Oil and Gas Project Interim Report
September 2022
OIL AND GAS PROJECT
INTERIM REPORT
September 2022
Oil and Gas Project Interim Report
September 2022 Page 2
Table of Contents
GLOSSARY .......................................................................................................................................... 3
1 INTRODUCTION ................................................................................................................................ 5
1.1 Oil and Gas Project ...................................................................................................................... 5
1.1.1 Scope of the draft Oil and Gas guidance ................................................................................ 5
1.2 Expert Advisory Group review ...................................................................................................... 6
1.3 Evidence used for this report ........................................................................................................ 7
2 THE NEED FOR OIL AND GAS SCIENCE-BASED TARGETS ......................................................... 8
3 OIL AND GAS PROJECT TIMELINE ................................................................................................. 9
4 ITEMS COVERED IN THE PUBLIC CONSULTATION .................................................................... 12
4.1 Scenarios ................................................................................................................................... 13
4.2 Intensity vs absolute targets ....................................................................................................... 14
4.3 Value-chain target location ......................................................................................................... 15
4.4 Disaggregation of targets by scope ............................................................................................ 16
4.5 Company progress indicators ..................................................................................................... 16
4.6 Accounting inclusions ................................................................................................................. 17
4.6.1 Carbon capture and storage (CCS) ...................................................................................... 17
4.6.2 Removals in the energy value chain .................................................................................... 18
4.6.3 Removals outside the energy value chain ............................................................................ 18
4.6.4 Energy accounting location .................................................................................................. 19
4.6.5 Electricity accounting ........................................................................................................... 19
5 OTHER ITEMS NOT EXPLICITLY ADDRESSED IN THE PUBLIC CONSULTATION ..................... 21
6 NEXT STEPS ................................................................................................................................... 24
6.1 Issues raised .............................................................................................................................. 24
6.2 Expert Review Process .............................................................................................................. 25
6.3 Finalizing the methods and guidance for the oil and gas sector .................................................. 26
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GLOSSARY
Integrated Energy Company
Oil and gas (O&G) companies, as well as energy companies
with oil and gas activities but that are no longer strictly just oil
and gas and so can be considered as companies that are
already in transition (defined as per the draft guidance). The Oil
and Gas Project was previously called the Oil, Gas and
Integrated Energy (OGIE) Project.
1
Upstream
O&G exploration, drilling, production and field services (defined
as per the draft guidance).
Midstream
Pipelines, terminals, marine transportation, storage, and
midstream services (defined as per the draft guidance).
Downstream
Refineries, retail outlets, natural gas distribution, and
petrochemicals (defined as per the draft guidance).
Scope 1
A reporting organization’s direct GHG emissions (defined as per
the GHG Protocol Corporate Standard).
Scope 2
A reporting organization’s emissions associated with the
generation of electricity, heating / cooling or steam purchased
for own consumption (defined as per the GHG Protocol
Corporate Standard).
Scope 3
A reporting organization’s indirect emissions other than those
covered in scope 2 (defined as per the GHG Protocol Corporate
Standard).
Neutralization
Residual emissions that “must be counterbalanced through the
permanent removal and storage of carbon from the atmosphere
(defined as per the SBTi Corporate Net Zero Standard).
Beyond Value Chain Mitigation
(BVCM)
Mitigation action or investments that fall outside a company’s
value chain. This includes activities outside of a company’s
value chain that avoid or reduce greenhouse gas emissions, or
that remove and store greenhouse gases from the atmosphere
(defined as per the SBTi Corporate Net Zero Standard).
Stance in draft guidance
Summary of what the draft guidance recommends.
Consultation response
Overview of responses as per the consultation feedback
summary document.
1
The project name was changed ahead of the publication of this report to ensure more widespread understanding of the sectoral focus of the
project. The project remit still includes integrated energy companies as defined in this glossary.
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Post-consultation view
Overview of the immediate feedback from the SBTi as detailed
in the consultation feedback summary document. Note that
since the publication of this document, numerous perspectives
have emerged on each issue, and therefore this does not
necessarily reflect the SBTi’s current position.
Stance in the Net-Zero Standard
Summary of whether any related information has been
published in the SBTi Net Zero Standard. This standard reflects
the SBTi’s requirements for Net Zero target setting.
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1 INTRODUCTION
This interim project report summarizes the progress of the Science Based Targets initiative’s Oil and
Gas (SBTi O&G) project to date. It sets out next steps for the review and finalization of the SBTi’s Oil
and Gas (O&G) sector methods and guidance.
1.1 Oil and Gas Project
In 2019 the SBTi initiated its O&G Project to develop methods and guidance to enable science-
based target-setting in the sector. The project aims to allow stakeholders, companies, investors,
governments and civil society to understand the alignment of O&G company emissions reduction
targets with the level of transformation required to meet the temperature goals of the Paris
Agreement.
2
Work on the O&G Project continued throughout 2020, including publication of draft guidance and a
public consultation phase from August to October 2020. In early 2021, the SBTi paused the project
due to a range of circumstances including resource challenges associated with the COVID-19
pandemic and the prioritization of other workstreams such as the SBTi Net-Zero Standard for
Corporates, which launched in October 2021.
The SBTi remains committed to creating robust methodologies that will better support companies
in the O&G sector, and other high-emitting sectors, to decarbonize in line with climate science.
