EEVS operates a certified Quality Management System for analytical measurement and verification services
FS-591998
Certificate of Carbon Footprint Verification 2016/17
This certificate is to certify that
Sussex Community NHS Foundation Trust has been assessed and judged to meet the principles for reporting Carbon Footprint under the guidelines of the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard for the 2016/17 emissions inventory.
The scope of this Greenhouse Gas Protocol covers:
The accounting and reporting of greenhouse gas emissions covered by the Kyoto Protocol for emissions from purchased electricity and heat. Additionally, the optional reporting of emissions from indirect sources including transport and water.
Signed on behalf of EEVS Insight:
………………………………………………. ……………………………………………….
Hilary Wood Michael Ndongala
Operations Director Consultant
Date of Issue: 20th September 2017
Issued by:
EEVS Insight Ltd
6 Stirling Park Laker Road Rochester Airport Estate Rochester Kent ME1 3QR
Sussex Community Foundation Trust – Carbon Footprint Verification – v3.0 Page 1 of 30
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Version 3.0 Carbon Footprint Verification Sussex Community NHS Foundation Trust 16/17 Carbon Footprint Verification Advisory Report November 2017 – FINAL
Prepared for:
Toby Donhou and Will Clark
Sussex Community NHS Foundation Trust Environment and Logistics Arundel Building, Brighton General Hospital Elm Grove, Brighton, BN2 3EW 01273 696011 [email protected]
Prepared by:
Michael Ndongala
EEVS Insight Ltd 22 Long Acre London WC2E 9LY 07718 242520 [email protected]
Peer reviewed by:
Hilary Wood EEVS Insight Ltd
07585 504 004
FS-591998
EEVS operates a certified Quality Management System for analytical measurement and verification services
Sussex Community Foundation Trust – Carbon Footprint Verification – v3.0 Page 2 of 30
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Contents 1. Executive summary ................................................................................................................ 3
2. Our approach ......................................................................................................................... 4
3. Compliance 2016/17 .............................................................................................................. 7
4. Carbon Footprint Data Assurance and Findings .................................................................. 10
5. Materiality ............................................................................................................................ 17
6. Data record, issues and recommendations ......................................................................... 18
7. Summary of issues resolved................................................................................................. 22
8. Recommendations for on-going improvements to SCFT’s footprint process. .................... 23
9. Sussex Community Foundation Trust’s on-going improvements to the footprint process.24
10. Benefits of independent assurance and continuous process improvement ....................... 25
11. Appendix 1 - Assurance Plan .............................................................................................. 26
12. Appendix 2 - Data sources reviewed ................................................................................. 28
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1. Executive summary Carbon reporting is the first vital step for organisations to make reductions in emissions. By measuring and reporting Greenhouse Gas (GHG) emissions, organisations can begin to set targets and put in place carbon management initiatives to reduce emissions in the future.
Sussex Community Foundation Trust (SCFT) has been actively engaged in the reporting of its Greenhouse Emissions since 2010, as part of a long-term strategy to track its carbon footprint until the target year of 2020. The greenhouse reports are produced to provide readers with a clear understanding of the Trust’s operations and their impact on emissions, with year to year comparisons being made to ensure the Trust is on track to achieve its goals. In addition, the baseline year has been used to produce a set of targets in the form of energy intensity ratios such as KPIs and energy efficiency metrics against which The Trust can measure progress.
For several years SCFT has used independent third party GHG assurance to validate and verify the accuracy of their emissions reporting. In keeping with this, EEVS Insight have completed the assurance for the 2016/17 Greenhouse Gas Emissions Report as an experienced provider of assurance, verification and certification services related to energy. The aim of the assurance exercise was to provide recommendations to the Trust to improve data quality and management processes, calculation and reporting methodologies, as well as improving the robustness of the footprint calculation for future years. EEVS has provided a certificate of verification with this report, allowing SCFT to demonstrate to stakeholders that external reviewers have assessed reporting for its compliance to the principles of good practice GHG accounting and reporting according to the protocol. Although Greenhouse Gas reporting is not a regulatory requirement, it is recommended as good practice. The role of independent assurance serves to improve accuracy, completeness and consistency of GHG emissions reporting, leading to better decision-making and stakeholder understanding.
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2. Our approach 2.1. Aims
To develop a robust and statistically sound verification methodology by making recommendations for SCFT’s current practices including practical changes that can be made to produce effective emissions management and transparency. In addition, ensuring that SCFT's carbon and sustainability reporting meets both regulatory requirements and the Trust’s own objectives, whilst adding value to SCFT’s environmental data and publicly reported emissions figures with independent insight and constructive feedback.
2.2. EEVS Assurance Checklist
The checklist below was used as part of the assurance process for SCFT’s Carbon Performance Report. The checklist presents a general overview of some of the items checked in determining whether the Carbon Performance Report meets the principles outlined in the GHG Reporting and Accounting Protocol.
