Kinder Morgan Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Kinder Morgan provides a solid amount of detail on its climate-policy lobbying. It identifies several concrete policy arenas it engages on, including incentives for carbon capture, utilisation and storage in the Inflation Reduction Act of 2022, the Texas Railroad Commission’s application to the EPA for primacy over Class VI CO₂-injection wells, and congressional proposals for a fee on methane emissions, thereby giving readers a clear sense of the specific measures it has sought to influence. The company also describes multiple, clearly identifiable lobbying channels and targets: it has “testif[ied] before U.S. House subcommittees,” “submitted comments to the U.S. Treasury Department,” held direct meetings with Texas state representatives during “Texas Energy Day,” and worked with the “Texas Railroad Commission,” as well as coordinating through trade associations such as INGAA and the American Gas Association. Finally, Kinder Morgan discloses the outcomes it is seeking, such as securing “reasonable incentives for CCUS and renewable natural gas tax credits” in the IRA, supporting the Railroad Commission’s bid for Class VI well-permitting primacy to speed CCUS deployment, and urging the EPA to refine its eRIN proposal and increase renewable volume obligations. Although quantitative targets are sparse, the company consistently states the legislative or regulatory changes it supports or wishes to adjust, demonstrating a high level of transparency on its lobbying objectives and approach.	3

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Kinder Morgan appears to have a strong governance framework for its climate-related lobbying, establishing clear oversight mechanisms and processes to align both its direct advocacy and trade association activities with its ESG objectives. Its Board’s EHS Committee receives “periodic reports by our COO” on trade association participation, and the company states that “Our CEO, President or General Counsel signs-off on and oversees any contributions made toward ballot measures, lobbying, or lobbying groups,” ensuring executive-level accountability. Each year, the company “reviewed the alignment between us and trade associations to whom we paid annual dues greater than $25,000, where a portion of those dues went to lobbying,” examining “each association’s current policy statements, climate-related political lobbying efforts, and other publicly available information to determine their alignment with our ESG strategy.” This review is further validated through input from its ESG Disclosure Committee, which “consists of our: CEO, President, COO, CFO, CAO, General Counsel, Corporate Secretary, Treasurer, business segment presidents, and other corporate officers.” Kinder Morgan also engages directly with policymakers on issues such as “methane regulation, cybersecurity policies, and corporate taxation” and advocates for incentives for “CCUS, RNG, renewable diesel, and hydrogen,” while preferring that trade associations “take positions … that are consistent with our own.” However, we found no evidence of a standalone public audit or third-party assessment expressly evaluating its climate-lobbying alignment, and the company does not disclose a public commitment to align its engagement activities with the Paris Agreement, noting “No, and we do not plan to have one in the next two years.”	3