BT’s response to Reporting Guidance for Business on Environmental Key
Performance Indicators: a consultation on Guidance for UK Businesses
16 October 2012
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Reporting Guidance for Business on Environmental Key
Performance Indicators: a consultation on Guidance for UK
Businesses
Q1. Is the guidance easy to understand and practical to use?
The guidance is written clearly and is easily understandable, with the notable
exception of the guidance on how to ensure that KPIs are both relevant to an
organisation’s stakeholders and of material significance. The document could be
made clearer with the use of flow diagrams and annexes for some of the more
specialist (industry specific) indicators – for example metal emissions. This might
make the guidance easier to comprehend for new reporters.
Q2. Was section 1 clear on why and where you should report on environmental
impacts? Do you have any comments to improve this section? What more
would you find helpful in developing your environmental strategy?
In our view, given the emphasis on management systems, setting targets to
demonstrate continuous performance improvement should be highlighted more
strongly in this opening section.
Q3. Is it clear in section 2 how an organisation should go about identifying the
environmental issues and KPIs most material to its operations? How could it
be improved?
See comments in Q1.
The guidance would benefit from clarity on the difference between a ‘Key
Performance Indicator’ and a ‘Simple Performance Indicator’. This should reflect the
materiality of the issue to an organisation’s stakeholders, strategy and risk profile.
Boundary setting: we believe that reporting boundaries should have, at their core,
the ability to give a transparent picture of the organisation. In our experience
identification of environmental risks and opportunities and relative impacts on
reporting units will serve as a more cost effective way of prioritising and addressing
key issues.
Q4. Did you find the references to legislation in the different subject chapters
helpful?
Yes.
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Q5. Does table 1 at Annex C (Environmental Impacts and ICB and ISIC
classifications) help you identify which are the main environmental impacts of
your organisation? How to use table 1 is set out in the guidance in section two
on page 13 under “Your Key Performance Indicators”.
Yes, as a start point for new reporters. This will need to be tested against the
relevance to an organisation’s stakeholders as business reporting systems mature.
Businesses should be encouraged to look for future trends, for example use of
natural capital is of growing concern across a broad range of forward looking
stakeholders.
Q6. Do you agree with the categories of pollutants in chapter 1 on Air Pollution
and Other Emissions? If not what do you consider to be a more sensible or
realistic approach?
Yes, these are all pollutants that are harmful to our biosphere and society. There are
some pollution sources that are very industry specific – the guidance could be
structured with annexes to simplify matters.
Q7. Have you any suggestions on how reporting of the pollutants could be
improved?
For many organisations breaking down their vehicle fleet (engine size, weight) and
use (rural, motorway) to the level of detail in the NAEI will be impossible. DEFRA
should publish average factors for key emissions (SOx, NOx, PM) by vehicle type for
simplicity.
Q8. Do you think the sample reporting tables in chapter 2 (water) are helpful?
Do you any other proposals for water reporting?
For new reporters the details as presented may be overly complex and off-putting. A
set of core and additional (industry specific) indicators may be easier to understand
and report against.
Q9. Does the new chapter on biodiversity/ecosystem services adequately
address the issues involved? What additional information would you find it
more helpful to include?
This chapter provides a good overview of the issues and methodology for assessing
the relevance to an organisation. It would benefit from the inclusion of some best
practice examples to help organisations think through these complex topics.
Q10. Does the chapter on materials adequately address the issues involved?
What could improve it?
No comment – this chapter affects specific industries.
Q11. Does the chapter on waste adequately address the issues involved? What
additional information would you find helpful?
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This chapter would benefit from a greater focus on waste as an input measure and
avoidance activities for hazardous and other waste. Reference to ROHS, REACH
and other requirements for inclusion at product design stages would be welcome.
We would be happy to discuss these issues further. Further enquiries can be
directed to David Pincott, Head of Political Research, Policy and Briefing, BT
Group Plc
Tel: 020 7356 6585/email: david.pincott@bt.com
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