Public bodies climate change duties - draft statutory guidance: consultation analysis - final report

8. Reporting of scope 3 emissions

Chapter 8 of the guidance, ‘Reporting’, provides an overview of reporting, with a particular focus on the mandatory reporting required under The Climate Change (Duties of Public Bodies: Reporting Requirements) (Scotland) Order 2015, as amended, known as public bodies climate change duties reporting.

Previous guidance mandated reporting of relevant scope 1 and 2 emissions, while voluntary reporting of scope 3 emissions was recommended. This new guidance proposes a reporting baseline for selected scope 3 emissions, which all public bodies would be expected to include in their inventory (see guidance section 8.3.5). This would include the emissions associated with: mains water consumption; waste and waste water treatment; business travel; staff commuting and homeworking; student travel (for colleges and universities); and fuel and energy-related activities not included in scopes 1 and 2.

Q12. To what extent do you agree with the proposed baseline reporting of the scope 3 emission categories as outlined?

Over three quarters (78%) of respondents answering Q12 either strongly agreed (29%) or somewhat agreed (49%) with the proposed baseline reporting of the proposed scope 3 emission categories. One in ten (11%) somewhat disagreed and 3% strongly disagreed (14% combined), while 6% were neutral and 2% were unsure.

Almost three quarters of all respondents left a comment to explain their answer at Q12. The most prevalent themes were perceived implementation challenges and positive views of the proposed approach. Other themes in order of prevalence included the need to consider different public bodies (see Chapter 2) and to strengthen or add to the guidance.

Implementation challenges

Many respondents raised potential implementation challenges associated with this proposal in their responses Q12. Some at Q15 also raised implementation challenges with the guidance as a whole, though views were aligned to those raised at Q12 and are therefore incorporated here.

Scope 3 emissions reporting was seen as a complex area. Some support was expressed for the suggested categories, with the proviso that certain ones were excluded, notably staff business travel and staff commuting and homeworking. Other respondents noted the resource-intensive and challenging nature of reporting against scope 3 emission categories. In order of prevalence, the key issues raised by these respondents were:

• Challenges with including staff travel and homeworking.
• Data issues, e.g. tracking or monitoring emissions data.
• The need for a consistent methodology and common approach.
• Capacity challenges.
• Views on other scope 3 emission categories.
• Supply chain or procurement issues.

Challenges with data availability and quality were identified, particularly around data for home working and staff travel, notably commuting, business travel, and overnight stays. Several commented on these scope 3 emissions categories, with challenges including that these categories were likely to involve significant assumptions and be based on voluntary self-reporting, resulting in inaccurate data. These were also viewed as difficult areas in which to influence change, and would be resource-intensive, given that the necessary data was not generally collected. One organisation indicated it used travel survey data to develop site plans, but it was considered resource-prohibitive to develop for all sites.

Other categories perceived as challenging to report on by a few respondents were, in order of prevalence, procurement and purchased goods, waste, and grey fleet and public transport. Issues noted with these included challenges with third-party reporting or disaggregating data, the guidance on waste not being sufficiently clear, and that waste emissions are also impacted by public behaviours. It was noted that public bodies that lease or share buildings could find it challenging to disaggregate their emissions data from that of other occupants. Calls were made for further guidance, standardised datasets and methodology, should additional new categories be included, such as how to calculate emissions from digital services.

Some respondents made similar comments about emissions data that extended beyond the above categories perceived as challenging. Comments included that: accurate calculations would require a Life Cycle Assessment for every product under consideration, which was unfeasible; baseline data would skew the data that had been collected in recent years; risks of double counting during data collection; and comparative challenges due to different approaches used, for instance materiality^[1] considerations may affect reporting.

Some other respondents at Q12 and a few at Q13 suggested using a recommended methodology to promote consistency, minimise the resource requirement, and support public bodies.

