Encouraging reporting entities to use estimation tools “as a starting point” to identify and meet Scope 3 obligations implies a normative expectation that estimation is only a temporary measure that may be unacceptable over the long-term which is inconsistent with legislation. The use of estimation methods remains permissible regardless of future data availability. This language is also inconsistent with Regulatory Guide RG280 Sustainability Reporting published by the Australian Securities and Investments Commission which clearly states that the extent of reliance on secondary data to measure Scope 3 GHG emissions “may evolve over time” as the availability and quality of data improves.
The NFF’s full submission can be found here.
Stacey Davidson