For future review - which datapoints from the CSRD in Europe would help enrich the dataset?

[mrchrisadams]

Hey folks.

I've been reading some more about sustainability reporting standards that come into effect this year

Hey folks,

I've been reading a little around the law in Europe that relates to a project we're working on, called Carbon.txt. We're building tooling to parse the structured sustainablity themed disclosures that various companies are mandated to publish this year if they want to operate in Europe.

Anyway, the thing that caught my eye, might be of interest to the group here. It looks like there's some language in the required disclosure standards about whether power is coming from PPAs or as unbundled power.

I haven't included them, but the scope 1 requirements, along with the EED stuff we discussed before give me the impression that even if not disclosed publicly, the data will need to be collected to provide region level location based carbon intensity figures that account for onsite generation. I think this is important for things like the 2 GW of gas generation to power Meta's new datacentre, the 170 MW gas generation intended to be used as supplementary power for the one of the Microsoft regions in Ireland, and DC's built following the Offgrid AI approach, where grid is very much presented as a secondary source of power if at all.

Anyway, here's the section from the standards, and the link to the text highlighted below

When preparing the information on gross Scope 2 GHG emissions required under paragraph 49, the undertaking shall:

• (a) consider the principles and requirements of the GHG Protocol Scope 2 Guidance (version 2015, in particular the Scope 2 quality criteria in chapter 7.1 relating to contractual instruments); it may also consider Commission Recommendation (EU) 2021/2279 or the relevant requirements for the quantification of indirect GHG emissions from imported energy in EN ISO 14064-1:2018;

• (b) include purchased or acquired electricity, steam, heat, and cooling consumed by the undertaking;

• (c) avoid double counting of GHG emissions reported under Scope 1 or 3;

• (d) apply the location-based and market-based methods to calculate Scope 2 GHG emissions and provide information on the share and types of contractual instruments. Location-based method quantifies Scope 2 GHG emissions based on average energy generation emission factors for defined locations, including local, subnational, or national boundaries (GHG Protocol, “Scope 2 Guidance”, Glossary, 2015). Market-based method quantifies Scope 2 GHG emissions based on GHG emissions emitted by the generators from which the reporting entity contractually purchases electricity bundled with instruments, or unbundled instruments on their own (GHG Protocol, “Scope 2 Guidance”, Glossary, 2015); in this case, the undertaking may disclose the share of market-based scope 2 GHG emissions linked to purchased electricity bundled with instruments such as Guarantee of Origins or Renewable Energy Certificates. The undertaking shall provide information about the share and types of contractual instruments used for the sale and purchase of energy bundled with attributes about the energy generation or for unbundled energy attribute claims.

• (e) 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.

• (f) not include any removals, or any purchased, sold or transferred carbon credits or GHG allowances in the calculation of Scope 2 GHG emissions.

It's not clear how detailed this would need to be, but it seems like it would mean disclosure of data not currently in the public domain in the very least.

Issue dependency with other WGs Groups

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