Greenhouse Gas Emission and Environmental Reporting for Transport

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1 . Introduction This briefing note provides information on the Government requirements for mandatory greenhouse gas (GHG) reporting for quoted companies and its recommendations for voluntary GHG reporting and environmental impact reporting. It also provides advice on how the Logistics Carbon Reduction Scheme can help fleet operators to record and report. Background From 30 September 203, the Companies Act 2006 (Strategic Report and Directors Reports) Regulation 203 requires quoted companies to report on greenhouse gas (GHG) for which they are responsible in their annual Company Strategic Report. In 205, the Department for Environment, Food and Rural Affairs (Defra) will review whether to bring large companies under the mandatory requirements. In the meantime, companies that are outside of the mandatory scope are encouraged to voluntarily report their GHG. Additionally, quoted companies are also required to report on the impact of their business on the environment within their strategic report including, where appropriate, the use of key performance indicators (KPIs). Previously, a company s Director report included a business review. Following a review by Department for Business, Innovation and Skills (BIS), the business review will be replaced by the strategic report from October Mandatory GHG reporting requirements more detail From 30 September 203, the Companies Act 2006 (Strategic Report and Directors Reports) Regulation 203 requires quoted companies to report on greenhouse gas (GHG) for which they are responsible in their annual Company Strategic Report. This regulation was introduced in accordance with Climate Change Act 2008 requirements. A quoted company is defined as a company that is UK incorporated and whose equity share capital is listed on the Main Market of the London Stock Exchange UK or in an EEA State, or admitted to trading on the New York Stock Exchange or Nasdaq. Quoted companies that provide distribution services will have to incorporate the associated with this activity in their company reporting. According to Defra, approximately,00 companies are expected to be affected by the regulation with around two-thirds already reporting voluntarily. Defra believes that companies publicly disclosing GHG emission data will provide investors and other stakeholders with the information they need to fully take account of climate change risks in their investment decisions. The benefits of recording and reporting greenhouse gas (GHG) Many logistics companies record and report their greenhouse gas on a regular basis. Some even publicise the results in Corporate and Social Responsibility Reports. The need to report is also becoming part of the procurement criteria. There are numerous benefits to recording and reporting such as: identifying any inefficiencies or wasteful practices within a business demonstrating to customers and suppliers that effective measures are being taken to tackle providing an opportunity to benchmark and compare performance with other organisations or areas of the business familiarising businesses with reporting practices in a timely fashion as wider scale mandatory reporting could be introduced in future providing a better understanding of exposure to the risks of climate change in some cases As defined in Companies Act 2006, a large company must meet two of the following criteria over 250 employees, annual turnover over 25.9 million, balance sheet over 2.9 million

2 Start of company reporting The start of a company s mandatory reporting will depend on its financial year. Usual financial year First reporting year under the regulation January to 3 January 203 to 3 December December 203 April to 30 March April 203 to 30 March 204 October to 30 October 202 to 30 September September 203 Defra accepts that companies may be required to report data on that have occurred before the regulation was made. If this is the case, companies will be expected to provide an estimate of the data or give an explanation as to why the data is not reported. Data collection period Companies are requested to collect for the period corresponding with their financial year. However, if a company has historically reported data on a calendar year basis, it may continue to do so but this must be stated in the Director s report. GHG covered by the mandatory requirements Companies will be required to report on their GHG from activities for which they are responsible such as distribution. However, the Directors report may contain information relating to operations covered by the financial statement but the company may consider that it is not responsible for, for example in the case of a subsidiary. Companies should therefore provide a clear understanding of the operations for which data has been reported and if and how this differs from operations within the consolidated financial statement. Companies are required to quantify and report on of the following six Kyoto greenhouse gases carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), hydroflurocarbons (HFCs), perflurocarbons (PFC) and sulphur hexafluoride (SF 6 ). Individual figures for of each of the GHGs listed are not required and few companies will emit all of the GHGs listed. Instead, companies must state in the Directors report the annual quantity of GHG in tonnes of carbon dioxide equivalent (CO 2 e). Emission scope The following emission sources must be reported. Area Combustion of fuel Operation of any facility Requirement Examples Stationary combustion Boilers, furnaces, burners, turbines, heaters, incinerators, Mobile combustion Process : from physical or chemical processes Fugitive : intentional and unintentional releases Electricity 2 engines Cars, vans, hgvs, buses, trains, airplanes, boats, ships, barges, vessels CO 2 from the calcination step in cement manufacturing Equipment leaks from joints, seals, packing, gaskets, coal piles, wastewater treatment, pits, cooling towers Heat, steam, cooling Quoted logistics companies that operate their own commercial vehicles will need to report transport as part of their. Companies are not required to report on other associated with inputs into the company (such as from their supply chains) or linked with outputs from their company (such as from your products when they are used by their customers). These are known as 3. For example, if a company subcontracts its distribution to another company, it would not be required to report the subsequent from this. However, Defra encourages companies to report 3 to give a more accurate picture of. For example, a retailer covered by the 2

