Do social housing providers have to comply?
This is one of the first questions we get asked. The official guidance does offer a formal answer but is quite legally orientated and interpretation depends on whether the provider is a public body or not. Our general advice to is to do the SECR anyway as doing so will probably involve the same cost and effort as securing legal advice. Plus, the organisation ends up with a carbon footprint which is useful for multiple other reasons.
Mandatory emissions reporting
The mandatory parts of SECR are scope 1, scope 2 and specified parts of scope 3. These are normally straightforward as they are based on the amount of gas, electricity, diesel and petrol the landlord has bought. We have found that even the exercise of tracking energy purchases can reveal wastage, most notable is paying for energy that the provider doesn’t use!
Optional emissions reporting
Apart from grey fleet business mileage, reporting on scope 3 emissions is optional. However, the homes that a provider manages typically emit a huge percentage of the carbon footprint and so we routinely report on these. Unlike mandatory emissions reporting, there are no standard conversion factors and so at SHIFT we have developed our own factors based on the energy efficiency rating of the properties.
The next most significant scope 3 is the embodied CO2 in the building materials of new homes. Typically, we have found that the primary data (e.g. tonnes of concrete used) needed to do the calculations is rarely available. This is something we believe the housebuilding sector needs to be more transparent on. In any event, we have built up a library of data that we can use to estimate these emissions in the absence of primary data.
The final bits
Energy efficiency actions – this normally extremely easy for providers, especially if they are reporting emissions attributed to homes. Providers are continually upgrading housing stock.
Methodology –this section will describe the use of Defra conversion factors, any other methodologies used and any estimates made.
If you need help with your SECR statement for compliance or other purposes, please feel free to get in touch: [email protected]