Sustainability now: “Clearing the air” on GHG–August 2026

0:00Thought Leadership from PwC's National Office.

0:09Hello, I'm Heather Horne, PwC's U.S. Sustainability Technical Leader, and welcome back to PwC's Accounting Podcast. This is Sustainability Now. In today's episode, we're connecting several important developments in greenhouse gas reporting, including the GHG Protocol's updated standard-setting roadmap, proposed changes to Scope 3, the evolving role of book and claim market instruments and recent implementation updates from California and the land sector removal standards. There's a lot to cover. To help us understand how these developments fit together, I'm joined again today by Colin Powell, PwC Canada partner and a member of the GHG Protocol Scope 3 Technical Working Group.

0:49And a quick note before we begin. Several of the items we're discussing today are proposals under development. The GHG Protocol posts its technical working group materials publicly and we'll include a link in the show notes. So just a quick caveat. All right. So Colin, welcome, as always. Thank you. So we have so much to cover today. But why don't we start first with talking about the announcement we saw coming last week from the GHG Protocols July 29th development plan. So can you first share us what they talked about? And then I have several questions. Great. Yeah. So ultimately, I mean, it was big news.

1:21We got a little bit of a sneak peek of this in the technical working group. But ultimately, the different groups of standards that are out right now will all be combined into one standard. So we'll have one GHG inventory corporate standard. The timing was also adjusted. So the original plan was changed. So we're looking at a final one standard out at Q4 in 2028 and a public consultation for a draft exposure or sorry, exposure draft for the whole standard in Q2 2027. So it's a bit of a year delayed right now, but there's one prime reason for that, and that's the relationship with ISO. That's a bad thing.

2:01I'm just saying that to accommodate them, that's why the shift has happened. And I think one thing that's interesting is this actually, if we rewind to the 2023 consultation that they did when they first asked for feedback on the standards, this is actually one of the prime recommendations that PwC made and actually a lot of people made. Because I think anyone who works with a GHG protocol knows part of the challenge is, wait, what does the standard say? What does that standard say? And even though all the standards are being updated, trying to keep overlapping guidance consistent, I think it's a huge challenge.

2:34So to me personally, that's a huge win. Obviously, the delay, given all the questions that are out there, that is more problematic, I would say. You might also say it was inevitable just because the relationship was announced and finalized in the middle of the process, right? So the expectation is it would be, it wasn't expected at the beginning. So now they're going to do it. And so we'll be delayed. But again, it's not a bad thing. I think it's a very positive development. So Colin, maybe just sidetracking slightly from a working group perspective, then would you have anticipated anyway you guys needed more time?

3:06Because I think originally you were supposed to be issuing exposure drafts this fall. Yeah, exactly. And as far as I can tell from the public materials, it doesn't appear that exposure drops would have been ready, putting aside the ISO. Yeah, probably not. Like I anticipated maybe a quarter delay if that wasn't there. But right now we're about to get some comments back from ISO on the previous work that was there. So ultimately their input has caused a bit of a delay. And then I think overall, as they opine on all of the other developments and all the other working groups, that's what's ultimately culminated in this year-long delay.

3:41And then ultimately, now that the partnership's been announced, you guys are working together, is it really working as one integrated group? Or are you expected to continue to sort of be there's a work stream and then the ISO commenting on it? No, I think the previous arrangement was because they had to get caught up. Yes. But now there are ISO members on the working groups. They have the same say as any other working group. And I think they're above the working groups. They have an input as well. So in the steering committee and the independent standards board, they're there as well. So I expect it to be much more streamlined.

4:12Okay, that's helpful. And then I know you've gotten a lot of questions from clients as soon as the announcement came up. I think there's a huge amount of interest in this announcement. So what is the nature of some of the questions that you're getting? And I guess what are your responses? Ultimately, I can't answer a lot of them. I think information is still to come. But one question is like, what is this going to be an ISO standard at the end of the day? Because it exists as an ISO standard, 140641. So will it exist as that in the future? That will be the GHG protocol ISO joint branded standard.