3 regulations that sub-contracts all their distribution may wish to request information from the transport of their goods from their sub-contractor for 3 purposes as additional non-mandatory information. But if the retailer was responsible for some of its own distribution, it would still be legally obliged to report within their. Companies are expected to make every reasonable effort to acquire all material data to comply with the regulations. However, there may be circumstances where it is difficult to compile all necessary data. If a company is in a situation where they cannot report on all material for which they are responsible, the omissions and an explanation must be stated in the Directors report. GHG methodology There is no prescribed methodology under the regulations but it is important that robust and accepted methods are used. The following are recommended standards from Defra. ISO 4062 Greenhouse gases. Part (2006) Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard Climate Disclosure Standards Board Climate Change Reporting Framework Global Reporting Initiative (GRI) Sustainability Reporting Guidelines Part of the ISO 400 series for international standards for environmental standards Led by the World Resources Institute and World Business Council for Sustainable Development Voluntary reporting framework created in line with the objectives of financial reporting and rules on non-financial reporting, GRI provides all companies and organisations with a comprehensive sustainability reporting framework that is widely used around the world. Companies already taking part in domestic and international regulatory reporting processes may use the information to fulfil mandatory reporting obligations. For example, data from Climate Change Agreements, EU Emissions Trading Scheme, Carbon Reduction Commitment Energy Efficiency Scheme. Intensity ratios Directors reports must express by way of an intensity ratio. Intensity ratios compare data with an appropriate business metric or financial indicator, such as sales revenue or turnover. This allows comparison of performance over time. Suggested intensity measurements for transport are tonnes of CO 2 e per kilometre and tonnes of CO 2 e per pallet cases. Data verification There is no requirement in the regulations for emission data to be independently verified or assured but is recommended. Enforcement As the regulations are made under the Companies Act 2006, the Conduct Committee of the Financial Reporting Council is responsible for monitoring compliance of company reports and accounts with relevant reporting requirements of that act. Example corporate GHG report The below table shows the data-points that are required under the regulation and is an example of how can be reported. Global GHG data for period April 204 to 3 March 205 Tonnes of CO 2 e Current reporting year Comparison year Emissions from: Combustion of fuel & operation of facilities Electricity, heat, steam and cooling purchased for own use Company s chosen intensity measurement: Emissions reported above normalised to per tonne of product output 8,00,700 4,500 5,

