Preparing Your Organization for a Carbon Footprint Verification

An earlier article on this blog described verification from the verifier's side. This one takes the organization's side, using the practical section at the back of the TGO Guideline for Verification of the Carbon Footprint of an Organization (2017) and the TGO Requirements (2022). Page numbers are printed page numbers.

#Before you contact a verifier

An organization that chooses verification must prepare a GHG report that is complete, consistent, accurate, relevant and transparent; the verification statement must be made available to intended users on request, and any confidential information withheld must be explained (TGO CFO Requirements, 2022, p.30). Section 10 adds a verification plan in line with the TGO guideline and an assurance level that fits its users and the registration criteria (TGO CFO Requirements, 2022, p.34). The documents supporting the inventory must be kept for verification, on paper or electronically (TGO CFO Requirements, 2022, p.28); where reporting is required by law, the usual practice is to keep them for 10 years (TGO CFO Requirements, 2022, p.72).

The guideline names three documents the organization prepares in the TGO format: TCFO_R_01, the GHG inventory; TCFO_R_02, the emissions and removals report; and TCFO_R_03, the verification request form (TGO Verification Guideline, 2017, p.105). A verifier needs enough information to decide whether to accept, and formal acceptance is by letter within two weeks (TGO Verification Guideline, 2017, pp.72-73). The verification body then checks the submission against the latest assessment guideline and may survey the site first (TGO Verification Guideline, 2017, p.74).

#Fix the common errors first

The guideline lists what verifiers most often find in a first submission: abbreviated process names; sources left out without a suitable reason; unstated data sources or collection methods; typing, copy and paste errors (TGO Verification Guideline, 2017, p.76); calculations that link to the wrong figures; and documents not in the TGO format (TGO Verification Guideline, 2017, p.77). The preparation phase should not take more than one month, but it runs longer when the verifier is waiting for data (TGO Verification Guideline, 2017, p.79).

#Understand how sampling will work

The sampling plan reflects the assurance level. For limited assurance the verifier checks the evidence behind the final figures and every item whose share of emissions is not less than the materiality threshold; for reasonable assurance every data item and every point where data are collected, transferred, separated or calculated (TGO Verification Guideline, 2017, p.78). High-emission items may be checked in full, and the riskiest points are manual entry and spreadsheet calculations (TGO Verification Guideline, 2017, p.79). For sample size the guideline gives the Taro Yamane formula, n = N divided by (1 + N times e squared), with a table at 95 percent confidence in which 100 records give a sample of 80, 1,000 give 286 and 10,000 give 385 (TGO Verification Guideline, 2017, p.80).

#The six preparation steps

The verifier then sends the preliminary information, the agreement and the schedule; the plan may still change, and any change is recorded in writing (TGO Verification Guideline, 2017, p.82). The guideline then sets out what the organization should do before the site visit (TGO Verification Guideline, 2017, pp.82-83):

1. Understand the objectives of the verification and review the TGO assessment guideline.
2. Assign roles and responsibilities for the verification to the relevant staff, and make them known to everyone.
3. Check and confirm the accuracy of the GHG data in the information system and in the prepared inventory.
4. Prepare the supporting documents referenced in the report, filed for easy retrieval, especially for the largest sources and those the verifier has flagged.
5. Prepare the documentary or electronic evidence of GHG data management, such as photographs of internal audits, management minutes on data review, and the procedures cited in the report.
6. If defects are found before the site visit, correct them at once or through a systematic process, and tell the team plainly that the data have changed from what was sent.

#What happens on site

The visit opens with a meeting that confirms the agreement, introduces the team and the schedule, and has the organization present its staff and the inventory (TGO Verification Guideline, 2017, pp.83-84). The team then checks evidence, interviews people, inspects the site and closes with a summary meeting (TGO Verification Guideline, 2017, p.84). The first part of the work assesses the information system and its controls, following the data flow from manual entry to the final figures (TGO Verification Guideline, 2017, p.85); the verifier records who was interviewed and how raw data are obtained, and checks that staff know their roles (TGO Verification Guideline, 2017, p.86).

The items assessed run from boundary and method decisions, monitoring procedures, instruments and the approval process before data enter the system to the competence of staff (TGO Verification Guideline, 2017, p.87), and on to management policy, calibration, the correction of defects and access rules that prevent improper changes (TGO Verification Guideline, 2017, p.88). The second part assesses the data through three kinds of evidence: physical, such as meters showing raw data before it is copied; documents; and attestations already approved internally or externally (TGO Verification Guideline, 2017, p.89).

For a combustion source, the sample questions include whether the fuel contains a biofuel component, how biogenic CO2 is calculated, whether internal and external records agree and whether fuel sold to staff is separated (TGO Verification Guideline, 2017, p.90), which GWP values were used and when instruments were last calibrated (TGO Verification Guideline, 2017, p.91). The verifier also recalculates figures and back-calculates conservative estimates (TGO Verification Guideline, 2017, p.92).

#Findings and how they are closed

At the closing meeting, findings fall into three types: a Corrective Action Request (CAR), an error the organization must correct or a risk it must prevent (TGO Verification Guideline, 2017, p.94); a Clarification (CL), a point that is unclear or insufficiently supported; and a Forward Action Request (FAR), a significant matter checked at the next verification. The organization may dispute the findings, but the verifier cannot advise on how to fix a CAR or FAR, must say exactly what a CL requires, and sets a deadline and channel for the response (TGO Verification Guideline, 2017, p.95).

After the visit the team sends a draft report; corrections generally take no more than two weeks for system defects and incomplete data, longer where equipment must be tested or installed (TGO Verification Guideline, 2017, p.97). Issues that cannot be fixed, such as missing historical data, are judged conservatively and may become limitations in the statement; an uncorrected material error, or one answered after the deadline, can lead to an adverse result with no certification (TGO Verification Guideline, 2017, p.100). The conclusion wording differs by level: limited assurance reports that no evidence of materially incorrect data was found, reasonable assurance that the material data are correct and fairly represented (TGO Verification Guideline, 2017, p.102). The draft statement goes back to the organization for approval before the official version is issued (TGO Verification Guideline, 2017, p.103).

#How CarbonBiz supports this

The App's verification features follow this process. An engagement records the year, scope and target assurance level, a readiness gate checks evidence coverage, and the data set is snapshotted with a SHA-256 hash and locked so the figures cannot drift during the review. An external verifier is invited with a single-use link to an engagement-scoped, read-only account. Findings are tracked with a clause, a severity and an append-only thread until closed; the App labels them NCR, CL and OBS rather than the CAR, CL and FAR of the TGO guideline. The statement is uploaded at the end, the data room can be exported, and the audit log is immutable. Preparing the people, the answers and the files remains the organization's job.