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Scientific Beta participated in the call for feedback organised by the TEG in July 2019 and, along with a majority of the respondents, opposed the introduction of a novel carbon intensity metric. At the time, the normalisation metric was accounting-based and the TEG explained: "The TEG explicitly uses the book values instead of market values for the definition of Total Capital, as market effects can significantly affect this indicator and create misleading results." (p41)

The final report of the TEG recognied issues about book values and introduced enterprise value for normalisation, i.e. a metric mixing market and book values. In its February 2020, white paper analysing the TEG proposals, Scientific Beta devoted over 4 pages to the metric issue (Unsustainable Proposals: https://www.scientificbeta.com/#/news-events/unsustainable-proposals )

In its open letter to the European Commission dated 4 May 2020 and its public contribution to the consultation on the draft delegated acts, Scientific Beta again alerted against issues with the metric and how it was used - some of these issues were corrected in the Commission's final proposal but fundamental problems remain unaddressed.

Using EVIC normalisation in a carbon footprinting and reporting context can be defended as explained in Scientific Beta's latest white paper ( https://www.scientificbeta.com/download/file/carbon-intensity-bumps-on-the-way-to-net-zero ). What is objectionable is to guide index construction by a measure that is particularly subject to market effects and obscures the efforts made by issuers to control their emissions, which, on the contrary, should be encouraged.