Although some 25,000 organisations across Europe currently report their Scope 1 greenhouse emissions under the Community's Emissions Trading Scheme (EU ETS), it is probably not appreciated that these same business entities must also submit details to their national authorities under separate laws designed to regulate the release of pollutants into the environment (atmosphere, water and/or the soil). In the case of emissions to the atmosphere, this data is collected under the scope of the following directives:
- Integrated Pollution Prevention and Control (IPPC)
- Large Combustion Plants (LCP)
- Waste Incineration
- Solvent Emissions
Once collected and reviewed, this data is placed on the European Pollutant Release and Transfer Register (E-PRTR) where it can accessed freely by the public under the auspices of the internationally ratified Aarhus Convention. Similar registers are maintained and access rights provided in other regions of the World, though results for North America which are published by the Commission of Environmental Cooperation (CEC) presently does not provide simple access to details of greenhouse gases.
Example of Reported Pollutants Released to the Atmosphere
Didcot 'A' Power Station, Oxford, 2008. Details from a submission by
RWE nPower plc to the UK's Department for Environment and Rural Affairs (DEFRA)
Source: European Pollutant Release and Transfer Register (location sited)
Greenhouse gases highlighted in red
|Carbon Dioxide (CO2)||5,180,000 tons||Calculated|
|Nitrous Oxide (N2O)||60.5 tons||Calculated|
|Carbon Monoxide (CO)||2,600 tons||Calculated|
|Nitrogen oxides (NOx / NO2)||10,500 tons||Calculated|
|Sulphur oxides (SOx / SO2)||19,100 tons||Calculated|
|Chlorine and inorganic compounds (as HCl)||229 tons||Calculated|
|Fluorine and inorganic compounds (as HF)||252 tons||Calculated|
|Arsenic and compounds (as As)||92.6 kg||Calculated|
|Chromium and compounds (as Cr)||139 kg||Calculated|
|Copper and compounds (as Cu)||231 kg||Calculated|
|Mercury and compounds (as Hg)||11.6 kg||Calculated|
|Nickel and compounds (as Ni)||500 kg||Calculated|
|Zinc and compounds (as Zn)||589 kg||Calculated|
|Polychlorinated biphenyls (PCBs)||200 g||Calculated|
|Particulate matter (PM10)||1,090 t||Calculated|
Corporate Publication of Results
Once placed in the public domain, one would hope that larger businesses would take the opportunity to collate their performance and then discuss in the management commentaries that accompany their annual accounts, details of the risks associated with the emissions they are responsible for. In practice, such companies remain reluctant to disclose this data directly and increasingly seek to present it in sustainability or corporate social responsibility (CSR) reports such as those championed by the Global Reporting Initiative (GRI). Sadly, the formats of these reports are becoming all too similar and tend to underwhelm readers by avoiding any real assessment of performance !!
A specific example of a reluctance to publish details of green- house gas emissions can be found in a response submitted in 2009 by the American Petroleum Institute (API) to the Environmental Protection Agency (EPA), during a consultation period held before the introduction of mandatory reporting in the US. This organisation which develops standards and codes of practice for companies in the oil and gas sector expressed concern that others might be able to reverse engineer the business strategies of members if competitors had access to details of the emissions (particularly locations) that its members would be obliged to submit under the new reporting rule. In the event, the EPA was partly swayed by the argument. It still requires emissions from facilities to be published, but it has formulated an amendment that excludes data inputs considered confidential and commercially sensitive.
Some companies in the UK's retail sector such as Walkers Crisps and Tesco have also invested time and effort to determine and publish details of the carbon footprint of the products they sell. However, it seems unlikely that knowing how much carbon dioxide was emitted in manufacturing and delivering something like a packet of crisps to a point of sale will do much to convince consumers to change their life styles !!
Other sources that publish corporate details of greenhouse gas emissions include voluntary reports from the Carbon Disclosure Project (CDP) and The Climate Registry (TCR). Whilst data from the CDP is accessible, current and provides a snapshot of the total carbon emissions of some of the World's largest companies, the presentation of results (see previous post) appears to be losing focus and becoming more qualitative in nature. Reports from The Climate Registry's site which covers facilities in parts of the US and Canada, tend not to be so up to date or that user friendly to generate, but they do identify the six major greenhouse gases at facility level.
Extending Reporting to Smaller Businesses
How might the reporting of greenhouse gas emissions by small businesses that currently are not required to submit annual reports be improved? Would it for example:
- Be feasible to change company law and introduce a statutory obligation to publish such information? I doubt this will be possible for now because all sorts of organisations would lobby against the idea.
- Be possible to obtain results by seeking details from the regulatory authorities via freedom of information requests? Possible, but this would still require a lot of hard work to interpret any details received.
- Be feasible to develop software that allowed organisations to quickly determine and record their externalities whilst (subject to audit) allowing them to retain the detailed information in-house? I think this is an approach which could have some potential.
- What are the legal issues that are preventing businesses from publishing details of their externalities? Can these be addressed by altering the provisions of legal statutes?
- How can the processes that some businesses already use to record emissions of pollutants:
- be used by other businesses that to date have not had to report emissions?
- be modified to cover a wider range of externalities? and
- be incorporated in management reports?