This Four Twenty Seven webinar familiarizes participants with an approach for assessing city-level physical climate risks and provides insight into concrete actions that cities can take to more effectively attract investor financing for climate adaptation and resilience.
Read Four Twenty Seven’s report on Assessing Exposure to Climate Change in U.S. Munies and learn more about our advisory services for risk assessments, adaptation finance and policy consulting.
Chief Development Officer, Frank Freitas, discusses Four Twenty Seven’s report on Assessing Exposure to Climate Risk in U.S. Municipalities on the Midday Briefing. During this brief interview Frank describes Four Twenty Seven’s work as a data provider for investors, highlights the ubiquity of climate hazards across United States munies and explains the impact of both acute events like hurricanes and more subtlety destructive chronic stresses such as drought.
March 21, 2018 – 427 ANALYSIS. The first year of reporting under Art. 173 in France saw limited uptake of disclosures of physical risk and opportunities. Our review of disclosures from 50 asset owners in France shows only a quarter of respondents included substantial analysis and metrics on their exposure to physical impacts of climate change. We find insurance companies AXA and Generali provided the most detailed analysis for property portfolio, while FRR and ERAFP were the only pension funds to provide an initial assessment of physical risk exposure in their equity and fixed income portfolios.
Art. 173: the world’s first legal requirement to disclose climate risk
Article 173 of the French Law on Energy Transition and Green Growth passed August 2015 requires major institutional investors and asset management companies to explain how they take Environmental, Social and Governance (ESG) criteria into account in their risk management and investment policies. These institutions are also asked to report on the impacts of both physical risks and ‘transition’ risks caused by climate change on their activities and assets.
The law applies to French companies, meaning that French subsidiaries of large financial groups are potentially subject to requirements that do not apply to their parent companies. Its implementing decree invites these organizations to establish scenarios and models to take into account climate risks impacts on the value of their portfolios.
Article 173 covers publicly traded companies, banks and credit providers, asset managers and institutional investors (insurers, pension or mutual funds and sovereign wealth funds). In addition, asset managers managing funds above 500 M€ and institutional investors with balance sheets above 500 M€ are subject to extended climate change-related reporting obligations, including both physical impacts of climate change and transition risks (impact of the transition to a low-carbon economy).
The inclusion of physical impacts of climate change in financial risk analysis is in line with the industry-led Task Force on Climate-related Financial Disclosures (TCFD) recommendations report, released in July 2017.
What did financial institutions report?
We conducted a desktop analysis of the 2017 reports (applying to 2016 portfolios) to understand how financial institutions responded to the requirements laid out by Art. 173 in the first compliance year. We reviewed 50 asset owners in France, including public pension funds, sovereign wealth fund and insurance companies, with an aggregate €5.5 trillion euro ($6.8tn) under management. Our analysis included all the public entities covered by the Article 173, as well as private insurers with asset under management above €2bn. Insurance companies play a particularly important role as asset owners in France, where individual savings are massively invested in life insurance savings products. French pension funds, on the other hand, are relatively small due to France’s pay-as-you-go retirement system.
We were able to find Art. 173 reports for 36 out of 50 organizations. It is possible that, in spite of our best efforts, we failed to locate reports. However, Art. 173 has a ‘comply or explain’ provision which also makes it acceptable not to publish a report if one can justify climate change is not a material risk.
Among the Art. 173 reports, we found 29 from insurance companies and seven from public entities. Among them, 20 organizations (40%) discussed only their carbon footprint and/or their exposure to energy transition risk, without including physical risk disclosures.
A small group of organizations (8%) mentioned physical risk as a topic they were exploring but not yet able to report on. Most of them emphasized the lack of tools and models as a major impediment to reporting physical risk.
All in all, we found 12 financial institutions (24%) of the institutions under review made an explicit attempt to disclose their exposure to physical climate risk.
We broke down this latter group in three categories. Eight companies (16%) provided an analysis of the physical risks threatening either their operations or property portfolios (for insurance), ranging in scope from a few buildings to €15bn worth of assets in the case of AXA. Most of the reports contain limited details on methodology and findings.
Two companies (4%) performed what we call a “top-down” analysis, working with investment advisor Mercer to perform a multi-asset class, sector-level analysis of climate risk using Mercer’s proprietary climate risk model, which blends transition and physical risk. Finally, two high profile investors, pension fund ERAFP and sovereign wealth fund FRR, included an initial assessment of climate risk in their equity and fixed income portfolios, at the asset level.
