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					GRI Electric Utility Sector Supplement Draft for Public Comment

Comments must be submitted by 9 April 2007 using the Online Public Comment Form on the following website:

The draft version of the Global Reporting Initiative (GRI) Electric Utility Sector Supplement now open for public comment until 9 April 2007, is a sustainability reporting guidance tool for use by electric utilities, and is based on the third generation of GRI’s Sustainability Reporting Guidelines (the “Guidelines”). The Guidelines have been declared to be used by more than 1,000 organizations worldwide as the foundation for reporting on their organizational performance and contributions to sustainable development. The Guidelines were developed over several years using a global, multi-stakeholder process, which engaged hundreds of individuals worldwide from different constituencies and geographic regions. The Guidelines represent the reporting content that has been identified as most broadly relevant to both reporting organizations and report users. In order to support the use of the Guidelines by different sectors, GRI has initiated the development of Sector Supplements, which are sector-specific sustainability reporting guidance tools based on the Guidelines. These Sector Supplements are designed to complement the Guidelines and should be used in addition to, not in place of, the Guidelines. GRI released a third generation of the Guidelines in October 2006, and this Electric Utility Sector Supplement is designed to be compatible with this new version of the Guidelines, known as the “G3” Guidelines. This draft of the Electric Utility Sector Supplement was developed by a multi-stakeholder working group formed in 2006. The working group is comprised of individuals from a range of geographical regions and a number of different constituencies including electric utilities, civil society organizations, trade unions, and mediating institutions. A list of working group members can be found in the Annex 1 of this document. The first working group meeting was held in June 2006 to identify issues specific to the electric utilities sector and to determine the scope of the Sector Supplement. At the second meeting in September 2006, the working group prioritized the range of issues and began drafting new, sector-specific disclosures and performance indicators and commentaries on the relevant G3 Guidelines content to make them more specific to the sector. The group met for the third time in December 2006 to refine the proposals and to agree on a set of proposals for public comment. The working group has also taken into consideration the informal feedback provided from practitioners not directly participating on the working group, but who have been following the Sector Supplement development process. A fourth meeting is planned for May/June 2007 to review feedback received during the public comment period and to finalize the Sector Supplement for release as a pilot version. To broaden the scope and ensure its relevance to the sector, the draft version of the Electric Utility Sector Supplement is available for public comment from 8 January through 9 April 2007. The content of the Supplement will ultimately be published with the G3 Guidelines, however, this document only shows the content developed through the multi-stakeholder working group process for the purpose of obtaining comments during the public comment period.1


PDF version of the G3 Guidelines and the accompanying Indicator Protocols can be downloaded from the following URL: 8 January 2007 Page 2 of 21

GRI Electric Utility Sector Supplement Draft for Public Comment

Draft GRI Electric Utility Sector Supplement Public Comment Period 8 January – 9 April 2007
GRI welcomes all comments and suggestions on how to improve the draft GRI Electric Utility Sector Supplement. Specifically, GRI would like proposals on alternative wording options for the new sectorspecific, disclosures, performance indicators and commentaries on the G3 Guidelines as well as concrete responses to the questions posed to the public by the working group (these are highlighted in yellow throughout the document). GRI thanks all in advance for taking the time to comment. Instructions 1) Read the draft Sector Supplement after downloading it from the following website: The document is available in PDF format. Submit comments in English using the online comment form that can also be accessed from the above website no later than 9 April 2007 (no late submissions will be accepted).


Important Note · Please use the online comment form when providing comments. Since comments will be complied into one single document to be reviewed by the working group, it is important to use the provided online form to ensure that your comments are interpreted in the right context. Although separate arrangements can be made when it is not possible to use the online comment form to submit comments, there is no guarantee that the working group will be able to accurately identify the intention behind the comment when using a different form. In case you are unable to submit your comments using the online comment form, please contact the GRI Secretariat by Friday, 16 March to make a separate arrangement. To increase the chance of correct interpretation by the working group, please word your comments as clearly as possible. All comments submitted are considered public record. For GRI, this means that comments will be shared with the working group with attribution in order to finalize the Sector Supplement and would also be available to interested parties who wish to understand the development of the Sector Supplement. Comments must be received no later than 9 April 2007 to ensure that the working group will be able to review them prior to the final working group meeting in May 2007 and to be considered as public record.