Item Check a sample of input data for transcription errors ✓ Identify spreadsheet modifications that could provide additional controls or checks on quality ✓ Ensure that adequate version control procedures for electronic files have been implemented ✓ Confirm that bibliographical data references are included in spreadsheets for all primary data ✓ Check that assumptions and criteria for selection of boundaries, base years, methods, activity data, emission factors, and other parameters are documented ✓ Check that changes in data or methodology are documented ✓ Check whether emission units, parameters, and conversion factors are appropriately labelled ✓ Check if units are properly labelled and correctly carried through from beginning to end of calculations ✓ Check that conversion factors are correct ✓ Check the data processing steps (e.g., equations) in the spreadsheets ✓ Check that spreadsheet input data and calculated data are clearly differentiated ✓ Check a representative sample of calculations, by hand or electronically ✓ Check some calculations with abbreviated calculations (i.e., back of the envelope calculations) ✓ Check the aggregation of data across source categories, business units ,etc. ✓ Check consistency of timeseries inputs and calculations ✓
Source: The GHG Protocol Corporate Accounting and Reporting Standard
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2.3. Statistical approach
2.3.1. Sampling design
Considering the large inventory of energy data collected by the Trust, a sampling approach has been designed to produce a representative set of data for EEVS to verify. Verification of this sample is intended to provide a high degree of confidence in the whole of the Trust’s energy data without the need to verify every data point. This approach has been chosen with the robustness the assurance practice in mind.
Hence, to complete the assurance for the 2016/17 carbon footprint, EEVS has requested a number of invoices for each utility. The number of invoices requested was based on the minimum sample size required to achieve an assurance with the degree of confidence stated below.
The sample size was based on the following statistical criteria:
Precision – 10%
Confidence – 90%, which equates to a 10% sampling risk
Coefficient of Variation - 0.5
As it is impractical to recalculate the sample size based on the variance in the billed consumption concurrently, a higher than typical ‘starting point’ Coefficient of Variation (CoV) has been used. Having considered all statistical criteria, the sample size determined was at least 33 consumption totals. The sample size was then divided across the 4 billed emission sources utility groups (Electricity, Gas, Water, Oil), requiring a minimum of 8 sites being verified for each utility. This is the minimum sample size for each utility group required to detect whether there is a pervasive difference between invoiced consumption and emissions reporting figures. The larger the difference, the larger the sample size required to accurately complete the assurance. Once an adequate sample size has been chosen, the sites selected for the sample are randomly chosen with a number generator.
The invoices randomly selected for the sample then undergo the assurance process. The total consumption taken from the invoice for a given site is compared against the reported consumption to determine the accuracy. In cases where the CoV criteria is not met, the CoV is then adjusted in the sampling calculations to determine a new sample size. The potential increase in sample size is discussed further in the attribute sampling section.
The remaining emissions sources such as Transport, will be verified in their entirety and considered outside this sampling approach.
2.3.2. Attribute sampling
The attribute sampling technique has been used to determine the occurrence rate of errors for all billable energy consumption. The initial sample size was calculated based on the total population size. The total population size is based on all the billable sites with energy consumption with a tolerable error rate set to 10%. In the event that the error rate were to
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exceed the tolerable rate, EEVS would consider requesting additional invoices to check whether the higher than expected error rate is representative of the entire population. If upper deviation rate is above the tolerable rate, the sample size may also be increased by increasing confidence levels. The increase is determined by the difference between tolerable rate and upper deviation (assuming the difference is less than the sampling risk).
This allows us to determine whether consumption is being accurately recorded and correctly inputted into the main carbon footprint reporting spreadsheet, as well as allowing us to measure the rate at which errors are likely to occur. Once the error rate has been determined to be acceptable, the sample size is then deemed to be appropriate for assurance purposes.
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3. Compliance 2016/17 3.1. EEVS assessment
Sussex Community Foundation Trust emissions reporting was verified for compliance against The GHG Protocol Corporate Accounting and Reporting Standard. The results of the assessment were as follows:
Greenhouse Gas Reporting Protocol
EEVS assessment SCFT Compliance
Setting organisational and operational boundaries
SCFT have made efforts to establish a boundary that includes their most environmentally impactful activities. The basis for omitting certain activities is due to unreliable and difficult to obtain data.
Tracking emissions over time
SCFT set their emissions reduction target for the year 2020. With SCFT recalculating the base year emissions and targets to reflect any changes in the portfolio. SCFT have clearly shown their methodology in the carbon footprint reporting spreadsheet.
Identifying and calculating GHG emissions
SCFT have identified an appropriate source of energy data for each emission type. The Trust has selected an appropriate calculations approach by applying the correct data and emission factors. Energy data applied in emissions calculations is the highest tier available and the emission factors applied have been taken from DEFRA.
Managing inventory quality
The majority of evidence requested by EEVS for the assurance was provided by the Trust. SCFT was able to retrieve data for 2016/17 in a timely manner with existing energy data retrieval processes being implemented for other energy reporting delivery purposes being completed by the Trust. Furthermore, SCFT are considering ways in which their inventory can be better managed, with the use of energy management software being considered.
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Accounting for GHG reductions
SCFT’s carbon footprint calculations take into account changes in their portfolio. Baseline adjustments are incorporated to account for site additions/removals, improved methodologies and changes to the GHG protocol.
Reporting GHG Emissions
EEVS believes SCFT’s GHG emissions reporting is based on the most accurate data available at time of publication. In cases where data is unavailable, SCFT have been transparent about the data estimation procedures undertaken to fill missing data.