Table 1 presents a detailed breakdown of how those organizations take physical climate risks into account:
Case Studies: How do Investors Report on Physical Risk?
The best student in this 2016 reporting vintage is AXA France. AXA received the “International Award on Investor Climate-Related Disclosures” from the French Ministry for the Environment, for analyzing 15 billion euro of assets (real estate and infrastructures). The analysis takes into account most frequent European natural disasters and the geographical location of each individual asset as well as the destruction rate of their building materials. They found out that, over 30 years, the accumulated loss would aggregate to 24 million euro. The insurance company also reported that if a centennial storm was to occur, the portfolio would be impacted by a 15.2 million euro loss. While AXA provides some of the most detailed analysis, it also noted that “this new kind of analysis needs to be improved in order to take into account more natural disasters and other portfolios”.
The following graphs demonstrate the physical risk exposure to windstorms for the analyzed infrastructures. On the left, the graph displays the annual average destruction rate, which is linked to the average loss generated by windstorms every year (0.8M€ on average). The map on the right shows the destruction rates due to a 100-year event, with an estimated loss of 15.2M€.
Source (Award on Investor Climate-related Disclosures, AXA Group, October 2016: https://cdn.axa.com/www-axa-com%2Fcb46e9f7-8b1d-4418-a8a7-a68fba088db8_axa_investor_climate_report.pdf)
Generali France also provided a complete and detailed evaluation of the potential impact of physical risks on their property assets. They analyzed 112 assets, mainly in the Paris Area, accounting for 60% of their owned assets. Generali took into account two kinds of physical risks, flood and drought, to rate their assets from “high” to “very low” risk. Regarding drought, 3 assets enter the medium-risk category. As only 12 assets have been analyzed (Paris and the overseas departments being excluded), this risk is important as it accounts for 25% of their analysis. On the other hand, 10 out of 112 buildings owned by Generali France are exposed to a high risk of flood. They are mainly located in the Paris Area and would be heavily affected by a Seine flood.
To sum up, both AXA and Generali reports are valuable examples of emerging best practices as they show the willingness of those organizations to take physical risks into account in their reporting practice. However, their analyses would benefit from being extended to a broader portfolio and to other natural events.
In November 2017 the French pension fund, “Fonds de Réserve pour les Retraites” (FRR), released a report addressing Article 173 requirements. Four Twenty Seven performed the analysis, and applied its proprietary methodology to measure the types and levels of climate risk embedded in FRR holdings. Portfolio exposure was evaluated according to their respective industry and sector. The analysis produced a sector risk score based on three indicators:
This hotspot analysis gave FRR tools to get an initial understanding of its portfolios’ exposure. It highlighted strongly exposed sectors such as Materials and Consumer Staples, due to their dependency on natural resources, and Pharmaceuticals and Electronics hardware, due to their complex and global supply chains. Conversely, the results brought out the low exposure of service-based industries such as Media and Telecommunication.
Reporting on physical climate risk is a challenging task for financial institutions – many organizations lack the tools, models and data to perform a comprehensive assessment of their portfolios, whether they’re composed of real assets or equities. As TCFD reporting becomes standard for financial institutions and corporations, pressure will increase to report on physical risk. We expect fast changes in disclosures in this regard, starting as early as the 2018 reporting season.
This analysis was written with support from Thomas Poloniato.
Four Twenty Seven’s ever-growing database now includes close to one million corporate sites and covers over 1800 publicly-traded companies. We offer equity risk scoring and real asset screening services to help investors and corporations leverage this data.
From Recommendations to Action
March 15, 2018 – 427 ANALYSIS. The EU laid out a clear plan to move towards mandatory climate risk disclosure as part of a new set of regulations to finance sustainable growth and support the transition to a low-carbon economy. The European Commission’s Action Plan lays out a two year timeline for implementation, with a goal to create a taxonomy for climate adaptation finance by the end of 2019. These regulations from the EU will drive change into financial markets globally and set standards on reporting, disclosures and infrastructure resilience that will likely set the bar for the rest of the world.
