Projected vs Actual Carbon Emissions, CEMS, and ESG Integrity in Malaysia - 2023-2025

 

1. Core Principle: Intent Is Not Impact

Projected carbon emission data represents strategic intent, not actual environmental performance. While projections are a legitimate component of ESG planning and transition pathways, they are inherently dependent on assumptions, modelling choices, and future actions. They do not constitute empirical evidence.

Actual ESG credibility rests on measured, verifiable, and repeatable emissions data.

In Malaysia, this distinction is especially clear due to the mandatory requirement for Continuous Emission Monitoring Systems (CEMS) in selected industries. CEMS involves physical devices installed at emission stacks or chimneys, generating continuous, real-time, tamper-resistant emissions data, accessible simultaneously by regulators and operators. This data reflects what is actually emitted, not what is expected or promised.

Where such measured data exists, ESG disclosures that elevate projections to the level of performance risk substituting aspiration for accountability.

2. Mapping to GHG Protocol and ISO 14064

a) GHG Protocol (Corporate Accounting and Reporting Standard)

Relevant principles and requirements:

• Relevance and Faithful Representation Emissions data must reflect the entity’s actual GHG profile, not hypothetical future states.

• Accuracy Material errors must be reduced as far as practicable. Continuous measurement (e.g. CEMS) clearly ranks higher than estimates or generic emission factors.

• Consistency & Transparency Changes in methodology and use of projections must be clearly disclosed and distinguished from historical data.

Critical alignment point: GHG Protocol allows estimation where direct measurement is not feasible. However, where direct measurement exists (such as CEMS), reliance on projections without reconciliation violates the spirit of faithful representation, even if not explicitly prohibited.

b) ISO 14064-1 (Organisation-Level Quantification and Reporting)

Key clauses:

• Clause 5 – GHG Quantification Requires identification and quantification of GHG emissions using methodologies that ensure accuracy and completeness.

• Clause 6 – GHG Reporting Requires transparent disclosure of:

• Clause 7 – Verification (where applied) Emphasises traceability and auditability of emissions data.

Critical alignment point: Where CEMS data exists:

• It qualifies as primary data

• It has higher verifiability and traceability than modelled projections Presenting projected reductions without explicit linkage to measured CEMS baselines weakens ISO 14064 conformity, even if verification is voluntary.

3. "Stock Exchange Centre" : ESG Disclosure: Structural Weakness

The "Stock Exchange Centre"’s sustainability reporting framework emphasises:

• Transparency

• Comparability

• Decision-useful information

However, current disclosure practices reveal three structural gaps:

1. No mandatory hierarchy of data quality Companies may disclose projections alongside actual data without clearly prioritising measured emissions.

2. No explicit requirement to reconcile ESG emissions data with regulated CEMS data ESG disclosures and environmental compliance reporting operate in parallel, not in integration.

3. Limited enforcement differentiation between “targets”, “estimates”, and “measured performance” This allows projections to visually dominate ESG narratives.

As a result, investors may unknowingly rely on forward-looking claims while actual emissions trends already measured by regulators remain under-emphasised.

4. Malaysia-Specific Enforcement and Disclosure Gaps

Despite strong technical regulation, several gaps persist:

• Regulatory–ESG Disconnect Enforcement compliance; ESG reporting is largely self-curated. There is no systematic requirement to embed CEMS datasets into sustainability reports.

• Disclosure Selectivity Exceedances, fluctuations, or non-improving trends in CEMS data are rarely reflected proportionately in ESG disclosures.

• Verification Asymmetry Environmental compliance data is regulator-verified, while ESG emissions narratives often rely on internal modelling with limited external assurance.

This creates a paradox:

The most reliable emissions data in Malaysia is often the least visible in ESG communication.

5. Case-Based Examples (Anonymised)

Case Example 1: Energy-Intensive Facility

A large industrial facility publicly reports a “planned 35% carbon reduction by 2030” based on:

• Anticipated fuel switching

• Efficiency upgrades

• Renewable offsets

However:

• Five years of CEMS data show flat or marginally increasing stack emissions

• ESG disclosures summarise emissions using annualised estimates

• No reconciliation is provided between CEMS trends and projected reductions

Outcome: Projections dominate perception, while measured emissions tell a different story. This is not non-compliance, but it is misleading ESG framing.

Case Example 2: Multi-Plant Operator

A company operates several regulated facilities, each with CEMS installed. In ESG disclosures:

• Emissions are aggregated at group level

• Year-to-year reductions are attributed to “operational optimisation”

• Individual plant-level CEMS variability is not disclosed

Outcome: Aggregation obscures site-specific performance, diluting accountability and masking underperforming assets.

