ESG Integration in Sub-Sovereign Debt: The US Municipal Bond Market

This report provides an overview of current muni market practices and challenges to ESG integration in investment decisions. ESG integration focuses primarily on measuring and managing ESG risks to investment performance. It is one of three approaches that investors use to incorporate ESG into their valuation process.

The report’s content is suitable for fixed income investors and credit analysts in muni bonds who have not yet started incorporating ESG factors in their investment practices or are only just beginning to formalise them. The report is based on desk-based research and draws on the experience of the members of the SSDAC.

The US muni market is one of the largest and most liquid sub-sovereign bond markets in the world. Muni bonds are unique in many ways. They are similar to sovereign bonds in that the issuer can often raise and collect taxes.^[5] However, the issuers may not be as large or as diverse as sovereigns. Moreover, some muni issuers are focused on only one sector or service, making them more comparable to corporates than sovereigns. As a result, when it comes to ESG integration, some considerations are similar to those for corporate bonds, while others resemble sovereign debt due to the public-sector nature of the issuers.

Future work will examine ESG screening, which is driven by ESG-related norms and rules; a thematic approach, reflecting a desire to achieve specific real-world outcomes; and engagement around ESG topics.

With this report, the PRI is expanding its fixed income work of recent years beyond ESG incorporation in corporate and sovereign bonds, private debt and securitised products. Anyone new to responsible investment concepts should refer to the PRI’s series of guides, An introduction to responsible investment and to the Reporting Framework glossary. The PRI’s fixed income resources can be found on its fixed income page.

At nearly US$4trn,^[6] the muni market represents about 8% of the US bond market and is one of the largest sub-sovereign markets in the world (see Figure 2).

Figure 2: US fixed income market: outstanding bonds as a percent of total (4Q 2020). Source: SIFMA

Before addressing how ESG considerations feature in this asset class, it is important to understand the muni market’s distinct characteristics.

• The market is very broad. The number of active issuers with bonds outstanding is around 36,000^[7] and the number of issues is even larger.
• Issuer types vary significantly (see Figure 3).

Figure 3: Composition of Bloomberg Barclays tax-exempt municipal indices by issuer type. Source: Bloomberg*

 

*Sectors that comprise 1.5% or less of the total are included in the “Other” category^[8]

 

• The average maturity of munis at issuance is long. In January-May 2021, the average tenor was 16.9 years (compared with 15.7 for corporate bonds) reflecting the long-term nature of many projects being financed (see Figure 4, which shows the use of proceeds of muni bonds).^[9]
  
• Most bonds offer a favourable tax treatment. Interest on nearly 90% of outstanding muni bonds is tax-exempt at the federal level, and many are also exempt from state taxes when the investor is a resident of the state where the bond was issued. Taxation considerations are important for issuers too; borrowing costs are restrained by investors’ willingness to accept a lower yield in exchange for the tax advantage.^[10]
  
• Retail investors are an important part of the buyer base. The proportion of muni securities held by households and non-profit organisations stands at about 45%, however that figure declined by nearly 10 percentage points since 2005 (see Figure 5).
• Debt servicing sources vary. Revenue bonds fund a specific project that generates a revenue stream to service the debt, such as charges on toll roads. GO bonds instead pledge the full faith and credit of the issuer. They often fund public projects that do not generate revenues and can be serviced through local taxes or other means.
• State and local governments operate under different jurisdictions. Regulatory requirements and the level of support from other entities, such as state or federal governments, can vary substantially.

Figure 4: US muni bond issuance by use of proceeds(Jan-May 2021). Sources: Refinitiv, SIFMA Research

 

Figure 5: Holders of muni bonds by type (4Q 2020). Sources: SIFMA, Federal Reserve*

* The Federal Reserve classifies “households and non-profit organisations” as including domestic hedge funds, private equity funds and personal trusts. However, at least recently, the proportion of munis held by non-profits and domestic hedge funds appears to be minimal. “Funds” include mutual funds, money market funds, closed-end funds and exchange traded funds. The category ‘Other’ includes holdings by a variety of institutions including state and local governments and non-US residents.

Many ESG factors have traditionally been viewed as inherent in, and integrated into, muni risk assessment, similar to other fixed income instruments. It is only recently that institutional investors have started to frame muni ESG risks in a more formal fashion.

