GHG Protocol Guidelines Open to Improvement

Greenhouse Gas Protocol is surveying stakeholders on the need for updates or additional guidance related to GHG Protocol’s reporting standards. IEMA members attended a workshop during which this was debated and IEMA has submitted the findings to GHG Protocol. In this blog, Chloë Fiddy, IEMA’s Policy and Engagement lead on climate change and energy matters, reports on the key issues that IEMA members raised.

The workshop concluded that while the GHG Protocol has a solid foundation, improvements are needed to streamline the process and provide clarity to make it more accessible, prescriptive, and consistent.

One of the main areas for improvement is the length and complexity of the guidance. Complexity can lead to inconsistent and unrepeatable reporting which in turn undermines the reported outcomes, so overall, a more concise and prescriptive approach would improve the guidance.

Simple suggestions for clarifying the guidance include (in no particular order):

• Reducing the jargon and summarizing instructions
• Providing a list of examples for categorising out-of-scope emissions
• Providing worked examples and case studies
• Creating a special guide and reporting standard for SMEs, in acknowledgment of the fact that SMEs are increasingly being required to report on their GHG emissions to secure access to supply chains.
• How to treat working from home

Other matters which will require more detailed debate and international agreement include:

• Sector-specific guidance, noting that many sectors are writing their own guidance
• Defining and clarifying control within joint ventures
• Defining and clarifying control for arrangements such as facilities management where ownership of data and control can be blurred
• Guidance for outsourced projects

• Stratifying sample types by typology
• Accounting for embodied carbon
• Providing guidance (and possibly restrictions) on Scope 4 value chain emissions
• Clarity on treatment of market-based and location-based emissions, to avoid the risks of double or under-counting and greenwashing

Developing these more nuanced matters should not escape rigorous debate and clarity of output. As recognised by GHG Protocol, GHG accounting is increasingly being used as the foundation for transition planning. In turn, transition planning is intended to inform financial decision making. As the basis of investment-grade data, GHG accounting must be as rigorous as financial accounting, leaving no space for grey areas.