Mandatory Carbon Reporting Interim Advisory Briefing

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    Envido Ltd | 71-81 Whitfield Street, London W1T 4HG | T: 020 7199 0090 | E: [email protected] | W: www.envido.co.uk

    London Birmingham Glasgow Ipswich Manchester Leeds

    Mandatory Carbon (GHG)Reporting

    Interim energy professionals briefing.

    17.07.2012

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    Mandatory Carbon (GHG) Reporting | Interim client briefing

    Envido Ltd | 71-81 Whitfield Street, London W1T 4HG | T: 020 7199 0090 | E: [email protected] | W: www.envido.co.uk

    London Birmingham Glasgow Ipswich Manchester Leeds 2

    About Envido

    Envido is the UKs leading provider of

    energy, low-carbon and sustainabilitysolutions for private and public sector

    organisations.

    Our unique integrated solutions are

    delivered through the three divisions of

    our business:

    Opportunity

    Consultancy and carbon assessment

    services that put a cost figure against

    your business carbon emissions and

    identify what action is needed to reduce

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    within the organisational infrastructure

    Change

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    programmes that help staff know what

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    Working with Envido means you will

    have access to all the expertise,

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    manage energy more efficiently, helping

    you to improve your organisations

    carbon footprint and bottom line.

    Helping our

    clients conserveenergy, save money

    and boost business

    performance

    Contents

    1. Who will need to report? 3

    2. What will they need to report on? 3

    3. What will be the first (required) reporting year? 3

    4. What methodology will be required? 4

    5. What other requirements are included? 4

    6. Will audit / verification be required? 4

    7. When will we see further details? 4

    8. Action for environment and sustainability

    professionals 4

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    Mandatory Carbon (GHG) Reporting | Interim client briefing

    Envido Ltd | 71-81 Whitfield Street, London W1T 4HG | T: 020 7199 0090 | E: [email protected] | W: www.envido.co.uk

    London Birmingham Glasgow Ipswich Manchester Leeds 3

    Government has announced that regulations will be introduced to require UK listed companies to

    report on their greenhouse gas (GHG) emissions. This interim briefing sets out key points to

    support your preparation. Further communication will follow when draft regulations are published

    by Government (due at the end of July 2012).

    1. Who will need to report?

    All UK companies quoted on the main market

    of the London Stock Exchange, approximately

    1,100 companies (Defra estimate). Around

    60% of these companies are already reporting

    (Environment Agency estimate), although

    most do not do so in line with Defra/DECC

    guidance1. Government will undertake a

    review and decide in 2016 whether to extend

    the regulations to all large companies; thiscould bring a further 24,000 companies into

    the reporting regime.

    Non-listed large companies and SMEs will all

    initially be outside the scope of the

    regulations. However, many are being asked

    to provide data by larger supply-chain client

    companies as time progresses and therefore

    would be best advised to start preparing for

    GHG accounting as appropriate.

    2. What will they need to report on?

    Regulations are likely to require reporting of

    material Scope 1 and Scope 2 emissions

    incorporating the six primary Kyoto gases2

    (and converted to CO2 equivalent):

    Scope 1 (direct) emissions: i.e. from

    activities owned or controlled by an

    organisation that releases emissions straight

    into the atmosphere. Examples include

    emissions from combustion in owned or

    controlled boilers, furnaces, vehicles and

    emissions from chemical production in owned

    or controlled process equipment

    1Defra/ DECC (2009) Guidance on how to measureand report your greenhouse gas emissions

    http://archive.defra.gov.uk/environment/business/reporti

    ng/pdf/ghg-guidance.pdf

    2Carbon dioxide, methane, hydrofluorocarbons, nitrousoxide, perfluorocarbons and sulphur

    hexafluoride

    Scope 2 (Indirect) emissions from energy:

    i.e. emissions being released into the

    atmosphere associated with an organisation's

    consumption of purchased electricity, heat,

    steam and cooling. These are indirect

    emissions that are a consequence of the

    organisation's activity but which occur at

    sources which the organisation does not own

    or control.

    Companies will not be able to choose their

    organisational boundary for reporting. As the

    requirement to report will fall under the

    Companies Act, the organisational boundary

    for reporting will need to be that for their

    financial reporting, including all non-UK

    emissions.