While the O&G methods and guidance are being developed, the SBTi’s policy for fossil fuel
companies states that the companies described in the policy cannot submit a science-based target
for validation or commit to set a science-based target with the SBTi.
1.1.1 Scope of the draft O&G guidance
The scope of the draft guidance was developed through early discussions with the O&G Project
Technical Working Group (TWG). An important decision was to extend the boundary of the proposed
methodological approaches beyond ‘just’ oil and gas to include a wider range of types of energy
produced and supplied by companies, including renewables. This decision recognizes that some
companies are in a process of transition away from fossil fuels and allows for key metrics such as the
emissions intensity of energy to be calculated and compared to global energy transition scenarios
consistent with the Paris Agreement.
2
In this context “Integrated Energy companies” refers to Energy Companies with O&G activities but that are no longer strictly focussed on
O&G and can be considered as companies that are already in transition.
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With regards to specific activities and emission sources, the draft guidance primarily aims to address
embedded emissions in the fuel supplied. Operational emissions from methane, direct energy use and
electricity are also addressed.
The draft guidance also excludes certain activities because they were not considered sufficiently
distinct or significant in terms of GHG emissions. The key areas of exclusion are listed below, with
further detail provided in the guidance:
O&G services and logistics
O&G transportation and storage
Trading
O&G and electricity equipment manufacturing
Questions around the scope of the O&G draft guidance were not posed by the SBTi during the public
consultation. However, the scope has implications for how the guidance has been developed and is
relevant to some of the items discussed in this report.
1.2 Expert Advisory Group review
Following the publication of a Request for Proposals (RFP) in February 2022, Mott MacDonald was
appointed to support the SBTi in engaging and facilitating an expert review of the current draft O&G
guidance.
3
The SBTi is working with Mott MacDonald to convene an Expert Advisory Group (EAG) to review the
draft methods and guidance and to advise the SBTi on key issues so that the guidance can be finalized
and published. The EAG will balance expertise relevant to the specific technical and methodological
issues identified in this report with a broader strategic appreciation of the requirements of the SBTi
O&G guidance.
This review will consider experts’ technical knowledge, and comments received through the public
consultation and an internal review conducted by the SBTi. On completion, the SBTi will evaluate the
next steps required to revise and finalize the methods and guidance. This may include additional public
consultation. Further detail on the scope and schedule of work for the expert review is provided in this
report in section 6.2. The review is expected to be complete by late 2022.
3
The SBTi does not endorse, recommend or support any particular consultancies.
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1.3 Evidence used for this report
This report has been produced by Mott MacDonald working in close collaboration with the SBTi. It is
based on information publicly available on the SBTi’s website alongside non-public information
provided by the SBTi, such as internal SBTi communications, and discussions with members of the
SBTi team. It provides a concise summary of key issues addressed in the 2020 public consultation
exercise and identifies additional issues not directly addressed in the public consultation or that have
arisen since. It is intended to provide the basis for the EAG review, summarizing the current state of the
O&G Project at a high level, rather than replicating technical discussions in detail.
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2 THE NEED FOR O&G SCIENCE-BASED TARGETS
According to the IPCC, fossil fuel combustion and industrial processes account for around 85% of
global anthropogenic CO
2
emissions and 64% of total GHG emissions. To achieve the goals of the
Paris Agreement and limit the rise in global temperature to well-below 2°C, and preferably to 1.5°C, the
production and use of O&G must be greatly reduced in the coming decades with rapid and deep cuts in
emissions across all sectors of the economy. For the O&G sector, guidance is needed to enable
companies to set science-based targets and understand the level of cuts needed to align with climate
change objectives.
In 2021 the SBTi launched its Net-Zero Standard, the world’s first framework for corporate net-zero
target setting in line with climate science. This Standard establishes key requirements including a focus
on rapid and deep emissions cuts, the need to set both near- and long-term science-based targets and
the need for companies to invest in climate mitigation activities (i.e. beyond value chain mitigation).
However, the complexity and unique nature of the O&G sector, the fact that its current principal
products are the main driver of climate change, and the high-level of exposure of the sector to transition
risks, all mean that tailored sector-specific methods and guidance are required. By developing these
methods and guidance, the SBTi’s O&G Project aims to:
Enable companies, investors, governments and other civil society stakeholders to understand
how O&G companies can align with the level of transformation required to meet the goals of the
Paris Agreement.
Provide stakeholders with a method that shows how much companies need to reduce emissions
in the near-term (5-10 years) to be aligned with a 1.5
o
C temperature goal.
Align methods for both near- and long-term target setting with the SBTi’s Net-Zero Standard.
Drive O&G sector companies to maximize target impact by providing differentiated criteria and
guidance for integrated, upstream, midstream and downstream companies.
Enable independent validation of O&G company science-based targets through the SBTi.
The need for O&G sector methods and guidance has been underscored by recent events such as a
landmark court case against an O&G company that has been ordered to reduce emissions by an
amount deemed consistent with the Paris Agreement goals, and by the IPCC’s finding that emissions
from existing and planned fossil fuel infrastructure already exceeds the remaining carbon budget for
limiting warming to 1.5°C with limited or no overshoot.
