What Defra's Greenhouse Gas Reporting Consultation Won't Tell You

In late July I tweeted the news that the UK Department for Food, Environment and Rural Affairs (DEFRA) has released the final consultation on its proposed mandatory carbon reporting legislation.

If you went to Defra's website and download the consultation documents following that announcement, you might have felt somewhat confused and more than a little disappointed.  It all feels rather vague.

The draft consultation document from late last year, and Defra's ensuing feedback document released this spring each ran to dozens of pages focusing on the technical minutiae of setting organisational footprint boundaries based on operational versus financial control, whether or not to include Scope 3 emissions in the footprint, and the pros and cons of reporting all six Kyoto categories of greenhouse gases.  In the end, Defra expressed strong views on how these and other points should be addressed, and went to some length to justify those decisions.

The final consultation document totals just six pages and lacks specificity on most of these important points.  Required reporting standard? Not specified. Financial versus operational control? Not clearly specified. Penalties for non-compliance? Silence. What is more, the final consultation document appears to change the inclusion criteria that determine which companies are covered under the proposed legislation, narrowing them in one regard and substantially broadening them in others. You can find Defra's greenhouse gas reporting consultation page here - as I said, it's a relatively quick read.

When Nick Clegg announced the introduction of mandatory carbon reporting at the Rio+20 summit, it was touted as proof that the UK was leading the world in its response to climate change.  So why the sudden absence of detail?  I have three theories.

The first is political. The initial consultation documents clearly were written by technical specialists, who were focused on getting things right.  The final legislation needs to be read into the House of Commons and debated by politicians.  The more detail is included, the more likely the legislation will get delayed due to time pressure or tripped up by a Member of Parliament who objects to one or more provisions.  Seen from this perspective, short and sweet is the way to go.  Perhaps Defra will choose to issue clarifications containing the detail once the legislation is passed.

The second potential reason for this approach is to maximise the number of companies who report.  I call this the "boiled frog" approach.  By refusing to define rigidly what companies must report and how they must report it, Defra might be making it easier to comply.  Given the choice between companies submitting poor quality or incomparable data versus no data at all, my preference would be to get poor quality data. After all, we know the footprint isn't zero, and this flawed initial number gives us something with which to start.  Defra can then issue additional guidance as time goes on to improve the quality of data that companies submit and ensure that it becomes easier to make  comparisons between companies or industry sectors.  The responding companies, meanwhile, can gradually begin to implement better data collection and quality assurance systems - perhaps with less internal resistance than if they tried to jump from no carbon reporting to industry best practice all at once.

And the third potential reason Defra may have chosen to keep it simple, is that many of the largest companies already report their carbon footprints in a reasonably consistent way via the Carbon Disclosure Project.  CDP respondents report their greenhouse gas emissions using ISO 14064 or the GHG Protocol and answer the same standard questions about their carbon footprints.  Carbon Clear is a CDP accredited Consultancy Partner, and while respondents' footprints are not directly comparable, they do tend to take a similar approach.  I expect UK listed firms that already report their emissions to comprise the bulk of the total footprint covered under the Government's mandatory carbon reporting scheme.  As a result, Defra may have decided they did not need to reinvent the wheel.

The real reason is likely to include some of each of these, and perhaps some others that never see the light of day.  Whatever the reason, the result in the short term is confusion for firms that don't yet know whether they will be included, nor what they need to report.  Based on our previous conversations with Defra and the CDP, our team at Carbon Clear is able to tease some extra detail out of the current legislative draft, and will aim to give our clients a head start in preparing for the advent of mandatory carbon reporting in the UK.

Science: It Works on Mars and on Earth

On Sunday the NASA Mars Science Laboratory rover, nicknamed Curiosity, landed on the Red Planet and began beaming pictures home.  This isn't a space exploration blog, but I'll explain the relevance in a moment.

As you might imagine, landing a 900-kilogram, six-wheeled, plutonium powered robot car on another planet is not easy. In fact, this was the most difficult and complex Mars landing attempt to date. Let's run through the main challenges:

1. Build a plutonium-powered robot vehicle than can operate semi-autonomously for an entire year, tolerate sub-freezing temperatures, radiation, dust storms and the vacuum of space.

2. Fit that vehicle into the nose cone of a 58-meter rocket, fill that rocket with an explosive mix of kerosene and liquid oxygen, aim it at the point in space where you expect Mars to be in eight months' time and fire it off.

3. Eight months later, drop the space capsule into the Martian atmosphere at 20,000 kilometers per hour.  If it enters at too steep an angle it will burn up; too shallow and it will skip away and be lost in space.  It's now 154 million miles away - too far for mission controllers to steer it in real time, so you will have to have made the capsule smart enough to make its own high-speed course adjustments.

4. Once the capsule has slowed from to only a thousand miles and hour, jettison the heat shield and pop open a parachute. This will slow it even more.  Again, the capsule is too far away for humans to control directly, so this has to happen automatically.

5. Once the capsule is 1.1 miles off the ground, fire the eight retro-rockets on the descent vehicle. These will steer the lander and bring the whole SUV-sized assembly to a hover over the surface of Mars. Yes, this has to happen autonomously, too.

6. Once the assembly is hovering on its retro-rockets, lower the robot car gently to the surface on a 7.5 meter nylon cable.  When the car has touched down, cut the cord and fly the rocket assembly off to crash a safe distance away.

7. If the vehicle is okay, it will begin sending photographs to Earth.  The signals will go from the rover to a space observatory that has been orbiting Mars for the past six years.  That orbiter will then bounce the signal off another orbiter that has been circling Mars for ten years in order to reach Earth! The mission controllers on Earth will find out fourteen minutes later whether it all worked.

And amazingly, it all worked!  The Curiosity rover is sitting safely on the surface of Mars and Scientists and engineers are celebrating a trove of exciting photos and video footage.

The successful Curiosity landing was a triumph of science and engineering.  We can use these tools to make accurate predictions about a long chain of complex events. And we can use our knowledge and ability to achieve complex and ambitious goals.

Here on Earth, few goals are as complex and ambitious as tackling climate change.  But the science is unambiguous.  We know what is causing climate change and we know that greenhouse gas emissions need to drop.  We even know what emission sources to address and already have the tools to do it.  Reducing greenhouse gas emissions to safe levels doesn't require any new technological advances or scientific inventions.  Existing clean energy, energy efficiency, resource efficiency and forest management systems can do it.  Renewable energy use is soaring across the world, major carmakers are bringing high-efficiency hybrid cars to market, and ever-larger forest protection projects are being launched in Asia, Africa and Latin America.  We know what to do and how to do it, but we're not yet doing it fast enough.

It is clear that governments can't get us there on their own. Politicians' incentive structures make it difficult to make major changes to the built environment and to our energy, transportation and agricultural systems. Governments have an important role to play in promoting transparency, overcoming market distortions, and ensuring a level playing field, but when government is slow to act individuals, communities, civil society and businesses should not hesitate to get involved.

Around the world, companies are switching to renewable energy and improving efficiency, restructuring supply chains to reduce their carbon footprint and save money, and investing in innovative emission reduction projects that help people in the developing world make the transition to a low-carbon future.

Compared to landing a one-tonne rover on Mars, the scientific challenges preventing us from tackling climate change look almost easy.  And the Curiosity rover is there, showing us what we can accomplish when we have the determination.