Thread by @bbaue

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

bbaue.medium.com/memorandum-on-…

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.

A few examples:

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

sciencebasedtargetsnetwork.org

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

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 w/the Paris Agreement.

parisalignedinvestment.org/media/2021/03/…

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.

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.”

wri.org/news/2021/03/r…

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.

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 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?

“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.

washingtonpost.com/archive/opinio…

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 thru natural selection, SBTi appears to have used its power as de facto standard setter to bias the burgeoning field toward its own solutions & deprive the field of solutions that have been found by independent investigation to be robust.

“In evolution, from diversity comes opportunity…” states eminent Harvard evolutionary biologist Edward O. Wilson in his 2012 book "The Social Conquest of Earth."

SBTi now has the opportunity to support evolutionary opportunity by embracing methodological diversity.