    Reporting Scope 3 emissions is not anticipated

    to be a requirement. Some environment and

    sustainability professionals are supportive of

    the regulations requiring specific business

    travel scope 3 emissions to be included.

    Companies with significant indirect emissions

    (e.g. within their supply chains) may decide to

    report on such material scope 3 emissions

    voluntarily, although they will need to

    consider whether this should be in the

    directors report.

    3. What will be the first (required) reporting

    year?

    Regulations are expected to come into force

    from April 2013 and will set the date from

    which companies will need to report.

    Companies reporting years for GHG

    emissions will be that covered by their

    financial report and accounts, these vary

    between companies (e.g. some companies

    report on a financial year, others on a

    calendar year).

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    Mandatory Carbon (GHG) Reporting | Interim client briefing

    Envido Ltd | 71-81 Whitfield Street, London W1T 4HG | T: 020 7199 0090 | E: [email protected] | W: www.envido.co.uk

    London Birmingham Glasgow Ipswich Manchester Leeds 4

    4. What methodology will be required?

    It is anticipated that the regulations will not

    be over prescriptive on setting a single

    methodology. Flexibility is expected to bebuilt in to allow existing reporting to be

    incorporated (e.g. returns from the Carbon

    Reduction Commitment and Carbon

    Disclosure Project schemes). The key

    requirement will be for transparent

    disclosure.

    Defra has already issued voluntary GHG

    reporting guidance (2009)3

    based upon the

    GHG Protocols reporting principles. Defra

    also regularly updates and publishes emissionfactors

    4 to support companies with GHG

    reporting.

    5. What other requirements are included?

    The regulations will require companies to

    report both their gross emissions and also

    emissions based on an intensity ratio.

    Flexibility will allow companies to select an

    intensity ratio that is suitable and relevant to

    their business. Companies will also need to

    set and report against a base year (of theirchoice)

    6. Will audit / verification be required?

    Section 496 of the Companies Act provides

    that the financial auditor must state in his

    report on the companys annual accounts

    whether in his opinion the information given

    in the directors report for the financial year

    for which the accounts are prepared is

    consistent with those accounts. As the

    regulations will require GHG emissions to bereported in the directors report, they will be

    included in the scope of this audit

    requirement.

    3Defra/ DECC (2009) Guidance on how to measureand report your greenhouse gas emissions

    http://archive.defra.gov.uk/environment/business/reporti

    ng/pdf/ghg-guidance.pdf4Defra GHG emission factors are available from:

    http://www.defra.gov.uk/publications/2012/05/30/pb1

    3773-2012-ghg-conversion/

    Assurance and verification has an important

    role to play in improving the quality of data

    published and, for that reason, many

    companies choose to carry out some level ofassurance or verification (i.e. for their own

    benefit and for that of stakeholders). This will

    continue to be possible under the new

    regulations

    7. When will we see further details?

    Companies preparing to meet the new GHG

    reporting requirements will be able to review

    both the draft and final regulations to confirm

    key details5

    .Draft regulations are expected to

    be published at the end of July 2012 and atwelve week consultation will be held.

    Following this consultation period the

    regulations will be finalised and introduced by

    April 2013.

    8. Action for environment and sustainability

    professionals

    Environment and sustainability professionals

    need to liaise with their Finance Director/

    Company Secretary to establish whether their

    company falls within the scope of the

    proposed regulations. Companies that are

    covered by the regulations need to ensure

    they have a robust data management and

    reporting framework that covers i) the GHGs

    that will need to be reported and ii) the full

    scope of their organisation based on their

    financial reporting.

    5

    http://www.defra.gov.uk/environment/economy/busin

    ess-efficiency/reporting/

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    Envido Ltd | 71-81 Whitfield Street, London W1T 4HG | T: 020 7199 0090 | E: [email protected] | W: www.envido.co.uk

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    Envido Ltd | 71-81 Whitfield Street, London W1T 4HG | T: 020 7199 0090 | E: [email protected] | W: www.envido.co.uk

    London Birmingham Glasgow Ipswich Manchester Leeds 6

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