TODAY’S STUDY: THE RISKS OF FRACKING DISCLOSED

Disclosing The Facts: Transparency And Risk In Hydraulic Fracturing Operations

Richard Liroff, Investor Environmental Health Network, Danielle Fugere, As You Sow, Lucia von Reusner, Green Century Capital Management, Inc., Steven Heim, Boston, Common Asset Management, LLC, Leslie Samuelrich, Green Century Capital Management, Inc., November 2013

Executive Summary

Since 2009, institutional investors have been pressing oil and gas companies to be more transparent in reporting how they manage and mitigate the environmental risks and community impacts of their hydraulic fracturing operations. Measurement and disclosure of best management practices and impacts are the primary means by which investors gauge how companies are addressing the business risks of their operations.

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This inaugural scorecard is a collaborative effort of As You Sow, Boston Common Asset Management, Green Century Capital Management, and the Investor Environmental Health Network. The scorecard analyzes and benchmarks the public disclosures of 24 oil and gas companies on the use and effectiveness of best management practices for reducing and managing environmental risks and community impacts from hydraulic fracturing operations. It does so by examining overall industry performance on use of quantitative metrics for disclosure, identifying those indicators most commonly reported, and distinguishing companies disclosing more about their practices and impacts from those disclosing less. The scorecard specifically measures company disclosures across five areas of environmental, social, and governance metrics: (1) toxic chemicals; (2) water and waste management; (3) air emissions; (4) community impacts; and (5) management accountability, on a play-by-play basis.

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The assessment in this scorecard is based solely on information companies make publicly available on their websites and in their financial statements. The results of the scorecard demonstrate a widespread industry trend of underperformance in disclosure of key performance metrics. Companies, nearly across the board, are failing to provide investors and the public with sufficient quantitative information to adequately understand and compare the risks and opportunities these companies present within their hydraulic fracturing operations.

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Key Findings

1. Poor Overall Industry Performance on Disclosures of Key Metrics: Quantitative, play-by-play disclosure is inadequate across the industry. Company disclosures remain mostly qualitative and narrative in form, making it difficult for investors to rigorously assess and compare company performance. Too often, companies provide aggregate reporting (e.g., on a companywide or countrywide basis) and rely on anecdotes or narrative statements as a substitute for systematic, quantitative reporting on critical regional and local practices and impacts. Further, we believe that narrative reporting does not give investors and other stakeholders the information necessary to determine if individual companies are sufficiently managing the risks inherent to their operations across their multiple plays.

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2. Reporting Varies Widely Company to Company: The highest scoring company in this review, Encana, provided disclosures on only 14 of the 32 indicators. QEP provided disclosures on only 1 of 32 indicators, receiving the lowest score in the report.

3. Most Commonly Reported Indicators: The most commonly reported survey indicators were: executive compensation tied to health, environment, and safety performance (71% of companies surveyed); the use of pipelines to transport water in lieu of diesel trucks to lower air emissions (62%); and company policy on the use of non-potable versus fresh water (46%).

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4. Least Reported Indicators: Companies scored worst on their disclosure of how community concerns are tracked and responded to, especially on a play-by-play basis. Only 6 companies received any points in the community impacts section of the scorecard. While certain companies may be addressing local community impacts, no company is systematically reporting company successes and failures in accommodating community concerns on a play-by-play basis.

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