4:44What happens to the actual like assurance part of that standard? So 140642. Does the GHG protocol exist as an entity anymore? Like I'm getting very, very like broad questions once that comes out. But again, we don't know for sure. I think some of those details are left to be figured out. Yeah. I mean, again, it's interesting. I think when you think from an assurance perspective, there's obviously a lot of other bodies that are focused on issuing assurance guidance. So I think leaving it to them would be my personal Heather Horn point of view of what should happen. I do think the GHG protocol is interesting because they've been the preeminent standard setter for GHG.

5:26And so for them to not exist anymore, it seemed unexpected to me, but I guess we have to wait and see. In the meantime, though, companies should continue to use the standards we have and to carefully follow what's going on. Absolutely. The change is still a few years away. So ultimately you still want to follow the exact same GSU protocol you've been using. But just keep abreast of the changes. Yeah. Anything else in the announcement you'd highlight? Those were the headlines. Yeah, the headline, I mean, as part of the same announcement, they released the scope two consultation summary. They also said that the consultation for the AMI, the actions and market instruments is about to come out.

6:04So it was a pretty big announcement at the end of the day, but obviously the headline being that, you know, pushed out a year. Sorry. So I actually didn't focus on this. Did the AM, is the AMI standard also going to be incorporated. So then in a way that one is actually on track for what they had always announced. And that I actually do think will be much easier for companies because I think so much concern about what, like, were they going to release the scope two standard that has market and then subsequently issue AMI. So I do personally think that's a really positive change. I think so. I think we talked about this before.

6:39Yes, I think we did that they needed to coordinate. Maybe they were listening to our podcast. Yes, yes. Yeah, you'll see it all come out in one go, hopefully. Yeah. So I think it is a good positive development. We'll see it at the same time. And it will definitely be interesting to see what the feedback from the initial AMI constitution was. That's very quick, actually, for them to get comments released because the letters were only due in June. Any headlines from Scope 2 or too soon for you to have analyzed them? No, no. I mean, it was quite easy to see. The document's pretty clear. And if you look at the headlines, like the things that were also a bit controversial, there wasn't strong support for it.

7:18So like, I'm going to say controversial, just like the hourly matches. Yes, I mean. It was controversial. Yeah. And there wasn't a lot of support or not majority support. Yes. The concept of deliverability. So your contractual market-based instruments have to match the region you're operating in. That was not well supported. Location-based emission factors. So much more granular emission factors. it was a bit even in support, like 40%, I believe, for support, 44 % no or little support. So that one was actually a bit more even keel than I thought it was going to be. Yeah, I'm actually surprised about that as well.

7:55Yeah, yeah. So, I mean, it remains to be seen what they'll do with it. Now they have a bit more time to respond. I think that's what also gives them the more time. But yeah, I think the bigger headline ones that were a bit more iffy didn't get a lot of support. How about the grandfathering or that was related to continue to permit old contracts that didn't meet the quality criteria? And I have a specific reason for asking that, but you respond first. Generally strong support. I think it was like 70 or 80 % support for that. So the reason I'm asking, and I have some follow-up questions, is because the LSR standard has a different approach to that.

8:30And I think that's, we're starting to see companies really struggle with the fact that, you know, you not really don't have the same grandfathering necessarily for offsets. Yeah. And so I guess two questions about LSR, since we're on the topic. First of all, will LSR be also incorporated into the standard? Seeming like not. Yeah. So that's extremely interesting because there are a few things that seem to me at least inconsistent with some of the other developments. So that might be an interesting point that hopefully maybe will evolve because I think having that to the side is going to be quite complicated.

9:05I guess the other thing, since we're on LSR, there's been some developments since we last had a podcast. So can you talk about the technical guidance? And then we can talk about the effective date. So, yeah, the technical guidance was released June 30th. It's been a long time. They met their deadline. Yes, they did. Yes. Congratulations. Yes. So, I mean, it's been a long time coming. I did a read of it. I mean, it's pretty clear on the things, although the concepts are quite complex. Yes. I think the guidance is pretty good. Yeah. 500 pages. I did a skim. I was going to say, that'd be impressive, Colin, if you studied at all.

