Reporting Renewable Energy Guarantees of Origin (REGOs)
Background
In 2017 the following statement was agreed by Scottish Government and SSN:
“The Sustainable Scotland Network (SSN) has been asked by members to establish a position on the use of Renewable Energy Guarantees of Origin (REGO) accredited energy options and how these should be reported in annual public body climate change reports. SSN has worked with the Scottish Government to agree a consistent approach, which applies to both renewable electricity and ‘green-gas’ schemes available in the UK energy marketplace and which are available for public bodies to procure.
The Scottish Government fully supports the uptake of 100% renewables tariffs. However, for the purpose of Public Bodies Climate Change Duties (PBCCD) annual reporting bodies should continue to report using UK-wide emission factors in section 3 of the reporting template. This approach will ensure consistency of reporting across the sector, using a well-established reporting framework.
We fully support positive action taken by public bodies to tackle climate change, and the reporting template will enable public bodies who have purchased 100% renewables tariffs (or other green energy options) to highlight their leadership in this area. This should be done within the appropriate comment boxes in the reporting template.”
Update: If electricity is purchased through a green tariff, you should still account for the electricity consumed using the BEIS average UK grid factor. This is because PBCCD reporting uses the ‘location-based’ approach to accounting, as opposed to a ‘market-based’ approach.
The ‘location-based’ method reflects the average emissions intensity of the grid on which energy consumption occurs (using mostly grid-average emission factor data). A market-based method reflects emissions from electricity that companies have purposefully chosen (or from a lack of choice). It derives emission factors from contractual instruments, which include any type of contract between two parties for the sale and purchase of energy bundled with attributes about the energy generation, or for unbundled attribute claims. The GHG protocol Scope 2 guidance stipulates using both methods to report emissions, but PBCCD reporting does not have any facility for this, apart from noting it qualitatively in Section 3 of the report, which bodies are encouraged to do.
Three reasons to opt for locational-based accounting:
1. There is relatively little evidence that green tariffs incentivise additional renewable generation.
2. Reducing electricity consumption has strong benefits with regard to costs and security of supply.
3. Enabling organisations to zero their electricity carbon footprint through purchasing is likely to de-incentivise actions to reduce consumption.