Memorandum on Science Based Targets Initiative Steering Committee Response Letter to the Formal Complaint

To: Science Based Targets Executive Board: Lila Karbassi: Chief of Programmes, UN Global Compact; María Mendiluce: CEO, We Mean Business; Paul Simpson: CEO, CDP; Andrew Steer: President & CEO, World Resources Institute; Manuel Pulgar Vidal: Climate & Energy Global Practice Leader, WWF

From: Bill Baue: Senior Director, r3.0; Former Technical Advisory Group Member, Science Based Targets Initiative (SBTi)

Re: Memorandum on SBTi Steering Committee Response Letter to the Formal Complaint

Date: 24 March 2021

Dear Lila, Maria, Paul, Andrew, and Manuel,

Thank you for your response to the Formal Complaint I submitted to you, the Executive Board of the Science Based Targets initiative (SBTi). To be clear at the outset, I am writing as an original instigator of SBTi and member of its Technical Advisory Group (TAG) since inception through October 2020 — and not, as is erroneously asserted in the Response Letter authored by the SBTi Steering Committee, as a methodology developer: I am not; and I have never “helped develop” any of the methodologies covered by SBTi.

I submitted my Formal Complaint as “a formal request for the SBTi Executive Board to investigate apparent technical shortcomings and governance lapses, and to take steps to adjudicate and resolve these issues.” (Emphasis added)

I appreciate that the Executive Board has taken a first step in the direction of this ultimate goal by asking the Steering Committee to “provide further information.” This step builds on the foundation set by the Formal Complaint to identify the issues at play, as it provides the perspectives of SBTi on these issues. I have significantly different perspectives, and I believe that the empirical evidence outlined below supports conclusions that differ significantly from the perspectives advanced by the Steering Committee.

Now that SBTi has entered into a Formal Response to my Formal Complaint, the question arises whether the “further information” supplied in the Response Letter authored by the Steering Committee — who are, of course, primary actors behind the actions at issue — amounts to investigation, adjudication, and resolution. More specifically, can independent investigation and adjudication be performed by the same actors whose actions prompt the Complaint? Due process suggests that defendants cannot serve as the police, judge, and/or jury in their own cases, given the obvious conflicts of interest. Such roles require independence if they are to have integrity and accountability.

Accordingly, I now ask the Executive Board to take the necessary next steps to investigate, adjudicate, and resolve the issues identified in the Formal Complaint. To get a sense of options, I have looked into ombuds functions at your respective organizations, and found little evidence in the public domain of existing mechanisms. I, therefore, welcome hearing what mechanisms you have in place for independently resolving serious process and governance complaints, or if these don’t exist, what mechanisms you propose to put in place and a transparent timeline for doing so.

This Memorandum details a series of questions; answers to these questions will help resolve the many issues that remain unresolved by the Executive Board’s response (which was by way of the Steering Committee Letter). I request responses from the Executive Board to each and all of the following questions, to help bring resolution to these points. I list the questions below, followed by detailed discussion of each in the main body of this memo.

1. Is SBTi faithful or derelict in fulfilling its duty to “define and promote best practice … in line with the latest climate science … with the support of a Technical Advisory Group” and to “reduce barriers to adoption”?

1a. Do SBTi’s against recommendations erect barriers to adoption of best practice methods?

2. Why did SBTi shift from its original unbiased guidance?

2a. Do any unrecommended methods “ensure the 2°C carbon budget is conserved” & “ensure that global emissions are reduced in absolute terms in the long term”?

2b. Are any unrecommended methods “updated with recent data”?

2c. Why did SBTi not vet its policy shift to a recommendations regime with its Technical Advisory Group?

2d. Why did SBTi recommend against CSO, given the apparent lack of evidence to support this decision, and the abundance of evidence against it?

3. Did SBTi assume its GEVA critique applied equally to all economic intensity methods?

3a. Did SBTi willfully misrepresent the CSO method in its April 2020 Manual?

4. Does the Bjørn et al scientific study affirm or refute SBTi’s recommendation regime on the question of carbon budget balance?

4a. Why does SBTi advance a self-contradictory argument to defend ACA on emissions imbalance (that ends up supporting CSO)?

4b. Why does SBTi challenge the assertion that the strongest temperature goal is 1.345°C?

4c. Why does SBTi apply the precautionary approach in instances that favour its own method, but not in instances that favour an independent method?

4d. Why does SBTi defend the moot point that its SDA method now aligns with a 1.5°C temperature goal in a single sector?

5. Why does the SBTi Steering Committee make the readily refutable claim its decision to stop recommending economic intensity methods “has nothing to do with … emissions imbalance”?

6. Why does SBTi seem to apply asymmetric bias to its scrutiny of “the inherent fluctuations associated with intensity metrics”?

7. What steps has the SBTi Executive Board taken in response to the admitted bias of the SBTi Steering Committee?

8. How does the SBTi Executive Board intend to investigate / adjudicate / resolve the conflict of interest and self-dealing concerns?

9. Does the SBTi Executive Board definition of “conflict of interest” include conflicting with the public interest?

10. Will SBTi enact the simple solution of removing CSO from the list of methods SBTi recommends against, and adding it to the list of recommended methods?

Before delving into the details and exploring the evidence, it makes sense to briefly set the context of the significance of the issues raised in this Complaint. In a nutshell, the Science Based Targets initiative has gained significance beyond its own direct purview, raising the stakes for it to exhibit deep integrity. Here are just a few specific examples:

SBTi → SBTN: SBTi serves as a model for the broader initiative it has spawned, the Science Based Targets Network (SBTN),[1] which is establishing similar thresholds-and-allocations-based methodologies for other areas of ecological impact, such as biodiversity and water.

○ Will SBTN adopt the governance model that SBTi has, that is vulnerable to methodological guidance tainted by conflict of interest concerns?

SBTI = Default: In its recently released Net Zero Investment Framework, the Institutional Investors Group on Climate Change (IIGCC) lists Science Based Targets amongst its “recommended existing methodologies” for investors to apply in assessing asset class-level alignment with the Paris Agreement.[2] This is just one of many instances where SBTi is applied as the default approach — a positive development, if the approach maintains strong integrity.

○ However, any lack of integrity that plagues SBTi risks adversely impacting these broader initiatives. So, for the sake of the broader movement, it warrants bolstering and maintaining the integrity of SBTi

SBTi → Bezos Earth Fund: World Resources Institute President and CEO Andrew Steer was recently appointed as CEO of the $10 billion Bezos Earth Fund, which is committed to address “climate, nature and social justice.”[3]

○ Oversight of such significant philanthropic assets clearly requires strong governance integrity. Recurrence of conflicts of interest (perceived, potential and/or real) at the Bezos Earth Fund would adversely impact the integrity of this important new initiative.

Given the importance of SBTi as a de facto standard setter, it is imperative that SBTi hold itself to the highest standards of integrity for robust governance. The concerns raised below, supported by strong evidence, imperil SBTi’s license to operate under the goodwill of the public trust. It is in the best interest of SBTi and the public interest it serves to resolve these concerns as efficiently and effectively as possible.

I will stress here that resolving the technical concerns simply requires revoking the mistaken recommendation against one of the methodologies SBTi originally recommended. To be clear, while the concerns enumerated in the Formal Complaint and this Memorandum may raise questions about the relative strengths and weaknesses of the methods SBTi created, this Formal Complaint does not ask SBTi to stop recommending for these methods. What the Formal Complaint and this Memorandum seek to demonstrate, drawing on historical and scientific evidence, is that the currently unrecommended method in question is no worse than SBTi’s two recommended methods, and therefore warrants being recommended for. The fact that recent scientific research has found that the currently unrecommended method performs better than SBTi’s two recommended methods on the variable that SBTi continually cited as the reason for recommending against it should not be construed as an argument against those methods, but simply a necessary aspect of making the case for applying symmetry and fairness in recommendations.

