Resolved: Shareholders request that Enbridge annually disclose all of its material scope 3 emissions using accepted definitions and in absolute terms.

Supporting Statement:

Enbridge’s current scope 3 emissions disclosure methodology runs counter to guidance by the CDP,¹ the GHG Protocol,² and investor-led Climate Engagement Canada,³ leading to a large under-reporting of scope 3 emissions and by extension its transition risk.

Enbridge’s scope 3 reporting is incomplete because excludes downstream emissions for use of goods and services, so called “category 11 emissions,” from its midstream business. While Enbridge reports some category 11 emissions from its gas utility business, it does not report the category 11 emissions associated with midstream business services –transportation and storage of oil and gas. 

These emissions are material to Enbridge because its business model relies on their release, and their exclusion therefore obscures risks associated with these emissions.

Moreover, as Enbridge expands its infrastructure such as gas pipelines or LNG terminals, the trend line for these scope 3 emissions is not properly measured and assessed for risk.

Enbridge claims either existing reporting methodological uncertainty, incomplete data, or double counting as reasons to not fully report its scope 3 emissions. Yet, the guidance is clear that Enbridge should report the material emissions from category 11 and other energy companies have overcome these challenges to report relevant scope 3 emissions.⁴

In 2020 Enbridge made a commitment “to expand the scope of our public disclosure of scope 3 emissions within the next 2-3 years.”⁵ This resolution presents an opportunity for investors to ensure Enbridge fulfills this commitment.

This is the second year this proposal has been submitted. Last year 24.4% voted in favour, with another 4% abstaining, for a total of 28.4% breaking with management.⁶ Despite this relatively high vote by Enbridge investors, the company is yet to improve its approach to the issue.

We respectfully request that shareholders vote for this proposal.

1.  Section 3 “Industry and company structure” specifically states that the guidance document applies to midstream companies pg. 10 https://cdn.cdp.net/cdp-production/cms/guidance_docs/pdfs/000/000/469/original/CDP-Scope-3-Category11-Guidance-Oil-Gas.pdf
2. Provides guidance that the direct category 11 scope 3 emissions should be reported for “fuels and feedstocks” (e.g. petroleum products, natural gas, coal, biofuels, and crude oil) table 11.1 pg. 114 https://ghgprotocol.org/sites/default/files/standards/Scope3_Calculation_Guidance_0.pdf
3. CEC benchmark (Appendix A pg. 33) provides specific guidance that O&G distribution companies should report scope 3 “use of sold products” category 11 emissions https://climateengagement.ca/cec-net-zero-benchmark/
4. https://www.wri.org/update/trends-show-companies-are-ready-scope-3-reporting-us-climate-disclosure-rule
5.  Enbridge 2020 CDP report Section C3.1d https://www.cdp.net/en/responses/5581?per_page=10&sort_by=project_year&sort_dir=desc
6. https://www.enbridge.com/~/media/Enb/Documents/Governance/ENB_20230504_Report_of_Voting_Results.pdf