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    CSRD: EU revolutionizing corporate sustainability accountability and decisions

    By
    Will Dubitsky
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    0

    Introduction

    The EU Corporate Sustainability Reporting Directive (CSRD), many years in the making, is revolutionary.  CSRD will replace the questionable smorgasbords of stand alone inserts on corporate sustainability profiles.  It does so by requiring firms to provide detailed framed descriptions on integrating sustainability into all facets of corporate decision-making.

    This includes Scope 3 considerations on suppliers and end-users.

    Most important, CSRD will become an international gold standard since all firms with significant business in the EU most submit CSRD reports.

    In total, CSRD obliges disclosures on 13 different areas.

    With CSRD, sustainability will be at the forefront in recording past and planning future endeavours.

    Because it is highly complex to systemize descriptions of sustainability for every aspect of company activities and decision-making, the reporting process will be phased in and will organically evolve.

    Beyond doubt, CSRD is a radical departure from ESG, which, for many companies, has become a public relations exercise.

    CSRD overview

    The Corporate Sustainability Reporting Directive (CSRD) became effective January 5, 2023.  It replaces the Non-Financial Reporting Directive (NFRD).  EU Members States had until by July 2024 to integrate CSRD into their laws.

    CSRD goes much beyond NFRD by requiring the integration of risks, targets  opportunities and due diligence, relative to environment and people, in corporate strategies and business models.  This includes global financial activities and short- and medium term data to guide decision making.

    Consequently, CRSD assists investors, civil society organizations consumers and other stakeholders assess and compare the sustainability performance of firms, based on standardized reporting.

    These common standards pre-empt adhering to multiple voluntary criteria common to ESG.  The voluntary ESG boundless characteristics typically result in gaps in accountability.  This is especially so since ESG offers little or nothing on comparing annual sustainability performances.

    Firms falling under the umbrella of CSRD are large companies previously subject to the NFRD; other listed companies;  listed small and medium size enterprises; large private European firms; and non-European corporations with significant business in the EU.

    Companies outside the EU with significant business in the EU that must comply with CSRD stipulations are those having securities listed in a EU market; a huge EU subsidiary; and a large connection to an EU group such as a holding company, or a EU parent group. 

    CSRD reporting

    The essential information must cover quantitative, qualitative descriptions on 1) sustainability themes such as climate change; pollution; biodiversity and ecosystems; water waste and marine resources; plus resources use and circular economy; 2) social challenges including working conditions of a firm’s own workforce and workers in the value-chain, diversity, consumers/end users and community impacts; and 3) governance related to human rights and business ethics, all integrating Scope 3.

    The technical reporting rules known as the European Sustainability Reporting Standards (ESRS) became law in December 2023.

    Apart from general disclosures, all ESRS standards necessitate a materiality assessment.  Should such assessments not apply, an explanation must be provided.  Also, some reporting components are voluntary.

    The draft ESRS standards were originally conceived by the European Commission with the technical advice of the group previously known as the European Financial Reporting Advisory Group (EFRSG). The EFRSG was a multi-stakeholder independent body including investors, companies, auditors, civil society, trade unions, academics and national standard-setters.

    A hefty multi-stage series of EFRSG consultations followed and terminated in June 2023 with a 4-week public consultation.

    Refinements of the EFRSG became the blueprint point of departure for an organic continuing process for improvements and clarifications that, among other things, optimize interoperability with International Sustainability Standards Board (ISSB) standards and the Global Reporting Initiative.  This facilitates matters for those companies that wish to comply with one and/or the other.  The EU aims for a seamless global compatibility and comparability framework on sustainability reporting.

    Accordingly, not only will the evaluation criteria become an evolving/living universal foundation for rating the sustainability of companies, but they will also guide firms on how to improve their practices and standings.

    A company has the option of having its draft CSRD report audited by a third party.  Material so collected must appear in annual reports and are subject to audit.

    Penalties for non-compliance are determined by EU Member States.

    Scope 3 inclusion sets CSRD apart

    Scope 3 emissions dive into the entire value chain of a firm, from suppliers to end-users, typically representing the majority of emissions associated with a company.

    The most flagrant example of the importance of including Scope 3 in corporate sustainability descriptions is that of fossil fuels, the dominant global warming sources.  It is estimated that 75% of total emissions, and 90% of a fossil fuel firm’s emissions, are attributable to the burning of these fuels.

