Approach to target setting for an infrastructure asset with no employees

I am working with a private equity infrastructure fund that is evaluating how to integrate SBT best practices into their investment strategy. This currently includes having all PCs go through the SBT target setting process if it is eligible.

We are evaluating possibilities for investments related to a portfolio of solar energy and battery storage projects. These assets would be wholly owned by the fund and managed by a asset managers, so there are no employees related to the “PC”. We don’t interpret this to be project finance since the investment is of already-existing assets with no plans to expand and therefore are applying the methodology for private equity.

Based on our understanding of SBTi guidance, we interpret SBTi criteria to be that:

  1. Because the portfolio of assets is owned by the fund and is not an organization/PC with employees, the portfolio (e.g., grouping of solar projects) is not eligible to go through an SBTi-validated target setting process.
  2. With the current ownership structure, it could only be included within a parent company’s goal (and aggregated with other power sector investments for an SDA target).
  3. If the portfolio of assets were a PC with employees, we interpret that the PC would be eligible to submit its own validated target to the SBTi utilizing the Power Sector framework.

Is this a correct interpretation of the framework?
Thank you in advance for the clarification.