Climate change duties: statutory guidance for public bodies

Annex H: Reporting: further guidance and information

This annex provides further information and guidance to support reporting as laid out in chapter 8, on:

• boundary setting
• conversion factors
• environmental data management
• reporting in shared public buildings
• reporting on outsourced services
• scope 3 reporting: common data sources
• scope 3 reporting: expanding beyond minimum expectations.

Guidance on reporting land and nature-based projects is provided in Annex F.

Boundary setting

A vital first step in carbon management and reporting is to define the organisation’s boundaries. The inventory boundary determines which emissions are accounted for and reported by the organisation. Bodies should refer to the Corporate Accounting and Reporting Standard for guidance: they should first define their organisational boundary and approach; and then set the operational boundary. This will involve identifying the sources of emissions generated by their operations, categorising them as direct or indirect, and choosing the scope for indirect emissions.

As noted in the five key principles (section 8.2.2), the inventory boundary should include all relevant assets, activities and emissions generated by the organisation. Further guidance is provided below regarding the activities and emission categories which public bodies are, as best practice, expected to include within their boundary. The body should, in defining the boundary, be transparent as to any sources of emissions which have been excluded from the inventory and provide an explanation for these.

Setting a defined boundary is important for clarity in reporting, and to avoid double counting within the organisation’s inventory. For example, purchased electricity should be reported under scope 2. As this is a purchased service, it will appear on financial reports: bodies that report on purchased goods and services under scope 3 would therefore need to ensure that the electricity spend is extracted and excluded from any calculation in relation to scope 3 emissions, to avoid these being double counted.

Conversion factors

Calculation of carbon emissions typically involves applying a carbon equivalent conversion factor to a unit of consumption (kg or tonnes CO₂e per unit of consumption, e.g. kg CO₂e per kWh of electricity consumed or tonnes CO₂e per m3 of natural gas consumed). For the purposes of the mandatory reporting, the UK Government greenhouse gas reporting conversion factors should typically be used.

Other conversion factors are available and may be used where appropriate. For example, Scottish Water have calculated a conversion factor for the supply of mains water within Scotland which provides a more accurate estimate of emissions than the UK factor. The public bodies climate change duties reporting template contains built-in conversion factors (UK Government and Scottish Water) for the majority of emission sources, which are updated annually. Where bodies choose to use a different factor, or to calculate their own, this should be clearly stated and further details provided.

Environmental data management

Public bodies should ensure that their data collection, collation and processing methods are recorded, to ensure consistency year on year, and to support audits, business continuity and resilience. While it may be appropriate for bodies with larger or more complex datasets to have an environmental data management strategy or equivalent, a proportionate approach should be taken.

For bodies subject to the mandatory reporting duty, it is important that changes in staffing or staff responsibilities do not impact on their ability to comply with the duty. Ensuring that an operational environmental data management manual is maintained can assist with this.

Reporting in shared public buildings

Many public bodies co-locate in shared public buildings. Typically, this takes the form of one body (the tenant) leasing space from another (the landlord), and being included in contracted services such as waste collection. It is unlikely that the landlord would be able to provide sub-metered heating or electricity data, or separated waste data.

In such cases, a pragmatic approach could be taken where the landlord includes all relevant energy, water and waste related emissions in their annual PBCCD report, rather than splitting off estimated ‘shares’. The landlord and the tenant bodies must mutually agree that this approach is to be taken; which sources of emissions are included; and both parties must note this clearly within their annual PBCCD report. This will prevent potential double counting and ensure transparency.

Where a public body leases space from a private landlord, efforts should be made to estimate and report on their share of emissions as outlined in the sections below.

Reporting on outsourced services

Over time, it is typical for bodies to outsource services that were previously undertaken in-house. An example of this is the trend to transition from in-house servers and data centres to external cloud-based systems. Data centres can be large consumers of electricity, and moving to the cloud might result in a significant drop in scope 2 emissions for that body. However, these emissions have not been removed – rather, they have moved from the body’s scope 2 to scope 3, now as purchased services. In such cases, bodies should report the emissions under scope 3, to ensure that their inventory continues to accurately reflect their operations. It will also encourage bodies to take emissions and other environmental considerations into account in their procurement exercises, and in their ongoing management of the contract.

Scope 3 reporting: common data sources

The sections below outline some of the common sources of data for the scope 3 emission categories public bodies are expected to include in their reporting as a minimum, where relevant.

