Summary and implications
On 5 June 2009, the Department for Environment, Food and Rural Affairs (DEFRA), in conjunction with the Department of Energy and Climate Change (DECC),
- published draft guidance on how to measure and report greenhouse gas emissions
- invited consultation on this draft, with the deadline for responses being 7 August 2009.
- said that final guidance will be published on 1 October 2009.
Reporting under the Climate Change Act
Under the Climate Change Act 2008 (the Act) the UK must reduce total greenhouse gas emissions by at least 80% by 2050. Voluntary reporting of emissions by organisations is seen as crucial to achieving these legally binding 'carbon budgets'. Guidance clarifying how organisations should report is required by s.83 of the Act. The draft guidelines are based upon the Greenhouse Gas Protocol; the internationally recognised standard for the corporate accounting and reporting of greenhouse gas emissions.
The guidance is not however directly concerning the introduction of mandatory reporting of greenhouse gas emissions as required by 2012 under the Climate Change Act. There is further consultation planned for this. However there are hints in this consultation that the Government is moving away from the introduction of this reporting requirement. It can be avoided by a report being laid before parliament by the Secretary if State explaining why mandatory reporting will not be introduced. Throughout the published materials there are references to this alternative option being given serious consideration.
The measuring and reporting requirements
The guidance does not intend to align measuring and reporting under other reporting requirements; for example the Carbon Reduction Commitment, with the suggestions it puts forward. It is left specifically up to the organisation itself to decide what methods it uses for measuring and reporting emissions.
This flexibility in what method an organisation selects is understandable with the Government not looking to be too heavy-handed. However, given that it allows organisations to pick and choose whichever reporting and measurement standard will put them in the most positive light, it seems to undermine the key goal of the guidance; to reduce greenhouse gas emissions. Organisations can avoid making real cuts in emissions by picking a methodology that effectively appears to reduce their emissions. Furthermore this flexibility undermines comparability of organisations, an aim which lies at the heart of the Carbon Reduction Commitment.
The 'key' questions for a measuring reporting exercise:
Overall the guidance seeks to provide help to organisations by outlining a series of questions to take into consideration:
- Which parts of your organisation do you need to collect data from?
- Which activities in your organisation release greenhouse gas emissions?
- What information should you collect from these activities to calculate your greenhouse gas emissions?
- How do you calculate your greenhouse gas emissions?
- How do you report your greenhouse gas emissions?
- How do you set targets for reducing your greenhouse gas emissions?
In order to produce this guidance five stakeholder meeting were held to consult with representatives from a wide range of organisations both public and private. A number of workshops are planned to be held for consultees to engage more directly after comments have been received. We will provide a further report on the progress of the guidance as responses become available.