SUPPORTING STATEMENT: : Enbridge’s current scope 3 emissions
disclosure methodology runs counter to guidance by the
CDP,1 the GHG Protocol,2 and investor-led Climate
Engagement Canada,3 leading to a large under-reporting of
scope 3 emissions and by extension its transition risk.
Enbridge’s scope 3 reporting is incomplete because
excludes downstream emissions for use of goods and
services, so called “category 11 emissions,” from its
midstream business. While Enbridge reports some category
11 emissions from its gas utility business, it does not report
the category 11 emissions associated with midstream
business services — transportation and storage of oil
and gas.
These emissions are material to Enbridge because its
business model relies on their release, and their exclusion
therefore obscures risks associated with these emissions.
m. (sic)
Moreover, as Enbridge expands its infrastructure such as
gas pipelines or LNG terminals, the trend line for these
scope 3 emissions is not properly measured and assessed
for risk.
Enbridge claims either existing reporting methodological
uncertainty, incomplete data, or double counting as reasons
to not fully report its scope 3 emissions. Yet, the guidance is
clear that Enbridge should report the material emissions
from category 11 and other energy companies have
overcome these challenges to report relevant scope 3
emissions.4
In 2020 Enbridge made a commitment “to expand the scope
of our public disclosure of scope 3 emissions within the next
2-3 years.”5 This resolution presents an opportunity for
investors to ensure Enbridge fulfills this commitment.
This is the second year this proposal has been submitted.
Last year 24.4% voted in favour, with another 4% abstaining,
for a total of 28.4% breaking with management.6 Despite this
relatively high vote by Enbridge investors, the company is yet
to improve its approach to the issue.
We respectfully request that shareholders vote for this
proposal