9:42I have a lot of time on my hands. And then the effective date changed as well. So they made that much more clear. So it's 2028 on 2027 data. Yeah. Which is a bit of a stronger clarification of what it originally was, which was, in effect, January 1st or 30th of 2027. So very short. Yeah. Although I do think this one, I have to say, from a governance perspective, I think I personally, again, Heather Horn, would have had some concern because I think they had originally had a Q &A that said it's for reports issued after January 1, 2027. And then on this LSR webinar they had in mid-July, they announced with no indication this was a change that it's effective starting January 1, 2027 for reports in 2028.

10:28And they changed the Q &A with no indication. And so, again, I think this is a welcome change. I think we had raised the question. I'm sure many other people raised it as well. I just, like, hopefully from a governance perspective as things move forward, we'll see a bit more transparency for this type of change. But again, it was very welcome. It's just the way it was handled. I think you'll start to see it. I mean, ultimately, with the announcement from the GCP this week or last week, sorry, I think you're starting to see much more transparency in how they're doing things. Yes. So hopefully that continues.

11:01Yeah. And then anything else from the technical, it's probably deserving of a separate podcast, but any highlights you would say that was surprising in the technical guidance or more that is just detail on what's in the standard? There's a lot more detail. So I think one of the, like when it first came out, the standard, it was like, okay, whoa, how do I get in here? And I think that like the gap between the standard and the guidance, in my opinion, was a bit long. And so that's where it was the confusion arise. But like ultimately the details are in there. Obviously it's 500 pages. I haven't got a single detail, but I think it's a welcome addition to the standard.

11:38Yeah. And I think you and I have talked about this before, but it's worth repeating, is that obviously there's the land sector portion and the land use change and that portion and affects a lot of companies. And so if you're potentially impacted, please pay attention. But I think the part maybe companies are paying a little less attention to is removals and the offsets and otherwise that this is not just companies generating offsets, but if you're using them. And I don't think necessarily companies have started to think about their practice. And then that's where these quality criteria come in.

12:11So I don't know if you can briefly just explain what's going on there. Yeah. I mean, it also aligns with some of the book and claim stuff we'll talk about. And ultimately, within the removals part of the land sector removal standard, there are quality criteria to recognize removals you're either buying or selling that exist in your inventory already around transparency. So are you using the right methodology for calculation? Are you disclosing on those methodologies? Is there permanence with the removals? Like, how are you tracking this? Is there ongoing monitoring? What type of removal is it?

12:43Is it biological? Is it technological? There's a whole host of them. A whole huge list, yes. So I won't go into all of them, but ultimately you're going to see a lot more rigor in these. So whether it's a removal, whether it's a book and claim, which is going to be fit into the actions and market instruments piece, like you're going to see and need a lot more rigor into the use of these credits. And then the disclosure on them. Yeah. So definitely encourage companies that are using those to pay attention. Yeah. But let's move to your favorite topic. So Scope 3, this is your technical working group.

13:16And it continues to be a lot of interesting things coming out of that group. But I think today I wanted to ask you about Scope 15 and our new Scope 16, proposed Scope 16. So we touched on this previously, but it's probably worth rewinding and just what's being proposed there. Yeah, I think so. So this should be in the GHG protocol website already, but maybe not. So ultimately, over the last couple months, ISSB reviewed the previous Category 15 and Category 16 drafts and provided comments. And then the protocol reviewed them and ultimately made some modifications. And to confirm, ISSB. Yeah. So like IFRS Foundation.

14:00Yes, exactly. Not the ISB from the GHG protocol. And sorry, I just wanted to confirm because I think it's an important point here. So the ISSB was looking at them and they, interestingly, for those who weren't paying attention, made a specific point in their podcast that the versions of the GSU protocol guidance that they incorporate by reference are static and that they would need to do their own due diligence when these new standards come out. So I guess this is at least a precursor to some of that. So sorry, that was a lot of side, but I just think it's important. It is a very important distinction.