Rectifying this technical problem with this simple fix will take a first step toward addressing the deeper conflict of interest issues that the Formal Complaint and this Memorandum submit for the SBTi Executive Board to assess.

Questions and Commentary

1. Is SBTi faithful or derelict in fulfilling its duty to “define and promote best practice … in line with the latest climate science … with the support of a Technical Advisory Group” and to “reduce barriers to adoption”?

To understand the basis of the Complaint, it’s necessary to start with understanding SBTi’s foundations. SBTi’s “aim,” according to its Science-Based Target Setting Manual, is to

define and promote best practice in setting SBTs [science-based targets] with the support of a Technical Advisory Group…[4] (Emphasis added)

and to offer

guidance to reduce barriers to adoption.[5] (Emphasis added) (See Figure 1 in the Appendix for a screenshot)

SBTi considers targets “science-based” if they are

in line with what the latest climate science says is necessary to meet the goals of the Paris Agreement…[6] (Emphasis added) (See Figure 2 in the Appendix for a screenshot)

The Complaint raises serious questions whether SBTi is faithfully fulfilling this aim, or whether it might be derelict in this duty, particularly when it comes to SBTi’s target-setting method recommendations regime. This regime recommends exclusively for two methods:

Sectoral Decarbonization Approach (SDA) that “was developed by [SBTi Partnership Organizations] CDP, WRI and WWF”;[7] and

Absolute Contraction Approach (ACA) that SBTi attributes to Mars,[8] which produced the approach in collaboration with SBTi Partnership Organization WRI.[9]

As this pedigree record makes clear, the only two methods that SBTi recommends for are methods created by SBTi Partnership Organizations. SBTi’s regime recommends against four methods it lumps together as “economic intensity” approaches methods, all created independent of SBTi:

Center for Sustainable Organizations (CSO) Context-Based Carbon Metric, developed by CSO Founder and Executive Director Mark McElroy as “the first science-based metric for assessing the sustainability of greenhouse gas emissions by organizations ever developed” in 2006, according to the SBTi Methods Webpage circa 2018;[10]

Climate Stabilizing Intensity (CSI) Targets, the second science-based target-setting method, created by Chris Tuppen of BT in 2008 in collaboration with Limits to Growth Co-Author Jørgen Randers who later generalized his contribution as GEVA (see below);[11]

Corporate Finance Approach to Climate-stabilizing Targets (C-FACT), a method created by Emma Stewart and Aniruddha Deodhar of Autodesk in 2009 based directly on CSI (hence GEVA-based);[12]

Greenhouse gas Emissions per unit of Value Added (GEVA), introduced in a 2012 journal article by Randers laying out the general specification of the approach he contributed to the BT CSI method.[13]

As is demonstrated in the following pages, it is unclear if SBTi’s actions actually “define and promote best practice in setting SBTs” and “reduce barriers to adoption.” It is also unclear if SBTi works productively “with the support of a Technical Advisory Group” or whether it systematically disregards valid and vital input from its TAG. Finally, it is unclear why SBTi recommends against a method that is “in line with the latest climate science.”

1a. Do SBTi’s against recommendations erect barriers to adoption of best practice methods?

The Formal Complaint raises the substantive question of whether SBTi’s against recommendations are warranted — or whether, on the other hand, SBTi’s against recommendations might actually erect “barriers to adoption” of “best practice” methods. In order to explore this question, this Memorandum lays out evidence suggesting that SBTi’s recommendation regime, instead of reducing “barriers to adoption” of “best practice” methods, achieves the opposite by precluding adoption of best practice methods.

The Formal Complaint also raises the unavoidable parallel governance question: whether recommending exclusively for its own methods, and against methods created by others, represents self-dealing conflicts of interest.

In addition to the evidence presented in the Formal Complaint and this Memorandum — which includes empirical evidence and scientific findings — it is also necessary to examine the origins of SBTi’s method recommendation regime, to inquire if the structural foundations of the regime are legitimate.

2. Why did SBTi shift from its original unbiased guidance?

An historical review of the Methods landing page on the SBTi Website using the Internet Archive Wayback Machine finds that SBTi originally took an unbiased approach to providing methodological guidance in its early years.[14] Specifically, it retained a statement on this landing page affirming this stance across years (from at least May 2016 through at least January 2018):

There is not one ‘best’ method but there will be one that will work best for your company.[15] (Emphasis added)

Sometime between 24 January 2018[16] and 6 April 2018,[17] SBTi radically revised the Methods section of its Website, replacing the above-quoted language with the following language:

Recommended methods

The Science Based Targets initiative recommends companies use either the Sectoral Decarbonization Approach or the Absolute Emissions Contraction Method to set their Scope 1 and 2 targets as these methods ensure that global emissions are reduced in absolute terms in the long term. They are the most robust methods to ensure the 2°C carbon budget is conserved. In addition, the other methods (C-FACT, GEVA, CSI and CSO) might not be updated with recent data.[18] (Emphasis added) (See Figure 3 in Appendix for a screenshot)

The new Webpage does not explain why SBTi made this radical shift, which it did not vet with its Technical Advisory Group (that I served on actively throughout this period).

As can be seen from the “Recommended methods” quote above, SBTi presents three criteria undergirding its new recommendation regime; in order to qualify for recommendation, a method must:

● “ensure that global emissions are reduced in absolute terms in the long term”;

● “ensure the 2°C carbon budget is conserved”;

● “be updated with recent data.”

It seems reasonable to assume that all the “other methods” run afoul of one or more of these criteria. It also seems reasonable to assume that SBTi conducted robust due diligence to test each method against each criterion to arrive at its resulting recommendations.

This raises the question: is it in fact the case that none of the “other” methods fulfilled these three criteria?

2a. Do any unrecommended methods “ensure the 2°C carbon budget is conserved” & “ensure that global emissions are reduced in absolute terms in the long term”?

The first two criteria — “ensure the 2°C carbon budget is conserved” and “ensure that global emissions are reduced in absolute terms in the long term” — are interrelated, seeing as conserving the carbon budget requires reducing absolute global emissions in the long term. Examining the SBTi Methods page before the policy shift, which included blurbs on all methods covered by SBTi, reveals the following statement that clearly demonstrates that the Center for Sustainable Organizations (CSO) method fulfills both criteria:

CSO’s carbon metric … features an internal mass balance function that helps ensure that the logic used to define targets for individual organizations, if generalized to the wider population as a whole, will not result in emissions that exceed science-based thresholds at the global level. Emissions targets for individual organizations are thereby recalculated on a year over year basis in a way that is (a) sensitive to changes in an organization’s size, (b) sensitive to changes in the broader population of emitters, and © mindful of the need to strictly abide by steadily declining (and science-based) emissions budgets at the global level. Performance is then reported annually and cumulatively in three different ways: intensity, absolute, and context-based.[19] (Emphasis added) (See Figure 4 in the Appendix for a screenshot)

It is unclear why SBTi’s due diligence process failed to detect this information, given that it was readily visible on SBTi’s own Website.

2b. Are any unrecommended methods “updated with recent data”?

