point in ESRS where they say you may consider those ISO standards.
35:48
SPEAKER_05: That's been a point of confusion.
35:50
SPEAKER_01: So so yeah, it's leading to a bit more of an extended timeline.
35:54
SPEAKER_01: And so I'm expecting another whether it's in like a full exposure draft, yes, depends on how drastic the pairback will be, I think, or the change.
36:02
SPEAKER_01: Maybe a pairback.
36:03
SPEAKER_04: Um everyone, let's say the pairback.
36:06
SPEAKER_01: Nothing promised.
36:07
SPEAKER_01: Um, so I guess it depends on how drastic it is.
36:09
SPEAKER_01: Yes.
36:09
SPEAKER_01: But the like I do expect another period of public consult, especially if maybe it's the full draft altogether, um, where it's just like the full, here's the full standard.
36:19
SPEAKER_01: Yes.
36:19
SPEAKER_01: Um, and I I've heard that there is more coming.
36:22
SPEAKER_05: So okay, so more to come.
36:24
SPEAKER_05: So if I'm a company and particularly a company that started looking at this and thought it was overwhelming and confusing, or a company that's thought this is great, either way, what do you recommend to companies to do right now?
36:38
SPEAKER_01: Yeah, I think like keep doing what you're doing.
36:40
SPEAKER_01: I mean, these things aren't going to change overnight.
36:42
SPEAKER_01: Um, I think you know, the expectation is that the new standard will be out the beginning of 2028.
36:47
SPEAKER_01: Um, there's a bit of an open question of, you know, when is it in effect?
36:50
SPEAKER_01: Um, and then even it's still a voluntary standard, right?
36:54
SPEAKER_01: And so there's probably a bit more market pull than anything versus you know, have to do this as of 2029, January 1st.
37:01
SPEAKER_01: And so I wouldn't change anything drastically.
37:03
SPEAKER_01: I would still maintain that, like, you know, if there's an intention to go for market-based instruments, you know, do a VPPA is to continue down that path because the expectations that the legacy like will still be there.
37:14
SPEAKER_01: Um, and hopefully it's not too much of a chill on the market because it's just so fast.
37:19
SPEAKER_05: And uncertainty.
37:20
SPEAKER_01: And uncertainty, yeah.
37:21
SPEAKER_01: So I think like, you know, we haven't been telling a lot of clients to change any of their approaches here.
37:26
SPEAKER_01: I think just stay close to this and and um just understand where the the challenges are and then ask questions within your peer groups of or or your consultants or or accountants just to understand like where direction of travel is on these things.
37:38
SPEAKER_05: So we started with this and I just want to loop back.
37:42
SPEAKER_05: So with the 2023 consultation, they published a lot of summaries and points of view, and it is extremely helpful actually to see them in that form.
37:51
SPEAKER_05: So, do you have any sense what we're gonna see coming from this consultation itself?
37:56
SPEAKER_05: So put us out what they're gonna do with it, but just what we're going to hear publicly about it.
38:00
SPEAKER_01: It's it's very likely to be published.
38:02
SPEAKER_01: I don't know how um how like uh flashy they will be with it.
38:07
SPEAKER_01: Yes.
38:08
SPEAKER_01: Um, because one of my criticisms uh has been just like there's transparency.
38:13
SPEAKER_01: You can see what's ever what's happening in every single technical working group.
38:16
SPEAKER_01: It's the accessibility of that is a bit of a challenge because it's very hard to find.
38:20
SPEAKER_01: Yes.
38:21
SPEAKER_01: And then once you what you don't know what you're looking for, um, you're seeing minutes or you're seeing a presentation, you don't really know where everything is.
38:28
SPEAKER_01: And so I I fear it might sit in that world if you see the summary of public consult, you know, it's gonna be a bunch of stuff in your presentation to the working group versus here is the document, like here is a good summary.
38:39
SPEAKER_05: Oh, like what they put together last year.
38:40
SPEAKER_05: It was actually was very readable.
38:43
SPEAKER_05: Yes.
38:43
SPEAKER_05: And you really got a good sense for, yeah.
38:46
SPEAKER_01: So I'm hoping it's the readable side.
38:48
SPEAKER_01: Yes.
38:48
SPEAKER_01: Um, and and honestly, they've been very good at transparency on this.
38:52
SPEAKER_01: Like, I won't stress it enough.
38:53
SPEAKER_01: The governance is there, they know what they're doing.
38:56
SPEAKER_01: Um, and and so I hope that it will just be in the same digestible form.
39:00
SPEAKER_01: Um, that has been one of the asks.
39:02
SPEAKER_01: Like, help us bring this to the light.
39:04
SPEAKER_01: Yes.
39:05
SPEAKER_01: Um, and so I I trust it will be in some digestible form.
39:09
SPEAKER_01: It's just like, where will it sit?
39:10
SPEAKER_01: And like when will they tell us?
39:11
SPEAKER_01: And yeah.
39:12
SPEAKER_05: Well, so even if it's not, then we will have you back on the podcast and you can help our listeners digest.
39:18
SPEAKER_05: So that sounded slightly sarcastic, but that's okay.
39:23
SPEAKER_05: All right.
39:23
SPEAKER_05: Well, Colin, it's always such a pleasure to talk to you.
39:25
SPEAKER_05: Look forward to continuing this conversation.
39:28
SPEAKER_02: For sure.
39:28
SPEAKER_02: Thanks.
39:28
SPEAKER_05: Thank you.
39:29
SPEAKER_05: And then to our listeners, thank you as well for joining us.
39:31
SPEAKER_05: And it's always nice to have you with us.
39:34
SPEAKER_05: And please join us again next week for more from Sustainability Now.
39:41
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39:43
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39:47
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39:49
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39:54
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40:03
SPEAKER_04: From thought leadership at PWC, I'm Heather Horn.
40:08
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40:19
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