The European Commission recently released its Action Plan: Financing Sustainable Growth to establish a regulatory framework that supports the goals of the Paris agreement. The Action Plan calls for transformation of the whole financial system and to enable the financing a sustainable, resource-efficient economy.
The Action Plan builds on the recommendation from a high profile expert group, the High-Level Expert Group on Sustainable Finance (HLEG), which was created by the European Commission in December 2016. The group included experts from banking, insurance, asset management and stock exchanges. Its final recommendations to the Commission, released in January acknowledged the responsibility of the financial system to drive change towards “enduring and inclusive economic prosperity”. HLEG recommendations aimed to both promote sustainable investments, so that capital reaches sustainable projects and also to ensure that the financial system itself addresses risk and builds resilience.
Incorporating many of the recommendations of the HLEG, the Commission’s Action Plan lays out ten specific actions, setting deadlines within the next two years, with a number of thematic sub-actions that willbe pursued simultaneously. Action 1 lays the groundwork for many of the following actions as it will establish a Technical Expert Group on Sustainable Finance, with the responsibility of drafting a standardized EU sustainability taxonomy , including climate mitigation by Q1 2019 and adaptation by Q3. This effort will be supported by legislation this year that mandates the creation of the taxonomy.
The 10 actions are summarized in this infographic from the European Commission:
Of most immediate importance to investors is Action 7, which calls for the proposal by Q2 2018 of legislation mandating investors to explicitly consider sustainability factors in their investment decisions and disclose their methodology of doing so. This effort is particularly focused on improving the consistency and transparency of climate risk considerations by investors.
Likewise, Action 9 is focused on improving the methodologies and practice of corporate risk disclosure. The Commission will publish a report on current reporting legislation by Q2 this year, which will inform a revision of corporate reporting guidelines to help them align with the TCFD recommendations, by Q2 2019. Later this year the Commission will develop a European Corporate Reporting Lab, under the European Financial Reporting Advisory Group, to help develop best practices for corporate reporting. The goals of Action 10 will support these actions by supporting a shift in corporate governance. It aims to improve transparency and combat long-termism, by engaging with stakeholders around corporate governance starting by Q2 next year.
Revamping Credit Ratings
The Commission also commits to revamping the ways in which credit ratings incorporate sustainability metrics into their scoring. Through Action 6, the European Securities Markets Authority (ESMA) will examine the credit ratings’ current practices around this topic by Q2 2019 and the Commission will pursue comprehensive research on reporting standards, exploring the potential of mandating agencies to integrate specific sustainability metrics into their standards.
To improve consumers ability to identify sustainable investments, Action 2 calls for the technical expert group to publish a report exploring green bond standards by Q2 2019 and the Commission will consider expanding the EU Ecolabel to include financial products, initially focusing on retail investments. Likewise, Action 4 says that by Q2 2018, the MiFID II and IDD rules will be updated to ensure that sustainability preferences are considered when banks, investment firms and insurers offer accounts to clients and by the end of the year the ESMA will include these provisions in their guidelines. Through Action 5 the Commission will adopt acts that improve the transparency of sustainability benchmarks by Q2 2018.
Comprehensive Sustainability Support
The Commission identifies a lack of technical expertise as a challenge to pursuing sustainable infrastructure projects and aims to confront this by to increasing the technical support available to investors. It will run a pilot project offering tools for sustainable infrastructure projects, from 2019-2023 through Action 3.
Action 8 states that the Commission will consider including sustainability frameworks in prudential requirements, looping in the European Insurance and Occupational Pensions Authority (EIOPA).
“A Blueprint” for Change
While the HLEG emphasized that its report is only the beginning of an enduring effort to create a resilient financial system that supports a sustainable society, the Commission’s resulting Action Plan clearly defines the next steps. And as HLEG also emphasized its report’s relevance for financial sectors worldwide, the Commission’s Action Plan states that a “coordinated, global effort is crucial.” As “the HLEG hopes to stimulate a wide public debate that helps shift Europe’s financial system from post-crisis stabilization to supporting long-term growth,” that same widespread conversation is essential to driving global change. These regulations from the EU, as is often the case, will drive change into financial markets globally by setting new standards global financial institutions must meet.
For more resources on building a sustainable financial sector, read about Four Twenty Seven’s work providing the technical secretariat for an EBRD and GCECA initiative to build a resilient financial sector and download the GARI Investor Guide to Physical Climate Risk and Resilience.
