CMS Energy Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	CMS Energy provides a high degree of transparency around its climate-policy lobbying. It names multiple, clearly identifiable policies it has engaged on, including the “MI Healthy Climate Plan,” the federal “Infrastructure Investment and Jobs Act,” the “Inflation Reduction Act,” EPA’s methane rulemaking “NSPS 40 CFR Part 60 Subpart OOOOa,” the proposed “Clean Energy Performance Program,” and SEC proposals for mandatory climate-risk disclosure. The company also spells out how it lobbies and who it targets: it takes part in “roundtable discussions, workgroups, and public presentations,” is “actively engaged in the Council on Climate Solutions and several of the Council Workgroups,” and uses indirect channels such as the American Gas Association and Edison Electric Institute, which “has been actively tracking and engaged with policymakers on regulations regarding the regulation of methane.” These disclosures identify concrete targets such as the State of Michigan, federal lawmakers, EPA and the SEC. Finally, CMS Energy is explicit about what it wants from these engagements: it seeks to “invest in the hardening our grid and furthering our green energy development and deployment” through the IIJA, supports the MI Healthy Climate Plan “with no exceptions” to reach an “economy-wide carbon neutrality goal,” and advocates for “revised mandates on utilities for energy efficiency and renewable energy” as well as clean-energy tax credits and R&D funding. Together, these details demonstrate comprehensive transparency on the policies addressed, the mechanisms and forums used, and the specific outcomes the company is pursuing.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	CMS Energy has implemented a governance framework that explicitly integrates climate policy into its lobbying activities through a “set of principles to guide its perspectives on climate change policy proposals,” including positions “consistent with policies that limit global warming to no more than 2 degrees Celsius, and preferably 1.5 degrees,” which “are implemented on a policy-by-policy basis by at least two internal working teams known as the Regulatory Policy Team and the Carbon Council and Policy Team.” Oversight resides with its Board of Directors, which “oversees our political engagement policies, programs and practices,” and the Governance, Sustainability and Public Responsibility Committee, to which the senior vice president for governmental, regulatory and public affairs “reports the prior year’s expenditures for political purposes” annually. The company also manages its indirect lobbying by tracking trade association dues and reserves the right to “abstain or withdraw membership” from organizations whose positions conflict with its values, and discloses the non-deductible portion of those dues. While this structure demonstrates clear oversight and policy alignment for climate-related advocacy, CMS Energy does not disclose a dedicated climate-lobbying review or publicly available audit, and the specific procedures by which its working teams translate climate principles into direct lobbying strategies are not fully detailed.	3