GHG Reporting Consultation
Clear about Carbon recognising Cornwall Council Response.
1. Do you support Option 1 (enhanced voluntary reporting)?
Although voluntary reporting is becoming more common amongst the largest
UK companies, (anecdotally through engagement with the private sector
through delivery of the ESF funded Clear About Carbon project) much of the
private sector with little regulatory pressure has still to make this step,.
Therefore we feel that the time for voluntary reporting has passed and basic
mandatory reporting must be enforced.
2. There are various ideas (outlined in Option 1) for increasing the
number of companies reporting on a non-regulatory basis, which do you
prefer? Have you any other proposals to increase the number of
companies reporting and the quality and consistency of reports on a
non-regulatory basis?
a) Much effort has already been placed on highlighting the importance
and benefits of organisational carbon footprinting. However, much of
the private sector have not realised these opportunities and remain
untaken.
b) Unfortunately the approaches taken by CDP amongst other NGO’s
tend to suit larger companies but are not easily transferable over to an
SME based economy. Given that such a large proportion of the UK
economy is built on the activities of SME’s
c) There are currently a range of issues around sector specific carbon
management. Although certain sectors are clearly the highest emitters,
many of which are regulated under CRC and EU ETS, the borderline
sectors are, as would be expected, are resistant to additional regulation.
d) Of the voluntary options, this is highly preferable and seems the most
logical approach. It would allow progression to act with SME’s in the
medium to long term and the banded reporting would ensure that
capacity issues are kept to a minimum in all cases. However, this
option does tread a fine line between voluntary and mandatory
reporting frameworks since there are targets and deadlines against
agreed performance. The additional administrative capacity required
from a regulating body must be consider.
3. Should corporate reporting of GHG emissions be made mandatory for
some companies? If so, please explain.
Corporate reporting of GHGs is already mandatory for a number of companies
through both the EU Emissions Trading Scheme and the CRC Energy
Efficiency Scheme. Our view is that basic reporting for those companies
currently below the current CRC threshold is required to achieve the UK
government’s carbon reduction targets.
4. If mandatory reporting is introduced, which would be your preferred
Option: 2, 3 or 4? It would be helpful if you could explain your reason.
Have you any suggestions for improving any of the regulatory options?
Our preference is for option 3 however, clarification would have to be given as
to how overlap would be avoided with CRC since many of the organisations
would be the same.
Option 2 would simply duplicated EU ETS and CRC.
Option 4 hinges entirely on electricity consumption which is seen as one of
the major downfalls of the current CRC legislation and therefore is
inappropriate.
5. Do you have any comments on the economic analysis in the impact
assessment? In particular, do you think the costs and benefits for the
different options are reasonable? Can you provide any further
information which would help in estimating costs and benefits for the
different options?
No answer given.
6. Do you agree that a company should specify which approach it is
using to set its organisational boundary?
Organisational boundary setting is key to accurate and representative carbon
reporting. Therefore, identifying the methodology used and the rational for its
use is crucial to ensuring a high level of understanding of the data provided.
7. Do you agree that a company should (where possible), report on all
their emissions within the chosen organisational boundary, including
those that occur in their operations overseas? If you don‟t agree, can
you explain which emissions you think a company should report?
We agree with the exception of overseas emissions. Although this particular
legislation would only apply to the UK, it is likely that similar legislation may
start to be enforced in other European countries within the foreseeable future.
This creates a risk of double counting which must be avoided at all costs to
maintain the integrity of the system. Although limiting the carbon footprint to
geographical boundaries increases the risk of carbon leakage across
boarders, this would seem to be the lesser of two evils at this stage.
Additionally, cross boarder calculations raising issues of complexity and
verification/assurance.
8. Do you agree that, if it isn’t possible for a company to report on all
emissions within their organisational boundary (because of data
problems, etc), then a company should clearly state the extent to which
it has been able to report?
Assumptions, data omissions and the use of secondary data should be
avoided where possible; however, occasionally exceptions will have to be
made. It is vital that any assumptions, uses to secondary data and data
omissions are made explicit in the reporting document.
9. Do you agree that companies should be required to measure and
calculate emissions from the six GHGs covered by the Kyoto Protocol?
Yes, this will bring any new reporting requirements in line with the rest of UK
and Europe. It would seem logical to follow the same guidelines as the GHG
Reporting Protocol and include all 6 Kyoto Gases.
10. Do you agree that companies should be required to measure, or
calculate, and report on all their scope 1 and scope 2 emissions? If not,
which emissions do you think a company should measure, calculate and
report and why?
Yes, scope 1 and 2 emissions are both relatively easy to measure and without
this measurement; management is impossible.
11. Do you think that companies should be required to measure and
report on any of their scope 3 emissions (in addition to scope 1 and 2)?
If so, can you specify which ones you think should be required?
Information is gathered by most organisations on both business travel and
waste collection. These aspects of an organisations footprint, if collected,
could provide richer information on the organisations activities and a better
idea of their overall carbon footprint. Some organisations hold much of their
carbon footprints within the business travel sector and it can therefore prove
important.
12. Do you agree that companies should specify in their directors’
reports, the company’s total annual amount of GHG emissions in CO2e
broken down by direct emissions (scope 1) and indirect energy (scope
2)?
This would be a very valuable step towards mainstreaming carbon footprinting.
The formalisation this process and the professionalization of carbon audits
through professional service providers would further the agenda greatly and
contribute heavily to the achievement of the UK’s carbon reduction targets.
13. Do you agree that companies should specify an intensity ratio?
It would be a useful option for companies to specify an intensity ratio in
addition to an absolute footprint. However, intensity ratios can sometimes lead
to creative carbon accounting and it must be ensured that there are a
predefined set which can be used. It also must be ensured that if comparing
year on year, the same intensity ratios are used to avoid misleading
information being published. Alternatively, a suite of around 3 intensity ratios
could be used, against which, all companies would have to report: per
£ turnover, per employee, per m2 functional space.
14. Should companies specify a base year when they report their annual
emissions?
Yes, without a solid baseline year it is going to be very difficult to measure
direction of travel. Carbon reduction is all about measuring to manage and
reduce – without a baseline year, showing any potential reductions can be
very difficult.
It is also important that either a baseline year is set at 2012/13 for the
purposes of this reporting structure or companies give clear justification for
the baseline year they have used. If full freedom is given on the selection of a
baseline year then organisations could potentially use this to skew their future
results.
15. Is there any other information which you think a company should
report?
Scope 1 & 2 emissions should take priority at this stage. However, baring in
mind the ease with which companies can shift their scope 1&2 emissions into
their supply chain through outsourcing, details of any large scale outsourcing
should be supplied if possible.
16. If reporting is made mandatory, should companies be obliged to
seek some kind of assurance or verification on their emission report? If
not, could you explain your thinking?
This is about balancing the reporting requirements with the capacity issues
which are experienced in SME’s. We would propose that in the first instance a
threshold is set requiring assurance or verification for larger organisations but
not SME’s. This could then be reviewed after a 2/3 year period once the
assurance and verification market has had a chance to grow and self regulate.
17. Is internal verification of greenhouse gas emissions sufficient, or
should external third party assurance be sought? If the latter, should it
be limited or reasonable?
In line with our previous answer it is felt that 3rd party verification or assurance
should be required for large organisations. This would most likely be provided
by professional services companies, most likely accountancy/financial
services.