“We strongly disagree that commuting and homeworking should be included as a reporting metric. This is for several reasons. We cannot mandate staff to provide this information. Therefore, information will be provided on a voluntary basis or via travel surveys, and will produce an incomplete data set. We do not have the means or the authority to require staff to validate this information (as with other reporting metrics) through provision of bills, receipts, or other financial/consumption information. We have no means to take action to mandate how staff travel to work. We can encourage staff behaviours, but could do this without the introduction of a reporting metric.” - Scottish Police Authority/Police Scotland

“There needs to be clear guidance alongside the introduction of any further reporting requirements on calculation, application and relevant timelines for introduction. One barrier to the aspirations of the guidance is the absence of a single, simple, cost-free tool or platform compatible with the knowledge, resources and maturity of all possible suppliers (small, medium and large) across all business and industrial sectors in all conceivable contracts involving 3rd party suppliers. The lack of cost-neutral verification of 3rd party emissions data is considered to be a further barrier to realising the aspirations of the guidance.” - Aberdeen City Council

Positive views

Several respondents supported including scope 3 emissions in the baseline reporting or gave reasons why it was important. Some also highlighted specific positives about the guidance document. Often these points were made alongside qualifications, such as those noted in the previous theme.

This approach was supported because it would support the need for urgent action on addressing climate change, encourage more focused and meaningful action, enhance pragmatic reporting, and provide a strong foundation to build on in the future.

“The Highland Council supports the inclusion of Scope 3 emissions in the guidance, recognising that they represent a significant share of public sector climate impact. The proposed baseline categories are a good starting point, but further refinement and support are needed to ensure the approach is proportionate, consistent, and achievable.” – Highland Council

Aspects of the guidance highlighted as useful included the inclusion of student travel, the correct identification of most emissions that fall under scope 3, the clear rationale, and the suggested categories, which provide an achievable baseline for public bodies.

Strengthen, add, or simplify the guidance

Areas to strengthen, add or simplify were highlighted by some respondents. Suggested revisions or additions, in order of prevalence, included:

• Calls for strengthened reporting requirements, such as for public bodies to achieve a minimum level, or adopt a mandatory component, when working to achieve emissions reductions.
• To amend land-based emissions and removals to include Scope 3 emissions from transport, fertilisers and livestock. For instance, it was noted that there are no references to recording the level of nitrogen-based fertilisers in the provision of public spaces and the grounds of public bodies, or to motor-driven tourism. For agriculture, it was suggested that reporting should include emissions of imported livestock feed and other livestock goods, including both carbon miles and the impact of growing feed (including, where relevant, the carbon impact of deforestation).
• Clarity over which public bodies are expected to report against all Scope 3 emission categories.
• Cross-referencing to parts of the statutory guidance which expect public bodies to expand scope 3 emission reporting boundaries where emission sources are deemed significant (e.g. ‘Materiality’ section on page 23 of the draft guidance).
• Further explaining the baseline One category, such as giving more detail on how the different emissions are divided.
• For ‘fuel and energy-related emissions not included in scopes 1 and 2’ to be excluded from baseline reporting.

More practical support

At Q11, some respondents suggested other ways to support additional scope 3 emissions reporting. Specific comments included: the Scottish Government creating an endorsed list of carbon accountancy software packages; to support the development of sector-wide benchmarking data; and to publish a timeline for incorporating baseline data and phasing in any additional categories.

“The guidance is a solid starting point but could be improved by offering more practical tools for integrating sustainability into specific public body functions, such as asset management or service delivery. A clearer framework for evaluating the sustainability of procurement choices and decision-making processes, with specific examples, would be helpful.” - Merman Conservation Expeditions Ltd

Q13. Do you think that any other categories of scope 3 emissions should be included in the recommended baseline for reporting, where these are relevant and applicable?

Please indicate which other categories of scope 3 emissions you think should be included, and provide an explanation.

At Q13, respondents were presented with a list of other categories of scope 3 emissions and asked which they thought should be included in the recommended baseline. Out of all 119 respondents, 72 (61%) did not answer the question.

The table below shows the percentage of the 47 respondents who answered this question and selected each category. Please note that the percentages add to more than 100% because multiple categories could be selected.

Among the 47 respondents who answered Q13, the categories of scope 3 emissions which respondents were more likely to indicate should be included were purchased goods, works and services (87%), and capital assets, e.g. construction (72%). These were most commonly cited by both public bodies and non-public bodies. All other categories were selected by under half of those answering, with the next most selected being upstream transportation and distribution (43%) and investments (43%). One notable difference between public bodies and non-public bodies was their views on upstream leased assets, with 31% of public bodies in favour of including, compared to 9% of non-public bodies.