Verification of GHG Emissions
SCFT are aware of the need for third party verification, having sought assurance for their annual carbon footprint reporting each year. EEVS have been enlisted to complete the verification for the 2016/17 emissions.
Setting GHG targets SCFT have set a target of 34% reduction in GHG emissions from energy and water sources and a 75% target for emissions from waste. These targets are in line with reductions we expect an estate of the Trust’s size to achieve.
Accounting for Indirect Emissions from Purchased Electricity
SCFT have reported on the supplier specific emissions resulting from the production of electricity with specific emission factors having been obtained from a relevant source.
3.2. Footprint scope and boundary
In keeping with the GHG Protocol, SCFT’s Greenhouse gas emissions have been categorised into three ‘scopes’ as shown in the table below. Determining and justifying boundaries is a fundamental stage in emissions accounting. As a way of understanding the environmental impact of operational activities, organisations are increasingly expanding the scope of their carbon footprint reporting. By taking a closer look at data collection process, the trust may be able to identify potential means of expanding. Full coverage of the emissions sources allows the Trust to present emissions figures to the stakeholders as a figure representing the entire operational impact of the Trust on the environment.
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3.2.1. SCFT Specific activities
Scope 1: All direct GHG emissions from sources owned or controlled by the organisation. Scope 2: Indirect GHG emissions from the generation/consumption of purchased electricity, heat or steam. Scope 3: Other indirect emissions, such as the extraction and production of purchased materials and fuels, transport-related activities in vehicles not owned or controlled by the reporting entity, electricity-related activities not covered in Scope 2, outsourced activities, waste disposal, etc. Emissions scope Footprint area EEVS Verified
Scope 1
Gas use in buildings Yes
Gas oil use in buildings Yes Fuel used by owned vehicles Yes
Scope 2 Electricity use in buildings Yes Scope 3 Fuel used by Grey fleet vehicles Yes
Scope 3 Electricity use for the Transmission and Distribution Yes
3.3. Key Performance Indicators for 2016/17
The following indicators will be used to monitor the Trust’s progress towards its 2020 emissions goal.
• Carbon footprint (tonnes CO2e) • Energy efficiency (kgCO2e/m2) • Water efficiency (m3/m2) • Trust vehicle emissions (gCO2/km) • Grey Fleet Mileage (miles)
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4. Carbon Footprint Data Assurance and Findings The follow
ings section contains our findings and recomm
endations from the Carbon Footprint assurance. Recom
mendations have been m
ade in line w
ith the principles outlined in the GHG reporting standard, with the aim
of forming a m
ethodology that adheres with this standard.
4.1. Scope 1
4.1.1. Gas
Site Docum
ent(s) Tab
Cell Issue type
Recomm
endation Actions taken by SCFT
Status
Bognor Health Centre
Bill logger 2016-17 V1.1
BOGN
OR
REGIS HC
G32 M
issing evidence / Data record incom
plete.
Complete data for
2016/17 was requested
however the data
provided by the Trust is incom
plete. Provide data to cover this period or com
ments on w
hy it has not been included.
Invoice missing on data portal –
estimate from
previous year’s invoice instead
Closed
Uckfield
Comm
unity Hospital
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy &
Water
H90, N90
Cells are not referencing correct inform
ation from
the bill logger.
Correct Excel formulae.
Fixed Closed
Westham
pnett Centre
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy &
Water
H80, N80
Cells are not referencing correct inform
ation from
the bill logger.
Correct Excel formulae.
Fixed Closed
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Westham
pnett Centre
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy &
Water
B80 Com
ment does
not appear valid. There appears to be gas consum
ption at this site. The Trust should update the com
ment.
Cell reference fixed. Now
showing 0 gas consum
ption as per note
Closed
4.1.2. Oil
The table below provides details of our findings for em
issions calculated for SCFT oil use.
Site
Document(s)
Tab Cell
Issue Recom
mendation
Actions taken by SCFT Status
All sites SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Oil Calcs
B2:B6 O
il calculation is based on estim
ates.
SCFT should keep track of future fuel oil deliveries for reporting purposes.
SCFT keep track of oil deliveries; how
ever as it is only used as backup fuel in a num
ber of cases over a year. Going forw
ard SCFT will use 1 of 2
approaches.
Closed
All sites SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Oil Calcs
C22:C28 Fuel properties used can be im
proved with
actual fuel specific inform
ation.
EEVS recomm
ends that the Trust obtains Gross Calorific Values and Fuel Density values from
the supplier.
Noted – w
ill endeavour to gather this inform
ation when
fuel is ordered.
Closed
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4.1.3. Ow
ned vehicles
EEVS Insight did not find any issues with the em
issions calculated for fuel consumed by SCFT ow
ned vehicles.
4.2. Scope 2
4.2.1. Electricity Site
Document(s)
Tab Cell
Issue Recom
mendation
Actions taken by SCFT Status
Morley Street
School Clinic Bill logger 2016-17 V1.1
Morley Street
Clinic M
18 Data record incorrect.
Amend the
spreadsheet according to the invoice.
Fixed Closed
Morley Street
School Clinic Bill logger 2016-17 V1.1
Morley Street
Clinic M
21 Data record incorrect.
Amend the
spreadsheet according to the invoice.