Purchased mains water (category 1)

Purchased mains water falls under category 1, as a purchased good or service. At the time of publication, only water is suggested for inclusion in the expected reporting from category 1, due to the ease with which it can be monitored, and for resource efficiency reasons noted in section 8.2.5.

There are emissions associated with the supply of mains water. The majority of sites will have water meters – whether analogue meters or digital meters with remote monitoring – and water consumption can therefore usually be measured fairly easily. At a basic level, meter readings could be taken on an annual basis. More advanced meters, typically digital meters with remote monitoring capabilities, take readings at regular intervals such as daily, hourly or half-hourly, and can also be used to monitor consumption patterns and identify maintenance issues.

Most utility bills include an estimate of consumption. Bodies should be cautious about using unverified bills as a source of consumption data, as they can be inaccurate. Bodies are advised to using billing or invoice data only where this has been verified using meter readings, where possible.

Where water meters are not installed, or where one meter covers an area shared with another organisation, estimated data can be used. For the former, the bill or invoice will include an estimate of consumption. For the latter, a proportionate share could be estimated based on, for example, overall share of floorspace or numbers of staff on site. Any assumptions and estimates should be clearly stated.

Waste and waste water (category 5)

All public bodies will generate waste through their day to day operations. Bodies should follow the waste hierarchy, by preventing and reducing waste, re-using where possible, recycling and recovering materials, with only residual waste finally being disposed of as landfill. Following circular economy principles at procurement stage can help ensure that materials can be moved further up the hierarchy, resulting in a longer useful life, and less waste at end of life.

Types and volumes of waste generated will however vary widely, from simple food waste and easily recycled packaging, through to specialist streams of clinical, scientific, chemical and hazardous waste. Waste data should be readily available to most public bodies. Waste is a heavily regulated sector, and clear records at each stage between site collection and final disposal are required. Where public bodies are responsible for their own waste contracts, the waste contractor should be able to supply detailed data including types of waste, volume or weight of waste collected, and treatment or disposal route. This information can be used, with the UK Government conversion factors, to estimate the emissions associated with the waste collection, treatment and end destination of the treatment output or residue.

Waste data is typically based on estimates, based on size of bin and how full the average bin is at the time of collection. This data can be improved by undertaking waste surveys.

Where public bodies do not arrange their own waste contracts, for example where a landlord arranges such services, bodies can request this data. Bodies on shared sites could estimate their share of the emissions using an appropriate proportional approach based on, for example, overall share of floorspace or numbers of staff on site. Any assumptions or estimates should be clearly stated.

Local authorities should include only the waste generated by their own operations in their corporate reporting. Municipal waste treatment should be included within the boundary for the area-wide plan (see Annex D – CCP template).

Waste water is typically estimated to be 95% of mains water consumption. Bodies responsible for producing large volumes of effluent may have waste water metering in place and be able to take more accurate measurements. However, this is uncommon for most public bodies and taking the 95% approach for reporting is acceptable. This assumption should be clearly stated, in line with the principle of transparency.

Business Travel, including overnight stays (category 6)

Emissions in this category should include emissions associated with business travel taken by staff, using vehicles or modes of transport that are not owned by the public body, in the course of their work. Such emissions are likely to include journeys on public transport, in hire cars, and by air. ‘Grey fleet’ journeys – those taken in personal vehicles and for which staff claim a mileage rate – should also be included. Business travel emissions should, as good practice, also include overnight stays.

Emissions from trips taken in vehicles owned by the organisation, such as pool cars, fall under scope 1 and are excluded from this category.

When reporting on business travel, bodies should take a proportionate approach and focus effort on reporting sources material to their footprint. For example, a body may on occasion use taxis, but the use of these may be minimal such that the emissions form only a very small proportion of their overall footprint, and obtaining the data may be resource intensive. In such a case, the body may choose to exclude taxi travel, and should note this along with an explanation. However, there may be other reasons to report on specific travel modes. For example, if a body’s use of public transport is currently low, but they want to encourage a modal shift from grey fleet to public transport, they may want to monitor and report on this.

There are likely to be multiple sources of business travel data within a public body.