Perhaps SBTi’s due diligence process discovered that the CSO method ran afoul of its third and final criterion, that methods must be “updated with recent data.” Here again, however, the CSO blurb on SBTi’s Methods Webpage clearly states that the CSO method has been “in continuing use ever since [2006] with steady improvements being made as needed” and that the specific scientific scenario the CSO method uses “changes over time as the climate science evolves.”[20] (Emphasis added) (See Figures 5 and 6 in the Appendix for screenshots)

A deeper review of evidence shows that CSO has consistently updated its metric with climate scenarios reflecting “the latest climate science” as the science evolved. CSO employed the following climate science scenarios as they became available (with the update years included after, in parentheses):

● WRE350 (2006)[21]

● PoleStar Policy Reform Scenario (2012)[22]

● RCP2.6 (2014)[23]

● SSP1–2.6 (2017)[24]

● SSP1–1.9 (2018)[25]

So, it seems that SBTi misapplied its new policy when it included CSO in the list of methods that “might not be updated with recent data.” By this criterion, as well as, it appears that the CSO method should have been recommended for.

2c. Why did SBTi not vet its policy shift to a recommendations regime with its Technical Advisory Group?

Stepping back to consider the due process perspective, it seems that the creators of the two methods that qualified for recommendations — ACA and SDA — had voice in the new policy decision, seeing as the method creators and decision-makers were one-in-the-same: SBTi.

The creators of the disqualified methods, on the other hand, seem to have been systematically denied a voice in the decision process. The fact that three of the four independent method creators (Mark McElroy of CSO, Chris Tuppen of BT, and Emma Stewart of Autodesk) served on the Technical Advisory Group raises the question: why did SBTi not vet its radical policy shift — from unbiased guidance to a recommendations regime — with its TAG? Vetting the policy shift with the TAG would have provided critical input on the decision, including the opportunity for the independent method creators to assess if their methods were accurately represented. This question is particularly germane, given that SBTi’s stated aim is to “define and promote best practice in setting SBTs with the support of a Technical Advisory Group…”

2d. Why did SBTi recommend against CSO, given the apparent lack of evidence to support this decision, and the abundance of evidence against it?

All of this leaves unanswered the most confounding question: why did SBTi recommend against CSO, given the absence of evidence to support this determination, and the abundance of evidence (readily visible on SBTi’s own Website at the time) supporting the opposite determination — recommending for CSO? Given the consequences involved — depriving the world of the very method that established the practice of science-based target setting — it is striking that a logical explanation is so difficult to find.

I asked this question directly to SBTi leadership at the time — including at an in-person meeting at the World Resources Institute in November 2018[26] — but these interactions did not bring resolution.

3. Did SBTi erroneously assume its GEVA critique applied equally to all economic intensity methods?

The prior month (October 2018), the Intergovernmental Panel on Climate Change (IPCC) released its Special Report on Global Warming of 1.5°C (SR15).[27] SR15 introduced a new set of scenarios aligned with a 1.5°C temperature goal, an ambition level surpassing the previous scenarios pegged to “well below 2°C.” Given that SBTi defines science-based targets as those “in line with the latest climate science,” this development raised the significant question of how the SBTi recommendation regime would align with the new 1.5°C temperature goal.

In March 2019, in the run-up to the April 2019 Technical Advisory Group Consultation Call (the first TAG gathering after the release of SR15), I raised the following issue in an email thread to the full TAG:[28]

It isn’t clear from the agenda if the call will address the following issue: on the Methods landing page,[29] under the “Economic-Based Approach” clickable tab, SBTi states, “We are updating the economic-based approach and will provide new guidance by the end of January 2019.”

I haven’t seen this update — did I miss it? Or, will you be filling us in on this on the call?

This is, of course, particularly relevant with the advent of the IPCC 1.5°C report and underlying scenarios. Existing sector-based targets are aligned to 2°C scenarios. It is unclear to me how long it will take until 1.5°C sector-based scenarios are developed. The fact that there are still sectors that lack 2°C scenarios (see the SDA landing page[30] FAQ “WHAT SECTORS ARE NOT INCLUDED IN THE SDA?”) suggest that the lag time could be quite significant. I assume others share this concern.

On the other hand, economic allocation can align with 1.5°C scenarios right now — and yet current SBTi guidance seems to place roadblocks on companies employing economic allocations, for reasons that have always seemed unclear and illogical to me. So, the lack of clarity on SBTi’s approach to economic allocation is reason for concern. It seems logical that SBTi would want to remove unnecessary obstacles for companies to align with the 1.5°C scenarios. I trust the urgency of resolving these matters is readily apparent to all…[31] (Emphasis added)

SBTi responded by sharing its analysis of the GEVA method, in particular identifying an apparent Achilles Heel:

the GEVA method equates a sum of products (the sum of each company’s GEVA multiplied by its value added) to the product of sums (global GEVA multiplied by global GDP). That is where the special condition comes from (all companies growing at the same rate or all companies having the same initial carbon intensity).[32] (Emphasis added)

CSO method creator Mark McElroy responded directly, providing specific and detailed information on how the problem identified by SBTi is anticipated, and resolved, by the CSO method. The specificity and detail of the response warrants quoting the message in its entirety:

We should not confuse the defense I am trying to make for the use of economic intensities for target-setting and performance accounting with the specific manner in which the GEVA approach has handled things — I’m not here to defend GEVA. Rather, I am only prepared to defend the way in which CSO’s Context-Based Carbon Metric uses economic intensities in the way that it does, backed as it is by science-based absolute calculations…

Indeed, unlike other economic-based methods, the CSO method does not commit the false assumptions you identified: all companies growing at the same rate or all companies having the same initial carbon intensity. Any metric predicated on either of these assumptions, I agree, is deeply problematic, as neither assumption actually obtains in the real world.

That is why in the CSO metric we (a) differentiate between, and allow, different intensity starting points for different organizations, just as they are found in a baseline year, and (2) differentiate, and allow, for different rates of growth (or even contraction) over the span of a target-setting period of interest, and once again, just as they are found. We do not force-fit organizations into an arbitrary mold on either front, and instead accept and work with the facts on the ground as we find them.

When we use contributions to GDP as an allocation mechanism in this way, of course, it means that (a) total allowable emissions in a target year will very likely exceed a science-based budget if we were to sum them all up (i.e., because GDP tends to grow over time), and (b) unless we do something else as well, all firms arriving or converging at the same target level of intensity (assuming we have set one) is highly unlikely, if not impossible.

As for the former, our metric, like SDA, effectively “snaps” all values (i.e., all targets) to a level that in the aggregate always equals, and never exceeds, the maximum allowable global budget in the individual years of interest, since we always adjust targets in a way that takes changes in the underlying allocation scale or proxy (GDP) into account. Thus, individual targets for individual firms are set by using baseline year intensities as a starting point, followed by modifying those intensities in a way that takes (1) the trajectory of a science-based pathway, (2) a company’s own growth, and (3) changes in the allocation scale (GDP) explicitly into account. The result? Organization-specific targets which, if achieved and combined with the targets specified for all other emitters on Earth, always equals and never exceed the globally allowable limit!

