FAIRR seeks to respond to policy-relevant consultations where relevant to our research and to the work of our investor members. Please find copied below a list of the most recent consultations which we have responded to. Please do get in touch if there are a policy related consultations that you think we should feed into as a network:
FAIRR consultation responses in 2021:
UNFCCC consultation response on ‘Finance for Nature-Based Solutions’
The SCF’s next forum on ‘Finance for Nature-based Solutions’ will seek to provide a platform for a wide range of stakeholders to promote linkages and coherence in climate finance. FAIRR’s response to the consultation highlighted the need to consider investment in nature-based solutions in collaboration with the private sector; current barriers to financing nature-based solutions, notably agricultural subsidies; and the topic of a just transition for food system workers, given the lack of preparedness of protein producers for a 2 degree warming scenario. We recommended the Forum make use of the Coller FAIRR Protein Producer Index and the Appetite for Disruption report in their discussions.
US Securities and Exchange Commission (SEC) consultation on Climate Change Disclosures:
FAIRR supported the SEC’s increased interest in ESG disclosures, and endorsed the need for mandatory and standardised disclosure on these issues. We highlighted the current lack of clarity and comparability in food sector environmental disclosure and recommended a mandatory disclosure of minimum information be imposed across the board. We suggested that the SEC developed its rules in collaboration with third-party providers of voluntary disclosure frameworks as well as sector specialists, to leverage existing frameworks whilst also increasing ambition and rigour in the new standards developed. We recommended that a comprehensive global set of standards would be most effective, and noted that climate-related disclosure should comprise only one element of a broader ESG framework.
Taskforce for Nature-Related Financial Disclosures (TNFD) Consultation on Technical Scope: Submitted via email to TNFD Working Group, 31 March 2021
FAIRR agreed with the broad goals outlined in the consultation document. Further recommendations we advised included more attention to how nature-related financial risks should be treated, as well as separating out the risk types in order to increase the visibility of likely solutions. We also strongly supported a prioritising approach and recommended that the food supply chain would be the most appropriate place to start, with a particular focus on impacts of commodities such as beef on deforestation. Some potential improvements we identified included carrying out an early assessment of nature-related metrics which are meaningful to investors. Finally, we noted the need to establish links between the TNFD work and the UN CBD process.
European Bank for Reconstruction and Development (EBRD)’s consultation on the ‘Methodology to determine the Paris Agreement alignment of directly financed EBRD investments’, 16 July 2021
We submitted that the current list of “Paris aligned” projects does not align with the consensus on transformations needed to limit warming to 1.5 degrees. When it comes to agriculture specifically, we asked for more detail on the information and decision making which included ‘Fishing and aquaculture’ and ‘non-ruminant livestock with negligible lifecycle GHG emissions’ in Paris aligned activities. We advised that the criteria for inclusion in these categories should be strengthened in order to avoid other ESG and climate change impacts; particular areas for further consideration should include feed production, effluent and manure management. We additionally proposed that sustainable and alternative proteins should be added as a category within the agricultural section.
The European Commission’s Platform on Sustainable Finance has launched a call for feedback on preliminary recommendations for technical screening criteria for the EU taxonomy (with a deadline of 24 September)