Resolved clauseRESOLVED, shareholders request that Coterra issue a report analysing a critical climate change concern, the reliability of its methane emission disclosures. The report should:
• summarize the outcome of any Coterra efforts to directly measure methane emissions, using recognized frameworks such as OGMP;
• explain whether there is likely to be a material difference between direct measurement results and Company’s reported methane emissions;
• assess the degree to which any differences would alter estimates of the Company’s Scope 1 emissions.
The report should be made public, omit proprietary information, and be prepared expeditiously at reasonable cost.
Whereas clauseWHEREAS, methane is at least 80 times more potent than carbon dioxide over a 20-year period, meaning reducing emissions now can buy time to address the climate crisis.
In 2020, 32 percent of U.S. methane emissions from human activities came from natural gas and petroleum systems.(1)
Methane emissions can be quantified directly through measurement or indirectly through calculations and modelling. Estimates improve when direct measurement methodologies are used, when emissions are identified by source type and at a site or facility level, and then reconciled, as shown by the Oil and Gas Methane Partnership 2.0 (OGMP). The Environmental Protection Agency (EPA) methodology used to estimate methane emissions fails to capture many major leaks, wasting valuable product (worth $2 billion per year) and substantially underestimating emissions. Studies have found actual emissions to be 50 to 100 percent higher than reported emissions.(3) In certain basins, emissions are more than 10 times industry disclosed figures.(2) Therefore, oil and gas industry Scope 1 emissions may be significantly higher than reported.
Companies that do not manage methane emissions jeopardize the oil and gas industry’s broader decarbonization efforts, and risk their reputation and license to operate, as investors, regulators and civil society are setting expectations to address this issue. In 2021, investors managing more than $6.23 trillion supported strong federal methane regulations. The U.S. joined the Global Methane Pledge, committing to using best available inventory methodologies to quantify methane emissions. Companies across the world, including ConocoPhillips, Devon and Pioneer, have joined the OGMP, committing to improving methane data quality and consistency. According to EPA data, predecessor organizations to Coterra Energy (“Coterra”), Cabot Oil & Gas and Cimarex Energy, ranked 96th and 52nd in methane intensity among U.S. top 100 oil and gas producers, with intensities of 0.02 percent and 0.13 percent, respectively.(5) However, given the limitations of EPA’s methodology, this ranking lacks credibility.
Supporting statementSupporting Statement
At management’s discretion, we recommend that the report:
• Describe the types of source- and site-level measurements used;
• Provide an explanation of the difference between the Company’s estimated methane emissions and their own or third-party direct measurements, by site or region;
• Describe any effort to improve emission estimates over time, consistent with frameworks such as OGMP; and
• Describe any efforts to validate emissions estimates and disclosure through third-party audit or evaluation.