UPDATE: There was an interesting debate at the House of Commons yesterday where Mary Creagh, Shadow Secretary of State for Defra, called for mandatory greenhouse gas reporting as part of her 3 point plan for Defra.We already set out our argument for why GHG reporting does not need to be made mandatory earlier in the year - read below:
The Case Strengthens for Reporting: but is mandating necessary?
EEF welcome the revised Impact Assessment estimates provided by the Aldersgate Group in conjunction with WWF, The Co-operative Group and Christian Aid, published today, as providing more evidence about the costs and benefits of reporting. EEF are not against reporting GHG emissions and agree that there are significant benefits to be gained by reporting in company reports.
EEF represents the manufacturing industry in the UK, which is already significantly burdened with other climate change policies – CRC Energy Efficiency Scheme, CCL and CCAs, and EU ETS. This is a lot of regulatory pressure for companies to comply with; without the addition of mandatory reporting.
Indeed, some EEF members do already report their GHG emissions in company reports, and not just in the UK, but for their global operations too – and they see the benefit in doing so. EEF agree with many of the revised costs and benefits, such as the better scope for which costs and benefits are included, but at the same time, do not see why this means that GHG reporting should be made mandatory.
As we have already argued in our response to the Defra GHG reporting consultation earlier this year, Government has taken little to no steps towards promoting the current guidance for GHG reporting. The up-take in GHG reporting may have only increased by 4% since 2009, but instead of immediately jumping on the regulatory bandwagon, why not sit back and think about what the barriers to up-take have been?
To me, a logical step is to make sure that the current policy instrument is working to its full potential before introducing a new approach. Surely this is much lower cost than introducing new regulation? It will sit better with the Government objective to reduce the regulatory burden for business.
The commitment in the Climate Change Act – to make GHG reporting mandatory by April 2012 or present evidence as to why not - is less relevant today than when it was first published. At that time, we did not have the crowded and confusing climate change policy landscape we have today. It was also a commitment
It should also be remembered that UK manufacturing differs from other sectors as they are more likely to be caught under these other policies. Discounting the person-day input doesn't really make much difference to a lot of EEF members, who already have this many person-days through CRC so additional burden is seen by them as just that, a burden with no additional benefit.
The revised benefits assumes that, year-on-year, there are savings to be made; and for a company new to energy efficiencies this is true. Many EEF members are already working to make their sites more efficient and for some there is no possibility to go any lower – it is just the nature of what they are producing.
Yes, EEF agree there are merits in reporting on your GHG emissions and as today's publication shows, quantifiable benefits, but I just don't see why it needs to be made mandatory before the voluntary approach has been taken seriously. In order to push through with mandatory reporting there needs to be stronger evidence that the current approach is not working and a policy ‘out' will also need to be found.