4 Methodology We have reported on all of the emission sources required under the Companies Act 2006 (Strategic Report and Directors Reports) Regulations 203. These sources fall within our consolidated financial statement. We do not have responsibility for any emission sources that are not included in our consolidated statement. Summary of mandatory GHG requirements Companies may use a reporting time period that does not correspond with their financial report, but must state if they have done so Companies must report on from activities for which they are responsible Companies must report on all material of the six Kyoto GHG gases from direct sources and from purchased electricity, heat, steam and cooling ( and 2) No specific methodology for reporting is prescribed but quoted companies should state which methodologies they have used to calculate GHG With the exception of the first mandatory reporting year, companies must repeat the data disclosed in their previous report alongside information on from the present year Companies must express their annual using at least one intensity ratio related to their activities Verification of the data is not mandated but is encouraged 3. Voluntary GHG reporting guidelines Logistics companies which do not fall under the mandatory GHG reporting requirements are encouraged to report voluntarily using the same reporting principles. Advice on voluntarily reporting GHG is featured in Defra s Environmental Reporting Guidelines. Additionally, Carbonfta provides a section on Carbon Reporting Management. Key elements of a carbon management plan A management plan to reduce carbon dioxide from supply chain operations should consist of three stages: Stage record in a systematic way so as to establish a reliable baseline against which progress may be measured Stage 2 report in consistent units that allow comparison within and between businesses for benchmarking purposes Stage 3 reduce through the adoption and implementation of tactical actions intended to improve operational efficiency and strategic actions that make structural changes to existing operational practices 4. Logistics Carbon Reduction Scheme The Logistics Carbon Reduction Scheme (LCRS) is a voluntary UK initiative to record, report and reduce carbon managed by FTA. The scheme was endorsed by the Department for Transport in 20. More recently, the LCRS submitted evidence to Government's Freight Carbon Review. This directly resulted in Government's decision to continue to support a voluntary approach to carbon reduction from freight transport. In July 203, membership of the scheme had grown to over 85 companies including 3PLs, retailers, local authorities and waste companies, operating some 62,000 commercial vehicles. The scheme is free to join and open to any company that has at least one commercial vehicle. LCRS members submit fuel data (eg litres of diesel) and other business related activity data to FTA on a confidential basis either annually or quarterly. FTA then aggregates the data to produce a carbon footprint for the scheme. In this way, we can track the progress that industry is making to reduce its 4

5 . By joining the LCRS, members can demonstrate their green credentials and commitment to reducing carbon from freight transport. Using the LCRS to help you report your The LCRS can help fleet operators who are just beginning to record and report their carbon. The data requirements match voluntary reporting requirements and Defra conversion factors are applied to produce a carbon footprint for the scheme. Data collected by the LCRS Litres of diesel and other fuels Vehicle fleet Vehicle km Turnover FTE Fleet operators can use their data collection process for the LCRS to contribute to their overall businesses carbon reporting, whilst also supporting an industry wide initiative to reduce. Example from LCRS datasheet for 203 Fuel consumption 00,000 litres of diesel 00,000 x (conversion factor) = 260,080kg or 260 tonnes CO 2 e 20,000 litres of petrol 20,000 x = 44,288kg or 44 tonnes CO 2 e 0,000 litres of gas oil 0,000 x = 29,343kg or 29 tonnes CO 2 e Vehicle km total 333,000 kg of CO 2 e or 333 tonnes CO 2 e Average kg of CO2e per vehicle km 333,000 kg of CO 2 e /525,000 vehicle km = 0.63 Conversion factors taken from 203 Defra Guidelines available to download from 5. Environmental reporting requirements Quoted companies are required to report on the impact of their business on the environment within the Directors report including at least three key performance indicators (KPIs) associated with key environmental impacts. However increasingly, companies out of scope of the mandatory requirements may wish to also report to customers and investors on the impact of their operations on the environment. Companies might wish to consider water, waste and materials. Additionally, Defra s Environmental Reporting Guidelines also provides advice on reporting on the impacts of air quality from freight transport. As it is difficult to capture reliable nitrous oxide and particulate matter emission data, it is suggested that fleet operators could report the number of owned vehicles within each Euro Standard category to demonstrate that the company is contributing to improving air quality. For further information, see Defra s environmental guidelines. 6. Conversion factors Defra has published 203 conversion factors to enable companies to calculate greenhouse gas from fuel and energy usage. The conversion factors are available via a web-based tool which allows users to specify their own set of conversion factors. FTA has a short user guide to conversion factors available to download from 7. Further resources Logistics Carbon Reduction Scheme Carbonfta Defra 203 conversion factors Defra Environmental Reporting Guidelines: Including mandatory greenhouse gas reporting guidance https://www.gov.uk/government/publications/environ mental-reporting-guidelines-including-mandatorygreenhouse-gas--reporting-guidance 5

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