Reaching the goals of the Paris agreement, and financing a sustainable, resource-efficient economy, requires a transformation of the whole financial system. Understanding that private-sector investments must be joined by a transformation of the regulatory landscape, the European Commission created the High-Level Expert Group on Sustainable Finance (HLEG) in December 2016. As the need for reform spans across all facets of the sector, HLEG members include experts from banking, insurance, asset management, stock exchanges and others. The group acknowledges that a sustainable society depends upon enduring and inclusive economic prosperity and that the financial system has a responsibility to drive change towards this sustainability. Thus, the HLEG aims to both promote sustainable investments, so that capital reaches sustainable projects and also to ensure that the financial system itself addresses risk and builds resilience.
After releasing an interim report and soliciting public feedback in July, the HLEG released its final recommendations for actions to facilitate this financial system reform. The report describes a set of priority recommendations and a set of “cross-cutting recommendations.” The former include developing an EU sustainability taxonomy, pushing investors to focus on ESG factors and consider broader time horizons, creating European sustainability standards for green bonds and other financing options, identifying investment needs by focusing first on climate mitigation, providing sustainable finance options for retail investors, and integrating sustainability into both the governance and financial oversight of financial institutions. The “cross-cutting” recommendations include embracing long-term vision, empowering citizens to shape a sustainable financial sector, monitoring sustainable investment and delivery, integrating a “Think Sustainability First” outlook throughout EU policy, and promoting global sustainable finance.
HLEG acknowledges that there are other social and environmental issues that must be addressed alongside climate change. Emphasizing that this report is only the beginning of an enduring effort to create a resilient financial system that supports a sustainable society, HLEG also states the report’s relevance for financial sectors worldwide. As “the HLEG hopes to stimulate a wide public debate that helps shift Europe’s financial system from post-crisis stabilization to supporting long-term growth,” that same widespread conversation is essential to driving global change.
For more resources on building a sustainable financial sector, read about Four Twenty Seven’s work providing the technical secretariat for an EBRD and GCECA initiative to build a resilient financial sector and download the GARI Investor Guide to Physical Climate Risk and Resilience.
The year 2017 will stay on the record as one of the most expensive years to date for climate and weather disaster events. The U.S. experienced 16 weather and climate disasters that caused over $1 billion in damages, tying the record year of 2011 for the most billion-dollar disasters. From summer through the fall, wildfires in various parts of California led to fatalities, destruction of entire communities, and damage costs of $18 billion, with economic consequences that will continue to impact the region. These events have highlighted that climate change has already begun to and will continue to impact local communities and businesses, and that local economies will benefit from more coordinated resilience planning.
Communities across the U.S. are taking steps to identify their climate change risks and enhance their resilience to changing climate conditions. Many local governments have assessed their vulnerabilities and are developing resilience plans with support from local stakeholders. However, a key set of stakeholders are often not at the table: businesses. Collaboration between local governments and the business community on climate change resilience remains limited. As local and regional climate change planning continues, it becomes increasingly important for local governments to engage with businesses, both large and small, on these issues.
The success of businesses and communities is intertwined
Many larger companies recognize the impacts of climate change on their operations, including risks to physical assets, disruptions to supply chains, and impacts on their workforce. In fact, some businesses, like Google, are examining how to develop company resilience strategies that address changing climate conditions. Businesses are also dependent on public infrastructure and local government services, and climate risks on these “outside the fence” components are much harder for businesses to evaluate. In fact, a number of companies have highlighted these uncertainties as a major barrier in addressing adaptation.
Local governments are dependent on the private sector in many ways. Businesses are essential to the economic health and growth of communities. Business interruptions can affect the quality of life for residents, disrupt the local economy, and reduce tax revenues. The costs of Hurricane Harvey are still being evaluated, but preliminary estimates suggest that lost economic output from this storm was in the range of $9 billion to $11 billion, including $540 million for goods-producing industries and $141 million for oil and gas industries. The October 2017 wildfires in California’s wine country are estimated to have caused economic losses between $6 and $8 billion dollars due to property damage and business interruptions alone, with $789 million in commercial property claims. These costs do not include the potential losses to the wine industry for many years to come.