    Across all categories of firms, Scope 3 represents an average of 70% of company-specific emissions.

    By including Scope 3 in a firm’s sustainability statements, at the very least, creates an incentive for companies to put emissions reduction pressure on suppliers and/or change certain suppliers.

    Year-by-year reporting comparisons helps guide corporate investment choices.

    Phased-in start timelines

    Recognizing that extensive sustainability reporting could be especially burdensome for firms with less than 750 employees, the ESRS makes way for a phased-in reporting process.

    The first phase of CSRD reports will begin in 2025, based on 2024 corporate performances.  This phase covers firms listed on an EU-regulated market that have more than 500 employees.

    Large companies with less employees, listed as well as non-EU listed, must submit their first report in 2026, for the financial year 2025.  Such companies must meet two of the following criteria: over 250 employees, €50 million ($55 million) in turnover, €25 million ($28 million) in total assets.

    Listed and non-EU listed small and medium size enterprises (SMEs), along with small and non-complex credit institutions, and captive insurance undertakings, will have the obligation to submit their CSRD reports in 2027, with respect to the 2026 fiscal year.  Plus they will have a 2-year opt-out option after that.

    SME reporting standards are more supple and will be capped.  Draft versions of these less demanding standards are underway.

    For non-listed SMEs that may have to submit sustainability information to banks, investors, customers and other stakeholders, the EFRSG conceived a simpler voluntary guide.

    Non-EU companies with net revenues over €150 million ($165 million) annually earned in the EU; have a branch with either a turnover exceeding €40 million ($44 million); or a subsidiary that is a large company or a listed SME, will have to report on the sustainability impacts at the group level of that non-EU company, starting with the financial year 2028.  The first sustainability statement is to be published in 2029.  There will be different standards for such cases.

    For EU firms not listed, such as an EU subsidiary of a non-EU headquartered company, reporting is obligatory for firms having two of the following characteristics in their profiles for two consecutive fiscal years.  These characteristics are 1) total assets €25 million ($28 million) as of December 2023; 2) net revenue €50 million ($55 million) as of December 2023; and an average of 250 employees.

    The takeaway

    The CSRD will be an effective international corporate sustainability crusader because it applies to all large companies and SMEs doing business in the EU.  Since the overwhelming majority of multinational large firms and SMEs with international markets conduct significant business in the EU, the CSRD impacts are world-wide.

    The thoroughness of the CSRD process lends credibility to corporate descriptions of sustainability progress to-date and influences on a broad sphere of decision-making.  Without the CSRD portrait requirements on sustainability risks and opportunities, it is hard direct firms towards more sustainable practices.

    The CSRD is much more than a compliance exercise with lofty ESG narrations.

    Nuclear debacles: UK, Canada, U.S., IEA and others

    By
    Will Dubitsky
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    0
    Canadian Darlington Nuclear Facility

    Nuclear cost and time overruns

    While nuclear power has gained interest as a low carbon solution, cost and time overruns have dampened this interest.

    A Boston University study of 400 nuclear plants over 80 years indicated that, on average, building nuclear plants cost double the before construction projections, and 64% exceeded their timelines.  Average costs go 120% over original budgets, with the majority more than doubling.

    High maintenance costs add to the unattractiveness of the nuclear option, in particular, the old reactors in the U.S. and France.

    There is no shortage of examples of cost and timeline overruns.

    In 2008, the U.K government made an announcement on its first nuclear power plant, since 1995, the U.K. Hinkley Site C.  Back then, the AP 1000 project was to be completed by 2020.

    Subsequently, the project joint venture project group revealed it would not be completed until 2025. It ended up with a government bailout out and nationalization with a financing contribution from Chinese entities.  Construction began in March 2017, with a timeline of 10 years.  Now, 16 years after the original announcement, the project is still not completed.  And the termination date has once more been revised, this time to 2030, more likely 2031, and by then only one of two reactors will be operational.

    The Hinkley Site C AP 1000 original budget was US$11.3 billion, but the cost has been upped to US$62.7 billion.

    The Netherlands approved 2 nuclear reactors 1-1.6 gigawatt (GW) each, expected to run up to US$5.5 billion by 2030. The revised cost is US$13 billion.  There is no plan.