· ·


GRI Secretariat Contact Information E-mail: Phone: +31 20 531 0000 Staff: Sean Gilbert, Director, Technical Development; Naoko Kubo, Project Manager

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Introductory Text for Public Comment
Comments are invited on the following introductory section of the Sector Supplement. Who is the Sector Supplement intended for? The Sector Supplement is intended for organizations engaged in the generation, transmission, distribution or retail of electricity. The Supplement content was developed to be globally applicable to electric utilities regardless of their type of generation, size, ownership or range of activities within the sector. Based on the G3 Guidelines, the Sector Supplement provides reporting guidance on key aspects of sustainability performance that is meaningful and relevant to the industry. Reporting using this sectorspecific guidance provides stakeholders with the ability to evaluate an electric utility’s sustainability performance on economic, environmental and social factors that are comparable with other electric utilities using the GRI Reporting Framework on a regional, national, and international scale. It also helps them to track the utility’s performance over time. Sector-specific guidance is provided in the form of commentary on the G3 Guidelines content and new, sector-specific disclosures and performance indicators. This includes guidance on metrics, definitions, and calculation methods relevant to the sector. Some of the disclosures and indicators included in this Sector Supplement may be relevant to other sectors that have similar operational footprints or sustainability issues. Nonetheless, all aspects included in this Sector Supplement are important and appropriate for the electric utility sector and should be used to guide sustainability reporting in this sector (i.e., reporting on economic, environmental, and social performance at an organizational-level).

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Overview Electric utilities provide essential and vital services to society and users. The services provided are crucial to the growth and security of economies in all countries. However, economic growth must be achieved in a sustainable manner in order to protect key resource systems, and to provide for future generations. Specifically within the electric utility industry, a number of factors are fundamental in determining an electric utility’s economic, environmental, and social sustainability performance as the generation, transmission, and distribution of electricity utilizes the global commons. These three sustainability factors - economic, environmental, and social performance - are captured by the disclosures and indicators included in this Electric Utility Sector Supplement. Economic Factors: Investments in new equipment and maintenance of existing infrastructure along with assets in research and development of sustainable electricity generation, transmission and distribution technologies all require significant financial resources. The reporting organizations are expected to develop strategies to appropriately allocate these financial resources, to provide reliable and high quality electricity supply into the future, and to manage demand to provide shareholders and other stakeholders with the information necessary to assess the economic performance of the reporting organization. In this respect, it is important that all stakeholders are represented in the electric utilities to reflect the stakeholders’ views in their decision making process. Environmental Factors: Electric utilities are expected to minimize the impact on the environment of the full life cycle of their business operations. Electric utilities are among the largest consumers of fossil fuels in the world, making fuel use/mix an increasingly important environmental sustainability concern. Fossil fuel combustion and other modes of electricity generation can result in wide spread environmental effects, including acid rain, climate change, radioactive and other contamination, and human health issues, if not adequately addressed in the electric power generation business. This responsibility has required electric utilities to consider strategies such as the installation of pollution control systems, development and utilization of power generation methods based on renewables and other non-fossil sources such as wind, biomass, hydroelectric, and solar power, and to help meet demand with demand-side management solutions. These operational strategies include energy reduction strategies as well as the shifting of energy demand to off-peak hours of operation. Social Factors: Electric utilities have an obligation to provide electricity to their customers in a socially responsible way. In providing this energy, electric utilities must operate with ethical standards and engage stakeholders in decision making in order to achieve consistency with community goals and values. Electric utility assets and activities are often of a large scale, potentially impacting neighboring and distant communities. Also, the electric utility sector employs a workforce that can be exposed to potentially hazardous conditions such as high voltage electrical conductors and radiation at nuclear power facilities. Thus addressing workforce and safety issues are vital to the electric utilities’ performance, since a qualified staff is fundamental to ensuring safe and reliable electricity services. For the overall sustainability of the community, access and affordability of electricity to all users are also important social factors that electric utilities need to consider.