As part of the work already undertaken for the O&G Project, the SBTi has identified several potential
transition modes for O&G companies, some of which leverage the sector’s existing assets and skills to
support a rapid net-zero transformation. These specific strategic responses to the challenge of the
energy transition include diversification to other forms of energy (energy company), transitioning to a
circular economy model for using carbon capture and storage (carbon company), ramping down O&G
operations and returning capital to shareholders (managed decline) and completely transitioning away
from O&G to other activities (new direction). The SBTi’s O&G methods and guidance are needed to
support companies engaged in these strategic shifts to develop and set science-based targets.
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3 O&G PROJECT TIMELINE
This section outlines the key activities undertaken by the SBTi and its partners to date.
November 2019 O&G Project start
The O&G Project was established by the SBTi in November 2019. The purpose of the project
was to develop science-based target setting methods and guidance for oil, gas and integrated
energy companies.
A Technical Working Group (TWG) was established, including 20 organizations covering
different sector stakeholders. O&G companies are represented in the group, along with
investors, environmental organizations, academic institutions and industry bodies.
March 2020 5 Technical Working Group meetings
The TWG met on five occasions between November 2019 and March 2020, working to
establish the foundational elements of the guidance, the roles for specific methodological
development and the forward work plan.
This involved the commitment of two organizations to develop draft materials for the three core
methodologies:
Least-cost methodology: Carbon Tracker
Well-to-wheel methodology: CDP
Sectoral Decarbonization Approach: CDP
August October 2020 Draft guidance published and public consultation
The SBTi published the draft guidance in August 2020, including the three key methodologies
outlined above.
The public consultation ran from August October 2020 and covered six key issues:
1. Scenarios
2. Intensity vs absolute targets
3. Where in the Value chain targets
4. Disaggregation of targets by scope
5. Flexibility vs comparability
6. What counts for reaching a near-term and net-zero target
A summary of these issues and their post-consultation reflection is covered in Section 4 of this
report.
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During the consultation, more than 35 meetings and webinars were held, enabling interested
parties to explore the material in depth. A total of 54 responses were received by the SBTi.
A summary of the public consultation was published on the SBTi’s website and showed
general agreement with the way the draft guidance addressed many of the consultation topics,
with further work required in some areas.
Sept 2020 March 2021 Technical review process
Throughout the end of 2020 and start of 2021, the SBTi continued to engage with the TWG in
an ongoing review and iteration of the draft methods and guidance, considering feedback from
the public consultation. This phase included reporting to the SBTi project Steering Committee
in December 2020.
April 2021 Steering Committee decision to pause project
The project Steering Committee paused the O&G Project in April 2021 due to several
challenges including resource challenges associated with COVID-19 and the prioritization of
other SBTi workstreams, such as the SBTi Net-Zero Standard.
At this point no further iteration of the draft guidance was published, meaning the draft
published in August 2020 as part of the public consultation remains the most recent version.
October 2021 SBTi Net-Zero Standard published
The SBTi released its Net-Zero Standard in October 2021. The Standard is the world’s first
framework for corporate net-zero target setting in line with climate science. The information
available in the Standard presents the SBTi’s latest stance on net-zero target setting and has
relevance to many of the items discussed within this report. The O&G guidance is expected be
developed in accordance with the key criteria set out in the Net-Zero Standard.
January 2022 Forest, land and agriculture draft guidance published, and public
consultation opens
The SBTi published its draft Forest, land and agriculture (FLAG) guidance for comment during
a two-month public consultation starting in January 2022. The FLAG guidance stance on land-
related emissions and removals has relevance to this project. The SBTi aims to release the
final version of the FLAG guidance in September 2022.
March 2022 Updated SBTi policy on fossil fuel companies
The SBTi updated its policy regarding fossil fuel companies in March 2022. This set out
restrictions and exclusions around the companies which can submit targets and commitments
to the SBTi. This policy became effective immediately and resulted in the removal of some
previous commitments by O&G sector companies.
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May 2022 Mott MacDonald appointed to support expert review
Following an RFP in February 2022, Mott MacDonald was appointed to support the review and
finalization of science-based methods and guidance for the O&G sector, through the facilitation
of an Expert Advisory Group (EAG) review. This work is now underway and includes delivery
of this interim report.
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4 ITEMS COVERED IN THE PUBLIC CONSULTATION
The public consultation on the draft methods and guidance ran from August to October 2020 and
resulted in 54 responses to the SBTi from a range of organizations as shown in Figure 1. These
responses covered the six key questions detailed in this section, which the SBTi used to structure the
consultation.
Figure 1: Organizations that responded to the SBTi O&G public consultation in 2020
Source: SBTi Public Consultation Responses Summary
Below we review each of the six main consultation questions. In each case we provide summary of the
context, the stance adopted in the August 2020 draft guidance, key messages from the consultation
responses and the immediate post-consultation response that was summarized in the consultation
feedback summary (noting that the SBTi’s position is subject to change following the expert review
process). Where appropriate we have also included links to the SBTi’s Net-Zero Corporate Standard
which was published after the consultation had closed.
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4.1 Scenarios
Which scenarios should be used for setting science-based targets?
Context: The setting of a science-based target depends not only on the specific method used to set the
target but also on the scenarios used within the methodology. Historically, the SBTi recognized well-
below 2°C (WB2C), or targets with a likelihood of staying within ~1.7°C of warming, and 1.5°C targets
and required that these are met with low-overshoot, preferring scenarios that prioritize early action.