The diversity and complexity of the market highlighted in the “Overview of US muni market” section partly explains why it has taken longer than in other fixed income sub-asset classes for muni bond market participants to frame ESG considerations in investment decisions. Issuers reflect the wide geographical diversity of the US, implying that environmental and social risks also vary significantly.

Furthermore, although riskier than Treasury bonds, muni credit quality is generally better than corporate bonds: the average credit quality of the Bloomberg Barclays US Municipal Bond Index is Aa2/Aa3, while the average credit quality of the Bloomberg Barclays US Corporate Bond Index is A3/Baa1. This perceived safer-asset status and higher yields than Treasuries may have contributed to delays in taking a more holistic approach to risk assessment, amid low interest rates and low inflation.

Finally, municipalities may receive state or federal support beyond that offered to corporates to mitigate environmental and social risks. This support may vary: for example, the response to the coronavirus pandemic^[11] was more generous than after the 2009 recession. And, while such support is not guaranteed, it may diminish the credit risk of muni bonds.

As a result, identifying the materiality of ESG factors in the muni market has historically attracted less interest compared with other fixed income asset classes. ESG factors are considered material if they affect the bond’s initial pricing, its performance or credit quality (i.e. the issuer’s willingness or ability to service and repay debt). However, other factors generally play a greater role in price and yield in the muni market, such as interest rates, inflation and tax status.

The muni bond market can resemble corporates, sovereigns or neither when considering ESG factors, as shown in Figure 6.

 

Figure 6: ESG considerations: similarities and differences across different types of issuers

	Corporate*	US muni**	Sovereign
Issuer structural features that may offset or reduce an ESG risk
Taxation authority to service debt	No	Depends on security; general obligation bonds are typically full faith and credit, which can include taxing power	Yes
Monopoly over selected products or services	Occasionally	Often	Often
Debt monetisation***	No	Deficit financing is rare due to balanced budget requirements	Yes
External support	Potentially from a parent company or government subsidies	Borrowers may have access to other state or federal support, depending on the jurisdiction	No, aside from bilateral or multilateral debt relief
Diversity of economic activity as a risk mitigant	Depends on size, product offering, breadth of revenue streams	Depends on issuer economic characteristics, breadth of revenue and purpose of financing	Depends on issuer economic diversification and taxable base
Managing ESG issues
Availability of ESG data	Disclosed by issuers Available through CRAs and third parties Peer comparison difficult	Disclosed by public sources and issuers (often upon request) Available through CRAs and third parties Data can be patchy	Disclosed by public sources and issuers (often upon request) Available through CRAs and third parties Data can be stale
Investors screening issuers for ESG reasons	Yes	Sometimes	Rarely
Degree of investor engagement with issuer	Less common than for shareholders	Less common than for corporate bondholders and more challenging	Less common than for corporate bondholders and more challenging
Able to move geographic location	Yes	No****	No
Social stakeholders	Employees, customers, supply chain	Local population, taxpayers, employees and the service base	National population, taxpayers
Governing body	Appointed	Depends on sector as to whether elected or appointed	May be elected

*Corporate excludes quasi-governmental organisations, which have the legal characteristics of both governmental and private entities.

**US muni issuers as per the classification of Figure 1.

***Debt monetisation is also known as monetary financing and is colloquially referred to as printing money by a central bank to allow a sovereign to finance its deficit or repay its debt.

****General obligation issuers typically cannot move. In rare cases revenue bond issuers may be able to relocate within their service area.

However, whilst investors have been slow to adopt a formal ESG incorporation approach to date, new factors have come into play that are changing the landscape:

• There is evidence that retail and institutional investors want to be more informed about ESG investing options.^[12]
  
• Asset management firms are working to demonstrate ESG incorporation across all asset classes in a standardised fashion, driven by commercial pressures from clients and beneficiaries.
• CRAs have sharpened their focus on ESG factors.^[13]
  
• Foreign investors have been increasingly interested in the taxable segment of the muni market. European investors – who are relatively more advanced in ESG incorporation practices – are part of this trend.^[14]
  

Discussions with the SSDAC highlighted that muni bond investors remain focused on downside risks, similar to all fixed income investors. To that end, governance has always been closely scrutinised and remains particularly relevant. However, the emphasis on environmental and social risk factors is increasing.