14:32Yeah. And so ultimately, they have a vested interest in this. They need to be able to have a view before these things come out. And so that was that opportunity. And so the protocol adopted some of the recommendations, but not all. Oh, okay. You can see in the documents, I think they should be public soon. There's some compromises made, but I mean, ultimately, there is a lot more interoperability in those categories with IFRS 2. So the changes that the protocol made to category 15 makes it very, very close to being interoperable with IFRS 2. I don't think it's perfectly interoperable because there's some definitions, for example, or some things that got moved to the guidance that maybe aren't exactly the same in IFRS 2.

15:18But that is one of the bigger developments. And when you say, when really focusing on interoperability, then is it including those additional categories that IFRS 2 requires disclosure of? Yeah, and there's some movement, which things that were originally placed in category 16, like cash deposits is a good example, that got moved to 15 in this current proposed draft. And so things like that were things that were categorized, maybe that weren't interoperable with IFRS 2 got moved. There's more clarification around some of the definitions. So even the definition of financed emissions has a definition in IFRS too.

15:54And so they have adopted that. Oh, the same definition. Yeah, I'm pretty sure it's the exact same. They've also removed a lot of the specificity that was in the GSU Protocol's current proposed draft because IFRS or ISSB said you don't need to do this. Like, you can leave it open to the preparer. Which I think you and I would both say is a good development that would have gone too specific. For sure. And again, we're talking about the draft standards, not the existing scope three standard. Yeah, the draft proposal. And there's also a lot of things that the ISSB recommended to remove from the standard and put in the guidance.

16:29And so ultimately, one of their comments was it's a bit heavy. And so a lot of it is pushed to the guidance at the end of the day. Sorry, just before you go on. So for people who may have heard us talk about 15 and 16 previously, but don't remember the exact difference. Can you just remind us what those two categories are intended to be used for? Yeah, so 15 is financed emissions or investment emissions. This could be the emissions associated with investments, lending, credit, project finance, a whole bunch of other activities. The 16 has gone through iterations of names, but other value chain and facilitated activities, I do believe is the current proposal.

17:07Okay, that's a mouthful. Yeah, so ultimately a facilitated activity. And so a good example in the financial services industry would be insurance or underwriting of a security, for example. In the real economy, it would be the facilitation of a movement of hydrocarbon through a pipeline, for example. So the reporter doesn't take ownership or doesn't own the actual source of emissions, but facilitates its downstream emissions, for example. And then 16 would be a required category or a recommended category? Still proposed to be optional, except if you are a distributor of fuel and electricity. And that is still in there as a mandatory activity.

17:50All right. So if you own transmission lines or pipelines, then you would be reporting the emissions associated. Yeah. Transmission lines is a bit stickier. I think there's a lot of questions of where they sit. Yes. And also how that would work. Yes. Yeah. But definitely if you're a pipeline operator. Yeah. Okay. Yeah. All right. And then what's next steps on this? Yeah. So the 15 and 16, like I do believe they're settled for now after the protocol has taken the ISSB's recommendations. But then the rest of the scope of work under scope 3 is now being finalized. I think we're getting exposure drafts for 10, 11, and a few other categories very soon.

18:32and they'll be back. They'll be open for comment for us for the internal technical working group over the next month or so. And then Collins, given that the actual exposure drafts are not anticipated until next summer, then are you guys going to get a break? Apparently not. There was an explicit ask in the email to us that's like, we hope you can stick around for another year. Okay. So I don't think there's going to be a pause. And I think it's a bit of a question, like, will they merge the working groups? Will they do something? Because now if the standards merge, Like, how are they going to streamline that as well?

19:04We don't know. Yeah. But ultimately, the ask was like, we're not asking you where to stop anything. And we ask you to continue as long as you can. So any other sort of scope three developments you'd highlight or has really been focused on 15 and 16 most recently? No, most recently actually was 10, 11 and 10, 11, actually. There's a lot of talk of circular economy. And so there's a lot more standard language on how to approach things with like recycling, end of use, end of life that will be integrated into the standard or the guidance. A lot of this stuff is like has been very vague, I think, over the last as long as it's existed.