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Overarching Issues for the Sector In addition to the set of new, sector-specific disclosures and indicators, the following three topics have been identified as key topics that require special attention by the electric utilities for sustainability reporting. Electric Utility Sector Regulatory and Market Structure An important feature of the electric utility sector is the different regulatory regimes within geographical locations of operations. Sustainability reporting by electric utilities needs to consider the specific regulatory and market environments in which they operate. In particular, implications of privatization, market structure, tariffs, governmental requirements and planning should be explicitly considered. Some of these regulations are still emerging or developing, and electric utilities must keep abreast of these requirements and incorporate them into their sustainability considerations and reporting. Stakeholder Engagement As providers of an essential service and as users of natural resources, electric utilities need to build trusting relationships with stakeholders in order to operate legitimately and sustainably. Across all economic, environmental, social, and cross-cutting themes described in this document, the engagement of stakeholders needs particular consideration. Electric utilities are expected to disclose their approach to effective stakeholder engagement. Specific areas for consideration include: stakeholder identification, means of engagement, level and weighting of stakeholder representation in decision making processes. At a minimum, stakeholders include customers, neighbors, regulatory authorities, interested organizations, workers and civil society. Particular attention should be given to vulnerable constituents. Contracting and Supply Chain Practices Electric utilities are often able to use their market presence and purchasing power to influence the social and environmental policies and practices of their suppliers and contractors. In fact in some cases, many of the major social and environmental impacts occur well upstream or downstream of the reporting organization’s operations (e.g., upstream fuel supply issues as well as downstream end of life considerations regarding electricity use). Contractors are often involved in various aspects of provision of electricity, and contractor’s performance can affect the environmental performance and safety and reliability of the core operations of the reporting organization. It is therefore important for electric utilities to monitor and report on the performance of contractors, where they are integral to the utility's operations, in order to ensure minimal risks to the communities as well as to ensure safety, reliability and security of the energy supply. Electric utilities are encouraged to disclose their supply chain policies and practices regarding the products and services they purchase or contract when these policies and practices are relevant to sustainability issues. In order to disclose these policies and practices adequately, the utility may need to consider information about contractor or supplier entities beyond the reporting boundary as defined by the GRI Boundary Protocol2. Typically, these policies and practices include capacity-building in suppliers and contractors, workplace safety, waste disposal, protection of human rights, regulatory compliance and remediation efforts undertaken.

GRI Boundary Protocol can be downloaded from the following URL: GRI Electric Utility Sector Supplement Draft for Public Comment 8 January 2007 Page 6 of 21


Proposals for Public Comment
Comments are invited on the following proposed new disclosures/indicators and commentaries.

The following section outlines the proposed new disclosures and performance indicators for the sector (these are labelled as EU1, EU2, EU3, etc.) and new sector-specific commentary on existing G3 Guidelines content (these are labelled as, e.g., CommEN1, indicating that it is a commentary on existing G3 indicator EN1).3 The proposals are presented in the following order: · Organizational Profile · Economic · Environmental · Social · Electric Utilities (cross-cutting issues) The Electric Utilities cross-cutting section has been created specifically for this Sector Supplement in addition to the Economic, Environmental and Social sections found in the G3 Guidelines, given that disclosures and indicators contained in this cross-cutting section cut across more than one of these three sections. A number of questions have been posed by the working group to seek feedback during the public comment period, and these questions are highlighted in yellow.

In addition to the disclosure items in the Organizational Profile found in the G3 Guidelines, electric utilities should also provide the following information specific to the sector. Proposals
EU1. Percentage of population served in area of operation, according to category (e.g., rural, commercial, residential, etc.). EU2. Length of transmission and distribution lines.


PDF version of the G3 Guidelines and the accompanying Indicator Protocols can be downloaded from the following URL: 8 January 2007 Page 7 of 21

GRI Electric Utility Sector Supplement Draft for Public Comment

Aspect Long-Term Reliability Proposal EU3. Description of how long term reliability, as well as social, economic and environmental performance criteria are used in investment decisions. (New Disclosure) Explanation Investment may concern new power plant construction, distributed or central generation, transmission and distribution, power purchase, and decommissioning.