Fixed Closed
Brighton General Hospital – Varndean Building
Bill logger 2016-17 V1.1
BGH Varndean and SRC
M43:M
44 Data record incorrect.
Amend the
spreadsheet according to the invoice.
M43 am
ended. Invoice for M
44 provided. Closed
Uckfield
Comm
unity Hospital
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater G90, M
90 Cells are not referencing the correct inform
ation from
bill logger.
Correct Excel form
ulae. Fixed
Closed
Westham
pnett Centre
SCFT 2016-2017 CARBO
N
Energy & W
ater G80, M
80 Cells are not referencing
Correct Excel form
ulae. Fixed
Closed
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PERFORM
ANCE
REPORT V1.7
the correct inform
ation from
bill logger.
Uckfield
Comm
unity Hospital
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Electricity E81
Cells are not referencing the correct inform
ation from
bill logger.
Correct Excel form
ulae. Fixed
Closed
Uckfield
Comm
unity Hospital
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Electricity K81:O
81 M
issing the cost inform
ation from
invoices
Electricity cost from
invoices should be used to populate this area.
Fixed Closed
Westham
pnett Centre
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Electricity I71,O
71 Cells are not referencing the correct inform
ation from
bill logger.
Correct Excel form
ulae. Fixed
Closed
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4.3. Scope 3
4.3.1. Grey m
ileage
Site
Document(s)
Tab Cell
Issue Recom
mendat
ion Actions taken by SCFT
Status
Transport SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Transport C3:C6
Grey Fleet m
ileage figures have not been inputted into m
aster spreadsheet.
Populate cells w
ith Grey Fleet m
ileage for 2016-17.
Corrected and figures now pulling
through to reporting document.
Also provided 1/4ly breakdown.
Closed
4.3.2. Leased car mileage
EEVS Insight did not find any issues with the em
issions calculated for fuel consumed by SCFT leased vehicles.
4.3.3. Procurement (Supply Chain) Em
issions
Site Docum
ent(s) Tab
Cell Issue
Recomm
endation Actions taken by SCFT
Status All sites
Bill logger 2016-17 V1.1
Brighton General Hospital
K10:K21 The Trust has om
itted LLF for Brighton General Hospital.
The Trust should consider w
idening GHG reporting scope to include em
issions produced by transm
ission and distribution losses. These losses should be
Agreed should be included – have added in on baseline adjustm
ent tab for 16/17 back to base year.
Closed
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considered attributable to the Trust as w
ell as their associated em
issions.
4.3.4. Water and W
astewater
The table below provides details of our findings for em
issions calculated for SCFT water and w
astewater use.
Site Docum
ent(s) Tab
Cell Issue
Recomm
endation Actions taken by SCFT
Status Lancing Health Centre
Bill logger 2016-17 V1.1
Lancing HC F41
Estimation
calculation unclear. The values do not show
the figures used to com
plete pro-rata calculation.
Pro-rata consumption
should be based on invoices from
2016/17.
Fixed Closed
Moulsecoom
b Health Centre
Water
Moulsecoom
b HC_W
ater N
/A M
issing evidence / Data record incom
plete. Data provided w
as for Hangleton Park Childrens Centre
Complete data for
2016/17 was
requested however
the data provided by the Trust is incom
plete. Provide data to cover this period for EEVS to review
.
Moulsecoom
b Health Centre W
ater data was
provided in folder of invoices.
Closed
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Moulsecoom
b Health Centre
Water
Water
N/A
Missing
evidence / Data record incom
plete
Complete data for
2016/17 was
requested however
the data provided by the Trust is incom
plete. Provide data to cover this period for EEVS to review
.
Data for Hangleton was
provided instead of M
oulsecoomb Childrens
Centre. Correct data set for M
oulsecoomb Childrens
Centre provided.
Closed
Uckfield
Comm
unity Hospital
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater K90, P90, Q
90 Cells are not referencing correct inform
ation.
Correct Excel form
ulae. Fixed
Closed
Westham
pnett Centre
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater K80, P80, Q
90 Cells are not referencing correct inform
ation.
Correct Excel form
ulae. Fixed
Closed
St Richard’s Hospital (M
ain Building)
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater K75
Cells are not referencing correct inform
ation.
Correct Excel form
ulae. Fixed
Closed
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4.3.5. Waste
Site Docum
ent(s) Tab
Cell Issue
Recomm
endation Actions taken by SCFT
Status W
aste SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Waste
E23 M
issing evidence / Data record incom
plete.
Master
spreadsheet should be updated to include the kgCO
2 e attributable to each w
aste type. Such as Healthcare w
aste incineration, W
aste Recycling and General W
aste.
Waste not included in
carbon footprint due to unreliability of em
ission factors for various w
aste stream
s
Closed
4.4. All scopes The table below
provides details of our findings which are relevant across all sources.
Site Docum
ent(s) Tab
Cell Issue
Recomm
endation Actions taken by SCFT
Status SCFT occupied Desk spaces
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater G95:K100
These sites are m
issing energy consum
ption data.
Energy consumption
from invoices should be
used to populate these cells. O
r reasons should be provided for these not being included.
