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WEBINAR 24 OCTOBER 2012




Introduction to the Draft Greenhouse Gas
Emissions (Director’s Report) Regulations
2013

Lois Guthrie, Executive Director
Climate Disclosure Standards Board




                                            @CDSBGlobal
Q&As from the last webinar

  cdsb.net/ukghgqa

  • Timing
  • Verification and enforcement
  • Methodologies
  • Reporting boundaries
  • Reporting practices
     • Breakdown
     • Narrative
  • Harmonization
  • Geographical limits to reporting?


                                        @CDSBGlobal
CDP & CDSB joint response to DEFRA Consultation

  cdsb.net/UKGHGConsultationResponse




                                                  @CDSBGlobal
And…..




  •A round table meeting

  •More questions

  •Update to the CDSB Climate Change Reporting Framework
                                                           @CDSBGlobal
A recap - What’s in the regulation?
       Companies within scope – Quoted companies (per section 385 of the Companies Act
       2006)

       Disclosures (Reg 3)
           GHG emissions (CO2, CH4, N2O, HFCs, PFCs, SF6)
                 Stationary & mobile combustion
                 Manufacturing processes
                 Fugitive emissions
                 Purchased electricity, heat, steam or cooling

            Calculation methodology (including for activities subject to other reporting
            regulation (Regs 4 & 5)

            Intensity ratio (Reg 6)

            First year information (Reg 7(2))

            Changes in information for first reporting year (Reg 7(3))

            Period for which GHG emissions are reported IF different from director’s report
            period (Reg 7(4)

                                                                                     @CDSBGlobal
Upcoming UK regulation mandating GHG emissions reporting:
                                  your questions answered



  Lois Guthrie         Gordon Wilson             Jenny Harrison            Stuart Wright             Chris Havers          Mardi McBrien
Executive Director, Chairman, CDSB Technical        Director                   Manager           Senior Account Manager,   Managing Director,
                         Working Group;      Sustainability Services,   Sustainability Services,
      CDSB                                                                                                 CDP                  CDSB
                     Senior Manager, Climate      Deloitte LLP,              Deloitte LLP,
                             Change           UK lead for carbon &        UK lead for carbon
                        and Sustainability,
                                              integrated reporting        carbon footprinting
                         KPMG LLP,UK


                                                                                                                       @CDSBGlobal
Boundaries

   Reg 3(1) – a directors report must state the annual quantity of emissions….resulting
   directly from the following activities undertaken by the company….

   (a) Combustion of fuel in any premises, machinery or equipment operated, owned or
       controlled by the company;
   (b) The use of any means of transport, machinery or equipment operated owned or
       controlled by the company;
   (c) The operation or control of any manufacturing process undertaken by the
       company

  Section 415(2) - for a financial year in which the company is a parent company and the
  directors require group accounts, the directors’ report must be a consolidated report
  relating to the undertakings included in the consolidation

   Do activities that are operated owned or controlled go into the consolidated report?



                                                                              @CDSBGlobal
Materiality


   “We recommend     that UK Government’s Guidance helps
   companies to understand whether and to what extent they
   are entitled or required to apply materiality determinations
   or de-minimis criteria in preparing GHG emissions results for
   inclusion in the Directors’ Report”.


   Only to the extent necessary for an understanding of the
   performance, position or development of the company?




                                                            @CDSBGlobal
Regulation 5

    “A directors’ report must state if relevant information included in the report
    was obtained as a result of the company’s compliance with………the CRC
    Energy Efficiency Scheme Order 2010”


    GHG Directors’ Report Regs               CRC Scheme


    Global in scope                          UK only


    GHG emissions per financial              Based on who pays the electricity
    consolidation                            bill




    Will adjustment be required or will CRC Scheme information be treated as
    representing compliance?

                                                                               @CDSBGlobal
Mandatory carbon reporting – key requirements

                             Announced by Nick Clegg at Rio + 20 in June


                 Scope - all UK incorporated quoted companies… (CA 06 definition) ie
with equity shares listed on main market of London Stock Exchange, EEA regulated, NYSE or NASDAQ



                            Scopes1 and 2 ie
                                                         Boundary issues
   Global carbon           direct emissions and
                                                          likely – financial
footprint (numerical)          indirect (from                                           Intensity ratio
                                                        consolidation rather
    disclosure in              consumption).                                               required
                                                         than operational
  directors’ report          Scope 3 remains
                                                                control
                                 voluntary



                  Consultation period (on draft statutory instrument) ends 17 October


                    Effective date – periods ending after April 2013 or October 2013



             In 2015 Government will consider expanding to all large companies from 2016

                                                                               Source: Deloitte LLP
Carbon footprint reporting – discussion points
Key issues around reporting
    •   What is the boundary for reporting?
    •   How will you collate the information? Are some countries going to be harder than others? Do
        you need a better process or to train your people?
    •   How can you get it in time for publication within the annual report?
    •   How robust is the data? You need appropriate controls, systems, validation checks
    •   Who will be responsible for producing this information and for managing performance?
    •   How will you inform the Audit Committee and get their input as to what they will want to see in
        order to feel satisfied things are under control?
    •   How will you consider assurance? Will you audit the information internally or seek independent
        assurance before this information is published in the annual report?