There are also important questions about the levels of carbon capture and storage (CCS), bioenergy
with carbon capture and storage (BECCS) and carbon dioxide removals (CDR) in scenarios meeting
the WB2C and 1.5°C goals. From 15 July 2022, the SBTi only accepts targets that are aligned with
1.5°C with no or limited overshoot. Overall, the higher the level of CCS the more lenient the transition
out of fossil fuels, and the higher the levels of BECCS and CDR are, the more dependent society is on
an even more uncertain technological fix to our current dependency on fossil energy. Scenarios with
high volumes of BECCS are also dependent on high volumes of bioenergy some of which might not
be available unless other sustainability objectives are compromised.
Stance in draft guidance: The scenario proposed in the guidance includes early action and limited or
no overshoot. In addition, to avoid overreliance on bioenergy (linked to the use of BECCS), the draft
guidance proposes a potential physical limit on sustainable bioenergy (close to the range where there is
“high agreement”, <135 EJ/yr) in its scenario filtering. This results in only a few scenarios available for
the purpose of setting O&G SBTs.
Consultation response: When asked if any scenario that meets WB2C or 1.5C should be allowed,
over half of responses agreed that a criterion should be required to filter scenarios, with consideration
to levels of overshoot, need for early action and uncertain physical planetary limits. Over half of
respondents also agreed that an envelope of scenarios should be provided as opposed to just one but
that these should be filtered for implausibility. The primary concerns around the criteria to remove
implausible scenarios were largely centred around CCS, BECCS and CDR.
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to
maintain the scenarios and criteria for inclusion set out in the draft guidance (limited or no overshoot,
early action and considerations to physical limits regarding bioenergy), but to reconsider the science to
set bioenergy limits.
Stance in corporate Net-Zero Standard: According to the SBTi Net=Zero Standard, scenarios for
reaching net-zero emissions at the global level by 2050 should assume only low/medium levels of CO
2
removal. The SBTi Pathways to Net-Zero provides further detail, stating that “no pathways currently
used by the SBTi include CO
2
removal with geologic storage in the pathway boundary”. The SBTi net-
zero pathways only consider CO
2
removal in the forestry, land and agricultural (FLAG) sectors and in
specific cases of bioenergy use. Based on the draft FLAG guidance, this includes only biogenic
removals, such as the restoration of natural ecosystems, improvements to forest management
practices, and enhanced soil carbon sequestration.
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4.2 Intensity vs absolute targets
Context: Limiting climate change requires absolute emissions reductions. However, companies are
mostly setting intensity targets at the point of sale. These targets do not necessarily guarantee absolute
emission reductions, particularly in the short-term. The SBTi generally accepts intensity targets,
provided that the consideration of growth expectations still leads to an absolute emissions reduction.
Absolute emissions targets sometimes raise an important psychological barrier in business actors in
terms of the “freedom to do business” - even if businesses already operate under all sorts of
constraints. On the other hand, for many stakeholders, intensity targets are seen as “potential
greenwashing” because they do not guarantee absolute emission reductions, even when reductions in
intensity are very significant and it is extremely unlikely that companies in established businesses
would be able to grow their activities in such a way that it would not lead to an absolute emission
reduction.
Given that the scope of the draft guidance includes not just oil and gas activities but a wider range of
energy types such as renewables, intensity targets can be used to draw parallels between the
emissions intensity of a company’s energy and the required intensity across the sector in the relevant
global transition scenarios.
Stance in draft guidance: The draft guidance currently requires a mix of intensity and absolute targets
which vary depending upon the source of emissions and where the company falls in the value chain.
The requirements in the guidance include:
Intensity targets that reflect change in final demand (i.e. provision of energy that is being
decarbonized), with a target year of between 5 to 15 years from the date of submission, though
recommend also setting a long-term target.
Integrated Energy Companies (IEC) should also set near-term absolute targets that reflect
supply changes (i.e. decrease of fossil fuel supply), and absolute targets to address methane
emissions.
For all other scope 1 and 2 emissions, it is currently acceptable to set absolute or intensity emissions
targets, apart from for downstream companies, where an absolute scope 2 emission target is required.
Consultation response: There was consensus that absolute targets should be required, and where
intensity targets are set, these should also lead to absolute emissions reductions. When asked if it is
suitable to set an intensity target to reflect demand-side changes and an absolute target to reflect
supply-side changes, 34% (the highest scoring response) agreed that this is a sufficient approach.
Though 26% expressed that the targets should be absolute.
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to
maintain the draft guidance approach including requiring absolute reductions for upstream activities and
intensity reductions for downstream activities.
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Stance in the Net-Zero Standard: Both absolute and intensity targets are acceptable for near- and
long-term targets. Though only the Sectoral Decarbonization Approach (SDA) intensity methodology is
accepted for scope 1 and 2 intensity targets.
4.3 Value-chain target location
Where in the value chain should companies set targets?
Context: IECs can set targets for different scopes as well as targets for different parts of the value
chain. This could lead to the setting of many targets, nine or more, which could be considered
infeasible. The Well-to-Wheel (W2W) methodology addresses many of these issues but does not cover
the issue of investment in the development of O&G resources. Yet the rate of reduction in O&G
exploration / development investments to avoid lock-in effects is a key aspect in the climate action and
investment debate today, as is ensuring that revenues are shifted to alternative forms of energy
compatible with the energy transition.