    Like Hinkley Point Site C,  Vogtle and Summer in the U.S., Flamanville in France and Olkiluoto in Finland, were all financial and scheduling fiascos.

    Many view China as an exception, with 43 GW of nuclear capacity added between 2012 and 2022, building 3 nuclear reactors per year for the past 5 years, down from 7/year between 2016 and 2018.  Notwithstanding, China’s nuclear path hasn’t been smooth.  Poised to triple renewables capacity by 2030 with the addition of 3,100 GW of capacity, 300 GW of new solar and wind capacity installed in 2023, perhaps China will give up on nuclear.

    Decline of the nuclear sector

    During the period of 2000 to 2022, nuclear capacity as a percentage of global power generation declined by half, from 17% in 2000, to 9% in 2022.

    The global number of nuclear reactors peaked in 2022 at 438 and that dropped to 407 in 23 counties by mid-2023.  The average age of a reactor was 31.4 years in 2022.

    All of the world’s reactors are losing money or are economically unviable.  The costs of storage, typically for 250,000 years, are not factored in, massively subsidized.

    In absolute terms, the global nuclear power supply increased 4% in 2022 compared to 2021, trailing all other power sources.

    The long lead time to arrive at the operational stage means that no nuclear plant for which the planning began in 2020 can be completed before 2030.  Too late for compliance with the Paris Agreement.

    Successful nuclear programs

    Successful nuclear programs in the U.S., France and South Korea were the object of major military involvement from the outset, including financing, technology requirements, safety, human expertise and weapons-grade enrichment of uranium.  Each of these governments selected a one GW-scale model.

    These military programs ran 20 to 30 years, thus were replicable for commercial use.  This kept commercial reactor costs down. 

    Nuclear boosters’ learning disabilities

    The International Energy Agency believes nuclear capacity will reach a new record in 2025.

    At COP28, the U.S. lead the way for a pledge involving 25 nations to triple nuclear power generation.

    In the nuclear development pipeline, China plans comprise 22 GW, India 6 GW; Turkey 4.5 GW; South Korea 4 GW; and Egypt 3.3 GW.

    Rowing against the current as well, in a big way, is Ontario, Canada.  More on Canada in the near last segment.

    Small modular reactors, learning disabilities on steroids

    Much hope for a nuclear renaissance lies with small modular reactors (SMRs), compact nuclear reactors.  But SMRs have yet to get beyond start-ups.  Not only are SMRs unproven, there are many competing designs, maybe 57.

    SMRs, which produce less than 1 GW, cannot not achieve the necessary economies for a manufacturing scale, aren’t faster to construct, are inefficient and decommissioning is slow plus expensive.  At best, one would have to wait until 2030 for scaling up SMR tech to be commercially viable.

    Most governments, with the exception of China and Canada’s Ontario Premier, Doug Ford, don’t see the case for SMRs.  After all, the costs are five times that of an onshore wind farm or solar project to produce the same amount of energy.

    Notwithstanding SMRs are a failed technology, the U.S. government is pouring billions into SMRs. The U.S, has yet to have an operational SMR.

    The U.S.-based NuScale had planned a SMR project for Oregan.  It pulled out due to cost overruns.

    The Utah Associated Municipal Power Systems (UAMPS) too, decided to back the construction of NuScale SMRs, a six-reactor 462 MW SMR project.  Utah townships pulled out after the costs, upped to US$89 megawatt hour (MWh) from the original estimate of US$59/MWh, proved to be too high and timeline target for 2030 didn’t seem realistic.  This, despite U.S. government providing US$1.4 billion.

    Canada’s learning disabilities

    Ontario, Canada

    Of the 19 nuclear commercial reactors in Canada, 18 are in Ontario.

    In Summer 2023, the Doug Ford government announced it would double the size of the Bruce Power nuclear station on the eastern shore of Lake Huron, currently the world’s largest.

    At the Pickering station near Toronto, the refurbishing of the first two of four unit A reactors went C$1.5 billion over budget, leading to abandoning the refurbishing of the other two Unit A reactors.  In 2020, Ford had said Pickering would be shut down by 2025.