We do not use
invoiced data, as we
do not hold it and given the sm
all values involved w
e choose not to gather it and m
ake an estimate on
typical energy consum
ption per desk and apply the
Closed
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appropriate emissions
factors. All sites
SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater and Electricity
Energy consum
ption figures are being pulled from
an outdated Bill Logger file - v1.0.
Energy consumption
figures should be taken from
the most up to
date Bill Logger -v1.1
Bill Logger -v1.1 was
an identical version of 1.0 saved as binary file as original w
as too large. Version 1.0 rem
ains the w
orking copy from
which data is being
pulled.
Closed
All sites SCFT 2016-2017 CARBO
N
PERFORM
ANCE
REPORT V1.7
Energy & W
ater and Electricity
In som
e places, energy consum
ption figures are being pulled from
the incorrect sites.
EEVS recomm
ends the Trust uses the site nam
e as a unique identifier. M
odifying excel formula
to extract consumption
figures from the bill
logger based on the site nam
e so that changes in either spreadsheet do not cause errors.
The bill logger for 2017/2018 w
ill be im
plementing the use
of site names as
unique identifiers with
which to pull data
from.
Ongoing
All sites SCFT 2016-2017
Targets & KPIs
N4:N
10 Percentage change calculation has not been correctly applied to all cells.
Correct calculations. Fixed
Closed
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5. Materiality After completing the audit and general review, the discrepancy between emission figures before and after assurance for each emission source and KPI was completed. GHG Reporting and Accounting Standard proposes 5% as a materiality threshold. This is shown in the tables below:
Emission sources Data before assurance exercise
Data after assurance exercise
Discrepancy
Electricity (tCO2e) 3,044 2,480 18.52%
Gas (tCO2e) 2,730
2,273
16.75%
Oil (tCO2e) 8.657
8.657 0.00%
Water consumption (tCO2e) 32.98
26.04
21.04%
Wastewater (tCO2e) 64.47
50.91
21.04%
Owned vehicle (tCO2e) 101.92
101.92
0.00%
Leased vehicle (tCO2e) 163.65
163.65
0.00%
Indicator
KPI Data before
assurance exercise
Data after assurance exercise
Discrepancy
Carbon footprint tonnes CO2e 7300.81 6483.61 11.19 Energy efficiency kgCO2e/m2 47.52 47.52 0.00%
Indicator
KPI Data before
assurance exercise
Data after assurance exercise
Discrepancy
Water efficiency m3/m2 0.873 0.873 0.00% SCFT Vehicle emission gCO2/km 109.92 109.92 3.41% Grey fleet mileage miles claimed 3,838,094 3,838,094 0.00%
It should be noted that the material discrepancies observed were mostly due to the incorrect double inclusion of a highly consuming site in the emissions report, caused by a referencing error in the master spreadsheet.
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6. Data record, issues and recommendations Based on statistical criteria outlined in Chapter 2, a sample of primary data was checked to see if the values it contained were correctly transferred to the master spreadsheet. The sample size was based on 90% confidence level, with a sampling risk of 10%. The attribute sampling procedure we designed would have required that additional samples are reviewed had a significant number of errors been found. Since the discrepancies due to transcription errors were not material, an increase in the sample size was not required. However, EEVS recommend that since the Trust has reduced the occurrence of errors, that the statistical criteria is made stricter, and a larger sample size is verified in future years to further minimise risk. Since the majority of errors arose due to incorrect referencing by Excel formulae, particular attention needs to be made to the manner in which data links are set-up across spreadsheets.
Some of the other Issues EEVS & SCFT came across during the assurance include the following
• Difficulty in gathering data for certain sites
• Metering or measurement issues
• Data management constraints
• Incomplete information for the period
• General changes in the building portfolio
Over the course of the assurance process, the issues listed above were identified. Upon being discovered, these issues were logged and documented. Where possible SCFT were able to provide feedback on any historic attempts to address the issue with a solution as noted in their feedback in Chapter 4.
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6.1. Data validation process
As part of the data verification process, invoices were checked against the figures inputted into SCFT’s bill logger. Where applicable, monthly figures were checked as well as the calculation for the annual total. Almost all the discrepancies identified between the invoices and reported figures were minor in nature and were not pervasive or representative of the whole carbon footprint report. In cases where discrepancies were identified, these were raised to the Trust for correction. In comparison to previous carbon footprint reporting, such issues have been reduced significantly indicating that the Trust has improved its emissions reporting and internal assurance practices. However, it is our recommendation that the Trust continues to undergo assurance to ensure errors are reduced to a minimum and that stakeholder confidence is maintained.
6.2. Data quality and data management recommendations
Based on the Trust’s current practices, EEVS has made a tiered set of recommendations for how the management and maintenance of data can be improved. These recommendations centre around the use of software and data collection strategies to help reduce reporting time and increase data quality. Each tier is more effective at energy data management than the next, however it will most likely require a higher financial expense from the Trust to achieve.
The first-tier data management recommendation, is the use of proprietary energy management software, licensed from a provider which will provide full integration across energy billing, validation and reporting. The second tier, , which is the least disruptive to the Trust’s current practices, will require changes to the manner in which data is organised and linked across spreadsheets.