Stance in draft guidance: The guidance allows any company to set an intensity target based on the
W2W methodology, which considers emissions along the whole value chain and could therefore reduce
the quantity of targets. However, the W2W methodology does not address the continuation of fossil fuel
extraction. Supply-side emissions are therefore addressed by the requirement to set targets for IEC and
Upstream energy companies using one of three methodologies:
Scope 3 SDA
Least-Cost Methodology
Commitment to only sanction projects with a high likelihood of being competitive in 1.5°C or
WB2C budget
Nonetheless, there are challenges surrounding the requirement for supply-side (extraction/production)
targets, for various reasons, some examples being that this may lead to higher imports and possible
‘leakage’ of emissions with worse consequences (if other, less-environmentally conscious players fill
the demand).
Consultation response: There was consensus that integrated and upstream companies should set
near-term production targets though it is unclear what the most appropriate methodology would be. Of
those that did express an opinion on the methodologies proposed, there was a preference for the Least
Cost Methodology (though with reservations).
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to
maintain the requirement for IEC and upstream energy companies to set supply-side targets and retain
flexibility in choice of methodology.
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4.4 Disaggregation of targets by scope
Context: The setting of scope 1 and 2 targets for upstream and midstream activities is affected by a
lack of available and detailed scenarios and prior to the consultation the TWG had not been able to
address this issue. At the same time, the big challenge for IECs is the energy transition which is
captured in the W2W method with its value-chain scope 1, 3 and 3 indicator. However, in this method,
scope 1 and 2 emissions of O&G companies get dwarfed by scope 3 with the outcome that the
necessary reductions are not made in scopes 1 and 2. Additionally, the W2W model seems fit for
companies that want to transition but does not seem appropriate for companies that want to continue
being pure O&G companies. There are also arguments for not having separate scope 1 and 2 targets
such as the need for simplicity in target setting, an integrated perspective across the value-chain and
the fact that what really matters for upstream O&G is scope 3 emissions (with a reduction in scope 3
inevitably meaning a reduction in scope 1 and 2 emissions from O&G production).
Stance in draft guidance: The guidance allows IECs to set disaggregated targets for different scopes.
Given that different parts of the value chain can also set targets, this means that IECs could set nine or
more different targets. There are additional challenges in this approach, given that:
More work needs to be done in developing detailed scenarios for scope 1 and 2 emissions.
There is a desire to have an integrated indicator across the value chain.
Scope 1 and 2 emissions typically represent 15% or less of total emissions.
Consultation response: Views were equally split on whether to require a separate scope 1 and 2
target, or to include a consolidated scope 1, 2 and 3 target. Other views included that scopes 1 and 2
should be accounted for separately to scope 3, and so suggests a slight leaning towards
disaggregation.
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to pursue
disaggregated targets in line with investor and NGO preferences. Methodologies to calculate scope 1
and 2 emissions scenarios require further development.
Stance in Net-Zero Standard: The Net-Zero Standard allows corporates to set combined scope 1, 2
and 3 targets, providing that it is possible to determine the level of ambition of each component. This is
potentially a more flexible approach than the proposed position in the draft O&G guidance.
4.5 Company progress indicators
What is the appropriate balance between flexibility and comparability?
Context: Methodologies rely on a comparison between a company indicator to set and measure
progress of targets and a scenario variable that reflects the necessary pace of change of the indicator
to meet the Paris agreement goals. For example, in the case of the W2W method, the indicator is the
W2W carbon intensity of energy and the scenario pathway variable should be calculated in the same
way. There are many ways of building the indicators and of modifying scenarios to fit them, but there
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are also some constraints, both from the point of data availability and from the point of view of what can
logically be justified. Company targets will only be truly comparable with each other if companies follow
one single, prescriptive methodology.
Stance in draft guidance: Each methodology requires a defined indicator to set and measure
progress against targets. Methodologies also require scenario variables that reflect the necessary pace
of change of the indicator. The draft guidance states a requirement that under all circumstances, there
must be consistency between scenario variables and the variables used in the indicator when setting
science-based targets. Note that there are various ways in which companies can build indicators and
modify scenarios to meet this requirement, meaning that company targets may not always be fully
comparable unless following a prescriptive methodology.
Consultation response: There was an almost equal split of opinion between targets needing to be
comparable (through use of a single methodology) and targets needing to be flexible (validated with a
range of methodologies), though there is a slight preference toward comparability.
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to move
towards comparability through the provision of more prescriptive methodologies, as some stakeholders
consider comparability to be essential (particularly investors).
4.6 Accounting inclusions
What counts for reaching a near-term and net-zero target?
4.6.1 Carbon capture and storage (CCS)
Stance in draft guidance: Direct CCS is to be considered as a net neutral emission source when
included within the company boundary. Indirect CCS implemented by a client should not be counted to
reduce emissions (such as from scope 3 use of sold products).
Consultation response: Divided views on whether to include CCS in direct abatement, but consensus
that CCS should not be counted in indirect abatement.
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to keep
the draft criteria and add clarification on what types of CCS can be included (particularly around
enhanced oil recovery (EOR)).
Stance in the Net-Zero Standard: The SBTi Net-Zero Standard does not specifically address the
accountability of CCS technology other than including Direct Air Capture (DAC) as an example of
removals (which are required to ‘neutralize residual emissions’). Neutralization of residual emissions is
a key final stage required to meet the requirements set out in the Net-Zero Standard. In addition to
neutralization, the Standard also strongly recommends Beyond Value Chain Mitigation (BVCM) in the
transformation to net-zero. Investment in CCS could be considered as BVCM. The Standard also states
that emission reductions ‘insetting’ projects must only be included if they use a corporate accounting
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approach and are contained fully within its supply chain. This is perhaps a more lenient approach than
currently specified in the draft O&G guidance.
