Stakeholders are increasingly seeking greater transparency and data around voluntary corporate emissions reduction and renewable electricity commitments. While many Australian companies voluntarily report their emissions data and target information, formats and detail vary, making comparisons difficult. Industry and the Clean Energy Regulator have been collaborating to develop a simple way of presenting a company’s net emissions position.

The initial design of the Corporate Emissions Reduction Transparency (CERT) report was established with draft guidelines and a simple report format that presented key emissions, renewable energy and carbon offset information and data for participating National Greenhouse and Energy Reporting (NGER) scheme companies.

1. Public consultation 1
2. Public consultation 2

The Clean Energy Regulator published a consultation paper seeking feedback on a possible design of the CERT report and its proposed guidelines. Consultation was open from 19 February to Friday 19 March 2021.

What we heard

We received 55 submissions in response to our consultation paper. Most submissions stated that they valued an independently published report that presented the net emissions position of participating companies as well as progress against their voluntary commitments. Stakeholders also expressed support for the CERT report to:

• Provide flexibility in how emissions reduction commitments were presented, including the ability to present multiple commitments.
• Align with other domestic and international sustainability reporting frameworks where practical.
• Allow context statements to be included to aid understanding.
• Cover both net scope 1 and net scope 2 emissions.

Submissions (show/hide)

Some submissions are confidential and have not been published. Submissions are not owned by the Clean Energy Regulator and we cannot guarantee that they meet accessibility requirements .

Name    File Size    CERT submission - AEC 172 KB CERT submission - AGIG 113 KB CERT submission - AGL 126 KB CERT submission - Alinta Energy 98 KB CERT submission - Aluminium Council 923 KB CERT submission - Appea 5660 KB CERT submission - BCA 1137 KB CERT submission - BHP 300 KB CERT submission - Bioenergy Australia 183 KB CERT submission - BOSMA 895 KB CERT submission - CCL Citizens’ Climate Lobby Australia 65 KB CERT submission - City of Melbourne 625 KB CERT submission - Clean Gas Council 619 KB CERT submission - Climateworks 713 KB CERT submission - CME Chamber of Minerals and Mining of WA REDACTED_Redacted 387 KB CERT submission - Cooper Energy 206 KB CERT submission - CSIRO 251 KB CERT submission - Hydro Tas 1560 KB CERT submission - IGCC Investor Group on Climate Change 288 KB CERT submission - NAB 1155 KB CERT submission - NABERS 81 KB CERT submission - National GreenPower Accreditation Program 476 KB CERT submission - Ndevr 212 KB CERT submission - Northmore Gordon 541 KB CERT submission - Orica 254 KB CERT submission - Property Council of Australia 329 KB CERT submission - Rio Tinto 109 KB CERT submission - SANTOS 81 KB CERT submission - Six Capitals Consulting 163 KB CERT submission - South East Water Attachment A 192 KB CERT submission - South East Water 148 KB CERT submission - Tim Kelly 549 KB CERT submission - Town of Gawler SA 295 KB CERT submission - Wilmar 811 KB CERT submission - Woodside 4268 KB CERT submission - World Kinect Energy Services 92 KB CERT submission - WWF and Global Compact Network Australia 215 KB

What we heard

We received 34 submissions (10 of which were confidential). Most submissions supported CERT in principle and agreed that the proposed guidelines were a suitable basis for the pilot. Beyond the pilot, stakeholders were of the view that CERT should evolve to:

• Include the ability to verify data associated with Scope 3 emissions commitments, emissions intensity commitments, and international commitments and activities.
• Recognise large-scale generation certificate (LGC) surrenders as part of jurisdictional renewable energy targets in the calculation of progress towards renewable electricity commitments.
• Publish more detail about carbon units.
• Support participation by a broader group of companies beyond the companies that currently meet the National Greenhouse and Energy Reporting scheme publication threshold.
• Update state emissions factors for scope 2 emissions and expand eligible inputs to the calculation of the renewable electricity percentage.

Many submissions sought further clarity around the operation of specific aspects of the guidelines. Stakeholders also suggested improvements to the proposed Company View, especially around the presentation of certificates and carbon units.

Stakeholders welcomed the public consultation and recent co-design process, and many noted the positive progress that has been made on CERT’s design.

Submissions (show/hide)

Name    File Size    AGL Energy Limited 134 KB Alinta Energy 94 KB APA 289 KB Australian Aluminium Council 881 KB Australian Petroleum Production and Exploration Association Ltd 234 KB Bioenergy Australia 168 KB Cement Industry Federation 451 KB Chartered Accountants Australia and New Zealand 115 KB Clean Energy Council 255 KB ClimateWorks Australia 573 KB Electricity Working Group of South Australian Councils 756 KB EnergyAustralia 321 KB Engineers Australia 130 KB GFG Alliance Australia 128 KB Green Building Council of Australia 359 KB Hydro Tasmania 942 KB Iberdrola Australia 421 KB KPMG 900 KB NABERS 424 KB Neoen Australia 339 KB Pangolin Associates 182 KB Property Council of Australia 444 KB Six Capitals Consulting 382 KB Tim Kelly 1036 KB Water Corporation of Western Australia 272 KB

What we will do

We have made minor updates to the guidelines and the Company View as outlined below. We will also consider key themes raised in submissions and undertake further work where required, during the pilot, the pilot evaluation or as part of CERT’s future design.