As for the latter of the assumptions you listed (i.e., the unlikelihood of ever reaching or converging on a shared intensity target), this has always struck me as something that was perhaps of high theoretical interest, but completely impractical and totally arbitrary. In other words, why aim for convergence at all? If every company on Earth is able to reach targets in a way that features zero convergence and yet still, in the aggregate, conforms to a science-based not-to-exceed budget, why should anyone care about the fact that the individual intensities involved do not exactly match one another? For me, this adds a completely unnecessary complication to a process that is already fraught with complexity and for no particularly good reason that I can see. Rather, the reason, as I understand it, is that it is the IEA pathways used in SDA that is the source of this complication, and not something that any of us would otherwise choose to do. The result is an approach to allocation in the SDA that is not only activity-based, but which is convergence-based as well — activity/convergence-based, if you like, when activity-based would be more than sufficient. The fact that SDA adds the convergence factor to the calculation of targets is yet another strike against it in my view, as if the other strategic issues I have already identified (sector coverage is limited; can’t do 1.5-degree targets; too dependent on a single source, etc.) weren’t already enough.[33] (Emphasis added)

So, in his role as a Technical Advisory Group member, McElroy presented SBTi specific evidence that its critique of the GEVA method simply does not apply to CSO. This email thread ended after this message, without SBTi responding to these substantive points: that indiscriminately lumping CSO together with other “economic intensity” methods is inaccurate and invalid.

3a. Did SBTi willfully misrepresent the CSO method in its April 2020 Manual?

A year later, in April 2020, when SBTi published its Science-Based Target Setting Manual, it restated the case against GEVA that it had summarized in the above TAG email thread, which McElroy had clearly identified as not applying to the CSO method. Here is what SBTi published:

Unlike the Absolute Contraction and SDA methods, GEVA only maintains a global emissions budget to the extent that the growth in value added of individual companies is equal to or smaller than the underlying economic projection. The differentiated growth of companies and sectors is not balanced by GEVA (and other economic intensity target-setting methods); thus, the currently accepted GEVA value depends on idealized conditions where all companies are growing at the same rate, equal to that of GDP, and GDP growth is precisely known. For these reasons, and due to the volatility of economic metrics, economic intensity target-setting methods are considered less robust than absolute and physical intensity methods.[34] (Emphasis added)

As is evident from the above quote, SBTi explicitly applied this GEVA critique to “other economic intensity target-setting methods” in making its determination that “economic intensity target-setting methods are considered less robust than absolute and physical intensity methods.” Given that three of the four “economic intensity” methods are GEVA-based (GEVA, CSI, and C-FACT), the term “other economic intensity target setting methods” can only apply to the CSO method.

This publication creates a conundrum: evidence demonstrates that SBTi was informed that its GEVA critique does not apply to CSO in the April 2019 TAG email thread; yet the April 2020 SBTi Manual appears to explicitly apply the GEVA critique to the CSO method (“other economic intensity target-setting methods.”)

The question thus arises: did SBTi willfully misrepresented the CSO method in its April 2020 Science-Based Target Setting Manual? If so, why? Given the governance concerns that this possibility would raise, it seems that this is a question of utmost importance for the SBTi Executive Board to grapple with.

4. Does the Bjørn et al scientific study affirm or refute SBTi’s recommendation regime on the question of carbon budget balance?

In February 2021, the journal Environmental Research Letters published the “Accepted Manuscript” of a peer-reviewed study by Anders Bjørn, Shannon Lloyd, and Damon Matthews of Concordia University entitled “From the Paris Agreement to corporate climate commitments: Evaluation of seven methods for setting ‘science-based’ emission targets.” The study focuses in particular on the issue that apparently undergirds SBTi’s recommendations rationale: “emission imbalance, i.e. how accurately companies using a given method maintain a given carbon budget…” (to quote from the definition offered in the SBTi Response Letter, which establishes that emissions imbalance pertains to maintaining the carbon budget.)

However, Bjørn et al found themselves in the same position as many other SBTi stakeholders: unable to make sense of the rationale behind SBTi’s recommendation regime. In particular, they couldn’t clearly identify just why SBTi recommends for its own methods (ACA and SDA) and against the other methods. Bjørn et al write:

it is also not entirely clear why the SBTi generally recommends ACA and SDA over the other five SBT methods (SBTi 2020c), but suspected emission imbalances appear to play a role.[35] (Emphasis added)

The fact that a robust scientific investigation cannot find clarity on SBTi’s rationale for its recommendations is troubling, given that SBTi’s self-appointed role as de facto standard setter leverages the public trust to act in the public interest; the maxim trust but verify cannot be enacted in the absence of a transparent, clear, and compelling rationale for SBTi’s decisions.

The Bjørn et al study independently confirms that the CSO method does not exhibit the carbon budget balance problem that plagues GEVA-based “economic intensity” methods. Quite the opposite: Bjørn et al state that the

CSO method, followed by the SDA method, has the overall lowest emission imbalance across all scenarios.[36] (Emphasis added)

The Bjørn et al study includes charts to help visualize these emissions imbalances. The investigators explain their assessment of emissions imbalance (EI) thus:

A positive EI [emissions imbalance] means there are “leftover” (or unused) global allowable emissions after allocation of emissions to companies for a given year. A negative EI means that global allowable emissions are exceeded by the sum of company SBTs for a given year.

In their charts, the study authors represent positive emissions imbalance (carbon budget undershoot) in black, and negative emissions imbalance (carbon budget overshoot) in red. The below chart illustrates this finding (of “overall lowest emission imbalance” for CSO), as the imbalance calculations for the CSO method hover near the zero line, which represents a fully balanced carbon budget.[37] (See Figure 7)

CSO

Figure 7: CSO Emissions Imbalance Source: Bjørn et al 2021

For comparison purposes, below are the charts from the Bjørn et al study on the emissions imbalance performance of the two methodologies SBTi recommends for (ACA and SDA):

ACA

SDA

Figure 8: ACA and SDA Emissions Imbalance Bjørn et al 2021

These graphs demonstrate larger emissions imbalances for the ACA and SDA methods than for the CSO method. And as a reminder, SBTi rationalizes its recommendations regime primarily on the question of carbon budget balance. Therefore, the scientific evidence provided in the Bjørn et al study suggests that, far from recommending against CSO, SBTi’s recommendation regime rationale would require it to recommend for CSO. The scientific study authors note this plainly:

our results indicate that concerns over emission imbalance should favour the CSO and SDA methods, rather than ACA and SDA.[38] (Emphasis added)

The SBTi Steering Committee Response Letter addresses this issue, stating that

the paper does not make any recommendations for the selection of specific methods but merely highlights how different methods perform on this particular indicator and recommends additional transparency around reasons for method recommendations. (Emphasis added)

The Steering Committee is correct that the paper does not, itself, make such recommendations; what the study authors say is that the results of the study would guide a body with “concerns over emissions imbalance” to “favour the CSO and SDA methods, rather than ACA and SDA.” The fact that SBTi bases its recommendation regime on concerns over emissions imbalance, yet it recommends against the method with the “overall lowest emission imbalance,” raises questions and concerns over the logic, consistency, and integrity of the recommendations regime, and SBTi governance by extension.

4a. Why does SBTi advance a self-contradictory argument to defend ACA on emissions imbalance (that ends up supporting CSO)?