4.6.2 Removals in the energy value chain
Stance in draft guidance: Biogenic removals in the energy value chain are important in most
scenarios but this heavily depends upon the availability of sustainable biomass. The draft guidance
accepts the accounting of direct removals (such as in biorefineries) but does not accept the accounting
of indirect removals within the energy value chain, due to unclear accounting rules. Note that negative
emissions in the power sector through BECCS are accounted for within the energy sector scenario
calculation of net emissions, though has been minimized.
Consultation response: Strong support for counting of direct removals (e.g. biorefineries) and mild
support for counting of indirect removals (conflicting with existing stance in guidance).
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to
maintain draft guidance approach and await clarity on indirect removals accounting from the GHG
Protocol.
Stance in the Net-Zero Standard: As above, BECCS is provided as an example of an emissions
removal. In addition, though direct land use emissions and removals associated with bioenergy are
required to be included within a company’s target boundary (even though they are reported separately
from the company’s GHG inventory as per the GHG Protocol), the ‘positive impact of exceeding zero
emissions due to biogenic removals’ must not be included within target setting or progress reporting.
The same applies for indirect bioenergy. The proposed approach for the O&G guidance therefore aligns
with the Net-Zero Standard.
4.6.3 Removals outside the energy value chain
Stance in draft guidance: No allocation of land-use change removals has been made to other sectors
and no transfer mechanisms for these removals has been agreed with the SBTi or any other standard /
body. Therefore, removals outside the energy value chain (e.g. from afforestation, reforestation or
nature based solutions (NBS)) should not be allowed.
Consultation response: Consensus that non-energy value chain removals should not be accounted.
Post-consultation view: The SBTi’s immediate reflection on the consultation feedback was to
maintain the draft guidance approach but review upon finalization of the Net-Zero Standard and
consultation with the GHG Protocol.
Stance in the Net-Zero Standard: Inclusions of removals in target setting is only considered
applicable for land emissions and forest, land and agriculture (FLAG) targets.
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4.6.4 Energy accounting location
Context: The way in which companies account for energy is important to ensure consistency with the
chosen scenario. Using a consistent means to define the energy content delivered by a company
requires the selection of a ‘location’ within the value-chain to measure the energy delivered by a
company. There are typically three definitions of energy value-chain ‘locations’, relating to primary,
secondary and final energy. Losses occur between each of these ‘locations’ and so it is important to
understand which losses are included in reporting.
The main scenarios that are published usually use primary energy, so the use of secondary energy
would require some manipulation of the scenario data to calculate SBTi pathways. Primary energy has
some ambiguity in its calculation though, as often it is calculated by converting the energy content of
the final product (the secondary energy), which is readily available data, back to the primary energy,
which introduces several assumptions.
Stance in draft guidance: The suggested energy accounting approach in the guidance is to count
energy delivered by companies as secondary energy (as opposed to primary or final). Secondary
energy is generally defined as energy that has been transformed into a transportable form, such as
electricity or liquid fuels, and is measured at the ‘exit’ of the transformation stage, such as at the
refinery gate for liquid fuels.
Consultation response: Few responses were provided on energy accounting, though they were
generally in agreement with the draft guidance.
Post-consultation view: Due to obtaining only a small number of responses, most of which had
differing opinions, it is not possible to say that a consensus was reached on the issue. Therefore, the
different options require further elaboration.
4.6.5 Electricity accounting
Context: When calculating the emissions intensity of electricity, the total emissions associated with the
production of the electricity is divided by a measure of the primary energy used to create that electricity.
Historically, in energy accounting, renewable electricity has been converted into primary energy by
calculating how much fossil primary energy would be required to generate the same amount of
electricity in a thermal power plant. This is referred to as the partial substitution method. This has the
potential to lead to overcounting of primary energy production, and the conversion factors, such as
those used by the IPCC and IEA, can result in incentives for certain types of electricity generation that
may not be optimal. However, the conversion of electricity to primary energy recognises the high utility
of electricity.
Stance in draft guidance: When considering electricity accounting, the draft guidance uses the partial
substitution method to acknowledge the substitution potential of fossil fuels for electricity. This means
that the primary energy equivalent of the electricity produced (or production plus net purchases,
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whichever is largest) is accounted for according to the conversion efficiency of total electricity
generation in the scenario selected.
Consultation response: Few responses were provided on energy accounting, though they were
generally in agreement with the draft guidance.
Post-consultation view: Due to obtaining only a small number of responses, most of which had
differing opinions, it is not possible to say that a consensus was reached on the issue. Therefore, the
different options require further elaboration.
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5 OTHER ITEMS NOT EXPLICITLY ADDRESSED IN THE
PUBLIC CONSULTATION
Since the draft guidance was published, several further items have been raised with the SBTi, which
were not explicitly addressed by the six public consultation questions. These include items highlighted
by external publications since the consultation, or questions raised as part of consultation responses.
They cover a range of topics and are summarized below. They are listed in an approximate order of
priority, with regards to finalizing the O&G guidance. Not all the issues listed below will necessarily be
resolved or addressed through the finalization process.
