CDP s response to consultation feedback

Transcription

1 A summary document CDP s response to consultation feedback CDP s water questionnaire In order to improve transparency over questionnaire development processes, CDP has produced this document summarizing the feedback received from stakeholders during the annual public consultation period, 1-21 st September This document provides a summary of feedback received, categorized by topic, and articulates CDP s position as well as actions that will be taken based on these comments. CDP would like to thank all stakeholders who participated in the 2014 annual public consultation for water, as outlined below. Relationship to CDP Number of respondents Responding companies 39 Supply chain members 1 Service partners 3 Consultant to company 1 Other 1 TOTAL 45 Separate consultation summary documents have been prepared for: Climate change questionnaire 2015; Supply chain modules 2015; 1

2 Summary of proposed changes for the 2015 cycle Theme Feedback received CDP comment CDP action Addition of companywide water accounting questions for all companies to the current state module 31/45 respondents (69%) supported the inclusion of company-wide accounting in the current state module of the water questionnaire They agreed that the questions posed were detailed enough to demonstrate that a company s risk assessment is comprehensive and based on regularly monitored water accounting data However there were some suggestions for improvement on content and question guidance to assist companies responding Company-wide water accounting questions work best for companies with facilities or factories. If most of a company s water footprint is within their supply chain then this is the data needed to underpin a robust risk assessment, not facility/office level water accounting data Inclusion of company-wide accounting questions would mean an internal reporting change for some companies The breakdown information will be burdensome to collate for companies reporting for many sites The WASH indicator in question Q4 might be redundant in some locations Suggestions for improvement to proposed questions that will be incorporated Re-introduce rainwater as a source Include a category for grey water from municipal or other facilities This new suite of questions are in response to feedback from companies asking for the opportunity to demonstrate that their risk assessments were underpinned with robust water accounting information, regardless of having substantive risk to report. While this suite of questions will assist companies who use water in their direct operations/facilities (irrespective of volume), we are aware that we will need to develop options for companies wishing to provide more detail on water management in their supply chain, if this is where their largest impact lies. This will be researched more thoroughly for future reporting. Company-wide water accounting questions to be added in 2015 to current state module; slight amendments to originally proposed questions to reflect recommendations from respondents CDP has moved supplier reporting questions (formerly W2.5) from the Risk Assessment module into the Current State module (now W1.3) to allow companies to demonstrate the coverage that their risk assessments are based upon. 2

3 Clearer definitions for the sources and destinations listed Better guidance on measuring discharges (not always metered) Addition of new water quality question to company-wide accounting questions for reporting by water quality standards 9 respondents were in favor of this approach Standards give a more precise indication of the level of ambition and effort of a company regarding wastewater management Might need different types of treatment to meet a standard depending on location and operation conditions so standard is easier to list than multiple treatment types for reporting by treatment technology 13 respondents were in favor of this approach Different levels of treatment technology (primary, secondary and tertiary) are understood at facility level and accepted universally The standards question as presented leaves actual level and quality of treatment up for interpretation Due to the variety of feedback and the apparent difficulties in comparing meaningful data across multiple business sectors CDP has decided to do further research into this type of question. We will investigate more thoroughly what meaningful data we hope to get from this type of question, what impact the data can contribute to reducing and the best way to provide guidance to companies. We will not be including a new water quality question on standards or treatment technology in We will review this decision for future reporting following further research. Standards can be set by local regulator, internal company standard, regional or international standard which one is better? Depends on local context difficult to compare universally across companies and locations (too much interpretation) The proposed questions are not significant enough to reflect impact because the reduction of pollution depends on the wastewater characteristics (local context required and not directly comparable) 3

4 Neither approach allows companies to be compared universally unless CDP defines the common definitions between companies and sectors Relocation of product intensity metric to supply chain water module and removal of recycling data metric from all water accounting questions 18 respondents agreed that removal of the recycling data metric from future water accounting questions was an improvement to the questionnaire and agreed with the rationale provided for this change (see Comment column adjacent) Most respondents were indifferent to relocation of the product intensity metric to the supply chain water module but those that commented were supportive of our rationale for re-location stating that they product data from this question is difficult to compare across multiple industries Two respondents were not in favor of re-locating the product intensity question until sector specific questionnaires were available The removal of question W5.6 from the core water questionnaire is due to the lack of comparability between responses for investors due to a lack of current guidance on which products to report per sector. So we are removing this question from the core questionnaire for now to reduce reporting burden. We may reinclude this type of question for specific sector modules once we have better guidance on products to report per sector. The product intensity question (W5.6 in 2014) will be re-located to the supply chain water module for 2015 for suppliers to report on specific products for their customers The recycling data metric will be removed from both company-wide and facility level water accounting questions for 2015 The removal of the recycling data metric from all water accounting questions is to reduce reporting burden. Water efficiency may be reported using consumption volumes in water accounting. If companies wish to demonstrate they are 4

