Recently I published my first academic paper, which showed that the vast majority of companies publish emissions numbers without any associated communication of uncertainty. I made the case in a previous blog post on my website for why I think that uncertainty analysis is important in GHG accounting (if you didn’t read that, in short, most carbon accounting is currently a fugezi and, without uncertainty analysis, seems way more credible than it is).
Since then, I’ve had a back and forth with some people working at the GHG Protocol about the findings of my paper and the question of uncertainty. The GHG Protocol is the organisation that sets the standards for how corporate carbon footprints are calculated, and it is currently in the middle of a once-per-decade update to the standards. Given that uncertainty analysis is still optional, I felt that I needed to shoot my shot and send them my findings, so I reached out to some of the people co-ordinating the ongoing update cycle. What has followed has been a long and interesting email exchange about uncertainty which, while very useful, has left me fixated on one question - namely, what do we all think that GHG accounting is actually for?
Carbon accounting since its inception has largely been conducted by companies on a voluntary basis. Companies publish these numbers to publicly slap themselves on the back and signal to everyone else that they are conscientious actors in the world. This concept is simple and goes by many names: in organisational theory this is called “social licence to operate”; in the culture it’s called “virtue signalling”. It reflects the idea that organisations can only exist on condition of ongoing acceptance by wider society (I don’t fully subscribe to this idea; lots of organisations which are widely derided seem to be doing just fine). In this conception of carbon accounting, the numbers themselves are almost beside the point; it’s the act of reporting which is creating value. Whether this thinking informed the founding mission of the GHG Protocol or ISO standards remains unclear to me, but in its woolly modern Mission and Vision statement the GHG Protocol says, “Our vision is that all private and public entities account for their GHG emissions, enabling an acceleration in reductions in line with the global warming limits required by climate science.”
While this sounds good, it doesn’t provide a clear message which describes how they think that the numbers will enable this reduction of emissions. In particular, they don’t answer the most fundamental question: how should these numbers be used?
It seems clear to me that the purpose of reporting these numbers should be to provide credible decision-making inputs. They should be numbers by which not only the companies themselves, but investors, policy makers or consumers can take some of the millions of decisions necessary for us to organise our economies in the most carbon-efficient way possible. Decision-making at its core involves considering and evaluating potential options for a future course of action, and then making a choice based on the available information. A series of well-informed decisions is the only way we can get from our current unsustainable society to a society that has limited global warming in alignment with the climate science, and I think nearly all good decisions rely on comparing the viable alternatives. As we take this idea to its conclusion, I think that some kind of definition for the essential purpose of GHG accounting begins to emerge.
However, when I put my ideas to the GHG Protocol representatives and read their responses, I realised that my core conception of carbon accounting was not shared. In responding to my argument that uncertainty analysis should be mandatory to enable comparison, the GHG Protocol representatives responded with potential tiers of requirements which considered the different contexts in which companies were reporting their numbers. In short, they proposed the idea that if the numbers were only being presented in an informational context they shouldn’t require uncertainty analysis, but if they were being presented to underpin a specific claim (e.g. “we have reduced our carbon footprint by 50%”) they should.
While I welcome any change which introduces uncertainty analysis, this slightly baffled me. It was at once a recognition that in a real decision-making context uncertainty analysis would be valuable (i.e. as evidence for backing up a claim), while suggesting that there were scenarios for reporting where it doesn’t matter. Implicit in this idea is an underlying belief that there are situations in which the reported numbers don’t matter and aren’t likely to be used to take decisions. This seems nuts to me - why should we ask anyone to dedicate resources to producing the numbers in this case, and what impact will they have?
Carbon accounting and LCA for products are particularly clear examples of where this type of thinking breaks down. A consumer who is buying a new laptop, or a procurement team who is evaluating potential suppliers, might pick one over the other directly on the basis of the numbers which were reported. No claims have to be made by the organisations that make the products, but their reported numbers directly lead to a decision - a decision which may be incorrect if the numbers turn out to be incomparable on the basis of underlying methodologies, data and uncertainties. However, this idea of carbon accounting numbers being reported in some sort of neutral informational space, not intended for external decision-making, is something I’ve come across before.