1. Net vs full value chain accounting
The draft guidance currently requires net value chain accounting of a company’s emissions. However,
during and following the consultation there were questions raised about the extent to which this
approach is consistent with, or deviates from, existing approaches used elsewhere in GHG accounting
(such as to consider full value chain emissions in scope 3 reporting).
Some of the key considerations around net value chain accounting versus full value chain accounting
are that:
Although O&G companies may be integrated across the value chain (upstream, midstream,
downstream), in practice they often function as independent businesses, consisting of many
purchases and trades at different parts of the business, as opposed to maintaining the same
product throughout the value chain.
The total quantity of traded oil and gas is much greater than what is produced. This contrasts
with global scenarios, which only consider the energy produced and do not account for trading
of energy (i.e. they are usually aligned with a net value chain view).
Full value chain accounting may produce undesirable effects as it would be possible for
organizations to appear as though they are reducing emissions simply by integrating their
operations across the value chain, thus reducing their traded volumes.
The net value chain methodology was introduced by IPIECA and makes the reporting
organization responsible for the largest output across the value chain. It is commonly used.
Since the full value chain approach accounts for production and imports (but not exports) it
leads to double counting of scope 3 emissions across organizations, which presents an issue
when using absolute targets.
Due to the inclusion of imports, the full value chain method is the most expansive view of a
company’s climate responsibility as it includes all energy that the company ‘touches’ upon
across the value chain.
Some see the full value chain method as being a more precise application of the GHG Protocol
scope 3 practices.
While the net value chain methodology appears to offer the right incentives and places greater climate
responsibility with companies that produce a lot of fossil fuels, rather than those that simply trade more
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frequently along the value chain, some stakeholders preferred the application of a full value chain
approach due to its existing use within some organizations. A deeper review of this issue may be
required.
2. New fossil fuel production and the Paris Agreement goals
An increasing body of evidence suggest that ongoing fossil fuel exploration and the development of
new fossil fuel production infrastructure is incompatible with the temperature goals of the Paris
Agreement. The IPCC Sixth Assessment Report indicates that any additional fossil fuel production
infrastructure would likely result in warming of over 1.5°C and could result in warming of over 2°C (B.7,
IPCC Sixth Assessment Report). The IEA’s 2050 Net Zero Roadmap indicates there is no need for
investment in new fossil fuel supply provided low and zero carbon technologies are rapidly deployed.
In addition, the SBTi Finance Net-Zero Foundations paper identifies a ‘disclosure, transition, phase-out’
approach, whereby financial institutes are encouraged to:
a) End financing of all new fossil fuel exploration and production (as part of the transition element).
b) End all financial support to existing coal assets by 2030 and oil & gas assets by 2040 (as part of
the phase out element).
Whether O&G science-based targets should include a qualitative criterion, that companies must not
have plans for new fossil fuel infrastructure development, needs to be considered.
3. Other qualitative targets (e.g. phasing out of assets)
The IPCC recently stated that the use of existing and planned fossil fuel infrastructure for the remainder
of expected asset lives would likely result in warming of over 1.5°C (IPCC Sixth Assessment Report).
These findings imply that existing and planned fossil fuel infrastructure should be phased down.
Therefore, whether inclusion of an asset phase-down criterion is necessary within the guidance, and
then how that could be assessed, needs to be considered. The SBTi may wish to address this as part
of establishment of other framework requirements, where non-quantitative elements will feature.
4. Accounting of divestment
As the draft guidance accounts for assets on an equity share basis, it is possible for a company to
divest from assets to reduce their reported emissions, without this resulting in an actual reduction in
emissions from the asset. Therefore, the treatment of divestment that does not result in production
reductions needs to be considered.
5. Data requirement for target setting
As it stands, the data required to apply the methodologies laid out in the draft guidance is extensive and
could be considered overly burdensome. Concerns have been raised around whether current
accounting methods will easily provide the data that is needed to apply the proposed methodologies. A
key example relates to existing differences in how energy companies currently account for purchased
energy. This has implications for target setting, as they are likely to be calculated in different ways and
so cannot be easily compared. To produce consistent targets, it is likely that some organizations will
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need to adapt their reporting requirements to align with the SBTi criteria. Therefore, alongside
consideration of reducing the data requirement for companies to generate targets, the establishment of
consistent guidelines for organizations to follow may be required.
6. Subsectors not covered by the draft guidance
Currently service companies, and transport and storage companies (those that operate pipelines and
shipping), are not covered by the draft guidance. Further consideration is required on whether such
companies can and should be covered by the guidance, even if it is not necessary to establish exactly
how this should be applied at this point.
7. Definition of petrochemical boundary
The complexity of the sector leads to a blurred boundary between O&G and the chemicals industry,
specifically the petrochemicals sector. The boundary between these sectors will be defined as part of
the SBTi’s chemicals sector work and will be consistently applied to both industries.
8. Inclusion of petrochemical target
Petrochemical feedstocks are often produced in conjunction with energy products (i.e. fuels). The SBTi
will address the petrochemical value chain in other guidance and criteria. The necessity of a separate
target for O&G covering the production and downstream emissions associated with petrochemical
feedstocks may be addressed as part of the O&G guidance.
9. Scope 3 emissions for gas transmission and distribution
The SBTi currently requires companies that obtain revenue from the sales, transmission, or distribution
of natural gas to set 1.5°C aligned scope 3 targets on use-phase emissions (scope 3 category 11)
associated with the sold gas, regardless of the percentage these emissions represent in the companies’
full GHG inventory. The O&G guidance may consider whether to maintain this policy.