In its Response Letter, the SBTi Steering Committee acknowledges that the study findings favor the CSO method:

It is of course correct that the study finds CSO to lead to the smallest ‘emission imbalance’ in its assessment, which perhaps isn’t surprising given that the annualisation of carbon budgets is a major design feature of the method. (Emphasis added)

While one might expect this to be a concession acknowledging the fundamental flaws of SBTi’s recommendation regime and a commitment to immediately rectify this long standing problem, instead the Response Letter proceeds to introduce new justifications:

However, it’s worth digging a little deeper and noting that over the next decade, the timeframe companies most commonly choose for their SBTs, CSO is the only method that leads to companies exceeding their budget in this analysis. Again, it’s debatable what constitutes the “strongest” performance here. While the study treats ‘emission imbalance’ in both directions as equal, one could reasonably argue that a precautionary approach to not exceeding the carbon budget, and in particular over companies’ actual SBT target timeframe of 5–15 years as opposed to the study’s 30-year horizon, is a more meaningful performance indicator than proximity to the original scenario. (Emphasis added)

Visual aids help to better understand how the case made by the SBTi Steering Committee actually disproves its own point. At the beginning of the paragraph, the Response Letter notes that the CSO method exceeds the carbon budget “over the next decade.” The CSO chart does indeed show a sliver of imbalance in 2030. At the end of the paragraph, the Steering Committee shifts its time frame from “over the next decade” to “5–15 years.” At the 15 year mark (i.e. in 2035), the CSO chart continues to display a sliver of imbalance, while the ACA chart displays an imbalance that is clearly much more significant — well below the -2 line for imbalance. What’s more, the climate science community has broadly embraced 2050 as the relevant timeframe, so it is unclear why an initiative called Science Based Targets would prioritize the shorter time frame of the corporate community over the longer time frame of the scientific community.

CSO

ACA

Figure 9: CSO and ACA Emissions Imbalance Bjørn et al 2021

It seems that a close read of this paragraph, combined with the scientific data, finds that the case SBTi makes would yield a determination against SBTi’s own ACA method, and for the CSO method, given that the ACA method demonstrates much more significant divergence from the carbon budget (a negative emissions imbalance) than the CSO method.

It is unclear why SBTi would advance an argument for its favoured method (ACA) and against its unfavoured method (CSO) that holds only for the period it cites at the outset, but flips to argue against its favoured method and for its unfavoured method for the period cited at the end of the paragraph. This raises questions whether such attempted obfuscation is intentional. If it is not intentional, other questions arise.

It is worth noting here that the findings of the Bjørn et al study validate SBTi’s critique of GEVA-based methods with empirical evidence of emissions imbalance with the global carbon budget, in the positive direction. So, SBTi is, in fact, justified to recommend against GEVA-based economic intensity methods, seeing as they are out of alignment with the carbon budget. Indeed, all three methods undershoot the carbon budget (exhibiting what SBTi calls a “precautionary approach”) much more significantly than either the ACA or SDA method.

GEVA

CSI

C-FACT

Figure 10: GEVA, CSI & C-FACT Emissions Imbalance Bjørn et al 2021

4b. Why does SBTi challenge the assertion that the strongest temperature goal is 1.345°C?

The SBTi Steering Committee Response Letter states that emissions imbalance

is an important consideration in method selection, but certainly not the only one.

I agree on both counts: emissions imbalance is indeed an important consideration, seeing as SBTi listed it amongst its original three recommendation criteria (as noted in question 2b above); and, it is not the only consideration in method selection. In the Formal Complaint, I propose that alignment with “the latest climate science” is another consideration of high importance. On this issue, we also have agreement, as SBTi defines SBTs as targets that are “in line with what the latest climate science says is necessary to meet the Paris Agreement — to limit global warming to well-below 2°C above pre-industrial levels and pursue efforts to limit warming to 1.5°C.”

The SBTi Steering Committee Response Letter further states:

The Complaint states that the study finds that “the strongest methodology (…) in terms of alignment to the ‘latest climate science,’ is the CSO methodology”. However, the paper states no such thing.

The Steering Committee is absolutely correct that the Bjørn et al paper “states no such thing.” But I never claimed that the paper “states” so; I claimed that the study “finds” this so, which I supported with simple-to-understand numbers. I noted that the study identifies the “temperature goal” of all the methodologies, including the following for the methods at issue:

● SDA: Well-below 2°C

● ACA: 1.5°C

● CSO: 1.345°C

The SBTi Response Letter states: “What exactly constitutes ‘the strongest’ here is debatable.”

It seems undebatable to claim that a 1.345°C temperature goal is lower than a 1.5°C or well-below 2°C temperature goal, and therefore it is the “strongest” in that the lower the temperature rise, the greater the likelihood of averting catastrophic climate change. It is unclear how this logic is debatable, given that it is predicated on basic climate science and mathematics.

In any case, the burden of proof in this debate is to demonstrate how CSO’s alignment with the lowest temperature goal justifies SBTi’s recommending against it. Instead of debating the question at hand, the SBTi Steering Board proceeds to introduce confusion by suggesting that

ACA could easily employ the same scenarios the Complaint seems to consider the strongest (SSP1), i.e. to ‘align with the latest climate science.’

“SSP” stands for “Shared Socioeconomic Pathway,” a set of five broad climate scenarios, with SSP1 referring to the “sustainability” scenario.[39] However, there are two specific SSP1 scenarios: SSP1–1.9, which aligns with a 1.345°C temperature goal (which the CSO method currently employs); and SSP1–2.6, which aligns with a temperature goal of 1.761°C, according to Bjørn et al.[40] The point the SBTi Steering Committee is apparently trying to make only makes sense with the former (SSP1–1.9), given that its temperature goal is “stronger” (i.e. lower) than ACA’s current temperature goal (1.5°C); the latter (SSP1–2.6) actually undermines the point SBTi seems to be making, given that its temperature goal is “weaker” (i.e. higher) than ACA’s current goal. Why would SBTi be arguing for weakening (i.e. increasing) the temperature goal for ACA?

It is unclear why the SBTi Steering Committee introduces such confusion, particularly considering that this point has nothing to do with justifying its rationale for recommending against CSO. As well, if ACA can indeed align with a more assertive scenario, the question arises: why hasn’t SBTi already done so?

4c. Why does SBTi apply the precautionary approach in instances that favour its own method, but not in instances that favour an independent method?

This digression does raise questions around the “precautionary approach” that SBTi embraces elsewhere in the Response Letter when one compares SBTi’s recommendations regime on 1) near-term emissions reduction rates, versus 2) temperature goal.

● On near-term emissions reduction rates, SBTi recommendations force companies to make steeper reductions than the science demands — and disallow companies using the CSO method, which aligns reductions precisely with the most assertive climate science (which SBTi presents as a purported weakness, apparently). This point is vitally important in the context of SBTi functioning as the de facto standard on science-based targets, yet its recommendation regime deprives the world of a method that is designed to align with the science the most tightly of all methods.

● On temperature goal, however, SBTi appears to be arguing against applying the precautionary approach, which would support the use of SSP1–1.9 (as the CSO method does) to achieve a 1.345°C temperature rise, and instead justifies the application of a less precautionary approach aligned with a 1.5°C temperature rise (as the ACA method does).

If a de facto standard setter such as SBTi decides to apply a precautionary approach, it seems reasonable to expect application across the board, instead of applying this approach only when it favours SBTi’s own method, and neglecting to apply it when it favors an independent method.

To reiterate my earlier statement, I am not arguing against ACA here, as that is not the point of my Formal Complaint; I am simply pointing out that, here again, the case SBTi advances in its debates fails to invalidate the CSO method, so logic suggests that SBTi should be recommending for CSO.

4d. Why does SBTi defend the moot point that its SDA method now aligns with a 1.5°C temperature goal in a single sector?

The SBTi Response Letter similarly defends its SDA method for its application of a 1.5°C sector scenario to a single sector of the global economy (power). But again, the degree to which the SDA method can develop 1.5°C sector scenarios is also beside the point. It is also beside the point when the SBTi Response Letter expends four paragraphs explaining why it recommends for ACA and SDA. This information is only relevant in a comparative context, where SBTi applies all the criteria it cites to all three of the methods in question: ACA, SDA, and CSO.