Over three quarters of all respondents left a comment at Q13. Where views overlapped with points raised at Q12, comments have been included in the analysis of Q12 above. Certain proposed scope 3 emission categories provided at Q13 attracted most comments. In order of prevalence, these were: purchased goods, works and services; investments and finance; capital assets and construction; and upstream transportation and distribution.

Some respondents felt no further categories should be added, and a few felt all suggested categories should be included or welcomed further additions. Comments on specific categories are presented first for ease of reading.

Purchased goods, works and services

Comments on this category were made by some respondents at Q13 and a few at Q12. A range of views were expressed, from agreement with its inclusion to concerns regarding how resources were needed to collect and report on it or how to obtain meaningful data in a way that did not disadvantage smaller suppliers. Suggestions included asking suppliers to initially provide carbon data for the main items procured and build from there. This could be supported through the Supplier Development Programme, mandating the use of a specified tool and suppliers that secure contracts over a certain threshold being required to submit data to include in returns.

Investments and finance

Some respondents commented on the investment and finance category. The most prevalent issue was pension-related investments, with views expressed that these should be included due to the scale of pension investments by public bodies. However, a few respondents cited challenges measuring investments, particularly pension investments, given a perceived lack of technical and financial detail to measure emissions from investments across different sectors accurately. One respondent, for instance, called for more clarity on whether pensions and bank accounts are included in ‘investments’.

Other views included that: more responsibility should be placed on investment companies to contribute to net zero, and that local authorities should be empowered with regulatory freedom to take ethical and environmental considerations into account when making decisions about financial spending. One respondent was opposed to including this category, and another made a specific comment about animal products and scope 3 emission categories:

“The climate impacts of animal farming and consumption of animal products are relevant not just to the agri-food sector, but also as Scope 3 emissions for finance (e.g. in land & business investments), fashion (commodity textiles of animal origin), property (footprint from processing & sale of commodities of animal origin), health and education.” - The Vegan Society

Capital assets, construction and use of sold goods

Respondents supported including capital assets and construction due to the scale of emissions associated with construction and infrastructure projects. It was felt that including major infrastructure projects could help to produce more accurate predictions of the carbon impact of proposals, that it could support carbon management in construction projects, and that including capital assets could ensure public bodies considered the full lifecycle emissions of these projects, helping to prioritise low-carbon construction practices. However, it was also noted that reporting could be challenging as it would require further guidance and a consistent methodology to be used across public bodies. Two respondents noted that many public bodies operate from leased assets, which could pose difficulties due to a lack of data.

One respondent commented on the ‘Use of sold products’ category, given that the use of sold products in the housing and construction sectors (e.g. energy) had a substantial impact on scope 3 emissions, and was supportive of its inclusion as it would:

“…provide a clearer understanding of long-term environmental impacts beyond the immediate production or delivery phase.” - Bield Tenant Equality Network

Upstream transportation and distribution

A few respondents commented on this category, mostly welcoming its inclusion as they felt it could provide a more comprehensive understanding of such emissions and help identify where emission reduction opportunities lie in the supply chain or reflect the reality of dispersed supply chains in rural areas.

No need for additional categories

Some respondents expressed a view that no other categories should be added to scope 3 emissions reporting. Reasons given included that: more work would be needed to introduce new categories, for instance, through consistent methodologies, tools and support; it could pose a reputation risk due to the potential for misinterpretation of data and; there was insufficient capacity and resources to facilitate this.

“There is a strong preference for a carefully phased, temporally-nuanced, and holistic approach to all Scope 3 reporting, ideally underpinned by centralised tools and clear, consistent methodologies, rather than prematurely broadening the scope when capacity for existing expectations is already severely stretched. The priority must be to improve cross-departmental data collection and governance for the categories already proposed before considering any expansion.” - Argyll & Bute Council

Support for adding categories

A few respondents supported adding relevant categories, though generally this was given with additional considerations, for example, on the basis that methodologies or support were also provided.

Apply materiality

Two commented that materiality should help determine what high-impact categories are included in scope 3 emissions reporting for different public bodies:

“Not all categories will be relevant for every public body. The guidance should apply a materiality threshold and encourage prioritisation of categories based on carbon significance, influence, and data availability.” – Highland Council