EU4. Process and methodologies used to assess existing and future demand, such as integrated resource planning. (New Disclosure) Explanation Integrated resource planning involves long term projections of demand combined with an assessment of supply-side and demand-side options. This assessment may include consideration of cost, maintenance, asset life, regulatory requirements, climate change implications among others. Organizations engaged in transmission and distribution as well as in generation are expected to report on this topic. EU5. Planned capacity (MW), dispatching and/or generation mix (MWh) against projected electricity demand over the long term. (New Performance Indicator) Compilation Timeframe should be ten years or longer. Report also on planned reserve margins and purchases Short-Term Reliability EU6. Approach used for peak load management including load shedding. (New Disclosure) EU7. Customer or supply interruptions (as defined by IEEE recognized standard reliability indicators). (New Performance Indicator) Explanation One example of an Institute of Electronic and Electrical Engineers (IEEE) recognized indicator is Customer Average Interruption Duration Index (CAIDI): CAIDI = SAIDI /SAIFI SAIDI: Sum of all customer interruption durations SAIFI: Total number of customer interruptions. Refer to IEEE for more information (

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Aspect Research and Development

Proposal EU8. Approach to Research and Development (R&D), including R&D goals, investment mechanisms and processes for implementation. (New Disclosure) Explanation Since R&D is essential to promote sustainability, it is important for electric utilities to report on their R&D goals. Examples include plant optimisation, decreasing environmental impacts, renewable energy technologies, advanced generation and other innovative technologies. The approach may include the allocation of activities and resources across a range of levels, including research, development, demonstration and deployment. EU9. Research and Development expenditure by category as a percentage of total research expenditure. (New Performance Indicator) EU10. Research and Development expenditure as a percentage of net income. (New Performance Indicator)

System Efficiency

EU11. Generation efficiency. (New Performance Indicator) Compilation Generation efficiency is the ratio of energy going into the plant to energy leaving the plant (i.e., electricity sent out). Measures of efficiency should also include thermal efficiency. EU12. Transmission and Distribution Loss Factor. (New Performance Indicator) Compilation Report separately on transmission loss factor, and distribution loss factor where applicable. Question for public comment: Q1 There are a number of international standards to measure generation and system efficiency. Public comments are invited on which industry standards are most broadly applicable for widest range of electric utilities.

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Aspect Water

Proposals CommENDMA. Water: Watershed management in order to balance water supply for multiple uses (e.g., irrigation, drinking water, ecosystem conservation, tourism, etc.). Include approaches for managing watersheds for biodiversity and siltation of dams. (Commentary on Environmental DMA)

EU13. Long-term planning for securing water resources, including description of how the criteria for managing maximum/minimum flow of surface water and volume of ground water are determined and maintained. (New Disclosure) CommEN8. Report water used for processing, (include use of fresh water in ash handling), cooling and consumption in a thermal/nuclear power plant. Also report on volume of water used/MWh net generation. (Commentary on EN8: Total water withdrawal by source [core]) Net refers to electricity sent out of the power plant. Biodiversity CommEN13. Describe criteria and management approaches for assessing biodiversity of compensatory ecosystems. Report on how the biodiversity of compensatory ecosystem is compared to the biodiversity of the area it is replacing. Report also on provisions for facilitating fish passage around existing dams. (Commentary on EN13: Habitats created or restored [Additional]) CommEN14. Report on the impacts and mitigation measures to the following where appropriate: · Forested areas (e.g., alterations to crown density) · Landscape (e.g., impacts of wind farms) · Freshwater and wetland ecosystems (e.g., downstream water quality including turbidity, sedimentation, siltation and water quality of the lakes behind hydro-electric dams) Assessment and mitigation should consider alterations in the migration, breeding, or habitat of animals from the reporting organization’s infrastructure (e.g., power lines and dams) and its maintenance. (Commentary on EN14: Strategies, current actions, and future plans for managing impacts on biodiversity [Additional]) EU14. Percentage of area under Integrated Pest Management. (New Performance Indicator) Explanation Integrated Pest Management includes management of both flora and fauna.

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Proposals EU15. Ratio of compensatory ecosystem area to total area of land acquired with high biodiversity value. (New Performance Indicator) Explanation Refer to EN11 Indicator Protocol for the definition of areas of high biodiversity value.