REMEMBER

Where measured, regulator-observable emissions data exists, ESG reporting that relies primarily on projected reductions without explicit reconciliation crosses the line from strategic communication into structural greenwashing.

This is not about malicious intent. It is about data hierarchy discipline.

Measured emissions data such as mandated CEMS must form the foundation of ESG environmental disclosures. Projections should support strategy, not replace evidence. Without this hierarchy, ESG risks becoming a language of reassurance rather than a mechanism for climate accountability.

Here's a summary :

Below I integrate sample data, calculations, and interpretation so it aligns cleanly with:

• GHG Protocol

• ISO 14064

• CEMS reality

• "Stock Exchange Centre's" ESG disclosures

• Your climate-change article narrative

Everything below is illustrative but technically realistic.

1. Sample Data Set (Illustrative, Anonymised)

Scenario: An energy-intensive industrial facility in Malaysia with mandated CEMS.

Annual CO₂ Emissions (tonnes)

Key observation:

• CEMS data shows flat to slightly increasing emissions

• ESG projections show a smooth, continuous decline

This divergence is the core greenwashing risk.

2. Sample Calculation (GHG Protocol / ISO 14064–Aligned)

A. Actual Emissions (CEMS-based)

Typical CEMS calculation logic:

Example (simplified):

• Average CO₂ concentration = 9.5%

• Flue gas flow = 120,000 Nm³/hr

• Operating hours = 8,000 hr/year

• Conversion factor applied per ISO / Environmental method

Result: ~532,000 tonnes CO₂ (2024) This value is:

• Site-specific

• Continuous

• Regulator-observable

• Verifiable

B. ESG Projected Reduction (Model-Based)

Typical ESG projection logic:

Baseline (2020):

Assumptions:

• 2% efficiency improvement per year

• 10% fuel switching by 2023

• No production increase

Projected 2024:

Critical issue: These reductions are assumed, not measured.

3. Graph Interpretation (What the Chart Shows)

The chart you see illustrates:

• Upper line: Measured emissions from CEMS → Reflects real operations, production variability, and combustion reality

• Lower line: ESG projected emissions → Reflects modelling assumptions, not operational truth

Why this matters:

• ESG readers may intuitively trust the downward trend

• Actual emissions reality moves in the opposite direction

• Without reconciliation, the projection becomes implied performance

4. Standards-Based Analysis

GHG Protocol

Allows estimation only where direct measurement is not feasible BUT Does not support replacing measured data with projections

Issue shown by data: Measured Scope 1 emissions exist (CEMS), yet projections dominate disclosure → breach of faithful representation principle

ISO 14064-1

Relevant failures illustrated:

• Clause 6.4 – Transparency of data sources

• Clause 6.5 – Disclosure of assumptions and uncertainties

If ESG reports show only the projected line:

• Primary data (CEMS) is suppressed

• Secondary data (models) is elevated = Methodological imbalance

5. "Stock Exchange Centre's" ESG Disclosure Implication

From an investor’s perspective:

• ESG report suggests ~19% reduction (520k → 420k)

• Actual regulated data shows ~2% increase (520k → 532k)

This creates:

• Mispricing of transition risk

• False confidence in decarbonisation progress

• Reputational exposure once discrepancies surface

6. Case-Based Critique (Without Naming Companies)

Case Pattern Observed in Malaysia

“Companies comply with using CEMS, but communicate ESG using projections.”

This results in:

• Compliance data staying with regulators

• Optimistic narratives going to investors

• Two parallel truths, never reconciled

This is structural greenwashing, not necessarily intentional deception.

7. How This Should Be Reported (Correct Practice)

A compliant ESG disclosure would show:

1. Measured CEMS emissions (primary line)

2. Projected pathway (dashed or secondary line)

3. Explicit reconciliation statement, e.g.:

“Despite projected reductions, actual emissions have remained flat due to increased throughput and operational constraints. Transition measures have not yet translated into measurable reductions.”

That single paragraph restores ESG credibility.

SO

When real-time, regulator-observed CEMS data shows rising or stagnant emissions, ESG projections of decline, if presented without reconciliation do not represent transition progress, but narrative optimisation.

Memory, Policy Shifts and the Passage of a Changing Nation.

While backing up files from an old laptop, I unexpectedly came across a scanned copy of my classic birth certificate dated September 1966, interestingly the same month and year Ultraman and Star Trek first appeared. Reading through it again, I noticed several details that I had rarely paid attention to before.