Muni issuers’ revenue streams are often concentrated geographically and economically. This can intensify the local effect of any one environmental or social factor, especially in the US, which has a very diverse physical and social morphology. In fact, although the debate around climate change and social issues tends to focus on variations between countries, differences within countries apply too.

For state and local governments, ESG risks may encompass the whole local population, rather than just a narrower group of customers and employees, as in the case of corporate issuers. This local dependency means that ESG factors could affect a muni issuer’s capacity to service its debt, for example if the taxable base is affected or public spending increases. That said, state and local governments may have greater leverage to respond to these risks through policy intervention. Therefore, the quality of governance can be even more relevant to the materiality of environmental and social risks, as it can affect how these risks are managed or mitigated.

The remainder of this chapter focuses on risks within each ESG category. It is important to remember that ESG factors can also be drivers of positive change, for example if a community benefits from clean energy, resilient infrastructure or initiatives aimed at conservation, education or healthcare. Furthermore, the same risk could fall under more than one of the three ESG categories (for instance, cybersecurity could be labelled as a social as well as a governance factor).

The sections below contain six real-world examples that highlight how ESG factors can affect specific issuers, including related credit rating agency opinions. The categorisation of each event as E, S or G was done by the PRI and all relevant sources are in footnotes.

Environmental factors

Market participants and regulators have increasingly focused on climate change risks in recent years, particularly risks linked to physical exposure or related to the transition required to mitigate physical risks. Both of these risk types may also materialise in parallel, compounding the challenge.^[15] Municipalities offer and manage a broad range of services – such as sanitary sewage, waste collection, water supply and land use planning – which are inherently linked to biodiversity risks.

Physical climate risk

Physical climate risk can affect state and local governments on multiple fronts (see Figure 7). In turn, the consequences of climate change may affect issuers’ ability to generate revenues if, for example, property and land valuations decline and businesses relocate. Issuers may also need to increase expenditures to cover repairs, infrastructure adaptation, compensation, subsidies or higher costs of services.

Figure 7: Effects of physical risks and financial implications for muni bond issuers

Weather-related events are becoming more frequent and expensive: the US has sustained 291 weather and climate disasters since 1980, with total costs exceeding US$1.9trn (inflation-adjusted).^[16] And the frequency of these extreme weather events is increasing: a 30-year average of 7.1 events per year soared to 16.2 events per year during 2016-2020, hitting 22 in 2020 alone, a new record (see Figure 8). All 50 states had at least one billion-dollar disaster over the last 30 years, with Texas the most hit by far.

Figure 8: US Billion-dollar weather and climate disasters (2020).* Source NOAA

*Note: the chart refers to 2020 alone.

The ramifications of climate change risks are also complex: the direct effects can be local, but they can have knock-on impacts across states, cities and sectors where socioeconomic systems are connected. For example, changes in weather patterns associated with higher temperatures and droughts or extreme precipitation can have a significant impact on livestock or on crop yields for corn, wheat, soybeans, and cotton. While this could directly affect the Midwest, it could also have repercussions for food prices nationwide and in export markets.

Extreme weather events create disruption, increased costs, asset depreciation and can be deadly. For example, flooding during Super Storm Sandy caused prices to fall by 5%-7% for minimally inundated properties and by 8%-13% for properties with average inundation; non-flooded properties included in new floodplain maps experienced an 18% drop in prices.^[17]

The largest costs stem from tropical cyclones, followed by severe storms and drought (see Figure 9).

Figure 9: US billion-dollar natural disasters by type (CPI-adjusted).* Sources: PRI based on NOAA data

*For an event to be included for the purposes of determining both the number and cost of events, the CPI-adjusted damages or costs (rather than the actual figure) must be at least US$1bn.