• Travel agent: many public bodies hold a contract with a travel agent for the booking of business travel and overnight stays. Travel agents are likely to be able to provide detailed management information (MI) including the mode of travel, class of ticket, distance travelled, starting point and destination, price paid, country, and other relevant details for estimating emissions. Bodies may be able to work with their supplier to tailor MI reports to their environmental reporting needs; or could use the point of retendering the contract to introduce such a requirement.
• Other travel suppliers: bodies may have other travel-related suppliers such as hire car contractors, who will also be a source of MI from which emissions can be estimated. Hire car contractors, for example, may be able to provide data including distance travelled, fuel type used, size of car, and sometimes even amount of fuel consumed.
• Corporate expenses system: expenses claims are likely to include mileages, and travel tickets and accommodation paid for by the individual. This data is likely to be less detailed than that provided by a travel agent, but can still be used to estimate emissions. For example, if only the price of a train ticket is recorded, rather than any details about the journey and distance travelled, an appropriate spend-based factor can be used. Improvements to data quality should be sought over time, for example by introducing additional mandatory fields for claimants to complete.
• Corporate expenses cards or credit cards: some organisations may hold a number of expenses cards or credit cards, to allow the purchase of travel, consumables and other items at short notice. The statements from these cards are another valuable source of data – this may require more manual processing but should not be overlooked.
• Travel surveys: staff travel surveys can be used to gather data such as how often individuals travel to attend meetings, the mode of transport used, and the reasons for choosing that mode. This more qualitative information can help inform the development of travel plans and policies.

Commuting and home working (category 7)

Public bodies should report on both commuting and homeworking emissions. This is important for a number of reasons. If a body only reports on homeworking emissions, an increase in the number of employees working from the office will create a false impression of emissions going down, as the decrease in homeworking emissions is not counterbalanced by a corresponding increase in commuting emissions (or vice versa). Being able to compare commuting emissions with homeworking emissions will be important as bodies develop evidence-based policies around hybrid working, noting that emissions are only one of many factors to be taken into account.

While a standard conversion factor is provided for estimating homeworking emissions, there is no standard ‘Scottish commuter’ conversion factor and bodies will require to estimate commuting emissions themselves.

Public bodies should consider how they can effectively engage with their employees to understand how staff commute to and from work, how often staff commute and to which sites, and how often staff are working from home; and put in place measures to collect or estimate this data.

• Staff travel surveys: carrying out a regular travel survey across the workforce is a good way to collect data on employee commuting behaviour, produce a clearer picture of the types of transport staff use to travel to the workplace and the distance they travel in an average week. This data can then be used to estimate commuting emissions. Surveys can also be used to identify barriers to sustainable and active travel, and the measures which would encourage people to travel more sustainably. Such information can be used to help justify and target investment, for example in improved cycling facilities at particular sites or introducing cycle to work or electric vehicle salary sacrifice schemes.

A Commuter Emission Calculator tool has been developed by Zero Waste Scotland. The tool includes a staff survey and an emissions calculator.

• Homeworking or hybrid working survey: hybrid working is now widespread across the public sector. Homeworking emissions can be simply estimated using a standard homeworking conversion factor, based on the number of full time equivalent (FTEs) employees working from home. However, bodies may wish to include questions on working from home in a staff survey, for example in a hybrid working survey. This could seek to elicit more detailed information around energy use at home and heating behaviour. This could allow more accurate homeworking emissions to be calculated. In addition, the information could also inform employee engagement and communications plans, for example providing signposting to home energy advice services.
• Site occupancy data: buildings with a security system that registers staff as they enter and leave the building may be able to estimate typical building occupancy. Where more detailed data is not held, this could be used to estimate homeworking and commuting rates, e.g. average 20% of staff coming to the office, and so 20% of staff commuting and 80% working from home. The details of this calculation would depend upon the nature of the body and its staff, and could be supplemented with related data held in the HR system.

Higher and further education institutions should also, as best practice, report on student travel emissions (refer to Annex L).

Fuel and energy-related emissions not included in scopes 1 and 2 (category 3)

This category includes emissions related to the production of fuels and energy purchased and consumed in the reporting year, that are not already included in scopes 1 or 2. It includes the upstream emissions of purchased fuels (e.g. emissions generated by the extraction, production and transportation of fuels, also referred to as ‘well to tank’ (WTT) emissions), upstream emissions from purchased electricity, and transmission and distribution losses. Transmission and distribution losses are the amounts of energy in a system that are not consumed by end users or customers, for example losses through leakage or energy dissipation, or the energy needed to power the equipment that runs the distribution system.

To estimate the emissions associated with this category, bodies are recommended to use an average data method, and utilise the conversion factors provided by the UK Government. If this approach is taken, bodies can use the fuel and energy consumption information already gathered for scope 1 and 2 reporting, and apply the relevant conversion factors.

Bodies should refer to the practical reporting guidance for further details.