Emissions, Effluents and Waste

CommEN16. Report emissions intensity by generation type: · CO2e per MWh for net generation · CO2e from fossil fuel generation per MWh net fossil fuel generation (Commentary on EN16: Total direct and indirect greenhouse gas emissions by weight [core]). Explanation The former refers to the emissions intensity for all generating capacity, and the latter refers to that of the fossil generation capacity. Net refers to electricity sent out of the power plant. CommEN17. Report CO2e per MWh for net delivery to end users. (Commentary on EN17: Other relevant indirect greenhouse gas emissions by weight [core]) CommEN19. Report emissions per MWh net generation. (Commentary on EN19: Emissions of ozone-depleting substances by weight [core]) Explanation Net refers to electricity sent out of the power plant. CommEN20. · Report emissions per MWh net generation. · Examples of other air emissions include reservoir draw down dust, coal pile dust, ash lagoons or ponds, and precipitator dust. (Commentary on EN20: NO, SO, and other significant air emissions by type and weight [core]). Explanation Net refers to electricity sent out of the power plant. CommEN21. Include thermal discharges. (Commentary on EN21: Total water discharge by quality and destination [core]) Question for public comment: Q2 The working group proposed commentary on G3 indicators EN8, EN16, EN17, EN19, and EN20 on water use/emissions intensity. The group’s preference was that these should be reported per MWh gross generation (gross refers to generation measured at the alternator). However, it was suggested that not all utilities would be able to report per gross generation, and it would be more feasible to report per MWh net generation. Feedback is invited on whether intensity should be reported per MWh net generation or MWh gross generation, including whether either/both are practicable to report for utilities.

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Aspect Emissions, Effluents and Waste

Proposals EU16. Management strategy and storage methods for different types of radioactive nuclear waste, including temporary and permanent storage. (New Disclosure) Compilation Radioactive nuclear waste includes Low Level Radioactive Waste, Intermediate Level Radioactive Waste and High Level Radioactive Waste. EU17. Measures to manage environmental and health and safety impacts of radioactive nuclear waste, and security measures according to the applicable management standards/legislative framework. (New Disclosure) EU18. Isotopic composition of radioactive nuclear waste. (New Performance Indicator) Compilation Composition should be reported as volume, weight, total activity (in Bq per unit of time and energy). EU19. Radioactive nuclear waste produced per net GWh nuclear generation per year. (New Performance Indicator) Compilation Radioactive nuclear waste intensity should be measured both in terms of mass and activity. EU20. High level radioactive nuclear waste sent for processing and reprocessing per year. (New Performance Indicator) Compilation Report on activity, mass and resulting waste.

Polychlorinate d Biphenyls (PCBs)

EU21. Long-term strategy for managing and eliminating high level and low level inservice PCBs. (New Disclosure) Compilation Reporting organization should define high level and low level according to prevailing national or regional standards. In the absence of such standards, use 500 ppm as the high level threshold. Reporting threshold for low level should be according to the prevailing national/regional standards or, if no standards exist, 50 ppm. CommEN1. Report in-use inventory of solid and liquid high level and low level PCBs (in kilograms or litres). (Commentary on EN1: Materials used by weight or volume [core]). CommEN22. Report on PCB waste categorized by management method (in kilograms or litres). (Commentary on EN22: Total weight of waste by type and disposal method [core]). Compilation

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Proposals Management method includes treatment, storage, landfill, incineration, etc. EU22. Expected completion date and projected costs of remediation of all known contaminated sites. (New Disclosure) CommEN30. Report on expenditure to manage and clean up contaminated sites. (Commentary on EN30: Total environmental protection expenditures and investments by type [Additional]). EU23. Ratio of remediated sites to known contaminated sites. (New Performance Indicator)

Contaminated Land


CommEN29. This should be considered as a core indicator for the sector. (Commentary on EN29: Significant environmental impacts of transporting products and other goods and materials used for the organization’s operations, and transporting members of the workforce [Additional]).