I’ve had arguments time and again with carbon accounting and LCA experts who maintain that we shouldn’t expect or hope for comparability in carbon footprints across different organisations and products. They reject the idea of comparability outright and argue that the data is just an informational tool by which internal decision-makers can better understand their own impacts and make changes. To me that seems like a fairly unambitious vision for the discipline and one which is likely to fail in bringing about any system-wide reductions in emissions. The only people who can decisively influence emissions in this circumstance are a small group of people with a moral imperative for improving their own products and processes. Can we honestly expect that to bring about the change we need? What about when those same people also have to consider their costs, timeframes, or more likely, are impeded by that deep resistance to change that exists within most people? Furthermore, it excludes a whole set of people who should have the means to take impactful decisions to reduce system-wide emissions. It excludes the consumers, who want to compare two products with the same function on a like-for-like basis and pick the one which they know to be of lower impact. It excludes investors, who want to screen thousands of companies for their carbon performance and direct their resources to the best-performing ones. It excludes politicians, who want to try and reduce emissions across a whole sector of their national economy, and all of the companies which comprise it. Without comparability, none of these decisions can be taken.
In my view, we have completely lost sight of any wider theory of the purpose of carbon accounting (if there ever was one) across the sustainability industry. The discourse is now dominated by people arguing about incredibly niche methodological complexities and advocating for ever more complex and divergent methods for calculating footprints. This is reflected in the meeting notes emerging from the GHG Protocol’s ongoing update project, where scores of carbon accounting boffins appear to be engaged in a Hunger Games-like contest to have their chosen methodological ideas win. Chain of custody models, recycling methodologies, electricity accounting, biogenic carbon, the list goes on. Where is the working group that is investigating if carbon accounting as it currently exists is fit for purpose? I am not trying to criticise individuals who care deeply about the consistency and rigour of the methods; I have often fallen into this trap myself (the irony of nesting this criticism in the middle of a treatise on the importance of uncertainty analysis is not lost on me). However, I was alarmed to discover that this formless conception of the purpose of carbon accounting exists right at the heart of the discipline. It appears to me that most people involved in the discipline, including the standard-setters, care more deeply about the process than the outcome which we are collectively trying to achieve.
We need to get back to focusing on the outcomes. The goal is the system-wide reduction of emissions; the carbon accounting numbers are just a means. In that light, a good argument can be made for less complexity and nuance in the standards, not more, and more focus on genuine comparability between reported numbers, comparability which gives us a better chance of making the best decisions in pursuit of our goal. We should all be honest with ourselves in admitting that carbon accounting is currently a quasi-scientific discipline, as are, to some extent, LCA and other related methodologies. What I mean by this is that we’ve borrowed the aesthetics of science in how we talk about them (precise numbers, standardised methods, technical working groups) while jettisoning some of the foundational commitments of science, which include honestly representing what you do and don’t know and what you can and can’t infer from data. LCA is better at this than carbon accounting, but we still have a long way to go across the board.
I think that is why I care so much about uncertainty analysis and won’t stop banging the drum. If one number said that a product produced 10 tonnes of carbon dioxide, and another number said 11 tonnes of carbon dioxide, we are likely to pick the first one if we don’t understand that the former is a very uncertain estimate and the real value could be anywhere between 5 and 20 tonnes. It is a means of improving comparability by acknowledging the potential significance of the things which you don’t know, or the weaknesses and limitations of your methods and data. It’s about helping people to take the best decisions. I worry that if those principles aren’t at the core of how we think about the discipline, then carbon accounting is little more than a marketing tool.
We are in the middle of a rare opportunity to steer the discipline in a new direction which prioritises outcomes. For the past 20 years it didn’t really matter what the numbers were for because they were voluntary and not universal, but a slate of new legislation across the world, including CSRD, SB 253 and SECR, is explicit in defining these numbers as inputs to external decisions. They have the right idea, but we now need to ensure that our standards, discourse and best practices are fit to deliver on that.
Uncertainty analysis is one small piece of this puzzle, which also includes removing unnecessary flexibility, loopholes, and optionality in the types of data and methods that you can use. But the main thing we need is to be relentless in reforming the discipline in pursuit of a set of stated outcomes, which we all agree on and could explain clearly to a non-expert in 30 seconds without hesitation, repetition or deviation. If we do that, then people can easily do the things that are within their gift, like picking the right suppliers, deploying financing, or designing national policy which actually accelerates system-wide reductions in emissions.
If we can’t do that, then what exactly is carbon accounting for?