19:42Yeah. And so the intention in those categories is to provide a bit more certainty on how to calculate for things. So things will either be in standard or guidance. But again, we haven't seen the final, like, the quote-unquote exposure drafts or the internal exposure drafts, whatever you want to call it. Yeah. Yeah. And so it's interesting, scope or category 11, some of the most questions we're getting right now around that is to using market-based inputs. And category 11 currently has nothing to do with the proposal. So that leads me to the AMI standard or the developments related to AMI, the working group.

20:18So you mentioned they're working on book and claim, but let's rewind and just remind people. So we had the AMI. It wasn't like a full exposure draft, but more requests for input. Yeah, discussions. So those letters, I think, were due at the beginning of June. And now you're saying we're going to see the results soon, which will be interesting. But then they've continued to work. So what's the most recent development then? Yeah, there hasn't been much publicly available. I do believe they hinted that there was positive support. In the RFI, positive support for the overall impact statement or GHG impact statement.

20:53And just as a quick reminder, the AMI group will focus on a disclosure style for incorporating your physical GHG inventory. So the one you calculate anyway. A market-based inventory, which includes market-based scope one and scope three. An impact statement, which could be impacts related to emissions reductions or carbon offsets that may be in your value chain or outside your value chain. This could be avoided emissions because of the products you sell. And then some other bucket, which is related to non-greenhouse gas emissions KPIs. So that is their mandate to be able to build those things out.

21:29Right. And I guess that's where then we'll see what the feedback was, if there was broad support for all of those. Yeah. But I think one of the questions then you mentioned book and claim. So how does that fit into what they are trying to accomplish? Yeah, book and claim will be the prime type of carbon offset, for example, that will be used to claim under a market-based scope one and a market-based scope three. And so book and claim is a chain of custody model. It permits the physical delivery of a product separate from the environmental attribute associated with that product. So you could buy a low carbon hydrogen, for example, but you're actually taking delivery of a normal, like a standard carbon hydrogen.

22:14But you also get this environmental attribute that says like, here's a certificate that says you're 20 % lower than the standard, for example. And so companies that are familiar with the environmental attributes certificates in the EU or renewable energy credits, like that's the equivalent of those, but for other types of products. Yeah, exactly. I mean, the most like probably typical one would be sustainable aviation fuel. Obviously, it's a good candidate for this type of chain of custody model because there's, you know, there's only so many companies that make aviation fuel and then only so many that make sustainable aviation fuel.

22:49So it is a bit easier to track and monitor. And that will be a key challenge of expanding that scope to any other product in the world where you could apply this type of concept. And so that's what they're considering then for scope one and scope three. Exactly. And then how would we think about, I started this by mentioning market-based inputs. And so that's, for example, that if I have a supplier and they tell me they use renewable energy credits, so their emissions are lower and they give me a supplier specific emission factor. Would that also then be part of the market based statement or how would that work?

23:26Yeah, I mean, it seems like that's the way it will go. I actually hope it is the way they go to make it as simple as possible. And ultimately, I would be on the supplier to say, OK, we've done this. This is our disclosure on how we've calculated it. This is the clear justification for the relevance. So it's attached to a specific emission activity. This is where you would use sustainable aviation fuel to offset aviation fuel use. You can't use it to offset electricity. So that relevance to the emission source is important. But then the proof that it's been canceled and no one else can actually use it in another system, all those things will be a part of this.

24:04This is the quality criteria piece that we're talking about. So that mechanism has to be built ultimately within the GHG protocol to be able to then claim it in a market-based inventory that aligns with the GHG protocol. All right. And then how does this fit in with what we were talking about with the LSR standard and removals? Because ultimately, the quality criteria will be quite similar. Permanence, obviously, is one for removal specifically. Yeah, that wouldn't necessarily be the case here. But anything else around tracking, monitoring, progress, how it's being canceled, how it's being delivered, all the chain of custody stuff will have to be tracked.