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Aspect Labor: Employment Proposals EU24. Processes to ensure retention and renewal of skilled workforce. (New Disclosure) Relevance Maintaining a highly skilled workforce is essential to electric utilities, to ensure the safety of the workforce/equipment and operations, as well as the safety of the community, and to ensure the sustainability and reliability of the utility’s services upon which societies depend. Electric utility workers are called upon to perform highly technical tasks. These tasks require specialized skills, and mental and physical readiness. Question for public comment: Q3 The working group recognized that the issue of skill retention in the workforce was important for the sector, though not unique to the sector. The working group also discussed the issue of “brain drain”, that shortage of skilled workforce in certain countries are resulting in extrapolation of skilled workforce in other counties where the stability of their electricity supply maybe affected by migration of workforce. Feedback is welcomed on whether these issues are sufficiently critical to the sector to be included in the Sector Supplement. If so, concrete recommendations on how to address the issue are also welcomed – as part of the labor DMA, as an additional disclosure or as commentary on an existing G3 indicator. Labor: Occupational Health and Safety CommLA7. Report on health and safety performance of subcontractors. (Commentary on LA7: Rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities by region [core]). Question for public comment: Q4 As noted in the introductory section (page 6), the use of subcontractors is extensive within the sector. Given this, the working group considered that some of the labor performance indicators in the G3 Guidelines should be extended to require utilities to report on the performance of subcontractors, specifically with regard to health and safety. However, the working group was uncertain how practical this was for electric utilities for any indicators other than LA7. Feedback is invited on whether it is practical for utilities to report on LA7 for subcontractors, and whether utilities should be required to report on other labor indicators from the G3 Guidelines for subcontractors, specifically LA1 (Total workforce by employment type, employment contract, and region), LA6 (Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational heal and safety programs), LA8 (Education, training, counselling, prevention, and risk-control programs in place to assist workforce members, their families, or community members regarding serious diseases), LA9 (Health and safety topics covered in formal agreements with trade unions), and LA10 (Average hours or training per year per employee by employee category). Human Rights: CommHR5. Report on management mechanisms to address the right to strike or instances of lock out, given the context of the industry’s need to ensure continuous Freedom of provision of services. (Commentary on HR5: Operations identified in which the right to Association and Collective exercise freedom of association and collective bargaining may be at significant risk, and GRI Electric Utility Sector Supplement 8 January 2007 Draft for Public Comment Page 14 of 21

Aspect Bargaining Society: Community

Proposals actions taken to support these rights[core]) EU25. Participatory decision making processes with communities and outcomes of engagement. (New Disclosure) Compilation Details to be reported include quality of information, timing of engagement in projects, levels of stakeholder engagement and provision of resources for vulnerable stakeholders. CommSO1. Report on specific social issues related to electric utilities sector. These may include: · Influx of workers and impacts on neighbouring communities (including changes to local social structures and culture); · Changes to land-use including loss of global commons (e.g. access to land, natural resources, and heritage); · Impacts on infrastructure (e.g. roads, housing), and access to services (e.g. education, utilities, healthcare); and · Changes to the aesthetics of the landscape (Commentary on SO1: Nature, scope and effectiveness of any programmes and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting [core]). EU26. Percentage of projects which are compliant with IFC performance standards or equivalent. (New Performance Indicator) Compilation The website provides further details on the IFC standards. This should be reported as a proportion of all projects to which the standards are applicable.

EU27. Number of people physically or economically displaced. (New Performance Indicator)

Question for public comment: Q5 In developing a performance indicator on stakeholder engagement, the working group discussed that it would be better to measure compliance with existing, developed standards, rather than to prescribe good practice for stakeholder engagement within this Sector Supplement. Feedback is invited on the proposed performance indicators, specifically whether it is appropriate to reference a standard in the performance indicator, and whether the IFC standard is the most suitable reference point. Concrete recommendations for alternative performance indicators not involving reference to standards are also welcome.