Despite the increased severity of these events, they have had a limited effect on issuers’ credit ratings, as noted in a recent S&P Global Ratings report. For the period of 2017-2018, the CRA identified ESG factors as drivers for only 34% of 3,315 US public finance rating actions: within that subgroup, governance was the most dominant factor affecting credit ratings (67%), followed by social (26%) with environmental trailing at a mere 5%.^[18]

Mitigating factors include:

• the issuer’s preparedness to address physical climate risk
• the strength of the issuer’s financial position
• the resilience of its infrastructure^[19]
• increased production and economic activity associated with rebuilding
• the level of state or federal aid, for example through the Federal Emergency Management Agency (FEMA)
  
• the degree of insurance policy coverage

 

For the case studies in this section, PRI assigned a category as follows:

• Environmental
• Social
• Governance

 

The resilience of muni bonds to natural disaster may not continue, however:

• Climate change risks are expected to increase over time. Science-based models indicate that further global warming will continue to increase the severity and frequency of acute climate events and intensify climate hazards.^[22]
  
• Disaster aid through FEMA could become more limited going forward, either because the frequency and magnitude of events increases or because FEMA reduces support to incentivise local governments to be less complacent and adapt to climate change faster.^[23]
  
• Finally, risk recognition ahead of the manifestation of physical events could bring forward changes in asset valuations, insurance coverage and capital allocation. For example, although evidence is still mixed, some studies point to price drops for coastal properties. This could be due either to exposure to sea level rise or to the perception that this risk may materialise.^[24]
  

Transition risk

Transition risks arise from measures taken to mitigate the impact of climate change or from policy responses to climate change. A recent study outlining five different technological pathways to achieve the target of net-zero emissions by 2050, in line with the renewed commitment by the US to the Paris Agreement, highlighted profound changes to local landscapes, industries and communities in the next few years.^[25]

Many of these changes will require upfront investment, with the same study estimating at least US$2.5trn of additional capital spending towards energy supply, industry, building and vehicles by 2030. As the ultimate guardians of land-use planning and public investment, as well as the first responder to climate-related events, local governments, counties and municipalities are responsible for the planning and implementation of adaptation practices.^[26]

Changes to policy and spending priorities will have repercussions for sectoral economic activities and for state and local governments’ budgets, especially for those reliant on economic activities that are vulnerable to transition risks, such as in the utility sector.

Issuer: Gallia County, Ohio[27]

Event

The biggest taxpayers in Gallia County, located in southeast Ohio, are coal-fired power plants, accounting for more than one-third of the county’s property tax base in tax year 2019. Gallia’s median household income is 71% of the national average and the employment rate is 53%,versus 63% nationwide. Doubts over the future of coal in the US raise questions about how communities reliant on the coal industry will adapt.

Credit implication

The transition to a low carbon economy may ultimately affect Gallia’s credit quality. Coal plant closures could have a detrimental impact on the county’s finances through loss of tax revenues as well as loss of local employment, and S&P has said that this could lead to lower credit ratings.The ratings agency has pointed out that the county is home to a heavy concentration of the natural resources and mining industries.

 

Ultimately, differing regulations across states and local governments, as well as the degree of federal funding for technical support and guidance, will affect the relevance of transition risks for muni investors. The choices public policymakers face could shape, or be influenced by, local production, prices and demand preference and will depend on technology options and costs.

Policymakers’ responses will also depend on the challenges for specific locations, industries and communities; population density; public acceptance; and potential co-benefits of remedial action (for example, the positive impact on health as air pollutants are reduced). These factors illustrate the intertwining of environmental factors with social issues and governance.

Social factors

Muni issuers fund a wide range of essential services with inherent social implications, such as education, healthcare and water supply for local communities. The composition and the characteristics of the local population can impact the level of spending required for these services and the revenues available to repay debt, whether through general taxes or project-specific income.

Many material social factors are similar to the ones that sovereign bondholders consider, such as demographic trends, if they apply to the whole population of a state, city or local government.^[28] In contrast, if the issuer is, for example, a hospital or museum, then the social factors apply to a narrower portion of the population. In these instances, social factors are more similar to those considered by corporate bondholders when focusing, for example, on retail customers or company employee metrics.

Below are examples of useful social indicators:

Demographic characteristics

Population trends, such those relating to wealth, income and age, affect muni issuers’ current and future budgets.

