IEMA Concerned New Defra Guidance Could Lead to Carbon Reporting Confusion

Following the launch of a Defra consultation on new corporate Greenhouse Gas reporting guidance for accounting renewable or ‘green’ electricity tariffs, IEMA has expressed concern that revised guidance could lead to confusion around how organisations report their carbon emissions and, in some cases, potentially under-represent actual corporate emissions.

Commenting on the launch of the consultation, Nick Blyth, IEMA Policy and Practice Lead, said: “The consultation is proposing significant changes to guidance which will directly affect many businesses and public sector organisations that now report their GHG emissions. We are encouraging all environment and sustainability professionals in the UK to review the consultation and to respond directly to Defra’s short survey.”

Defra’s widely-used 2009 GHG reporting guidance advises that all affected organisations should report electricity consumption using the grid average emission factor and only allows any reduction in net emissions if a purchased tariff demonstrates clear additional carbon reduction. Many practitioners feel this approach has been suitable in the UK, where public funding has been a leading driver in securing electricity generation from renewable sources. However some organisations would like to report the zero carbon generation characteristics for renewable ‘green’ tariff electricity that they purchase. Defra is proposing to enable such reporting and is consulting on two options.

• In Option 1, Gross GHG emissions are still calculated and presented using the grid-average factor. However if the organisation purchases ‘green’ renewable based electricity tariffs then ‘zero carbon’ characteristics can now be accounted in the net emissions figure (i.e. they can reduce net emissions along with other actions taken by the organisation).
• In Option 2, the zero carbon characteristics of a purchased ‘green’ renewable electricity tariff will be allowed to factor in gross emissions as well as in net emissions. The organisation will report 2 figures for emissions side-by-side and if using net and gross lines 4 values will be reported.

Both options demonstrate a significant shift from the 2009 guidance which is widely used in both the public and private sectors. IEMA believes that Option 1 will be a more proportionate change. Blyth states that IEMA is “concerned that Option 2 could be confusing”. “It gives a disproportionate value for green renewable electricity tariffs ahead of other net reduction measures,” said Blyth. IEMA is also aware of further concerns that Option 2 may act as a disincentive to energy efficiency or other important at source reductions.

IEMA is keen to ensure that Members are aware of these potentially significant changes to the guidance and is encouraging its members and all other Environment & Sustainability Professionals to respond to the consultation before it closes on Monday 24^th March.