So, the SBTi Steering Committee’s statements defending its recommendations for its own methods, without placing the issues in a comparative context to rationalize and explain why it recommends against the independent method, would seem to serve to distract from the matter at hand, which is answering the Formal Complaint. By this measure, the SBTi Steering Committee Response Letter falls short of providing the evidence and explanation necessary to justify its actions. The question arises whether this is a responsible, accountable, and fair application of the significant power SBTi has been granted as the de facto standard setter in this space.

5. Why does the SBTi Steering Committee make the readily refutable claim that its decision to stop recommending economic intensity methods “has nothing to do with … emissions imbalance”?

One of the most striking aspects of the SBTi Steering Committee’s Response Letter is the following claim:

The SBTi no longer recommends the other methods we initially supported because it has stopped recommending economic intensity methods altogether — and they are all economy intensity methods. It has nothing to do with either emissions balance under experimental conditions or underlying scenario choice but rather the weak and unstable link between economic indicators and emissions at the company-level. (Emphasis added)

This claim is readily refutable, as has already been demonstrated in this document:

● SBTi has been making this very case — that its against recommendations are based on carbon budget emissions imbalance — since April 2018, when it listed “ensure the 2°C carbon budget is conserved”[41] amongst the 3 criteria it introduced when first recommending for its own methods and against all independent methods.

● SBTi also reiterated balance with the “global emissions budget” in its April 2020 Manual as the reason why “economic intensity target-setting methods are considered less robust than absolute and physical intensity methods.”[42]

The Formal Complaint contains further material from SBTi that clearly and explicitly refutes this claim.[43]

So it isn’t clear how SBTi believes it can accurately claim that its decision to stop “recommending economic intensity methods altogether … has nothing to do with … emissions balance” when its own words explicitly state in multiple instances that emissions balance is the primary reason. It is understandable that SBTi might want to disavow its stance, now that this stance is no longer tenable in light of the independent scientific findings of Bjørn et al, but the historical record is clearly documented on this point.

6. Why does SBTi seem to apply asymmetric bias to its scrutiny of “the inherent fluctuations associated with intensity metrics”?

In the 2020 Manual, SBTi tacked the parenthetical phrase “and due to the volatility of economic metrics”[44] onto its primary reasons for recommending against economic intensity methods (carbon budget balance), introducing a new rationale that hadn’t been amongst its criteria (absolute long-term emissions reduction; carbon budget balance; updated data) until that point. This issue of the “volatility” of metrics also arose in an email exchange appended to the Formal Complaint, where a member of the SBTi Steering Committee noted “the inherent fluctuations associated with intensity metrics.”[45] I responded:

wouldn’t the very dynamic that impacts economic allocation (i.e. these fluctuations, whatever they are) also impact a sectoral allocation / intensity approach, in similar ways?[46]

The SBTi Steering Committee member never responded to this message, even after a polite reminder to respond sent a week later. It is unclear why the Steering Committee member neglected to respond to an important inquiry from a Technical Advisory Group member who is also an original instigator of the initiative.

I agree with SBTi that there are “inherent fluctuations associated with intensity metrics” — which includes economic and sectoral / activity allocation approaches amongst the methods covered by SBTi. Indeed, the whole point of allocation methods is to align organization-specific emissions entitlements with real-world variables, which are, of course, subject to inevitable fluctuations in the real world. SBTi evidently embraces this strength in recommending for the Sectoral Decarbonization Approach (SDA), its preferred “intensity” (or allocation) method.

The SBTi Steering Committee Response Letter lists a number of issues that “can lead to changes in carbon intensity that have nothing to do with the environmental performance of the underlying activity.” As the Steering Committee member had already established in the quoted text at the end of this sentence (and I had already underlined in my response) in 2019, these fluctuation dynamics are “associated with intensity metrics” in general, not just economic intensity metrics.

The Steering Committee states in its Response Letter that it “has been intending to present these concerns more formally in a research paper about economic intensity targets for some time now…” It is unclear why SBTi would limit its research scope to “economic intensity targets” only, when real-world fluctuations apply to all intensity approaches. In other words, research will uncover these dynamics in all intensity metrics, so if this research only examines economic intensity metrics, it will only find these issues with economic intensity metrics. Research cannot find problems elsewhere — for example, in SBTi’s own SDA method — unless it looks. Until SBTi produces evidence that it has conducted research applied to intensity metrics across the board, conflicts of interest concerns will necessarily continue to follow from this asymmetric pattern of apparent bias.

7. What steps has the SBTi Executive Board taken in response to the admitted bias of the SBTi Steering Committee?

The existence of methodological bias amongst the SBTi Steering Committee is an established fact. A SBTi Steering Board member openly acknowledged such in a message of 2 April 2019 to the full Technical Advisory Group (included in the Appendix of the Formal Complaint, which has been submitted to the SBTi Executive Board), when noting it’s fair to say that

the SBTi has had a methodological bias. Yet, this bias has not been towards the SDA; but rather, towards absolute contraction methods, which we believe are more conservative from the perspective of carbon budget integrity.[47] (Emphasis added)

Several aspects of this statement are noteworthy:

● A member of the Steering Committee of the de facto standard-setter openly admits that SBTi, which derives its license to operate from the public trust, in the public interest, is consciously applying bias;

● Both methods under question (SDA and ACA) — including the method the Committee member confirms as the object of its bias (ACA) — are produced by SBTi, such that SBTi is leveraging bias in its role as a standard setter toward its own product, raising self-dealing conflict of interest concerns;

● The reason cited to justify this bias — “carbon budget integrity” — has been shown by scientific evidence (Bjørn et al) to “favour” the very method that the bias is applied against, over the method(s) that the bias is applied toward, establishing that the bias is misdirected.

Each of these aspects seem to warrant a response from the SBTi Executive Board; taken together, these three aspects would seem to raise significant concern over the integrity of SBTi if they continue to go unaddressed by the Executive Board. I look forward to hearing back from the SBTi Executive Board on the steps it has taken to address this egregious problem.

8. How does the SBTi Executive Board intend to investigate / adjudicate / resolve the conflict of interest and self-dealing concerns?

In the Formal Complaint, I asked

the SBTi Executive Board to investigate whether SBTi is enacting real, potential, and/or perceived conflicts of interest and self-dealing, and to report back on its determination within a month’s time, providing evidence to support its determination.

As noted earlier, the SBTi Executive Board delegated this “investigation” to the very body charged with enacting the conflicts of interest (the SBTi Steering Committee), thereby creating a conflict of interest in the act of “investigating” conflicts of interest. As I suggested atop this Memorandum, such a structure is akin to the defendant serving as police, judge, and jury. To play out this metaphor, a finding of innocence delivered by the defendant would inspire no faith; robust due process calls for scrutiny and deliberation by bodies independent of the actions in question if a determination that warrants faith is to be delivered.

In its Response Letter, the SBTi Steering Committee states that

the reasoning behind the accusation of “self-dealing and conflict of interests” is difficult for us to follow.

This difficulty does not come as a surprise, as following the reasoning would require the Steering Committee to grapple with the moral quandary of actual culpability. It is unreasonable to expect them to implicate themselves, even if the preponderance of evidence were to do so.

The Steering Committee continues:

Neither the SBTi nor its partner organisations derive any benefits from the use of either the Absolute Contraction Approach or the Sectoral Decarbonisation Approach. Both methods are completely open-source. Our only interest is for companies to set ambitious targets that lead to emissions reductions. It’s not clear to us what other ‘interest’ this supposedly conflicts with.

