New GSG, SHG, SEC Facilities Regulations and Reporting Requirements on the near-term horizon.
Is your organization ready?
How a company assesses and plans for climate-related risks may have a significant impact on its future financial performance and investors’ return on their investment in the company. (SEC 17 CFR 210, 229, 232, 239, and 249)
“ESG- Using Environmental, Social and Governance factors to evaluate companies and countries on how far advanced they are with sustainability. Once enough data has been acquired on these three metrics, they can be integrated into the investment process when deciding what equities or bonds to buy.”
ISO 14064
ISO14064 Boundaries
- Organizational
- Control
- Equity share
- Operational
- Direct GHG emissions and removals
- Energy indirect emissions
- Other indirect emission
GHG/SEC Reporting
The Securities and Exchange Commission (SEC) proposal to require that public companies disclose climate-related information. 17 CFR 210, 229, 232, 239, and 249, RIN 3235-AM87
Public organizations will be required to provide climate-related information in their registration statements and annual reports, including information about climate-related risks that are likely to have a material impact on its business, results of operations, or financial condition. The required information about climate-related risks would also include disclosure of greenhouse gas emissions, which have become a commonly used metric to assess exposure to risk. In addition, under the proposed rules, certain climate-related financial metrics would be required in audited financial statements.
- The proposed rules would require public filers to provide climate-related information in registration statements and annual reports such as the Form 10-K. The proposed rules draw from existing disclosure frameworks including the Task Force on Climate-Related Financial Disclosures and the Greenhouse Gas Protocol.
- Companies would be required to disclose Scope 1 and 2 greenhouse gas (“GHG”) emissions, including data on carbon offsets.
- Companies would be required to disclose Scope 3 GHG emission “if material” or if the company has explicitly set climate goals.
- In addition to GHG emissions data, the proposal would require companies to provide forward-looking statements about how climate risks are likely to affect their business, and information about the company’s governance around climate risks.
- The proposed rules contain a “safe harbor” for liability for Scope 3 emissions disclosure. Commissioner Peirce raised concerns about the efficacy of this safe harbor language.
Additionally, GHGRP (codified at 40 CFR Part 98) requires reporting of greenhouse gas (GHG) data and other relevant information from large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites in the United States. This data is used by organizations to track and compare facilities’ greenhouse gas emissions, identify opportunities to cut pollution, minimize wasted energy, and save money. States, cities, and other communities can use EPA’s greenhouse gas data to find high-emitting facilities in their area, compare emissions between similar facilities, and develop common-sense climate policies.
Base year GHG inventory is step one and determines your facilities carbon footprint, Step 2 is Reducing Carbon Footprint, Step 3 = Offset.
How to reduce the carbon footprint of a building?
- Design for long life and adaptability
- Source building material, bricks, cement, aggregate and sand from the closest source to reduce the transport distance and related emissions
- Modify and refurbish instead of demolishing or adding to avoid unnecessary production and transport of building materials
- Ensure that waste and off cuts are reduced by specifying standard sizes
- Ask suppliers for information on their energy practices to create awareness and allow for the making of informed decisions.
Reduction possibilities
- Energy savings
- Awareness
- Auto switch off
- Buffer zones
- Waste and packaging
- Take back agreements
- Use of biogas for chilling
- Use of organic waste as mulch/compost
- Transport
- Hybrid vehicles for fleet
National averages and ‘ad hoc’ processes won’t work
A locally researched, detailed unit price cost database and an associated LEAN, integrated planning, procurement, and project delivery process are both critical to reducing the carbon footprint of facilities and other built infrastructure.
Conclusion
The journey towards efficient life-cycle management of the built environment, carbon literacy, and LEAN process is not easy.
The challenge for organizations is developing appropriate leadership and commitment. Collaboration and integration of internal and external teams, and shared information that is transparent from cost and technical perspectives are all fundamental requirements.
Change is difficult for everyone. It’s critical to understand the risks and opportunities, and to establish a long-term commitment
“Greenwashing” is a huge problem. “LEED certification” is not sufficient to meet GHG requirements or other regulations (current and pending). LEED is NOT a standard, it’s a rating system.
via Four BT, LLC – Integrated LEAN Facilities Planning, Procurement, and Project Delivery Solutions