Key issues regarding the data
    -   Now you have to measure this, how will you then use the information?
    -   How can you get the value from doing this?..




                                                                                Source: Deloitte LLP
Disclosure rates from UK plc in 2012


   Total Response rate in the FTSE index

   • FTSE 100 – 96% - (Highest level of response ever)
   • FTSE 350 – 68%

   238 companies are disclosing emissions related data and much more in the
   FTSE main market. With a further 31 FTSE listed businesses outside of the
   FTSE 350 disclosing.

   A wealth of information is available for businesses who currently do report,
   and those who do not report.

   CDP is here to share the information and promote best practice in report with
   the power of climate data.




                                                                             @CDSBGlobal
Emissions Boundaries used in the FTSE 600




                                       Financial control

                                       Operational control

                                       Other

                                       Equity share

                                       Climate Change Reporting
                                       Framework (CCRF)




                                                                  @CDSBGlobal
Verification – Basic stats from the FTSE 600




 Scope 1                        Scope 2




                                               @CDSBGlobal
FTSE 600 - Intensity breakdown


                                 Not Specified
                                 unit of production
                                 square meter
                                 megawatt hour (MWh)
                                 square foot
                                 Other
                                 metric tonne of product
                                 passenger kilometer
                                 billion (currency) funds under management
                                 unit hour worked
                                 kilometer
                                 barrel of oil equivalent (BOE)
                                 unit of service provided
                                 liter of product




                                                                  @CDSBGlobal
Consumer Discretionary - Breakdown of Intensities                Not Specified

                                                                 unit of production

                                                                 square meter

                                                                 megawatt hour (MWh)

                                                                 square foot

                                                                 Other

                                                                 metric tonne of product

                                                                 passenger kilometer

                                                                 billion (currency) funds under
                                                                 management
                                                                 unit hour worked

                                                                 kilometer
Examples of ‘Other’ categories
                                                                 barrel of oil equivalent (BOE)
- per housing unit completed, - Unit of sold items, - per 1000
sq ft of salesfloor, - per retail Outlet
(Pub/Hotel/Restaurant), - Per cremation and funeral, -
Number of Set Top Boxes in customer homes


                                                                                      @CDSBGlobal
Consumer Discretionary - Breakdown of Intensities




                                                            Not Specified
                                                            unit of production
                                                            Other
                                                            metric tonne of product




  Examples of ‘Others’ categories

  - 000 tonnes of ore milled, - Ounces of PGM produced, - metric
  tonnes CO2e (net) per tonne of cementitious product, - tonne of
  fine Copper




                                                                                      @CDSBGlobal
YOUR
QUESTIONS

            @CDSBGlobal
Spotlight on leases

 A property investor owns property and
 lets it on full repairing and insuring
 lease. The landlord has minimal
 involvement and the tenants pay all the
 energy bills.

 Does the property investor need to
 report GHG emissions from the tenants’
 energy use?




                                           @CDSBGlobal
Calculation methodologies




                            @CDSBGlobal
Business Review vs Strategic Report Content Requirements
    Business Review                                                             Strategic Report

    A fair review of the company’s business (417(3)(a))                         No change (414C(2)(a))

    A description of the principal risks and uncertainties facing the company   No change (414C(2)(b))
    (417(3)(b))
    Balanced & comprehensive analysis of …development & performance….           No change (414C(3)(a))
    during the financial year (417(4)(a)

    Balanced and comprehensive analysis of he position of the business at       No change (414C(3)(b))
    the end of the year (417(4)(b))
    Quoted companies only – main trends and factors likely to affect the        No change (414C(4)(c))
    future development, performance and position of the business (419(5)(a))
                                                                                A description of the company’s strategy
                                                                                (414C(4)(a))
                                                                                A description of the company’s business
                                                                                model (414C(4)(b))
    Quoted cos - Information about environmental matters (417(5)(b)(i))         No change (414C(d)(i))
    Quoted cos - Information about he company’s employees (417(5)(b)(ii)        No change (414C(d)(ii))
    Quoted cos - Information about social and community issues                  Social, community & human rights issues
    (415(5)(b)(iii))                                                            (414C(d)(iii))
    Essential contractual arrangements (417(5)(c))                              Deleted
                                                                                A breakdown of the number of persons of
                                                                                each sex who are employees, directors
                                                                                and managers
                                                                                                          @CDSBGlobal
Thank you!