A few things stood out:

Time of birth - The recorded time of my birth is now effectively 30 minutes later due to the national streamlining of time implemented in January 1982, one of those quiet administrative changes that subtly rewrote personal history.

Place of birth - My birthplace was listed as Jalan Pasir Puteh. For clarity, this refers to the old Jalan Machang–Pasir Puteh, not the modern alignment. When I last travelled the route in 2023 while tracing historical data, parts of the old road still surfaced through places like Bukit Tiu, Badak Mati, Telosan, Cengal Pulas, Jeram, Wakaf Tukup, Saring, and Limbungan, fragments of a journey that time hasn’t entirely erased.

Vaccination fine - The document also mentioned a hefty RM1,000 fine related to pox vaccination an enormous sum in 1966 (roughly equivalent to nearly RM10,000 today). (Ironically, I still contracted chicken pox later in life, and tragically, my elder brother passed away at a young age due to the same illness) Today, the chicken pox vaccine is no longer mandatory, only optional under the National Immunisation Programme, another sign of how policies evolve with time and experience.

Early school registration - I was registered in 1971 with Sekolah Rendah Jenis Kebangsaan (Inggeris) Sultan Ismail 2. By the time I entered Standard One in 1973, the education system was already transitioning from English-medium to Malay-medium instruction. Over time, the “Jenis” (type) classification disappeared altogether. That time, the school remained widely known as SIPS 2 (Sultan Ismail Primary School 2) for many years, once sharing grounds with Islah, before eventually relocating to Jalan Long Yunus as Sekolah Rendah Kebangsaan Sultan Ismail 2.

A simple rediscovery, yet it quietly stitched together personal memory, policy shifts, and the passage of a changing nation.

(Had to omit certain details)

BEREHAT SEBENTAR DARI MEDIA SOSIAL JIKA INI BERLAKU PADA ANDA

Hidup di alam media sosial penuh dengan cabaran. Ia sarat dengan kata-kata semangat, nasihat, ilmu dan perkongsian yang baik, namun dalam diam, ia juga menguji jiwa.

1) Kita mula merasakan posting orang lain seolah-olah menyindir atau memperli diri kita,

2) Timbul keinginan untuk bersaing dengan posting orang lain

3) Hati menjadi mudah marah apabila posting sendiri kurang mendapat sambutan

4) Rasa cemburu apabila posting orang lain menerima perhatian yang meluas

5) Mengambil risiko menjalin hubungan di luar perkahwinan akibat interaksi tanpa batas walaupun usia sudah makin meningkat.

6) Menambah atau “mencuri” rakan orang lain yang sebenarnya tidak kita kenali

7) Sengaja memuat naik kandungan yang berpotensi mencetuskan pertelingkahan

8 ) Terlalu kerap memerhati jumlah tanda suka, komen atau perkongsian walaupun baru beberapa saat diposkan

9) Mengharapkan kebaikan dan manfaat daripada posting sendiri, namun tidak menerima sebarang respon

10) Berniaga di media sosial tetapi jualan atau sambutan tidak seperti yang diharapkan

11) Anda berpotensi menjadi mangsa penjenayah atau anda sendiri ingin menjadi penjenayah

Jika kebanyakan perkara ini mula berlaku, ia sering menjadi tanda bahawa media sosial tidak lagi dikawal oleh kita, sebaliknya kitalah yang sedang dikawal olehnya.

Media sosial seharusnya menjadi alat untuk kita berkawan, membina rangkaian, mengeratkan silaturrahim dan ukhuwah. Hakikatnya, ia bukan medan untuk mengejar pengaruh yang tidak sihat atau memenuhi keinginan ego semata-mata.

AKHIR KATA, SELAMAT TAHUN BARU 2026

SECRETS TO ETERNAL YOUTH? NOT REALLY

Many people ask how I manage to stay the way I am (not to mention my other half are surrounded demanding to know her "secret of youth), still with dark hair growing (not entirely black, there are a few whites people rarely notice - just look at my beard, you'll know), looking almost the same as I did in my 20s and 30s, and still able to roller-skate (unfortunately, no more stunts like I did when I was younger), with strong legs to match.

I’m just happy that my grandsons can see their cool grandpa roller-skating and that it even inspires the eldest to learn a few moves from me.

Some even want to come and learn from me, as if I were some kind of guru. Truth is, there’s no magic or miracle behind it. It comes down to how you were raised, and how you research on things, maintain discipline in your daily routine. And yes, I admit, being a construction guy, I do smoke but nothing hyper.

