Questions & Answers
Can a preparer state that data for biogenic emissions in Scope 3 is ‘not available’ as it is specifically possible for Scope 2 biogenic emissions?
- Biogenic emissions
- Scope 2
- Scope 3
- data availability
- proxies
- value chain
Background
ESRS E1 paragraph AR 45 (e) states the undertaking shall ‘disclose biogenic emissions of CO2 carbon from the combustion or biodegradation of biomass separately from the Scope 2 GHG emissions but include emissions of other types of GHG (in particular, CH4 and N2O). In case the emission factors applied do not separate the percentage of biomass or biogenic CO2, the undertaking shall disclose this. In case GHG emissions other than CO2 (particularly CH4 and N2O) are not available for, or excluded from, location-based grid average emissions factors or with the market-based method information, the undertaking shall disclose this.’
In addition to Scope 2 emissions, ESRS E1 AR 46 (j) requires the undertaking to report biogenic Scope 3 emissions separately. ESRS E1 paragraph AR 46 (j) states that the undertaking shall ‘disclose biogenic emissions of CO2 from the combustion or biodegradation of biomass that occur in its upstream and downstream value chain separately from the gross Scope 3 GHG emissions, and include emissions of other types of GHG (such as CH4 and N2O), and emissions of CO2 that occur in the life cycle of biomass other than from combustion or biodegradation (such as GHG emissions from processing or transporting biomass) in the calculation of Scope 3 GHG emissions …’.
ESRS 1 paragraphs 69 and 71 state that:
‘69. There are circumstances where the undertaking cannot collect the information about its upstream and downstream value chain as required by paragraph 63 after making reasonable efforts to do so. In these circumstances, the undertaking shall estimate the information to be reported about its upstream and downstream value chain by using all reasonable and supportable information, such as sector-average data and other proxies’; and
‘71. With reference to metrics, in many cases, in particular for environmental matters for which proxies are available, the undertaking may be able to comply with the reporting requirements without collecting data from the actors in its upstream and downstream value chain, especially from SMEs, for example, when calculating the undertaking’s GHG Scope 3 emissions.’
Illustrative example related to emission factors for biogenic emissions with fuel combustion in mobile sources:
Access to easily available emission factors for biogenic emissions associated with fuel combustion in mobile sources may not be readily available. However, producers of vehicles using internal combustion engines may have to model Scope 3 CO2 biogenic emissions – if deemed material - based on this data. If the estimation model is based on car sales per geography and average mileage of car during its useful life this could encompass finding country by country specific data on biofuel blends per type of fuel (diesel, gasoline, kerosene, etc), as well as likely evolution in future years. This will then allow to introduce a correction for the CO2 emissions and CO2 biogenic emissions of their Scope 3, Use of sold products category.
This example illustrates that while there may not be any “off the shelf” biogenic CO2 emissions for mobile combustion, it is possible to develop models and data that allows for their measurement. However, developing an emission model and its associated data will depend on the scope 3 category emissions being modelled and the specific facts and circumstances of the company.
Answer
As a reminder, it has to be clarified that AR 45(e) does not allow for the omission of Scope 2 CO2 biogenic emissions. What it says is that, in case that CH4 and N2O emissions are not available within the location-based or market-based emission factors, this fact shall be disclosed. However, this does not prevent the undertaking from estimating these emissions in case they are significant, for example based on the emission factors provided by the IPCC (see Tables 2.2 to 2.10) for specific fuels and combustion technologies.
Regarding GHG Scope 3 emissions, the principle of what to disclose is similar to GHG Scope 2 emissions. However, depending on the significant GHG Scope 3 category and the specific facts and circumstances of the undertaking, the identification of biogenic CO2 emission sources, of biogenic CO2 emission factors or the specific approach to model the biogenic CO2 emissions of the Scope 3 category may be challenging. EFRAG will develop illustrative examples in further guidance of approaches that can be taken to model Scope 3 biogenic CO2 emissions. [An illustrative example is listed in the background to this question.]
Relations
Paragraph | Content |
|---|---|
5.2 Estimation using sector averages and proxies | |
5.2 Estimation using sector averages and proxies | |
5.2 Estimation using sector averages and proxies | |
disclose biogenic emissions of CO2 from the combustion or biodegradation of biomass that occur in its upstream and downstream value chain separately from the gross Scope 3 GHG emissions, and include emissions of other types of GHG (such as CH4 and N2O), and emissions of CO2 that occur in the life cycle of biomass other than from combustion or biodegradation (such as GHG emissions from processing or transporting biomass) in the calculation of Scope 3 GHG emissions; | |
disclose biogenic emissions of CO2 carbon from the combustion or biodegradation of biomass separately from the Scope 2 GHG emissions but include emissions of other types of GHG (in particular CH4 and N2O). In case the emission factors applied do not separate the percentage of biomass or biogenic CO2, the undertaking shall disclose this. In case GHG emissions other than CO2 (particularly CH4 and N2O) are not available for, or excluded from, location-based grid average emissions factors or with the market-based method information, the undertaking shall disclose this. | |
disclose biogenic emissions of CO2 from the combustion or biodegradation of biomass that occur in its upstream and downstream value chain separately from the gross Scope 3 GHG emissions, and include emissions of other types of GHG (such as CH4 and N2O), and emissions of CO2 that occur in the life cycle of biomass other than from combustion or biodegradation (such as GHG emissions from processing or transporting biomass) in the calculation of Scope 3 GHG emissions; | |
disclose biogenic emissions of CO2 carbon from the combustion or biodegradation of biomass separately from the Scope 2 GHG emissions but include emissions of other types of GHG (in particular CH4 and N2O). In case the emission factors applied do not separate the percentage of biomass or biogenic CO2, the undertaking shall disclose this. In case GHG emissions other than CO2 (particularly CH4 and N2O) are not available for, or excluded from, location-based grid average emissions factors or with the market-based method information, the undertaking shall disclose this. | |
disclose biogenic emissions of CO2 carbon from the combustion or biodegradation of biomass separately from the Scope 2 GHG emissions but include emissions of other types of GHG (in particular CH4 and N2O). In case the emission factors applied do not separate the percentage of biomass or biogenic CO2, the undertaking shall disclose this. In case GHG emissions other than CO2 (particularly CH4 and N2O) are not available for, or excluded from, location-based grid average emissions factors or with the market-based method information, the undertaking shall disclose this. | |
disclose biogenic emissions of CO2 from the combustion or biodegradation of biomass that occur in its upstream and downstream value chain separately from the gross Scope 3 GHG emissions, and include emissions of other types of GHG (such as CH4 and N2O), and emissions of CO2 that occur in the life cycle of biomass other than from combustion or biodegradation (such as GHG emissions from processing or transporting biomass) in the calculation of Scope 3 GHG emissions; | |
disclose biogenic emissions of CO2 carbon from the combustion or biodegradation of biomass separately from the Scope 2 GHG emissions but include emissions of other types of GHG (in particular CH4 and N2O). In case the emission factors applied do not separate the percentage of biomass or biogenic CO2, the undertaking shall disclose this. In case GHG emissions other than CO2 (particularly CH4 and N2O) are not available for, or excluded from, location-based grid average emissions factors or with the market-based method information, the undertaking shall disclose this. |