24:41Yeah. And then I guess this is specifically focused on scope one and scope three, because scope two right now, at least, is being dealt with by the scope two technical working group. But would we ultimately expect then for there to be similar quality criteria for RECs and those types of instruments? Because they already have their own quality criteria. Yeah, you probably won't see that much difference. But yeah, ultimately, I think one of the advantages of a book and claim system is that you can take delivery of a product and it's not necessarily in your geography. It's one of the challenges with low carbon products like they're not everywhere.

25:16No. And so that deliverability piece may not be in a book and claim type. Yeah, and versus is very important from a scope too, or at least that's what directionally is the direction it's going. So, yeah, it'll be interesting to see, I guess, how they reconcile. And I guess this goes full circle back to your point of now, if it's an integrated standard, what does that mean for the working groups? Because it doesn't necessarily make sense for two different groups to be dealing with very similar issues like that. Yeah, exactly. I do believe they have ongoing check-ins. Yes, I would guess so. Yeah.

25:50So hopefully, yeah, the alignment comes before it goes to exposure drive. Yeah. Yeah. All right, let's turn our attention then to a couple other developments, maybe just one more development. And that's California. So many of our listeners are quite interested in the reporting requirements in California under SB 253. and the most recent workshop that CARB had and some of the announcements that they made. So hopefully most of our viewers slash listeners have read the in brief and in depth that we issued at the tail end of July. But can you share for this group what we saw and what we expect next?

26:27Yeah, so I mean, one of the key things was changing the report date to November. So scope one and two are now due in November of this year. Scope 3 is a little bit of a question mark, but I think the expectation is it would be next year. That would be the same report date. You'd report Scope 1, 2, and 3. They did decide on an approach, or at least the first year approach for Scope 3 reporting would be the most common categories they've claimed. So 1, 3, 5, 6, and 7, which is interesting. Yes. And then still a bit of a question mark around assurance, especially assurance moving forward. For scope three.

27:06For scope three. Yeah. Yeah. I mean, I think the thing that really struck me the most is now the more direct link to the GSU protocol. And maybe you can share a little bit. I will start with the fact that the bill itself or the actual legislation that was passed says it's reporting in accordance with the GSU protocol. But then we saw a lot of different discussions in the working group or in their webinars up to this point. But then now, most recently, it's gone back in the direction of the protocol. Yeah, yeah. I mean, ultimately, they have to decide one way or the other, but it seems like they have stuck to this.

27:43The one, I think, comment I've gotten from a lot of clients is that scope three decision aligned with the GSU protocol. Yeah. And so companies are ultimately looking for a bit more clarity as this came out. So hopefully that will come. Yeah, yeah. I do think the fact that for companies, at least put aside scope three for a moment, but for scope one and two, I actually think for most companies, even voluntary reporters, having the surety of, okay, it is going to be moving toward, or they've said it will be in accordance with the GHG protocol. At least now it's a more known target. And it's something then they can start benchmarking or otherwise with their current reporting.

28:23Yeah, for sure. I guess we'll see with scope three what, you know, what we get. I also noted that they have specifically said LSR standard will not apply, which is probably good for now. Yeah. So it's important. Anything else from that announcement that stands out for you? No, I think ultimately it answered some questions, but not all. And so, yes, hopefully. Yeah. Well, we're going to have, there's more workshops coming, right? So, all right. So from your perspective, then, as you're talking to clients, I mean, there's a lot of developments we didn't even talk about, USRS, here. And there's developments there.

29:00So what are you recommending to your clients, particularly those that are subject to multiple reporting regimes? Yeah, I think, like, you know, for GHG Protocol specifically, nothing is final. Yes, there's a bit more time. But that shouldn't mean, like, a pause on the work that you're doing. Yeah. specifically for those maybe impacted by 15 and 16 categories, 15 and 16, they'll likely be more things included in those. So ultimately, if you have activities under investments, under discretionary managed funds, like you can do the work to understand how material they are to you. Where's the data?

29:35If you need to calculate them, where they'll sit, whether it's in 15 or 16 at the end of the day, kind of doesn't matter. At least try to do the work to understand, like, do you have the data? Can you actually calculate it? Are you ready ultimately to report when it's there? There's some no regrets moves there. That mapping of the activity data is a really important one because ultimately, you know, 2030 comes around, but it sounds far away, but it is not. And there's going to be a lot of things that are coming down since then, like SBTI will come into effect at that point. A lot of companies' targets will come up.