To understand how conflicts of interest concerns apply, I previously (in the November 2019 email thread in the Formal Complaint Appendix) directed a Steering Committee member’s attention to SBTi’s own Conflict of Interests Policy, which it published in the Target Validation Protocol.[48] The Policy “aims to ensure an independent, credible, and objective” process — specifically around target validation, but the logic applies equally (and arguably more emphatically, given the more universalized implications) at the higher level of methodology recommendations. Indeed, target validation applies to an individual company, while method recommendations apply across the board, to the universe of methods that all companies can apply to even qualify for validation.

The SBTi Conflict of Interests (COI) Policy states:

Any situation where the impartiality and independence of a reviewer is at risk, it is considered a COI. More specifically, COIs include but are not limited to the following: …

Any affirmative answers … to the following questions:

1. Are you or have you been involved at any level in the development of the proposed target? (Emphasis added)

To apply SBTi’s Conflict of Interests Policy at the higher level of methodology recommendations, one need simply replace the term “development of the proposed target” to “development of the proposed method”.

As established earlier, SBTi was involved in the development of the Absolute Contraction Approach and the Sectoral Decarbonization Approach. Therefore, according to its own Conflict of Interests Policy, SBTi enters into a conflict of interests the moment it applies a recommendation to a method where it was “involved at any level in the development” of the method.

It therefore appears, according to this application of SBTi’s own Conflict of Interests Policy, that the SBTi is in a real conflict of interests, not only a potential or perceived COI.

What seems to block SBTi’s understanding is an exceedingly narrow interpretation of a conflict of interests to exclusively pertain to direct financial gain. It points to the fact that ACA and SDA are open source — which one must assume SBTi knows is true of all the methods, including CSO and the other economic intensity methods — so the question of direct financial gain is not an issue with any of the methods.

The issue, in a narrow sense, is the reputational boost that SBTi and its representatives access from being the purveyors of the only methods that readily qualify for SBTi validation — a boost that is systematically denied to the creators of any other methods. This boost translates into tangible benefits and interests that have indirect financial implications, including career security and advancement, for representatives of SBTi, which are commensurately denied to others, despite robust evidence of commensurate (and possibly even superior) methodological quality of at least one independent method.

9. Does the SBTi Executive Board definition of “conflict of interest” include conflicting with the public interest?

But this narrow pecuniary interpretation does injustice to the much more significant implications of adverse impacts on the public interest — which is to resolve the climate emergency. The SBTi Steering Committee states that its “only interest is for companies to set ambitious targets that lead to emissions reductions.” If this were indeed its only interest, then SBTi would not erect barriers to achieving this outcome, as it appears to have done based on the clear evidence presented in this Formal Complaint and Memorandum. As I see it, the evidence presented in this document overwhelmingly illustrates that SBTi has aligned its interests with advancing a subset of the universe of robust methods (namely, those it created), and has thereby acted against the public interest of advancing all robust methods and thereby providing the strongest and most diversified toolkit possible for combating the existential climate crisis.

“There are no silver bullets, only silver buckshot,” Bill McKibben famously said in a 2006 op-ed on applying the broadest set of solutions to the climate crisis possible.[49] Just as natural ecosystems thrive on biodiversity and human systems thrive on cultural, racial, gender, and other forms of diversity, so too do markets thrive on diversity of ideas. SBTi entered a marketplace, which was established in 2006 and was organically evolving a diversity of approaches, and it seems to have applied a colonization approach: instead of nurturing further evolution through natural selection, SBTi appears to have used its power as a de facto standard setter to bias the burgeoning field toward its own solutions, and deprive the field of solutions that have been found by independent investigation to be robust. “In evolution, from diversity comes opportunity…”[50] states eminent Harvard evolutionary biologist Edward O. Wilson; SBTi now has the opportunity to support evolutionary opportunity by embracing methodological diversity.

10. Will SBTi enact the simple solution of removing CSO from the list of methods SBTi recommends against, and adding it to the list of recommended methods?

In the spirit of resolution, I will point out that one element of solution is exceedingly simple: remove CSO from the list of methods SBTI recommends against, and add it to the list of recommended methods. I invite SBTi to immediately enact this simple shift, which is supported by the evidence base, and thereby start to resolve the tangle of inconsistencies identified in the Formal Complaint and this Memorandum.

Resolving the governance weaknesses that led to this moment will prove more challenging, hence my request for independent investigation, adjudication, and resolution as necessary steps. I look forward to hearing back with your identification of an appropriate independent body or bodies to address the issues identified in the Formal Complaint and further laid out in this Memorandum. I trust that this exchange can help initiate a journey toward sufficiently robust governance within SBTi commensurate with the responsibility SBTi carries in upholding the public trust to serve the public interest.

Thank you for your attention and responsiveness.

Sincerely,

Bill Baue

Appendix

Figure 1: SBTi Aim

SBTi 2020 Science-Based Target Setting Manual (Emphasis added)

Figure 2: What is a Science-based Target?

SBTi 2020 Science-Based Target Setting Manual (Emphasis added)

Figure 3: SBTi “Recommended methods”

SBTi 2018b Methods Webpage

Figure 4: CSO Context-Based Carbon Metric Blurb

SBTi 2018a Methods Webpage

Figure 5: CSO Context-Based Carbon Metric Blurb

SBTi 2018a Methods Webpage

Figure 6: CSO Context-Based Carbon Metric Blurb

SBTi 2018a Methods Webpage

[1]Science Based Targets Network. https://sciencebasedtargetsnetwork.org/

[2] Institutional Investors Group on Climate Change 2021 Net Zero Investment Framework: Implementation Guide. 10 March 2021. https://www.parisalignedinvestment.org/media/2021/03/PAII-Net-Zero-Investment-Framework_Implementation-Guide.pdf

[3] World Resources Institute 2021 “President and CEO Andrew Steer to Depart WRI to Lead Bezos Earth Fund” Press Release. 9 March 2021. https://www.wri.org/news/2021/03/release-president-and-ceo-andrew-steer-depart-wri-lead-bezos-earth-fund

[4] SBTi. 2020. Science-Based Target Setting Manual. Version 4.1. April 2020. https://sciencebasedtargets.org/resources/files/SBTi-manual.pdf.

[5] Ibid.

[6] Ibid. The goals of the Paris Agreement are “to limit global warming to well-below 2°C above pre-industrial levels and pursue efforts to limit warming to 1.5°C.”

[7] SBTi. 2019. Foundations of Science-Based Target Setting. Version 1.0. April 2019. https://sciencebasedtargets.org/resources/files/foundations-of-SBT-setting.pdf

[8] See the SBTi “Methods” page as recently as April 2020 (https://web.archive.org/web/20200416020800/https://sciencebasedtargets.org/methods/) where the description of the “absolute-based approach” ends: “Mars was one of the first companies to use this method to determine its science-based target” and links to Mars’ Website (https://web.archive.org/web/20190305160043/http://mars.com/global/sustainable-in-a-generation/healthyplanet/climate-action). Earlier versions of the SBTi “Methods” page even more explicitly labels this as the “Mars Method.” See this version from 17 March 2016: https://web.archive.org/web/20160317035531/https://sciencebasedtargets.org/methods

[9] WRI collaborated with Mars in developing this approach: Putt del Pino, S., C. Cummis, S. Lake, K. Rabinovitch, P. Reig. 2016. From Doing Better to Doing Enough: Anchoring Corporate Sustainability Targets in Science. Working Paper. Washington, DC: World Resources Institute and Mars Incorporated. http://www.wri.org/publications/doing-enough-corporate-targets

[10] SBTi 2018a Methods. Website Landing Page. 24 January 2018. https://web.archive.org/web/20180124064537/https://sciencebasedtargets.org/methods/; Center for Sustainable Organizations. Downloadable context-based metrics. https://www.sustainableorganizations.org/context-based-metrics-public-domain/

