The Global Reporting Initiative (GRI) has recently published the draft of a new reporting standard on air pollution issues, while simultaneously releasing standards on soil pollution and critical incidents.

It is a document of considerable interest in the field of sustainability reporting, for several reasons. First of all, it is worth remembering that reporting standards are documents that provide organizations wishing to publish sustainability reports with guidance on the type of information to collect. These documents are the result of in-depth reviews of sector publications and therefore offer up-to-date references aligned with international trends, while also being practical and usable for companies.

Until now, GRI had not dedicated an ad hoc standard to air pollution, which had been treated as a sub-topic within the GRI standard on climate change. At last, it is being given central importance. This standard therefore addresses pollutants with local effects such as nitrogen oxides, sulfur oxides, VOCs, carbon monoxide, particulate matter.

A gap is therefore being filled. And it is being filled rather late, given the very large number of initiatives of various kinds that have highlighted the importance of these forms of pollution: suffice it to mention the European directives on air quality and industrial emissions, as well as the many warnings issued by the WHO regarding premature deaths caused by air pollution.

This new standard gives companies that choose to adopt it guidelines for disclosing information on how they manage the impacts associated with atmospheric pollutant emissions. But what does it specifically require?

First, it requires a description of company policies related to this issue, which must of course be aimed at reducing emissions. It also asks companies to indicate the presence of significant emissions in their value chain, and this is an important innovation: although the disclosure on the value chain is purely qualitative, it represents a further push for companies to take an interest in what happens beyond their own operational boundaries.

Among the other noteworthy elements is the requirement to specify whether there are initiatives to reduce atmospheric pollutant emissions that are combined with climate change mitigation actions. In practical terms, companies are asked to indicate whether the measures undertaken for the ecological transition make it possible to reduce both CO2 and other air pollutants.

In this way, areas of synergy are made explicit: for example, reducing energy consumption makes it possible to reduce both CO2 emissions and those of other pollutants. It is therefore a way of emphasizing that the ecological transition involves many points of overlap, which makes the commitment to sustainable development less burdensome.

There are, however, still some unresolved issues in this draft. GRI has a strong strategic approach, and this is evident in the requirement to define targets and pollutant reduction pathways. It is precisely here that some weaknesses emerge.

Companies are in fact asked to identify a base-year value, that is, a year whose emission level for each pollutant must be used as a reference point for setting a reduction pathway, through the definition of a specific target. The value may be expressed either in terms of weight or as a KPI.

In theory, there is nothing to object to, especially since the structure of this approach is described in detail by GRI. This certainly makes it a useful tool for companies whose emissions are associated with mobile sources, such as public transport operators or businesses active in the distribution sector, which can assess their progress toward the target on a yearly basis. By contrast, for companies whose emissions cannot be monitored or calculated continuously, but are instead subject to periodic analysis for the emission points identified by environmental permits, the pathway becomes far more complicated. This is precisely because the frequency of emission calculations does not allow for the identification of either a reliable base value or a credible target. One possible solution could be to define a KPI based on the regulatory limit imposed through the environmental permit obtained, but there is no specific reference to this in the standard.

The terms for properly setting up an emissions reduction pathway therefore still need further clarification. These are important aspects, and it is to be hoped that they will be resolved through the public consultation, which will close in June. In any case, the publication of this draft is an important step, as it broadens and improves the possibilities for voluntary reporting using GRI standards.

Also read: CSRD, survey: 9 out of 10 companies disclose sustainability data even without legal obligations

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