Updates to the guidelines

We have updated the CERT guidelines to provide further clarity on the operation or context of specific elements. The guidelines now more clearly allow progress to be presented in terms of tonnes CO2-e, as well as a percentage, where relevant to a participant’s commitment.

Examples and explanatory information

Supporting information, including a suite of examples, will be published to assist participants understand and use the CERT guidelines.

Updates to the company view

The agency has adjusted the Company View. This includes:

• Visually separating LGCs from carbon offset units.
• Presenting progress in terms of tonne CO2-e alongside the percentage value.
• Highlighting scope 3 efforts by including an iconfor relevant commitments.

An updated version of the Company View is provided below. The Company View will continue to be refined during the pilot.

Please click on the image below to download a high resolution version.

Design elements for future consideration

During public consultation, stakeholders raised themes for the agency to consider as part of CERT’s evolution. Our proposed approach is set out below.

Proposed approach (show/hide)

Suggestions from stakeholders	Our approach
Include LGC surrenders made under jurisdictional renewable energy targets.	We will consider this issue in parallel with the pilot.
Recognise emissions intensity and renewable generation commitments as ‘progress verified’ using agency data; recognise contractual agreements as evidence.	We will consider this for the future design of CERT, noting that further work is required to be able to verify data associated with emissions intensity commitments. To avoid double counting, PPAs and contractual commitments for renewable electricity will not be accepted in CERT.
Broaden CERT eligibility to companies beyond NGER reporters above the publication threshold.	We will consider this issue during the evaluation of the pilot.
Recognise global commitments and associated emissions reduction activities.	Participants can include international commitments in the ‘Other commitments - company assured’ section. At this stage, we do not intend to expand CERT to include verification of data associated with international emissions commitments or activities. We are open to considering how international commitments may best be presented in the Company View as part of CERT’s future design.
Recognise Scope 3 emissions commitments as progress verified, particularly where a higher level of independent assurance has been undertaken by third parties (e.g SBTi commitments).	Participants can include Scope 3 emissions commitments in the ‘Other commitments - company assured’ section and include notes or links regarding any independent verification undertaken. We are open to exploring how independently audited information may best be presented in the Company View as part of CERT’s future design.
Recognise Climate Active certified products (electricity, fuels, etc.) and related units.	We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies.
Review the residual mix factor calculation methodology.	We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies.
Include other sources of emissions generated from activities that are not reportable as part the NGER scheme.	We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies.
Review Scope 2 accounting methodology, including emission factors. Recognise small-scale generation and other sources of electricity generation.	We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies.
Review renewable percentage calculation and recognise below baseline renewables and other types of electricity generation.	We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies.
Company view: Publish more detail on carbon units attributes.	We will consider further transparency on units in parallel with pilot for potential inclusion in future design of the CERT report.
Company view: Consider an alternate way to present progress towards long-term, capital-intensive commitments that result in step-change emissions reductions	We will consider whether further changes would aid comprehension in future design of the CERT report, noting that capital-intensive targets (step change) can already be described in commitment context statement.
Company view: Clarify where CERT aligns or diverges from Climate Active and GHG Protocol.	We will provide guidance on any areas of divergence between CERT, Climate Active and the GHG Protocol.
Company view: Allow groupings of subsidiaries rather than just subsidiaries and parents.	We will undertake further work during the pilot to consider alternative groupings of subsidiaries. For example, we can consider adding further icons or other visual elements to the Company View to aid readability.

Following public consultation 1, the Clean Energy Regulator undertook a co-design process with a cohort of NGER reporters.

The co-design process took into account feedback from public consultation and considered how the CERT report could contribute to corporate sustainability reporting by companies. The scope of the CERT report, alignment with how emissions commitments are framed, accounting frameworks and options for presenting data in CERT were worked on. A key priority was balancing the need for flexibility with the need for clarity and comparability.

As a result of the co-design process, updated guidelines and an improved report format were developed.

Opt-ins to the CERT report pilot are closed.

The first report is operating as a pilot to test and refine the guidelines, administration, and reporting arrangements. It is expected that the guidelines will continue to evolve beyond the pilot.

Participation in the pilot was open to companies reporting more than 50 kilotonnes of emissions a year under the National Greenhouse and Energy Reporting (NGER) scheme. The report will use data from NGER, the Renewable Energy Target scheme and Australian National Registry of Emissions Units. Participants will also provide information on their commitments and operating context.

Companies that have opted-in will be able to present:

• Progress towards their emission reduction commitments.
• Their net emissions and renewable electricity position.
• The volume and percentage of certificates and units voluntarily surrendered.