Lois Guthrie
   CEO
   lois.guthrie@cdsb.net
   Office: + 44 (0) 20 7415 7180 | Mobile: + 44 (0) 7740 988 391

Mardi McBrien
   COO
   mardi.mcbrien@cdsb.net
   Office: + 44 (0) 20 7415 7180 | Mobile: + 44 (0) 7920 463 046
   Skype: mardi.mcbrien.cdp.cdsb

                            www.cdsb.net | @CDSBGlobal
         Carbon Disclosure Project, Registered Charity no. 1122330. A company limited by guarantee registered in England no. 05013650.




                                                                                                                                         @CDSBGlobal
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Introduction to the draft greenhouse gas emissions(director's report) regulations

  • 1. WEBINAR 24 OCTOBER 2012 Introduction to the Draft Greenhouse Gas Emissions (Director’s Report) Regulations 2013 Lois Guthrie, Executive Director Climate Disclosure Standards Board @CDSBGlobal
  • 2. Q&As from the last webinar cdsb.net/ukghgqa • Timing • Verification and enforcement • Methodologies • Reporting boundaries • Reporting practices • Breakdown • Narrative • Harmonization • Geographical limits to reporting? @CDSBGlobal
  • 3. CDP & CDSB joint response to DEFRA Consultation cdsb.net/UKGHGConsultationResponse @CDSBGlobal
  • 4. And….. •A round table meeting •More questions •Update to the CDSB Climate Change Reporting Framework @CDSBGlobal
  • 5. A recap - What’s in the regulation? Companies within scope – Quoted companies (per section 385 of the Companies Act 2006) Disclosures (Reg 3) GHG emissions (CO2, CH4, N2O, HFCs, PFCs, SF6) Stationary & mobile combustion Manufacturing processes Fugitive emissions Purchased electricity, heat, steam or cooling Calculation methodology (including for activities subject to other reporting regulation (Regs 4 & 5) Intensity ratio (Reg 6) First year information (Reg 7(2)) Changes in information for first reporting year (Reg 7(3)) Period for which GHG emissions are reported IF different from director’s report period (Reg 7(4) @CDSBGlobal
  • 6. Upcoming UK regulation mandating GHG emissions reporting: your questions answered Lois Guthrie Gordon Wilson Jenny Harrison Stuart Wright Chris Havers Mardi McBrien Executive Director, Chairman, CDSB Technical Director Manager Senior Account Manager, Managing Director, Working Group; Sustainability Services, Sustainability Services, CDSB CDP CDSB Senior Manager, Climate Deloitte LLP, Deloitte LLP, Change UK lead for carbon & UK lead for carbon and Sustainability, integrated reporting carbon footprinting KPMG LLP,UK @CDSBGlobal
  • 7. Boundaries Reg 3(1) – a directors report must state the annual quantity of emissions….resulting directly from the following activities undertaken by the company…. (a) Combustion of fuel in any premises, machinery or equipment operated, owned or controlled by the company; (b) The use of any means of transport, machinery or equipment operated owned or controlled by the company; (c) The operation or control of any manufacturing process undertaken by the company Section 415(2) - for a financial year in which the company is a parent company and the directors require group accounts, the directors’ report must be a consolidated report relating to the undertakings included in the consolidation Do activities that are operated owned or controlled go into the consolidated report? @CDSBGlobal
  • 8. Materiality “We recommend that UK Government’s Guidance helps companies to understand whether and to what extent they are entitled or required to apply materiality determinations or de-minimis criteria in preparing GHG emissions results for inclusion in the Directors’ Report”. Only to the extent necessary for an understanding of the performance, position or development of the company? @CDSBGlobal
  • 9. Regulation 5 “A directors’ report must state if relevant information included in the report was obtained as a result of the company’s compliance with………the CRC Energy Efficiency Scheme Order 2010” GHG Directors’ Report Regs CRC Scheme Global in scope UK only GHG emissions per financial Based on who pays the electricity consolidation bill Will adjustment be required or will CRC Scheme information be treated as representing compliance? @CDSBGlobal
  • 10. Mandatory carbon reporting – key requirements Announced by Nick Clegg at Rio + 20 in June Scope - all UK incorporated quoted companies… (CA 06 definition) ie with equity shares listed on main market of London Stock Exchange, EEA regulated, NYSE or NASDAQ Scopes1 and 2 ie Boundary issues Global carbon direct emissions and likely – financial footprint (numerical) indirect (from Intensity ratio consolidation rather disclosure in consumption). required than operational directors’ report Scope 3 remains control voluntary Consultation period (on draft statutory instrument) ends 17 October Effective date – periods ending after April 2013 or October 2013 In 2015 Government will consider expanding to all large companies from 2016 Source: Deloitte LLP