    Nevertheless, on January 29, 2024, the Doug Ford administration announced it would refurbish all four Pickering Unit B reactors.  The government’s expects the refurbishment to cost C$19.4 billion with completion in eleven years, but that amount is uncertain.

    Ontario Power Generation is currently reviewing the extension of the Pickering operating license until December 2026.  If approved, the refurbishment would begin thereafter.  The Ford government intends to start refurbishing the Pickering B plant after 2026.  As a result, Ontario plans for decommissioning Pickering put on hold prime waterfront real estate for 30 years.

    The Ontario Darlington station on the north shore of Lake Ontario cost C$14.5 billion, 4 times the originally estimated amount, with the timeline from planning to operation 1981 to 1993, 12 years.  The Darlington plant cost overruns led to the Ontario Hydro equivalent to bankruptcy in 1988.  Debt retirement costs have jacked up Ontario electricity rates.

    The Darlington 4 reactors are now being refurbished with C$12.8 billion budgeted.  To cover the costs of the refurbishing, Ontario would need to have an electricity tariff of 13.7 (24.4) cents per kWh.

    Divulged in Summer 2023, the Darlington site, which has one SMR under construction, will get 3 more SMRs.  Never mind SMRs are several times more expensive than renewables.

    In the interim, until the expanded Ontario nuclear network is completed, the fossil fuel, natural gas, will be called upon to fill the supply gaps.

    Lastly, Ontario still does not have secure nuclear waste storage sites.  Currently, the province’s nuclear waste is stored in open pools or in casks in commercial grade warehouses alongside Lake Ontario.

    New Brunswick, Canada

    In New Brunswick, Canada, the only functioning Canadian nuclear station outside Ontario, the Point Lepreau CANDU reactor, commissioned in 1983, underwent a refurbishment, beginning March 2008.  The refurbishment was supposed to cost C$1.4 billion and take to 18 months to complete.  However, the time overrun went 3 years longer, to 2012, at a cost of another C$1 billion contributing to NB Power’s C$4.6 billion debt.  Not daunted by empirical evidence, a second refurbishment is being considered for 2041.  This assumes ongoing problems of unpredicted and planned outages and C$1 billion in lost production and repairs will be resolved.

    Quebec, Canada

    The current Coalition Avenir Québec government is considering re-starting operations of its Bécancour nuclear plant Gentilly-2, shut down in 2012.

    The hic in Quebec energy action plan for 2035 is that it assumes optimum electrification without a plan for reducing demand.  In 2021, Quebec consumed 23,000 kilowatt hours (kWh) per person while in France it was 7,000 kWh.

    The takeaway

    The global nuclear sector is mostly stagnant.  Typically, since 2018, there are 3 new plants per year.

    Also, it doesn’t help that plants must run 90% of the time to earn revenues.  Most nuclear technologies are not amenable to changes in required production output, up or down.

    It appears Ontario Canada, China, the U.S., the U.K., the IEA and a global nuclear cult are the last of the nuclear faithful, no matter what the facts are.  And China is not too sure.

    The nuclear faithful will find this article misleading.

    China’s electric vehicles go global: Protectionism won’t work

    By
    Will Dubitsky
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    0
    BYD Seal

    Electric vehicle (EV) imports from China will account for 25% of EV sales in Europe in 2024.

    Now China-based EV and battery firms are on the verge of coming to North America and there is no such thing as batteries without content from China.  This is the context for U.S. protectionist legislation.

    What follows is a most comprehensive plethora of reasons on why 1) protectionism won’t work and 2) North American and European EV manufactures are vulnerable to disruptive market threats from inexpensive Chinese EV alternatives.

    Continue

    Shell, two CEOs, two cultural shifts: Green transition to business-as-usual

    By
    Will Dubitsky
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    0
    Updated, October 27, 2023

    New vison, clean tech acquisitions and fossil fuel divestments

    Under the leadership of Shell CEO, Ben van Beurden, 2014 to 2022, it really seemed that Shell was taking climate change seriously.  In 2017, Ben van Beurden purported that the “biggest challenge” for the company was to acquire public acceptance.  He asserted “If we are not careful, broader public support for the sector will wane.”

    Perhaps, the most astonishing component of the new orientation was the Ben van Beurden plan to divest of US$30 billion of assets.  Amazingly, Shell had decided to sell its US$8.5 billion in assets in Canada’s oil sands.