Local governments have a strong interest in ensuring that businesses are resilient and remain operational as the climate continues to change. Companies will also benefit from engaging with the public sector on community resilience to enhance their business continuity plans and support their employees. In addition to better protecting their employees and operations, this type of collaboration will help businesses better understand community needs.
Businesses can assist local governments with expertise and solutions
Larger businesses often already understand local risks because of internal risk management processes. Risk management and emergency management plans, along with drills and training exercises with employees, help businesses prepare for extreme events. Local governments can coordinate with businesses on risk management, including participating in drills and trainings, to build and maintain community resilience.
Local governments can also use larger companies’ expertise and data on risk. Businesses may be monitoring information that could be relevant to local resilience planning. For example, utilities often track potential risks to their assets, such as those related to storms (e.g., wind, precipitation, flooding), wildfire, and temperature impacts on energy demand. This information can be helpful to local decision-makers in both emergency management and long-term resilience planning.
The private sector also offers opportunities in services and solutions. Businesses are often interested in developing and improving technologies, engineering approaches, technical assistance, and opportunities to connect with their communities. For example, Airbnb offered disaster relief to people impacted by the California wildfires, connecting displaced residents to available housing. The company also worked with the City of San Francisco’s Department of Emergency Management to share their lessons learned from Superstorm Sandy. Airbnb is also partnering with various local governments to help communities prepare for and recover from disasters. Local governments’ suggestions for climate change solutions and services can help businesses tailor their products to best serve the community.
In addition, financing for implementing community resilience can often be a challenge for local governments. The private sector can offer financing solutions to help fund climate change resilience. For example, Pacific Gas and Electric Company (PG&E) is investing $1 million over five years through their Better Together Resilient Communities grant program to support local climate resilience initiatives in California.
Local governments can share data and information with businesses
Some local governments have undertaken vulnerability assessments and climate change scenario planning for their regions. The data and results from these studies can be shared with businesses to help them understand what assumptions are being used by local governments, and whether their scenarios align, which will be increasingly important to ensure regional coordination as conditions change.
While larger companies may undertake scenario planning and vulnerability assessments, most small businesses do not. However, small businesses can also benefit from data and information sharing. Small companies do not often have the expertise or resources to adequately assess climate change risks and undertake resilience planning. Local governments can share information with small businesses to help them better understand their potential risks and prepare for extreme events. In California, Valley Vision has developed the Capital Region Business Resiliency Initiative to help engage the small business community in resilience planning. This effort helps small businesses engage with local stakeholders to understand potential risks and provides resources to help these businesses plan for disaster resilience.
Local governments can engage with businesses through existing networks or by creating new processes to assist with engagement
Local governments can engage with both small and large businesses through networks and organizations for the private sector, like local chambers of commerce, trade associations, and other business networking groups. For example, the City of Annapolis has engaged the Anne Arundel County Chamber of Commerce and the Downtown Annapolis Partnership in its Weather It Together initiative, which is focused on adapting the historic community to minimize the risks associated with flooding. Through this effort, local businesses are part of the planning process to help the community become more resilient. The City of Cambridge, Massachusetts has also engaged businesses in long-term planning efforts like the Cambridge Compact and the city’s Climate Change Preparedness & Resilience Plan. Establishing public-private partnerships focused on climate resilience will also help to facilitate conversations and collaboration between these two sectors.
Local governments may already engage with businesses individually, but it can be helpful to set up an ongoing process for involving the private sector in resilience planning. For example, business representatives can participate in local planning and advisory committees, contributing their perspectives and identifying any key issues for the business community. Effectively engaging the business community will often require targeted outreach and potentially different strategies, as businesses may not be aware of ongoing stakeholder processes or may not realize their relevance to company needs. Some communities have incorporated businesses into resilience planning through regional climate collaboratives. Several regional climate collaboratives in California focus on engaging different stakeholder groups, including businesses, to further climate change planning. For example, the Sierra Climate Adaptation and Mitigation Partnership was founded by the Sierra Business Council and has various business members, including ski resorts and forestry companies.
Effectively preparing for climate change’s impacts requires that cities coordinate with many different stakeholders. Businesses, public agencies, community groups, and citizens are all important to the discussion on community resilience, as they will all be impacted by climate change and have important ideas to contribute. Engaging the private sector is an important way for local governments to improve community resilience, and will benefit both the public and private sector through information sharing, aligning needs and goals, and developing multi-sector networks.