  • 11. Carbon footprint reporting – discussion points Key issues around reporting • What is the boundary for reporting? • How will you collate the information? Are some countries going to be harder than others? Do you need a better process or to train your people? • How can you get it in time for publication within the annual report? • How robust is the data? You need appropriate controls, systems, validation checks • Who will be responsible for producing this information and for managing performance? • How will you inform the Audit Committee and get their input as to what they will want to see in order to feel satisfied things are under control? • How will you consider assurance? Will you audit the information internally or seek independent assurance before this information is published in the annual report? Key issues regarding the data - Now you have to measure this, how will you then use the information? - How can you get the value from doing this?.. Source: Deloitte LLP
  • 12.
  • 13. Disclosure rates from UK plc in 2012 Total Response rate in the FTSE index • FTSE 100 – 96% - (Highest level of response ever) • FTSE 350 – 68% 238 companies are disclosing emissions related data and much more in the FTSE main market. With a further 31 FTSE listed businesses outside of the FTSE 350 disclosing. A wealth of information is available for businesses who currently do report, and those who do not report. CDP is here to share the information and promote best practice in report with the power of climate data. @CDSBGlobal
  • 14. Emissions Boundaries used in the FTSE 600 Financial control Operational control Other Equity share Climate Change Reporting Framework (CCRF) @CDSBGlobal
  • 15. Verification – Basic stats from the FTSE 600 Scope 1 Scope 2 @CDSBGlobal
  • 16. FTSE 600 - Intensity breakdown Not Specified unit of production square meter megawatt hour (MWh) square foot Other metric tonne of product passenger kilometer billion (currency) funds under management unit hour worked kilometer barrel of oil equivalent (BOE) unit of service provided liter of product @CDSBGlobal
  • 17. Consumer Discretionary - Breakdown of Intensities Not Specified unit of production square meter megawatt hour (MWh) square foot Other metric tonne of product passenger kilometer billion (currency) funds under management unit hour worked kilometer Examples of ‘Other’ categories barrel of oil equivalent (BOE) - per housing unit completed, - Unit of sold items, - per 1000 sq ft of salesfloor, - per retail Outlet (Pub/Hotel/Restaurant), - Per cremation and funeral, - Number of Set Top Boxes in customer homes @CDSBGlobal
  • 18. Consumer Discretionary - Breakdown of Intensities Not Specified unit of production Other metric tonne of product Examples of ‘Others’ categories - 000 tonnes of ore milled, - Ounces of PGM produced, - metric tonnes CO2e (net) per tonne of cementitious product, - tonne of fine Copper @CDSBGlobal
  • 19. YOUR QUESTIONS @CDSBGlobal
  • 20. Spotlight on leases A property investor owns property and lets it on full repairing and insuring lease. The landlord has minimal involvement and the tenants pay all the energy bills. Does the property investor need to report GHG emissions from the tenants’ energy use? @CDSBGlobal
  • 22. Business Review vs Strategic Report Content Requirements Business Review Strategic Report A fair review of the company’s business (417(3)(a)) No change (414C(2)(a)) A description of the principal risks and uncertainties facing the company No change (414C(2)(b)) (417(3)(b)) Balanced & comprehensive analysis of …development & performance…. No change (414C(3)(a)) during the financial year (417(4)(a) Balanced and comprehensive analysis of he position of the business at No change (414C(3)(b)) the end of the year (417(4)(b)) Quoted companies only – main trends and factors likely to affect the No change (414C(4)(c)) future development, performance and position of the business (419(5)(a)) A description of the company’s strategy (414C(4)(a)) A description of the company’s business model (414C(4)(b)) Quoted cos - Information about environmental matters (417(5)(b)(i)) No change (414C(d)(i)) Quoted cos - Information about he company’s employees (417(5)(b)(ii) No change (414C(d)(ii)) Quoted cos - Information about social and community issues Social, community & human rights issues (415(5)(b)(iii)) (414C(d)(iii)) Essential contractual arrangements (417(5)(c)) Deleted A breakdown of the number of persons of each sex who are employees, directors and managers @CDSBGlobal
  • 23. Thank you! Lois Guthrie CEO lois.guthrie@cdsb.net Office: + 44 (0) 20 7415 7180 | Mobile: + 44 (0) 7740 988 391 Mardi McBrien COO mardi.mcbrien@cdsb.net Office: + 44 (0) 20 7415 7180 | Mobile: + 44 (0) 7920 463 046 Skype: mardi.mcbrien.cdp.cdsb www.cdsb.net | @CDSBGlobal Carbon Disclosure Project, Registered Charity no. 1122330. A company limited by guarantee registered in England no. 05013650. @CDSBGlobal