6.2.1. Tier 1 – Use of Energy Management Software for Data Storage and Reporting
The collection and inventory of supplier data is a key component of correctly verifying the accuracy of the carbon footprint report. The Trust has a set of procedures in place for the storage and retrieval of energy data. In most cases where EEVS have made a request for data, the Trust has been able to locate and retrieve the required data within a short period of time. However, the use of energy and invoice management systems may allow the Trust to improve data quality and the speed of data retrieval. Electronic billing can be used to provide energy consumption details to the Trust, with the use of the ‘Electronic Data Interchange’. EDI is the computer to computer transfer of invoices between two organisations using an agreed industry standard. The EDI signal can be customised to contain the data of business documents, invoices, credit notes from an energy supplier.
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Typically, energy data and invoice management systems are used as a platform for aggregating and storing information stored within EDI signals. Considering SCFT’s large building portfolio, with certain sites being supplied by several meter points, energy management software may be an effective tool for managing and reporting energy consumption in a timely manner. The data can then be used for carbon footprint reporting purposes and the reporting of other energy reporting activities. The scope of the activities that can be completed with EMS extend beyond the scope of GHG reporting but include the following;
• Energy Procurement; • Utility Bill Validation; • Energy Performance, Targeting & Benchmarking; • Metering Data Storage (Fiscal and Sub-Meters); • Recharging of Utilities to internal or external Tenants;
Key Performance Indicators (KPI’s) can be readily integrated into most forms of energy management software, allowing The Trust to benchmark performance using presently used key metrics. Invoice validation and payment can also be automated with the use of energy management software. Utility billing system is capable of receiving electronic billing. Communication to the supplier data is achieved using EDI-enabled software. There are several companies and consultancies marketing such packages. These packages translate EDI data from the supplier into clear and understandable data for the Trust to use. This facility provides customers with billing data for internal use. It will convert an EDI file into a readable format that is user definable containing only the information that the customer requires.
An automatic data flow can be set up between the supplier’s systems and the Trust. Allowing for the automate transfer of billing information across platforms every month. This data can then be used to complete carbon footprint reports without the need for continuous time-consuming data entry of consumption figures allowing the Trust to process invoices as efficiently as possible. Aside from the introduction of data automation and energy management software, there are alternative means for SCFT to improve the quality and range of data that it collects, these include:
• Ensuring that a complete set of primary data is clearly linked to the calculations spreadsheets. Where required, this will allow the footprint calculations to be traced back to the primary data source in all cases;
• Working towards obtaining actual data for benchmarked sites.
Considering changes that take place in SCFT in portfolio, energy management software may be a viable option for storing and retrieving historic data. This becomes particularly pertinent when
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sites have been sold or have moved out of SCFT’s circle of control but historic data is still required for reporting purposes. Considering the wide range of energy reporting purposes that can be fulfilled by energy reporting software, the additional costs incurred by adopting such an approach may be worthwhile.
6.2.2. Tier 2 - Data inventory, Data entry and Data Storage recommendations for use of Microsoft Excel
Presently the Trust utilises Microsoft Excel spreadsheets across all its reporting data. Although this is a feasible option for such purposes, it can raise potential data issues. Consumption data is currently inputted manually into the bill logger from supplier invoices. These figures are then drawn into the master spreadsheet using VLOOKUP functions that are based on indexing information according to their location in a row. The bill logger itself is a large document containing all of the sites under SCFT’s management within individual tabs. The bill logger contains a summary tab which aggregates the site specific information before being called upon by the main master spreadsheet. Considering the importance of the link between the bill logger and master spreadsheet, it is the recommendation of EEVS that site name specific EXCEL formulas are used to differentiate between rows within the master spreadsheet. SCFT’s portfolio may change in future, these formulas with site specific and utility specific references will allow the layout changes in the master spreadsheet without a loss in data quality.
Navigation of the bill logger can also be improved by implementing hyperlinks on the summary tab. These links would allow direct movement to the required site for data retrieval and data checking purposes.
6.3. Energy emissions reporting recommendations
6.3.1. Electricity Transmissions and Distribution Emissions
Electricity consumption makes up a significant proportion of SCFT’s GHG emissions source, it is therefore important to correctly report this. Scope 3 emissions are all the other indirect emissions which are related to the reporting company’s activities, such as the emissions associated with electricity which is lost in the Transmission and Distribution (T&D) system used for delivering purchased electricity. For reporting organisations that purchase electricity from a T&D system, but do not own any part of that system, the emissions associated with T&D losses may optionally be reported under scope 3. These emissions are calculated by using a “T&D loss” emission factor. SCFT have taken steps to implement this entirely within their GHG reporting process. The T&D methodology has been verified and considered suitable by EEVS.
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7. Summary of issues resolved
The Trust has gone to great effort to collate all the available emissions data required to calculate its carbon footprint. Where required, the Trust has been able to supply primary data to EEVS for verification purposes. By completing the assurance exercise for 2016/17, EEVS insight has been able to identify the actions listed below that SCFT should consider to improve its footprint reporting.
The following issues were raised and corrected by the Trust over the course of the assurance.
• Data record incomplete: the master data sheet (or one of the calculation sheets which feeds the master sheet) was missing relevant data for a period of time during the reporting year.
• Missing evidence of data: consumption data recorded in the master data sheet (or one of the calculation sheets which feeds the master sheet) was not supported by copies of evidence (i.e. invoices etc.).