30:10So there are a lot of inflection points in the next couple of years. So ultimately being ready for things before 2030, I think, is an important piece. So you have companies right now, they're thinking about the future of the GSU protocol. How about companies that now maybe have been doing voluntary reporting, but in this interim are actually, let's assume CARB continues on this path, going to be required to report in accordance with the protocol, maybe with a few exceptions. So what do you recommend to those companies? I think it is about doing your own due diligence internally to understand, like, are we ready to be in accordance and or work with our insurance providers to understand that gap?

30:49because usually when we see volunteer reporting, especially just scope one and two, there are gaps around the in accordance with it. And it could be small things, but it could be some bigger things. So I think it is really understanding what are the gaps against the requirements of the current protocol. Yeah. Because I think even there are known new requirements under the proposed changes. And so even starting to understand what your gap is against those is an important first thing. Although I think it might be a bit daunting for some of these companies, just starting with the gaps against the current one.

31:25Because that would be reporting for this year end that they would be anticipating having to do that. And it's interesting timing because companies will barely have been required to file their current reports for this year and then start working on the new ones. So definitely a lot to think about. And how about LSR Standard? I know you have companies dealing with that. Any final words of wisdom there? I think, again, it's about trying to understand how material it is to you. I think that question was left into the standard of like, is it significant? The removals piece, we are getting a lot of questions on ultimately.

31:59You know, what counts, what doesn't count? How do we actually start? So I think building that governance mechanism into your purchases and procurement and understanding when and where and how is a good first start. Because also we're seeing uptick in SBTI coming into that conversation. So that's what we're ultimately recommending to clients is like, get an understanding of what you need to do if you're starting to make maybe a big purchase for removals, understand how it can impact your downstream reporting or regulatory requirements. And understand it is the right thing to do right now and build the governance around it.

32:34So then Colin, final question for you. I get asked a lot and I'm sure you probably get asked more is that even though you are focused full time, I'm mostly full time on this. It's hard to keep up. So what do you recommend to your clients that are trying to deal with the shifting landscape and don't have necessarily the bandwidth to fault every one of these developments? Yeah, I mean, I would selfishly say, come talk to us. Your phone is going to be ringing up the hook. My job. But ultimately, I think like, you know, you can't check in with these things every day. Yeah. And the protocol has been pretty good about being transparent on what's out there.

33:12Actually, I had one of my staff build an agent that reads what's on the. Oh, you mentioned this previously. Yes. And it's and it's been pretty good. Like it filters through what's what's important. It builds decks like there are ways to do this, especially if you have Copilot. Yeah. You can drive things pretty easily. But also thinking like really understanding where the changes might impact you. You, yes. Yeah, like specifically. And so, you know, maybe a bank doesn't necessarily care about category 10 and 11. A fertilizer producer doesn't care about 15 and 16. So just really understand where you need to monitor the changes.

33:48Have someone at least a little bit responsible in their job to just say, okay, hey, well, I saw something come up in the protocol. Like, are we prepared for this? Or should we comment on it? Should we find an avenue to jump ahead of this? So at least providing some sort of avenue to understand what's going on. I do have to make one comment on your comment about the fertilizer company, because if that company has investments, it does in fact care about Category 15. I think this is still a big myth that that is only for financial institutions. But all right, well, Colin, as always, such a pleasure to talk to you.

34:19Thanks so much for joining me today. Thank you so much. And then to our viewers slash listeners, thank you as well for joining us. to keep up to date on all of these announcements, I definitely encourage that you subscribe to our newsletter at viewpoint.pwc.com. In addition, I would encourage you to check out chapter seven of our sustainability reporting guide. We are making updates to it on a regular basis to deal with some of the most pressing issues, particularly related to application of the GHG protocol. And then that we also, as I mentioned, have other publications out there on the developments in California.

34:54So definitely a lot of information to talk about Or as Kwan said, just call him. So, all right. Thanks again for joining us and hope to see you again next week.