How investors can take action on methane disclosure resolutions, including intitial questions for engagement and follow-up questions.
Initial questions for engagement
- What are your plans to expand your methane reporting and what are the potential challenges to overcome?
- What form of a quantitative methane reduction target would work best for your company?
- What is your position on the role of regulations in reducing industry emissions and what would help make you more supportive?
- If you have a methane reduction target, how did your company decide on the target? What are the key drivers to building on your positive step and achieving the target?
- What is your company’s assurance process for methane emissions reporting?
- How can your company work to build trust with the public through greater public reporting on methane?
Investors require actionable data from oil and gas companies in order to manage methane risk, assess company performance and understand the materiality of methane for any given company. In addition to reporting absolute methane emissions on a stand-alone basis (i.e. not in a consolidated carbon dioxide equivalent figure), leading companies will report against the methane metrics detailed in the table below.
|METRIC||DESCRIPTION||WHY IT’S IMPORTANT||HOW/WHERE TO REPORT||LEADING COMPANY EXAMPLES|
|EMISSIONS RATE||Methane Emissions/ Gas Production (or throughput)||Enables comparison of company performance over time, and comparisons in methane performance between companies.||OG 7.5||SRS 505-4, page 21 line 412||E1-C3, page 45||NR0101-01 and NR0102-01||Marathon Oil, Chevron, and EOG report a methane emissions rate.|
|EMISSIONS REDUCTION TARGET||Quantitative, time-bound target to reduce emissions.||Targets signal importance of issue, and drive management and staff performance.||OG 7.7||SRS 302-2-c-iii, page 12 line 144||N/A||N/A||Southwestern Energy reports a goal of keeping methance emissions below 0.36 percent of production.|
|LEAK DETECTION AND REPAIR (LDAR) PROTOCOL||Frequency, scope (% of assets covered), and methodology (i.e. type of equipment used) of LDAR program.||LDAR is the most important operational practice to identify and fix accidental leaks, and all three aspects drive effectiveness.||OG 7.3||SRS 301-2-c-iii, page 12 line 144||N/A||NR0101-03 and NR0102-02||Southwestern Energy reports conducting LDAR at least once a year on 88% of total well count using an OGI/FLIR camera.|
|METHANE POLICY POSITION||Company position on the role of regulation to limit industry emissions and how this position differs from that of trade associations and other third party organizations to which the company is a member.||Leading corporate actors not only have best-in-class operations to limit emissions, but also support policies which reduce reputational and product risk for the whole industry.||N/A||SRS 615-1.2, page 10 line 102||SE14-01, page 124||NR0101-25||Statoil has disclosed a public policy position on methane regulations to “support with minor exceptions.”|
A note on methane metrics and reporting platforms
While the methane metrics included in the table above can, in some instances, be used in various reporting platforms, only CDP has formally incorporated these metrics into their methodology and so should currently be considered a leading option for methane reporting. Adoption of these methane metrics by GRI, SASB and other reporting frameworks like IPIECA can be achieved through investor input and support. Such harmonization of reporting across platforms can help manage reporting burdens on industry.
EDF research demonstrates that oil and gas companies, with limited exceptions, are not setting methane reduction targets. Target setting is a key practice to drive management attention and affect change. Investors should encourage companies to set and disclose targets, and be flexible to the form of the target, given that each company may have its own approach to this issue.
Companies may wish to set intensity targets based on their methane emissions rate. For example, the industry led One Future initiative seek to limit upstream and midstream emissions to no more than 0.36% and 0.30% of production by 2025, respectively. Alternatively, companies can set absolute emissions reduction targets based on tonnage or a percentage reduction over time. With the North American countries aiming to reduce emissions 40-45% by 2025, investors may wish to ask how companies can set targets that meet or exceed these national targets.
With the North American countries aiming to reduce emissions 40-45% by 2025, investors may wish to ask how companies can set targets that meet or exceed these national targets.
Action on methane disclosure resolutions
Over the last few years, investors like Trillium and CalSTRS have filed methane-focused resolutions, urging companies like WPX Energy, Gulfport Energy and Occidental Petroleum to provide better reporting on how they manage methane emissions. Methane disclosure resolutions filed in the U.S. during the spring 2016 proxy season have also been supported by proxy advisory firms ISS and Glass Lewis. In the U.S., organizations such as Ceres and the Interfaith Center on Corporate Responsibility (ICCR) can help investors support and file shareholder resolutions concerning methane.
|Reports on one of the methane metrics in table above||Reports against 2-3 methane metrics.||Reports against all the above metrics.|
|Reports methane emissions data separate from other GHGs.||Uses best management practice quantitative target, (e.g. conducting LDAR on a % of assets, reducing methane leaks incidence rate per inspection, improve frequency of LDAR).||Reported information is audited by third-party.|
|No methane reduction target or firm plans to set one.||Neutral stance on methane disclosure resolutions.||Transparently reports progress against public methane reduction targets.|
|Does not support shareholder resolutions seeking improved methane disclosure.||Supports appropriate methane disclosure shareholder resolutions, if applicable.|