[11] Tuppen C 2008 Climate Stabilisation Intensity Targets: A new approach to setting corporate climate change targets. BT. https://static1.squarespace.com/static/565ebf94e4b0f2a77109071e/t/5a01b78471c10b9d51d476ec/1510061996036/CSI+Methodology+Notes+Aug17.pdf

[12] Stewart E Deodhar A 2009 A Corporate Finance Approach to Climate-stabilizing Targets (“C-FACT”). Autodesk. White Paper. November 2009. https://damassets.autodesk.net/content/dam/autodesk/www/sustainability/docs/pdf/greenhouse_gas_white_paper000.pdf

[13] Randers J 2012 Greenhouse gas emissions per unit of value added (“GEVA”) — A corporate guide to voluntary climate action. Energy Policy. Volume 48. Pages 46–55. September 2012. https://doi.org/10.1016/j.enpol.2012.04.041

[14] SBTi. Methods. Website Landing Page. https://web.archive.org/web/2020*/https://sciencebasedtargets.org/methods/ This Wayback Machine index page links to 96 “captures” of this Webpage between 29 September 2015 and 6 November 2020. This stance aligns with the original intention of the SBTi, dating back to the first meeting in the Summer of 2013 attended by representatives of CDP, CSO, EPA, WRI, WWF, and me.

[15] SBTi 2016 Methods. Website Landing Page. 19 May 2016. https://web.archive.org/web/20160519044414/https://sciencebasedtargets.org/methods/; SBTi 2018a Methods. Website Landing Page. 24 January 2018. https://web.archive.org/web/20180124064537/https://sciencebasedtargets.org/methods/

[16] SBTi 2018a. op cit.

[17] SBTi 2018b Methods. Website Landing Page. 6 April 2018. https://web.archive.org/web/20180406180800/https://sciencebasedtargets.org/methods/

[18] Ibid.

[19] SBTi 2018a. op cit

[20] SBTi 2018a Methods. Website Landing Page. 24 January 2018. https://web.archive.org/web/20180124064537/https://sciencebasedtargets.org/methods/

[21] CSO. Global Warming Footprints. 7 March 2011. https://web.archive.org/web/20110307000926/http://www.sustainableorganizations.org/global-warming-footprints.html

[22] CSO. Downloadable context-based metrics. 8 December 2013. https://web.archive.org/web/20131208171344/http://sustainableorganizations.org/context-based-metrics-in-public-domain.html

[23] CSO. Downloadable context-based metrics. 29 Mar, 2014. https://web.archive.org/web/20140329074759/http://www.sustainableorganizations.org/context-based-metrics-in-public-domain.html

[24] CSO. Downloadable context-based metrics. 5 July 2017. https://web.archive.org/web/20170705234424/https://www.sustainableorganizations.org/context-based-metrics-public-domain/

[25] CSO. Downloadable context-based metrics. 23 June 2020.. https://web.archive.org/web/20200623020241/https://www.sustainableorganizations.org/context-based-metrics-public-domain/

[26] Email to author from SBTi Steering Board Member. 25 October 2018.

[27] IPCC 2018 Global Warming of 1.5 °C eds V Masson-Delmotte et al. https://www.ipcc.ch/site/assets/uploads/sites/2/2019/06/SR15_Full_Report_Low_Res.pdf

[28] Email from author to the SBTi Technical Advisory Group. 29 March 2019.

[29] SBTi. Methods. Website Landing Page. 3 April 2019. https://web.archive.org/web/20190403063808/https://sciencebasedtargets.org/methods/

[30] SBTi. SDA Tool and Methodology. Website Landing Page. 3 April 2019. https://web.archive.org/web/20190403063806/https://sciencebasedtargets.org/sda-tool/

[31] Email from author to SBTi Technical Advisory Group. 29 March 2019. Available in Formal Complaint Appendix.

[32] Email from SBTi to Technical Advisory Group. 9 April 2019. Available in Formal Complaint Appendix.

[33] Email from Mark McElroy to SBTi Technical Advisory Group. 9 April 2019. Available in Formal Complaint Appendix.

[34] SBTi 2020 op cit.

[35] Bjørn A Lloyd S & Matthews D (2021) From the Paris Agreement to corporate climate commitments: Evaluation of seven methods for setting “science-based” emission targets. Environmental Research Letters. Accepted Manuscript. 11 February 2021. https://iopscience.iop.org/article/10.1088/1748-9326/abe57b

[36] Ibid.

[37] Bjørn et al explained in background discussions that the reason for this slight imbalance is that the study relies on estimates for the baseline GHG emissions for all companies globally, given that those baseline calculations would be prohibitively challenging to identify with actual numbers. Therefore, the imbalance between the CSO method’s performance and the carbon budget is an artifact of the study parameters, not of the method itself. Email to author. 19 March 2021.

[38] Ibid.

[39] Hausfather Z 2019 “Explainer: How ‘Shared Socioeconomic Pathways’ explore future climate change.” CarbonBrief. 19 April 2018. https://www.carbonbrief.org/explainer-how-shared-socioeconomic-pathways-explore-future-climate-change. “The SSPs are based on five narratives describing broad socioeconomic trends that could shape future society. These are intended to span the range of plausible futures. They include: a world of sustainability-focused growth and equality (SSP1); a “middle of the road” world where trends broadly follow their historical patterns (SSP2); a fragmented world of “resurgent nationalism” (SSP3); a world of ever-increasing inequality (SSP4); and a world of rapid and unconstrained growth in economic output and energy use (SSP5).

[40] Hausfather Z 2019 “CMIP6: the next generation of climate models explained.” CarbonBrief. 2 December 2019. https://www.carbonbrief.org/cmip6-the-next-generation-of-climate-models-explained; Bjørn et al. op cit.

[41] SBTi 2018b op cit.

[42] SBTi 2020 op cit.

[43] An SBTi Steering Committee member states, “The decision to stop using economic intensity methods was not taken lightly. As explained yesterday, we identified a number of important issues and decided to stop using the method following a precautionary approach. In my view, the two main issues are: (1) the lack of provisions needed to ensure that a carbon budget is not exceeded and; (2) the inherent fluctuations associated with intensity metrics.” Email to author from SBTi Steering Board member. 6 November 2019. Available in the Formal Complaint Index.

[44] Ibid.

[45] Formal Complaint Appendix. Email to author, 6 November 2019.

[46] Formal Complaint Appendix. Email from author to SBTi Steering Board Member, 7 November 2019.

[47] Email from SBTi Steering Board member to the full SBTi Technical Advisory Group, 2 April 2019. Available in the Formal Complaint Appendix.

[48] SBTi. 2020. Target Validation Protocol. TWG-PRO-002 | version 2. April 2020. https://sciencebasedtargets.org/resources/files/target-validation-protocol.pdf

[49] McKibben B 2006 “ Welcome to the Climate Crisis How to Tell Whether a Candidate Is Serious About Combating Global Warming.” Washington Post. 27 May 2006. https://www.washingtonpost.com/archive/opinions/2006/05/27/welcome-to-the-climate-crisis-span-classbankheadhow-to-tell-whether-a-candidate-is-serious-about-combating-global-warmingspan/26b2ac5a-a4a3-46ff-b214-3fc07a3a5ab3/

[50] Wilson EO 2012 The Social Conquest of Earth. New York: Liveright (W.W. Norton). p27.

Catalyzing systems change toward thrivance. Co-Founder http://r30.org/ http://SustyContext.org http://currnt.com/ https://www.cchange.net/

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