5 becoming more water efficient by using recycling technologies, they can report this in the targets section (question W8.1a) Proposal to change W7.1 in 2014 questionnaire to ask for percentage of compliance violations globally rather than whether a company has significant violations to report Asking whether a company has any compliance violations at all is a good universal measurement for all companies, however a universal definition for compliance and violation would be necessary Continuing to keep a financial element to compliance e.g. fines and penalties is supported in general as fines can be linked to governance risks e.g. fines awarded by local government Applying a threshold to fines and penalties would help companies reduce their reporting burden Fines and enforcement illustrate attention from local government which implies some form of environmental impact (although not the certain degree of impact) A universal definition of compliance and violation would be difficult as it varies so much by locale and context and a global indicator would be meaningless without this universal definition Any new questions should allow for distinction to be made between significant and non-significant breaches e.g. frequency of occurrence Following valuable feedback, it was decided to limit change to this set of questions (W7. Compliance) and instead add a few extra recommended data points to question W7.1a to better illustrate the difference between significant and non-significant breaches Question W7.1 will stay the same. Question W7.1a will be modified to allow companies to report enforcement orders in addition to fines & penalties. The frequency of breaches will also be requested. Once breaches have been listed, companies will be required to state what % of global operations were associated with the list of fines/penalties/enforcement orders Proposed reintroduction of linkages and trade-offs question Majority of respondents were in favor of re-introducing this question but with the following suggestions: Would be nice to properly quantity trade-offs in terms of water and energy (or other environmental themes instead of just mentioning them This question will not include set categories but will be structured as a narrative question for The subsequent reported data will be This question will be reintroduced for It will be broadened to include other environmental themes as well as carbon/energy. 5

6 More specific guidance to point to linkages and trade-offs that companies may not have considered Re-inclusion of 2013 question asking for key inputs at risk in a company s supply chain Addition of facility level reporting column (grid references/coordinates) for future years (post 2015) as an option to report geographic locations Will be tricky to be comparable, especially if scored in 2015 While some companies are supportive of re-including this question, there were requests for clearer guidance from investors on which inputs should be reported. Traceability is not mature enough in some sectors to report this information at river basin level Companies would like better guidance on the best tools to identify the risks affecting their key inputs Companies would like sector guidance from investors on which inputs would be best to report for comparability Some companies had confidentiality concerns reporting locations of inputs due to commercial sensitivity While many companies reported that this was feasible and they were amenable to reporting at facility level, others also wanted to retain the option of country and river basin level reporting. This would allow companies more flexibility to disclose information at different geographic levels as appropriate. There were also queries for more information on how investors might use facility level data. used to inform better question structure and guidance for Following feedback that more detailed guidance is required to cater for the multiple sectors that might respond to this question, we have decided to postpone the addition of this question for We will instead research better guidance and possibly sector approaches to capturing this information in the future. This question will only be scored for disclosure points in This question will not be reincluded for Further research will be conducted on improving the water questionnaire for companies wishing to report in more detail on their value chains. Any subsequent question on key inputs will be considered within this context. Facility locations will not be requested in 2015 in the water questionnaire. Feedback from respondents will be used to inform IT updates post 2015 to decide the best way to provide this option to companies without increasing reporting burden. We will also investigate how this data will be best translated/communicated for data users 6

7 CDP is exploring sector specific questionnaires/modules and/or guidance in line with our new strategic plan There was broad agreement that a move towards a sector specific approach for questionnaires and question guidance was a good one for CDP. There were no objections to the high priority sectors identified for water. There were no recommendations for sector specific thresholds to categorize high risk or impact for water. CDP will continue to fundraise to allow sector specific questionnaires/modules to provide more granular information for investors and other stakeholders CDP is exploring verification for the purposes of water data quality There were recommendations that any future verification efforts should: Be made in tight relation to verification of other types of disclosure e.g. annual reports, broader reporting standards, CDP climate change verification requirements etc. Consider verifying only partial information where necessary rather than the whole disclosure/response. Feedback from the public consultation will be taken into account with any future sector specific work This information will be taken into account with any future verification studies 7