With respect to revenues:

• The higher the proportion of the population in employment, the higher the income tax revenue for issuers that collect this tax.
• A wealthier population generates more tax revenues through income tax or indirect taxes, such as sales or property taxes.^[29]

With respect to costs:

• A higher proportion of retired public workers is likely to increase pension expenditures. Across state and local governments, defined benefit schemes remain preponderant (in 2018, 94% of state and local employees had access to such a plan); the ratio of active workers to current retirees varies greatly across states and many plans are underfunded.^[30]
• Spending on welfare and health is likely to depend on demographics and the population income. The most recent data, from 2017, shows 35% of public welfare expenditure and 89% of health and hospital spending was funded at the state and local government level, rather than the federal level.^[31]

From a pure ESG integration perspective, social risks can vary depending on the social and economic features of different communities. However, an outcome-based or thematic approach may seek to address problems, rather than measuring only the risk premium associated with a muni bond investment.

 

Figure 10: Poverty rate by county. Source: US Census Bureau, 2015-2019 American Community Survey 5-Year Estimates

Estimated % below poverty level (of population for whom poverty status is determined)

0	30	60

Social justice and equality

• Declining trust in governing institutions among groups can pose a risk to credit, for example if it contributes to social unrest that can damage an issuer’s financial position.^[32]
• At the same time, poor oversight by state and local governments of issues affecting minority and disadvantaged cohorts can prevent an equitable provision of services and perhaps hinder local economic growth.^[33]

 

Issuer: Minneapolis, Minnesota[34]

Event

After George Floyd was killed by a police officer on 25 May2020 in Minneapolis, Minnesota, the city became the site ofunrest, with protests against racial inequality and calls forpolice reform. More than 1,500 businesses were damaged ordestroyed in the wider urban area in the weeks following thedeath. Debate in the wake of the incident raised questionsabout police funding.

Credit implication

S&P changed the outlook from stable to negative for thecity’s general obligation debt in September 2020, attributedin part to the fallout from Floyd’s death. The ratings agencypointed to potential costs related to reform of policing,potential liabilities from lawsuits related to his death, andincreased worker compensation claims related to the unrest.It also said that it could revisit its assessment of the city’sgovernance risk “if its approach to police reform perpetuatesconditions that could lead to greater social unrest”. In March, Minneapolis agreed to pay a US$27m settlementto Floyd’s family, some of which came from its general fund.Beyond this immediate cost, questions remain over howcities like Minneapolis reform and fund policing servicesand deal with discontent. In 2021, the city’s police budgetfell by US$28m, or 15%, compared with a general budgetcut of 7% across city departments. While this appears tobe a significant slash to policing services, additional fundsare available to the police chief, with city council approval,and resources have also been re-allocated to alternatives topolicing.

Employee issues

• A working environment where employees perform well (with low turnover, good training, health benefits and safe working conditions) may benefit an issuer’s financial performance and its reputation.
• Public sector bodies tend to have a more unionised workforce, meaning employees have more leverage to negotiate and address grievances with employers. Employees also have a greater ability to disrupt the issuer’s activities and financials in the event of a dispute.^[35]

Issuer: University of Southern California[36]

Event

The University of Southern California, based in Los Angelesand the largest private university in California, has agreedto pay more than US$1bn to women treated by its formergynecologist in relation to sexual harassment and abuseclaims. Some US$852m of this was announced in March2021, in what news organisation NPR called “the biggest sexabuse pay-out in higher education history.”

Credit implication

Moody’s changed USC’s outlook from stable to negativein March 2021 as a result of financial exposure to the legalissues. It also said this could lead to reputational harm, whichcould perhaps reduce student demand or philanthropicsupport. However, the ratings agency said in March that thisdemand and support had remained robust so far.

Governance factors

State and local governments’ responsibilities touch on many aspects of risks associated with governance. For instance, managing local resources and service provisions (operations and maintenance, the handling of competitive procurements); finance (raising revenues, including through taxation, managing expenditures and accessing grants, credit and private funding); and planning (prioritising investments, devising strategies through forecasts, monitoring and evaluation processes).