• Data record incorrect: the data had been copied from the evidence, or from another calculation sheet, incorrectly.
• Estimation calculation incorrect or incomplete: there was no estimation calculation, or there was an incorrect estimation calculation, used to fill a gap in the data.
• Organisation’s buildings portfolio record incorrect: the record of buildings under the organisation’s control was incorrect or unclear.
• Comments or colouring need updating: Comments were incorrect. • Spreadsheets not referencing the correct information from bill logger
These issues were identified as a result of SCFT seeking third party assurance. To ensure further issues are not missed in future, EEVS recommends that the assurance process remains in place for future carbon footprint
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8. Recommendations for on-going improvements to SCFT’s footprint process.
8.1. Expansion of the Assurance sample
Confidence intervals were set at 90% for the sampling required to complete the 2016/17 assurance. It is the recommendation of EEVS that as the Trust’s reporting processes improve over time, that the confidence interval required to achieve satisfaction be raised to over 95% of all emissions sources. To reach this level of assurance will require a more extensive assurance of SCFT’s sites and data points. EEVS Insight would be able to help the Trust in delivering this higher level of assurance confidence in future.
8.2. Uncertainty Analysis
Uncertainty analysis has been increasingly recognized as an important tool for improving an organisations inventories of GHG emissions and reductions. The process of completing an uncertainty analysis would provide the Trust with a more comprehensive understanding of the accuracy ranges of emissions inventories. Information garnered from such an analysis, would allow specific emissions activities to be targeted for greater data collection and management scrutiny. The level of scrutiny would be determined by ranking emissions sources according to their overall contribution to the emissions inventory and the overall uncertainty range. The results of such an analysis can be used to develop strategies for emissions reductions and to monitor the effectiveness of existing carbon abatement policies. More information can be gained on conducting an uncertainty analysis from GHG Protocol guidance on uncertainty assessment in GHG inventories.
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9. Sussex Community Foundation Trust’s on-going improvements to the footprint process. As part of a continual effort to maintain and improve the quality of Carbon Footprint reporting practices, SCFT will be undertaking the following EEVS approved activities due to be implemented in future reporting:
9.1. Oil calculation methodology
As part of the assurance, EEVS recommended the inclusion of a more detailed gas oil consumption inventory. SCFT are now considering two approaches for calculating gas oil consumption, with the intention of implementing an approach for future reporting. The first approach will use the volume of the oil tank and delivered oil volumes to calculated the oil consumed within a period of time. The second option will utilise the generator’s log book of monthly load readings. In future reporting, SCFT will proceed with the approach deemed most appropriate.
9.2. Expansion of Scope 3 emissions reporting
SCFT has identified that the scope of the Carbon Footprint could be expanded to include other aspects of the Trust’s emissions. The Foundation Trust has taken steps towards the calculation of emissions due to the procurement of medical equipment. The GHG emissions attributable to the procurement of medical goods and services forms a significant proportion of the environmental impact of SCFT.
In 2016, Environmental Resources Management was commissioned by the Sustainable Development Unit (SDU) to make an assessment of procured goods by hospitals. Sussex Community Foundation Trust has used this assessment to complete their initial analysis. However, due to the limitations of the tool SCFT will be exploring other options.
Sussex Community Foundation Trust are working towards developing an approach for the quantification of emissions attributable to the procurement of medical equipment by the Foundation Trust. SCFT will develop a bespoke tool capable of accurately reporting emissions specific to the characteristics of the Trust’s procurement activity.
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10. Benefits of independent assurance and continuous process improvement
Independent Carbon Footprint Assurance serves to increase the confidence that can be placed on GHG emission reports for decision-making purposes. Independent verification serves to ensure integrity in emissions base lining, tracking and reporting and that greenhouse gas emissions data and calculations are accurate and representative. It adds value to the information to be reported by identifying material departures or omissions from good practice reporting and suggesting corrections to the 2016/17 GHG emissions report. It has the additional long term aim of making lasting recommendations that improve reporting for future years.
In keeping with the carbon footprint verification procedure, EEVS Insight has issued SCFT with an assurance certificate, allowing the Trust to demonstrate its carbon footprint’s adherence to the principles of the Greenhouse Gas Reporting Standard. Certification is intended to be used as an official declaration to stakeholders of the carbon footprint report’s credibility. By measuring and reporting site emissions from year to year, SCFT are able to identify areas of emissions improvement. Insights from carbon footprint reports can be used to amend SCFT’s general carbon management strategy, aiding in its mission towards achieving its 2020 emissions target.
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11. Appendix 1 - Assurance Plan EEVS Insight have been engaged to perform a limited assurance of SCFT’s 2016/17 environmental data and performance. This responsibility includes the selection and application of the methods outlined below. Assurance objectives and criteria The objective of the assurance exercise is to ensure that the quantification of GHG emissions reported is reasonably near actual emissions, as far as can be judged statistically, and that uncertainties are reduced as far as is practical. Findings should be sufficiently precise to enable intended users to make decisions with reasonable assurance that the reported information is credible. These procedures have been defined in the context of SCFT’s current reporting practices, with the aim of providing recommendations which are practical and applicable. With guidance on how to improve and enhance a company’s GHG accounting and reporting system. This Assurance Plan has been structured in accordance with the five principles of the Greenhouse Gas Protocol.