Scope 3 reporting: expanding reporting beyond minimum expectations

Purchased goods and services (category 1)

Many public bodies are significant consumers of purchased goods and services. This is a wide ranging category of emissions and includes external consultancy and legal services, cleaning and facilities management, IT equipment, food and catering services, and scientific and research services. Bodies should follow circular economy principles in their purchasing decisions, for example whether products can be mended, and whether they can be re-used or recycled at end of life. These considerations should help result in lower related emissions over time, as product life is extended and resources remain in use.

Emissions from purchased goods and services are complex to estimate, and, at the time of publication, most calculation methodologies rely on a spend-based method. This method uses spend as a proxy, applying an average ‘kg CO₂e per £ spent’ conversion factor to purchasing data. While this method can be useful for an initial screening exercise to help identify areas of spend and products that are emission hotspots, it is not accurate and can encourage contradictory behaviours. For example, it can discourage investment in more sustainable products which may be more expensive. Equally, negotiating a cheaper price for the same goods can result in emissions appearing to reduce.

The spend based method should therefore be used with care, and not as a tool for ongoing assessment of these emissions. Bodies should work with their suppliers to access supplier and product specific data, increasing data quality and robustness over time.

Capital assets – embodied carbon from construction and retrofit projects (category 2)

Calculation of embodied carbon for infrastructure, construction and retrofit projects is important as it allows the full impact of the proposed project or intervention to be assessed and, ideally, reduced. It can help support the development and deployment of more sustainable construction materials and techniques. For some projects, the embodied carbon may be greater than any emissions associated with the operation of that asset.

Bodies are encouraged, as best practice, to calculate the whole life carbon of projects in line the Net Zero Public Sector Building Standard, RICS whole life carbon assessment, the UK Net Zero Carbon Buildings Standard, PAS 2080 (2023) or equivalent, as appropriate to the scale and nature of the project. Public bodies should keep records of whole life carbon emissions (in tonnes CO₂e), including embodied carbon, predicted to result from their major built environment projects. Such information on built environment carbon emissions impact should be made available upon request from Scottish Government by all public bodies.

Public bodies subject to the reporting duty should, as best practice, include the embodied carbon emissions from construction and major retrofit projects in their annual report.

If a public body’s construction or retrofit project is completed within a single reporting year, the total embodied carbon emitted from its construction should be reported in tonnes CO₂e. Typically, building projects will span several years. In this case, an estimate of the embodied carbon emitted during the reporting period should be included, e.g. a proportion of the total estimated embodied carbon based on construction spend in the period. This would result in the same project being reported over a number of years, with the annual emissions adding up to the total embodied carbon resulting from the project.

Downstream leased assets (category 13)

Some public bodies, such as local authorities, may own assets which are leased to third parties for the delivery of public services. For example, sports and leisure or cultural services may be delivered by a charitable trust or arms-length organisation using publicly-owned buildings. Delivering such services may be particularly energy intensive due to the nature of the buildings and facilities. Where the operation of downstream leased assets generates significant emissions, or is critical to the provision of public services, efforts should be made to include them within the reporting boundary. Where responsibility for upgrading the buildings lies with the building owner, this work should included in the body’s overall asset management and capital investment planning.

Local authorities and other social housing providers will own large numbers of social housing units. Social housing has its own regulatory regime, and statutory Annual Returns require to be submitted to the Scottish Housing Regulator. This reporting includes data on energy efficiency and heating fuel type. Consideration of whether the downstream emissions from the use of social housing should be included in the PBCCD reporting will be undertaken as part of the work to draft any future amendments to the Reporting Order, and further guidance provided as appropriate.

Investments (category 15)

Some public bodies may hold large investments, for example pensions funds and endowment funds. They may also have other types of investments, such as owning arms-length delivery bodies. For example, a local authority could own a share of a municipal bus company. Bodies should consider including such investments within their reporting boundary, in particular where these deliver essential public services. Initially, bodies could approach reporting on such investments in a qualitative rather than quantitative way, noting the complexity of estimating emissions in this category. For example, by reporting on their investment plan or strategy, plans to move away from investing in high carbon sectors or assets, plans to increase investment in renewables and low-carbon technologies, etc.

Wider travel-related emissions: end user travel

Service users often need to travel to sites owned by public bodies, for example visitors travelling to historic and cultural sites. Where appropriate, bodies may choose to monitor and report on end user travel, where this is estimated to contribute significantly to their emissions. Understanding end user travel is likely to assist bodies as they consider the impacts of the changing climate on their service users, helping to ensure services are resilient and remain accessible in the future.