Issuer: San Francisco Community College District[37]

Event

San Francisco Community College District serves thecounty from which it takes its name and covers the CityCollege of San Francisco. In September 2020, the Accrediting Commission forCommunity and Junior Colleges (ACCJC) said the collegewas subject to “enhanced monitoring” as a result ofweak financial performance. There have been concernsabout the district’s deficit and its fiscal audit for 2019-20recorded “material weakness” in financial conditions.In addition, the district has endured high managementturnover, with multiple chancellors or interim chancellorssince 2012. California’s Fiscal Crisis and Management Assistance Team(FCMAT) warned in April 2021 that the college “must actquickly if it wants to continue operating independently inthe California community college system”. The followingmonth, staff accepted pay cuts, although this was notthought to have resolved the entity’s financial problems.

Credit implication

In November 2020, Fitch Ratings said that continueddependency on deficit spending or loss of accreditationcould bring about negative rating action or a downgradefor the district. It warned that losing accreditation couldlead to closure of the district.

 

The list of governance indicators is long and many feature regularly in traditional muni credit analysis. Some are more backward-looking and track records and good practice. Others are more forward looking and aim at assessing issuer risk awareness and mitigation plans, if any. Importantly, they can be a mix of qualitative and quantitative indicators.

Identifying measures to assess governance risks varies depending on the sector in which a muni issuer operates and on whether the governing body is appointed (as with corporates) or elected (as in democratic countries). However, some of the World Bank worldwide governance indicators provide a good starting point (see Figure 11).

Figure 11: Selected governance aspects assessed by muni bond investors

Governance dimension	Governance area to assess
Voice and accountability	Accountability of officials and communication[38]
	Reliability of budget and accounts (completeness, timeliness, credibility, audit)
	Sophistication of management and formalisation of management practices
	Level of oversight by other governing bodies
	Controversies surrounding management, including ethical concerns
	Transparency in public procurements
Government effectiveness	Quality of infrastructure (roads, ports, airports, railways)
	Preparedness to deal with emergencies
	Cybersecurity policies
	Exposure to significant political in-fighting or impasse
	Management of pension and retiree healthcare liabilities

Of the items listed above, cybersecurity is perceived by investors as a growing risk to muni issuers, as it could lead to financial and reputational losses in the absence of adequate firewalls and skills to prevent potential attacks.^[39]

When assessing ESG factors, portfolio managers and research analysts use a variety of sources, including:

• issuer financial statements
• offering documents
• credit rating agency reports
• the Electronic Municipal Market Access website (EMMA), including issuer disclosure related to financial audits
• data on the local economy^[40]

Additional information sources that can be particularly useful for ESG information include the US Census Bureau and the College Navigator website. An issuer’s website may include useful information on ESG policies and practices. More resources are listed in the Appendix. These can be complemented by media reports.

Challenges to data collection remain, however, and some are more acute than others depending on the ESG category (see Figure 12 and Figure 13).

Figure 12: ESG data challenges when assessing muni bonds

Consistency	Despite progress by some, issuers do not disclose data consistently. At times, the information is either too granular or not sufficiently so. Few voluntarily provide ESG information beyond what is mandated.
Dissemination	ESG information coming from both issuers and other sources is not disseminated effectively. For example, in the case of EMMA, the data is displayed issuer by issuer, making comparisons time consuming.
Variety	The different sectors in the muni market make it more difficult to focus on universal ESG metrics that are relevant for all muni issuers.
Geographical boundaries	Datasets may not be presented in geographical boundaries that coincide with those of issuers.
Resources	Smaller muni issuers may find it harder to devote resources towards adequate disclosure.[41]
Third-party information providers	The coverage and the offering of new products by ESG data and service providers is broadening to the muni market but can be expensive at present.

Figure 13: Magnitude of data challenges by ESG category

 

Access to better data to enhance ESG incorporation ranks high on investors’ priority list. Ideally, market participants could access a centralised comprehensive hub providing free or cheap ESG data for munis, similar to the World Bank ESG data portal for sovereign data. However, at present there is no broad issuer buy-in to sharing ESG data and insufficient disclosure of such data in a user-friendly way. Furthermore, it would be a challenge to find a hosting organisation for such a large endeavour.