First, I face problems without panic. Challenges are simply part of life.

Second, I do take some traditional remedies certain herbs and preparations that are difficult to make because the ingredients and proportions must be just right. Finding them isn’t easy; it once required going deep into the jungle to source what was needed. That said, I still believe in and rely on modern medicine as well.

Third, the power of prayer plays a role. One thing I never do is pray in a state of panic; I calm myself first, because I know Who I am standing before. As a result, I also rarely envy those who are better off than me on the contrary, they inspire me, and I often learn a great deal from them.

Fourth, martial arts practice when done for health and discipline is a fascinating and effective form of exercise.

Fifth, family, relatives, friends, and colleagues matter deeply to me. I make a conscious effort to stay connected and communicate with them in whatever way I can.

Last but not least, genetics and DNA matter. Some of my ancestors lived beyond 100 years, though not all were so fortunate, some passed very young, some passed at 40, some at 63. Anything beyond that, we consider a bonus in life.

2026-2028 ECONOMIC OUTLOOK : GROWTH MAY BE UNEVEN BUT NOT ABSENT (From My Perspective)

As we move toward 2026, the global economy is entering a phase of fragmented growth, increasingly shaped by geopolitics, peace, and conflict.

PROJECTION (not a prediction)

a) Local: SMEs and domestic infrastructure will matter more than export-led narratives. Stocks linked to utilities, construction, logistics, and essential services show more resilience than speculative growth counters,

b) ASEAN: Supply chain realignment, energy transition, and food security will drive selective growth, not broad booms. Even regional tensions can affect logistics, tourism, and investor confidence. Equity markets favour domestic consumption, infrastructure, energy transition, and food security over export-heavy plays.

c) Global: Capital will be cautious. Conflicts such as Ukraine and Gaza continue to distort energy prices, shipping routes, insurance costs, and fiscal priorities, pricing risk faster than fundamentals. Stock market - remain volatile and selective. Valuations are increasingly driven by geopolitics, interest rates, and energy risks rather than pure earnings growth.

WHAT AM I WATCHING NOW

a) Public debt servicing vs development spending

b) Real FDI quality (jobs, technology transfer not headlines)

c) Energy, logistics, water, and food as strategic assets

The next few years won’t reward speed.

They’ll reward resilience, clarity, execution and stability.

NEVER CHOOSE THE WRONG PERSON TO MESS WITH

As we reach 2026 - more and more phishing emails are being disguised as legitimate ones. Even when the domain looks valid, a quick look at the HTML, IP trail, and most importantly the content reveals the truth.

Language, intent, and inconsistency never lie. Experience and discernment can’t be forged.

Yes, phishing software and toolkits do exist. They are commonly referred to generically as phishing kits or email spoofing frameworks. At a high level, these tools can :

a) Generate look-alike domains (using typos, Unicode characters, or subtle variations)

b) Clone the visual appearance of real emails or websites

c) Forge or manipulate email headers to appear legitimate

However : this is the key point I've already noticed from experience:

They imitate appearance, not understanding.

What they cannot reliably fake:

a) Contextual relevance

b) Logical flow of communication

c) Institutional tone and internal references

d) Behavioural consistency with past emails

That’s why content analysis (not just domain or extension checks) remains one of the strongest human defenses.

From a defensive mindset, this is why organizations should now emphasize:

DMARC / SPF / DKIM enforcement. Read also the intent, not just checking links and always have a zero-trust assumptions for unsolicited emails

You weren’t imagining it, the tools exist.

But they still fall short where experience and judgment begin.

Conmen still have a lot to learn. But don't even try and don't even think of it.

------------ People traced scammers’ cameras or CCTV mainly through digital footprints, not hacking magic. Common factors include misconfigured devices, exposed IP addresses, poor network security, and operational mistakes by scammers themselves. When devices are left online without proper protection, investigators and cybersecurity teams can legally trace them through logs, metadata, and network analysis.

In short: Scammers are often caught not because others are clever but because they are careless.

WHEN LIMELIGHT ENDS, REALITY SNEAKS IN

 

When surrounded by sycophants, we often forget those who truly need help and who once helped us when no spotlight was on us. When the praise fades and you fall, it is rarely the flatterers who return but the ones you once overlooked will step forward.So, while you are standing tall, stay grounded. Be kind to those without influence, be present to those without power. Don’t let success make you distant and don’t allow people to be ignored simply because they offer nothing in return.