• Relevance – Ensure SCFT’s GHG reporting reflects the GHG emissions of the Trust, providing internal and external decision makers the appropriate information to act upon.
• Completeness – Comprehensively review all GHG emission sources and activities within the agreed inventory boundary. Where specific exclusions exist, justified reasons have been provided for this.
• Consistency – Methodologies used are consistent, allowing direct comparisons over the reporting period to be made.
• Transparency – Data used for reporting purposes has a clear and defined audit trail. Assumptions made in the calculation methodologies are disclosed and referenced to appropriate sources.
• Accuracy – Reducing uncertainties within the best capability of the Trust, ensuring reported emissions are near actual emissions with a large degree of statistical confidence.
SCFT’s GHG report compliance with the principles outlined above will form the basis of our verification. Quality management procedures In keeping with these principles, our assurance process will consist of quality management procedures used to assess data and carbon footprint validity. These include,
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• Checking data has been correctly transcribed from invoices to GHG report, including ensuring that aggregation of data across source categories has been completed correctly. Ensuring the appropriate tier of data is being used, based on availability of data. • Assumptions and criteria for selection of boundaries, base years, activity data, emission factors, and other parameters are made using sound and appropriate methodology. • General methodology used is coherent throughout the footprint
Level of assurance The sample plan outlined below utilises statistical techniques to objectively select the sample population due to be audited as part of the assurance exercise. Although the sample has been designed to be representative of the total population, it should be noted that total assurance is not possible. The assurance exercise completed for SCFT’s 2014/15 carbon footprint was limited to an objectively selected 10% of all emissions sources. This year as part of SCFT’s effort towards continual improvement in carbon footprint assurance practices, the sample size will be based on the following statistical criteria. Statistical Criteria To design the sample due to be audited, EEVS will be considering four statistical properties, the population size, confidence level, precision and the Coefficient of Variation. Each parameter will be based on GHG assurance best practices, inquiries from SCFT, and prior GHG assurance exercises. • Population - The population contains all emission sources to be considered for testing. Each
will have an unbiased chance of selection to ensure the final sample is representative of the population.
• Confidence Level - The sample's confidence level refers to the reliability that can be placed on the sample results. Typically, confidence levels of 90 percent to 99 percent are used. For the purposes of this exercise, EEVS Insight intends to set the confidence level at 90 percent in the emissions. Hence, sampling risk has been set to a conservative 10 percent.
• Precision - A measure of the possible difference between the sample estimate and the actual population value-the better the design, the less margin of error, smaller sample size required. The rate has been based on EEVS observations of SCFT reporting processes and prior year assurance results.
• Coefficient of Variation - Based on the statistical inputs above the sample size needed to
achieve the required precision depending on the population proportion using random sampling.
Materiality Materiality is required to quantify changes made due to the completion of the assurance exercise. In order to determine the point at which a discrepancy is considered material, EEVS as verifier has set the threshold at 5 %. Previous carbon footprint verifications completed for SCFT have used the same materiality threshold, and it is EEVS judgement that this is still suitable.
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12. Appendix 2 - Data sources reviewed
Footprint area Site Document/Folder containing invoices Gas East Grinstead Health Clinic Gas (Excel file) Gas Lancing Health Centre Gas (Excel file) Gas Morley St School Clinic Morley Street_Gas (Folder) Gas Heathfield Community Centre Gas (Excel file) Gas Bognor Health Centre Gas (Excel file) Gas Horsham Hospital Gas (Excel file) Gas Salvington Lodge Gas (Excel file) Gas Zachery Merton Hospital Gas (Excel file) Gas Shoreham Health Centre Gas (Excel file) Electricity Brighton General Hospital Brighton General Hospital_Elec (Folder) Electricity Brighton General Hospital British Gas consolidated Electricity Lewes Victoria Hospital Electricity (Excel file) Electricity Horsham Hospital Electricity (Excel file) Electricity Nightingale Primary Care
Centre Electricity (Excel file)
Electricity Folders Lane (Finches) British Gas consolidated (Folder) Electricity Morley St School Clinic British Gas consolidated Electricity Conway Court British Gas consolidated Water/Wastewater Morley St School Clinic Morley Street_Water (Water) Water/Wastewater Moulsecoomb Health Centre Moulsecoomb HC_Water (Folder) Water/Wastewater Moulsecoomb Children’s
Centre Moulsecommb_CC_Water
Water/Wastewater Haywards Heath Health Centre Water (Excel file) Water/Wastewater Newhaven RC & PC Water (Excel file) Water/Wastewater East Grinstead Health Centre Water (Excel file) Water/Wastewater Lancing Health Centre Water (Excel file) Water/Wastewater Moulsecoomb Children’s
Centre Water (Excel file)
Water/Wastewater Crawley Hospital Water (Excel file) Transport - Owned All sites OWN Carbon Report - 2016-17 Actual Transport - Leased All sites LEASED Carbon Report- 2016-17 Actual Master sheet All sites SCFT 2016-2017 CARBON PERFORMANCE REPORT
V1.7 Calculation sheet All sites Bill Logger 2016-17 V1.1 Transport All sites Travel Transactions 2016-17 full year