    Likewise encouraging, Shell assured it would comply with the Paris Agreement; concluded peak oil would occur in the next few years; set a goal to cut its carbon emissions by 20% by 2035, 50% by 2050, issued a joint statement with lead investors for Climate Action 100+  representing US$32 trillion in assets, to deliver on the Paris Agreement; withdrew from the far right climate denial organization, the American Legislative Exchange Council; and advised the Canadian Association of Petroleum Producers (CAPP) that the CAPP climate and energy-transition-related policy positions constitute a “misalignment.”

    The flip side to the disavowal of traditional paths was the awesome pro-active Shell clean tech firms investment spree, entailing clean tech acquisitions, mergers and partnerships.  Many on the lengthy list of new clean tech can be found in my 2019 article.

    In 2018, Martin Westelaar, then head of Shell’s gas and new energy division, described Shell’s green transition as one of modestly beginning with a budget of US$1-2 billion year up to 2020, to prepare the case for shareholders to get on side for a doubling of such investments to US$4 billion annually after 2020.

    In 2019, Westelaar gave reason to believe that the Shell acquisition of First Utility, the largest electricity supplier in the UK, was a steppingstone for entry into a global solar market, presuming solar would become the biggest source of low carbon energy.

    Westelaar had exclaimed “electrification is the biggest trend in energy … it’s easier to grow in growing markets”.  And Shell wants to play a lead role in the new energy landscape to become “largest electricity power company in the world in the early 2030s.”

    In April 2019, Brian Davis, formerly Global Vice President, Energy Solutions from 2016 to 2020, vaunted the Shell vision of a global transition to electrification, including electric vehicles, batteries, microgrids.   

    February 11, 2021 press release officializes green transition

    Boasting Shell’s new vision as an oil and gas industry energy transition leader, in a Shell February 11, 2021 media release, Ben van Beurden, is quoted as saying “Our accelerated strategy will drive down carbon emissions and will deliver value for our shareholders, our customers and wider society.”

    This announcement indicated Shell that Shell’s corporate-wide carbon emissions peaked in 2018, its oil production peaked in 2019 and the firm would pursue divestments averaging US$4 billion a year.  Doing so, he portrayed Shell becoming less vulnerable to oil and gas prices.

    Ben van Beurden, depicted the Shell makeover crystal clear in the dispatch: “We must give our customers the products and services they want and need – products that have the lowest environmental impact.  At the same time, we will use our established strengths to build on our competitive portfolio as we make the transition to be a net-zero emissions business in step with society.”

    Accordingly, the communiqué implies the integration of environmental and social ambitions.

    This integration proposal comprises linking 10% of the bonuses of directors to lowering carbon emissions; US$2-3 billion annually for Renewables and Energy Solutions to become a world leader in clean power as a service; and 500,000 charging stations by 2025.

    New CEO, “ruthless” transition to oil and gas prioritization and clean tech fire sale

    All changed when Wael Sawan became the CEO of Shell in January 2023.

    Beginning June 2023, Wael Sawan implemented corporate reorganizational changes to put the emphasis on the “ruthless” approach to maximising value, specifically “absolutely committed to our upstream business.”  This new approach entailed a shift priorities in favour of oil and gas production and scaling back renewables.  Sawan prescribed a ‘fundamental cultural shift” critical to re-establish investor confidence.

    That meant that only green power projects with high returns or in sync with the value chain of Shell would get corporate support.  Sawan even had the audacity to declare that these changes would benefit schoolchildren in countries like Pakistan!

    To greenwash  the environmental consequences of the makeover, Shell announced it had not abandoned its goal to becoming a net-zero company by 2050.

    But the bluffing in that message became obvious in September 2023 when news broke out that Shell aimed to divest its majority or all shares in Sonnen, a major competitor with Tesla in the energy storage sector.

    Just prior to the revelations on Sonnen, Shell sold Octopus Energy, a German and UK retail energy business, meaning 1,800 employees were no longer with Shell. 

    Flurry of resignations

    In June 2023, Thomas Brostrom, who had been the Shell, VP for renewable generation, and head of offshore wind, quit after his position was downgraded to a new regional role.  Brostrom had been Ørsetd North America wind chief until joining Shell in 2021.  The Danish Ørsetd is the world leader in offshore wind development.