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Aspect Society: Public Health and Safety

Proposals EU28. Exposure limit(s) to electric fields (in kV per m) and magnetic fields (in μT) for members of the public and employees in the areas in which reporting organization operates. (New Disclosure) CommPR1. Processes for assessing community health risks including monitoring, prevention measures and, if applicable, long term health-related studies. (Commentary on PR1: Life-cycle stages in which health and safety impacts of products and services are assessed for improvements, and percentage of significant products and service categories subject to such procedures [core]) Explanation Community health risks can include issues such as electro-magnetic fields, emissions, noise, diseases, etc. Long-term health related studies may include epidemiological studies. EU29. Number of injuries and fatalities to the public including diseases involving utility assets. (New Performance Indicator) Question for public comment: Q6 Occupational health and safety was recognized as a key issue for the sector, but one which is already covered extensively in the G3 Guidelines. General feedback is invited on whether the G3 and this Sector Supplement together capture the key health and safety impacts for the sector. More specifically, the issue of public health and safety was recognized as a key industry issue. However, the working group was uncertain exactly what was reasonable to expect utilities to report in this area. With reference to the proposed commentary on PR1, we welcome feedback on whether it is reasonable to expect electric utilities to fund and/or be involved in long-term health-related studies. In addition, feedback is invited on whether it is practical for utilities to report on diseases which involve assets of the reporting organization. Concrete recommendations for alternative performance indicators which capture the broader public health and safety impacts of utilities are welcome.

Product Responsibility: Access

EU30. Programs, including those in partnership with government, to assist underprivileged, low-income or vulnerable customers to afford electricity connection and consumption. (New Disclosure) Question for public comment: Q7 The importance of the issue of affordability was discussed by the working group. The group recognized the differences in the way the issue is manifested across different markets, in terms of the numbers of people affected, and how utilities deal with the issue. The working group wanted to propose a performance indicator, but was not able to develop one which was globally applicable. Concrete recommendations for performance indicators that would be globally applicable are welcome.

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Proposals EU31 Description of flexible billing arrangements, timely reconnection and other practices to assist customers to manage debt and avoid electricity disconnection. (New Disclosure) EU32 Initiatives to extend electricity services to unserved and underserved communities, particularly in rural or remote areas. (New Performance Indicator) Compilation Description of initiatives should specify where these are driven by regulatory requirements. EU33. Percentage of population unserved in licensed area of operations, broken down by population in rural areas and urban areas. (New Performance Indicator) Compilation This indicator applies to organizations that engage in network distribution activities. EU34. Average reconnection time for customers disconnected for non-payment. (New Performance Indicator) Explanation This indicator refers to the amount of time between payment and reconnection. EU35. Number of debt recovery actions and disconnections for non-payment per thousand customers, broken down by type of user. (New Performance Indicator)

Provision of Information

EU36. Practices to address language, cultural, low literacy and disability related barriers to accessing and using electricity services. (New Disclosure) Compilation Major areas to be covered include billing information, pricing policies, safety information, energy efficiency, complaints mechanisms, customer satisfaction, customer surveys and affordability programmes.

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There are three broad issues containing some elements of economic, social and environmental aspects that are tightly interrelated. These issues are therefore collectively presented in this section. Site Planning is an important factor for electric utilities as its operational sustainability highly depends on its locality and impacts on the local environmental & social conditions. Demand-side Management contain economic, social and environmental implications to the electric utilities themselves, the public and the local, regional and global environment. Same applies to Disaster/Emergency Planning and Response.

Disclosure on Management Approach Provide a concise disclosure on the Management Approach items outlined below with reference to the following Electric Utilities Aspects: · Demand-side Management (including residential, commercial and industrial programs) · Site Planning · Disaster/Emergency Planning and Response GOALS AND PERFORMANCE Organization-wide goals regarding performance relevant to the Electric Utilities aspects. Use organizationspecific Indicators (as needed) in addition to the GRI Performance Indicators to demonstrate the results of performance against goals. POLICY Brief, organization-wide policy (or policies) that defines the organization’s overall commitment related to the Electric Utilities Aspects listed above or state where this can be found in the public domain (e.g., web link). ORGANIZATIONAL RESPONSIBILITY The most senior position with responsibility for Electric Utilities Aspects or explain how operational responsibility is divided at the senior level for these Aspects. This differs from Disclosure 4.1, which focuses on structures at the governance level. TRAINING AND AWARENESS Procedures related to training and raising awareness in relation to those Electric Utilities aspects that are applicable. MONITORING AND FOLLOW-UP Procedures related to monitoring and corrective and preventive actions to those Electric Utilities aspects that are applicable. List of certifications for related performance or certification systems, or other approaches to auditing/verification for the reporting organization or its supply chain. ADDITIONAL CONTEXTUAL INFORMATION Additional relevant information required to understand organizational performance, such as: · · · · Key successes and shortcomings; Major organizational risks and opportunities related to issues; Major changes in the reporting period to systems or structures to improve performance; and Key strategies and procedures for implementing policies or achieving goals.
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GRI Electric Utility Sector Supplement Draft for Public Comment