In the short term, a good starting point would be increased use of the Carbon Disclosure Project (CDP), which operates a global portal with city data (see box), or the LEED for Cities and Communities,^[42] which requires disclosure of social, economic and environmental performance indicators for certification purposes. Investors and issuers could also explore new alternative sources of information such as satellite data, which can help show the effect of, for example, wildfires and other natural disasters on local economies.^[43]

 

 

Importantly, state and local government associations, such as the National Association of Counties, the National League of Cities, the Conference of Mayors or the Government Finance Officers Association (GFOA), should encourage their members to disclose more information that is useful for investment decisions.

And, in turn, wider availability of data could prompt more investors to adopt ESG incorporation approaches.

Figure 14 contains a more detailed list of investor asks for issuers, based on discussions with the SSDAC.

Figure 14: What investors would like from issuers

*See GFOA Best Practices ESG Disclosure and (June 2020) ESG Considerations for Governmental Issuers.

It is important to note that, similar to companies, muni issuers have to disclose material information so that investors can make informed assessments.

Under US Securities and Exchange Commission (SEC) rules, materiality is broad and encompasses non-numerical information.^[45]

 

Benefits of improved discosure for issuers

Issuers may currently view data reporting and the need to discuss it with investors as a burden, but they should recognise the multiple benefits that the process can bring, including:^[46]

• Identifying support and financing opportunities to advance issuers’ broader sustainability objectives. In particular, disclosure projects may encourage issuers to network and explore best practices.
• Tapping into increasing demand for thematic investments with positive real-world outcomes.
• Appreciating that transparency can provide a more accurate profile of the issuer, thus avoiding investors relying on assumptions, especially when it comes to assessing mitigating factors or future plans that are difficult to understand without the issuer’s input.
• Improving their own understanding and management of ESG risks, particularly if new technology and data is employed.
• Broadening ESG consideration to their own assets/pension investments.^[47]

Smaller issuers can find reporting even more challenging because they have limited resources. However, they may not need to duplicate disclosure that is available at the sector level or published by larger administrations.

Next steps

This report is the first that the PRI has published to enhance ESG consideration in the muni market.

The PRI hopes that, together with future work on screening and thematic approaches and investor engagement, the report will encourage investors, underwriters and muni issuers themselves to better incorporate ESG factors in this market segment.

Investors should review the ESG factors and the data sources in this report to evaluate new qualitative or quantitative information to incorporate into their risk assessments. It is also important that they consider how they can contribute to sustainability goals through strategic asset allocation, especially related to key sectors that muni bonds fund, such as education, health, transport and infrastructure.

Issuers should make information accessible and improve disclosure via existing platforms. They should view data dissemination as a way to raise transparency and good governance standards, thus enhancing their risk profile.

If anything, the drivers behind ESG transparency are rapidly increasing:

• Climate change features among the top four priorities of the current US administration, alongside the COVID-19 pandemic, the related economic downturn and racial justice.^[48]
• Regulatory bodies are focusing more on ESG factors to enhance disclosure or better assess implications for the financial system.^[49]
• Foreign investor purchases of muni may increase further if federal policy encourages greater taxable issuance through a new Build America Bonds programme.^[50] This increase may come with requests for more ESG clarifications from investors located in jurisdictions where ESG regulation or responsible investment practices are more advanced.

In the months ahead, the PRI intends to:

• Gather case studies illustrating best practices among muni investors.
• Broaden the investor dialogue with issuers, credit rating agencies and ESG information providers, along the lines of a similar PRI programme in the corporate market.
• Explore the extent to which the findings in this report apply to countries outside the US.

Appendix

Useful ESG resources
Bureau of Economic Analysis	Economic data at state and local levels
Bureau of Labor Statistics	Employment data
CDP	Corporate and governmental body ESG data
Climate Central	Sea level rise programme provides data on coastal threats in the US and globally, e.g. the vulnerability of affordable housing in the US to sea level rise and coastal flooding
Energy Information Administration	Energy data and analysis
Flood Factor	Property flood risk across the US
National Center for Education Statistics	Educational institutions data
NOAA (National Oceanic and Atmospheric Administration)	Weather and climate data
SeaLevelRise.org	Sea level rise data, by state
US Census Bureau	Population data
US EPA (Environmental Protection Agency) Watershed Index Online (WSIO)	Watershed data
US Forest Service	US forests and grasslands data
WRI (World Resources Institute) Aqueduct	Maps of water-related risks
Zillow Housing Data	House price data