    Also in June 2023, Shell’s power trader, Steffen Krutzinna resigned over what for him was “heart-breaking,” to the effect that Shell was putting short-term profits over social and environmental responsibilities.  He posted on LinkedIn “I perceive that as a pivotal shift in corporate values.” “I don’t want to be part of that, so I’m out.”

    Not long after in July 2023, Melissa Reid, who had been Shell’s UK offshore wind manager chief, left too.  She had led Shell’s successful bid for the ScotWind seabed license.

    A year earlier, Caroline Dennett, a consultant for an independent agency Cloutt, terminated her working relationship with Shell with an open letter to Shell executives and its 14,000 employees regarding Shell’s “double-talk on climate.”  Expressing her disgust, “…they are not winding down on oil and gas but planning to explore and extract much more.”

    Aside from the aforementioned resignations, anxieties of Shell staff still with the company were reflected in posts by employees.

    Virtual “A Conversation with Wael”: Staff pacification

    Responding to internal anxiety over Shell’s recentering Shell’s goals, Wael Sawan planned a virtual meeting with staff,  “A Conversation with Wael” for October 17, 2023.  The advance promotion advised the meeting would “deepen our conversation on the opportunities and dilemmas we face as we position Shell to win in the energy transition.”

    The Wael Sawan October 17, 2023 message confirmed Shell believes in “urgent climate action” notwithstanding the about-face.

    Sawan assured Shell staff that Shell is simply modifying the strategy delivery.

    He explained this second cultural shift as the challenge of the affordability of clean tech.

    These are lies.

    Major job cuts in low carbon unit, not strategy tweaking

    The Wael “conversation” sequel on tweaking the strategy, came quickly, on October 25, 2023, when Shell announced that it will cut 200 jobs in its low carbon solutions unit, originally known as Shell New Energies.  Some of these jobs will be transferred to other corporate divisions, and an additional 130 position roles are “under review” in 2024.  Ergo, anxieties among employees will go up many notches.

    Ideological shift, not clean tech affordability or potential, nor belief in urgent climate action

    Renewables are now the least expensive sources of power and 90% of the sources of global annual newly installed electrical generation capacity has been renewables since 2022.

    Sawan conveniently ignored the growth curve of electric vehicle (EV) sales to-date, EVs having reached an inflection point.  EV sales in China and EU may reach 50% of the market in 2025.  In North America, there is an ongoing tsunami of investments in EV and battery production facilities because EV demand exceeds supply.

    Most automakers are committed to a full transition of their respective lineups to electrification.

    This is the backdrop for the year 2022 being an historic year.  For the first time ever, investments in the green transition, US$1.7 trillion, exceeded those unabated fossil fuel supply and power at US$1 trillion.

    Since 2021, the growth of investments in clean tech have outpaced those of fossil fuels three-to-one

    The greenwashing is self-evident.

    The takeaway

    1) It is possible for a fossil fuel company to become a diversified energy company committed to the Paris Agreement.

    2) The old guard fundamentalists remain in denial and, guided by the rearview mirror, believe the future must be like the past.

    3) Powerful shareholders having the characteristics described in item #2, plus addiction to quarterly reports, are among the biggest hurdles to a fossil fuel firm migration to clean tech.

    Fossil fuel sector contrasts: Green transition engaged, but not enough

    By
    Will Dubitsky
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    2
    Not all fossil fuel companies the same

    Not all Big Oil firms are alike. Some are engaged in a rapid green migration, many are sitting on the fence and others are still in climate denial. Meanwhile, the value of fossil fuel assets are declining but the industry is camouflaging this by selling assets and debt financing to keep shareholders happy.

    Continue

    Canada’s Green Economy needs public investment

    By
    Will Dubitsky
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    0

    Both the Intergovernmental Panel and Climate Change and the International Energy Agency have concluded that public policies, rather than the availability of resources, are among the key determinants for a shift from fossil fuels to clean technology development and deployment.  Public banks are critical agents for change along these lines.

    Public financial institutions and the green economy around the world

    Starting with some of the largest public banks, in July 2013, both the World Bank and the European Investment Bank announced that they will limit to the bare minimum investments in fossil fuel projects, while shifting the lion’s share of their respective energy investments to renewables.

    Continue

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