10. Treatment of coal value chain
The scope of the O&G Project does not include coal products and it is not anticipated that this issue will
need to be addressed by the EAG. The exception to this is in the build-up of scenarios where coal may
need to be removed from carbon intensity calculations to ensure a suitable indicator benchmark.
However, since the 1.5°C pathways already generally transition away from coal very rapidly, this is not
anticipated to be a major factor for scenarios as they move into the 2030s and 2040s.
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6 NEXT STEPS
6.1 Issues raised
Several issues have been identified through the review of progress to date in sections 4 and 5 of this
report. A high-level view on the issues is provided below, with further information and context provided
in sections 4 and 5. Several of these issues will inform the expert review process to enable the
finalization of the O&G guidance.
Scenarios: The setting of bioenergy limits to accompany the existing guidance on scenarios
and criteria for their selection.
Intensity vs Absolute Targets: The requirement for absolute reductions for upstream activities
and intensity reductions for downstream activities.
Value chain target location: The requirement for IEC and upstream energy companies to set
supply-side targets and retain flexibility in choice of methodology.
Disaggregation of targets by scope: Methodologies to calculate scope 1 and 2 emissions
scenarios to support disaggregation of targets.
Company progress indicators: Further prescriptions on the methodologies for creating
indicators and modifying scenarios to improve the comparability between organizations.
Accounting Inclusions:
o Confirm approach to accounting of CCS: What types of CCS can be included and
alignment with the SBTi Net-Zero Standard.
o Removals within the value chain: Alignment with the SBTi Net-Zero Standard.
o Removals outside the value chain: Alignment with the SBTi Net-Zero Standard
o Energy accounting location: Suitability of secondary energy as a measurement.
o Electricity accounting: Suitability of the partial substitution method.
Net vs full value chain accounting: Suitability of the net value chain method.
New fossil fuel production and the Paris Agreement goals: Alignment with other SBTi
guidance, including that for financial institutions, and potential additional criteria to ensure
alignment with the Paris Agreement.
Other qualitative targets (e.g. phasing out of assets): Potential qualitative targets to ensure
alignment with climate science.
Accounting of divestment: The treatment of divestment that does not result in production
reductions.
Data requirements for target setting: Feasibility of the volume and complexity of data
gathering required by organizations.
Subsectors not currently covered by the draft guidance: The scope of the guidance, and
whether it can be applied elsewhere.
Definition of petrochemical boundary: Compatibility with the chemicals sector guidance and
consistency of the boundaries.
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Inclusion of petrochemical target: A potential separate target for O&G covering the
production and downstream emissions associated with petrochemical feedstocks.
Scope 3 emissions for gas transmission and distribution: Whether to maintain the
requirement for companies that obtain revenue from the sales, transmission, or distribution of
natural gas to set 1.5°C aligned scope 3 targets on use-phase emissions.
Treatment of coal value chain: The scope of the guidance, and whether it can be applied
elsewhere.
6.2 Expert Review Process
The expert review process is expected to begin by September 2022 and be completed in late 2022. It
will include the following stages:
Expert Advisory Group selection and mobilization (August 2022). An Expert Advisory
Group (EAG) of around ten members will be engaged, with the aim of securing representation
across industry, finance, academia and other independent / analytical organizations, with
expertise across the O&G value chain. The names and organizations involved in the EAG will
be made public, but EAG sessions will be confidential with feedback summarized anonymously
in a final report. The EAG will be selected using several criteria, including the following:
suitability and credibility, representation, willingness and availability. It will blend expertise
relevant to specific technical and methodological issues with a broader strategic appreciation of
the requirements of SBTi O&G guidance.
Development of evaluation rubric and case-studies (August 2022). To inform the expert
review, an evaluation rubric will be prepared to provide a structured framework for capturing
expert feedback in a way that will result in actionable outcomes. It will comprise a series of both
closed and open questions focussed on the key outstanding issues identified in this Interim
Project Report. The rubric will be accompanied by hypothetical case studies to illustrate how the
proposed O&G guidance would apply to different types of companies. These case studies are
yet to be developed but are likely to consider hypothetical upstream, midstream, downstream
and integrated energy companies.
Expert review period (September-October 2022). The expert review will start with a kick-off
session to share key documents and familiarize EAG members with key issues, the evaluation
rubric and case studies. The EAG will then have up to eight weeks to complete their review.
During this time there will be a small number of topic-based workshops.
Expert review evaluation and summary report (expected late 2022). Following the EAG
review period, responses will all be synthesized through the rubric framework, drawing
quantitative and qualitative data from across the group. Qualitative data will undergo a thematic
review, to ascertain points of consensus and disagreement. Expert recommendations will be
grouped together into a small number of options for how to move forward on key topics. Other
insights that can be drawn from the responses will also be captured. The summary report will be
made publicly available on the SBTi’s website.
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6.3 Finalizing the methods and guidance for the O&G sector
The process for finalizing the methods and guidance will depend on the outcomes of the expert review
process, so it is not possible at this stage to determine the extent of subsequent work required or the
specific timescales associated with this.
Once the expert review is completed, the SBTi will evaluate next steps and define the further activities
needed to finalize the guidance, which could include additional public consultation and/or further
analysis of key unresolved issues. The SBTi is aiming to publish the methods and guidance in 2023.