Aspect Demand-Side Management

Proposals EU37. Demand-side management programmes including residential, commercial and industrial programmes. (New Disclosure) EU38. MWh saved through demand-side management programs. (New Performance Indicator) EU39. Load shedding and load shifting (MW). (New Performance Indicator) Question for Public Comment: Q8 The issue of demand side management was recognised as an important issue, but one which manifests itself very differently across different markets and it was therefore difficult to propose performance indicators which are globally applicable. Feedback is invited on whether the proposed performance indicators are measurable. The working group considered referencing existing protocols such as the International Performance Measurement and Verification Protocol as published by the Efficiency Evaluation Organization (www/ Concrete recommendations for alternative performance indicators that would be globally applicable are welcome.

Site Planning

EU40. Approaches for conducting alternatives analysis of new investments. (New Disclosure) Compilation Alternatives analysis includes the site selection process and integrated social, environmental and economic studies. Question for public comment: Q9 This topic was included to address specifically the site selection process for new utilities projects (both large and small). It was recognized that there is some overlap with other areas, in particular with regards to the social, environmental and economic impact assessment. However, the working group felt that the alternatives analysis and the initial impact assessment of alternative sites were both important, and are the areas where utilities’ performance is often weak. Feedback is invited on whether this is a sufficiently critical issue to be addressed as a separate topic. Concrete recommendations on performance indicators are also welcome.

Disaster/ Emergency Planning and Response

EU41. Contingency planning measures and disaster/emergency management plan and training programs. (New Disclosure) Compilation Report on key event risks and assumptions, and how emergency plans are tested, audited by external parties, and adhere to specific regulatory requirements, performance standards, and/or Codes of Practice (e.g., The Institute of Chemical Engineers (IChemE) and The International Network of Engineers and Scientists for Global Responsibility (INES)).

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Proposals EU42. Plans to involve the community and to deploy back-up supply and restore power. (New Disclosure)

EU43. Number of incidents of non-compliance with regard to contingency standards and inspections. (New Performance Indicator) Question for public comment: Q10 The working group felt that it would be better to measure compliance against existing, developed standards, rather than to prescribe good practice for disaster and emergency response within this Sector Supplement. However, it was also noted that the quality of regulation and enforcement in many countries in this area is poor. Feedback is welcomed on whether this is the most appropriate way to measure performance, or whether a more prescriptive performance indicator would be better. In addition, feedback is invited on which international standard, if any, should be referenced in the performance indicator.

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Annex 1. GRI Electric Utility Sector Supplement Working Group Members
Kevin Bennett, Energy Research Centre, University of Cape Town, South Africa (Chair, Non-Industry) Simeon Cheng, CLP Holdings, China (Chair, Industry)

Robert J. Barkanic, PPL Services Corporation, USA David Boys, Public Services International, France Robyn Camp, California Climate Action Registry, USA Hélène Connor, HELIO International, France Lily Donge, Calvert Asset Management, USA Laura Douglas, E.ON US, USA Elissa Freeman, Public Interest Advocacy Centre, Australia Derek C Knudsen, BC Hydro, Canada Marina Liborakina, RAO UES, Russia Dave Lucas, Eskom, South Africa Hans-Peter Meurer, RWE, Germany Raul Montenegro, Fundación para la defensa del ambiente, Argentina Koji Nagano, Central Research Institute of Electric Power Industry, Japan Hans Nooter, Nuon, The Netherlands Pierluigi Orati, Enel, The Netherlands Susie Cristina Pontarolli, Copel, Brazil Rory Sullivan, Insight Investment, UK Myriam Truchon, Hydro Québec, Canada Monali Zeya Hazra, Centre for Science and Environment, India

GRI Electric Utility Sector Supplement Draft for Public Comment

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