How One School Solved A Covid-19 Social Distancing Headache
(and sorted out its carbon footprinting and SECR liability)
James Andrew, Estate Bursar at St Oggin (the Endless Redeemer) College in Plymouth gazed out to sea. He was indeed a lucky, lucky man. After several years’ service in the Senior Service he had scooped this dream job in one of the two famous independent schools in his adopted home-town and thus avoided uprooting the family when the time came to return to civilian life. By another remarkable stroke of good fortune, his office overlooked the River Tamar and on a clear day he could see the ships moored in Devonport.
Today his luck was in. It was a cloudless sky and one of the carriers was in. But he had work to do and no time to gaze longingly. Happily nearly all the students had returned at the start of the Autumn Term and his gaffer, the COO, was now slightly more relaxed about the balance sheet; but unhappily the issue of social distancing was proving a nightmare. The bursary staff and Assistant Head had spent many long days working out the new plan, but inevitably the harsh reality of 1000 independently minded youngsters plus over 250 not quite so young but equally inclined-not-to-conform-with-careful-plans staff had put a strain on the coordination of school programme and available space. And now it fell to him to find a way to host the exams when the new sports centre project was behind schedule because of Covid-19 – and the Great Hall had just been put out of commission because the ancient Grade 2 listed tower above it had just been deemed unsafe by a structural engineer. So, there was now a shortfall in available space but it was not an option not to hold the exams: not after the summer of 2020.
He looked at the vast expanse of emails in his in-tray, almost comparable in size to the vast expanse of the carrier deck away in the distance. They’d have to wait: he needed to get on with the exam space issue, which he had nicknamed Operation Long Shot. But then he glanced again at the carrier, with its vast flight deck, and thought about the immense hangar space below deck; and a crazy idea ventured into his mind. ‘If only’, he thought…
But at that moment his flight of fancy was interrupted by the arrival of a rather urgent and important email from the COO:
Title: SECR. ‘James. This has come up, or rather resurfaced. You may recall we got the heads up on this in 2018 but we put it on the back-burner because it wasn’t due yet. Now it is, and with all the Covid issues it’s slipped my mind. Coincidentally, the Chair of Governors is asking what we are doing about carbon-footprinting for the school. I think they are pretty much the same thing, but I’m not sure to what extent there is overlap and whether this is two tasks or one. Please would you muster all the detail and let me have your views – and the detail – by the end of the month.Sorry.’
It’s how it goes, isn’t it Dear Reader: you start the day thinking you have it under control and then – by a seemingly tortuous chain of apparently unconnected events – a Pooh-Trap arrives on your desk and nobody else in the entire staff, or world even, can resolve it but you.
Nothing daunted, James reached for his bible: ISBA Guide to Everything You Need to Know About Everything You Need to Know, sub-titled (by him) How to Keep School Governors Out of Court. Happily, he’d studied it in detail in his spare time and written copious notes, so that he didn’t have to read everything in detail each time a question arose. Here is an extract from his notes on carbon-footprinting and SECR.
Notes on Carbon-Footprinting & SECR (break glass in case of fast ball from Gaffer).
- Carbon-footprinting. Term tends to be used somewhat loosely. Best thought of as ‘determining our impact on the environment’ and actually covers much more than just our carbon footprint.
- SECR = Streamlined Energy & Carbon Reporting.
- SECR is in practice a subset of ‘A’. It is the legislation that requires certain organisations, including certain larger schools, to report on key aspects of their environmental impact annually.
- It came into force on 1 April 2019 and liable schools must start reporting in their first full reporting year after 1 April 2019. ‘Meaning Sept 2019 to August 2020 for us’ thought James. ‘Meaning that report is due to be submitted by end November; meaning this is now an issue. Ho-hum.’
- SECR liable schools are those which submit an annual Directors (and Trustees) Report under the Companies Act 2006 and meet 2 or more of these criteria:
- Turnover (or gross income) of £36 million or more,
- Balance sheet assets of £18 million or more,
- 250 employees or more.
(There is also an annual energy usage hurdle of 40,000kWh per year, but any large school will use much more than that on power, heat and transport combined).
N.B. Just because a smaller school will not be liable that does not negate the value of methodical assessment and annual reporting along the lines described here.
Reference Doc. The legislation is enshrined in HM Govt. Environmental Reporting Guidelines: Including streamlined energy and carbon reporting guidance, dated March 2019. This covers off environmental impact reporting in general but also gives specific guidance on SECR.
Underlying Purpose. Measure impact on environment and improvements (reductions in impact) year on year.
What Needs to be Done? 5 steps:
- Determine boundaries of organisation. Generally means the whole school, including the junior campus if there is one. But for SECR does not include non-UK assets, if a school has them; e.g. overseas branches.
- Determine period for data collection. Match financial year if possible.
- Determine key environmental impacts to be assessed. Generic categories in the govt guidance are:
- Greenhouse gases and other emissions.
- Materials & resource efficiency.
Comment. For any school wishing to assess its environmental impact, whether or not SECR liable, assessing the first 4 categories would make sense. Emissions and greenhouse gases from heat, power, transport have by far the biggest impact on climate change and pollution; but also addressing wastage & resource efficiency would be an area where proactive engagement by the staff and students could make a big difference to the school and environment. Besides, this broader exercise would have some clear educational benefits if the whole school could be engaged in the exercise.
- From utility bills, or energy management systems, etc,; i.e. how much are we using?
- For SECR has to be incl in annual Directors/Trustees’ Report. But wouldn’t it be so much more useful if the output from this exercise was communicated internally to the whole school so that everybody was kept engaged; and learnt from the exercise?
N.B. SECR schools MUST report on UK energy usage and specified greenhouse gas emissions (GHG) relating to power, gas combustion and transport usage, plus their intensity ratios for these (see Other Useful Nuggets below, for explanation), plus steps being taken to improve energy efficiency. BUT it would arguably make sense to treat this as a broader exercise: instead of just doing SECR, the mandatory bare minimum, do the complete exercise of determining environmental impact and progress across all relevant categories and then extract the SECR parts for the annual Directors Report as required. Why go to all that effort but leave out a large chunk of relevant and useful analysis?
How to Approach Task?
Best approach would be to gather data in-house but outsource the analysis of the data, partly because the analysis is a specialised task, but also because this meets the remit to have the exercise validated by an impartial 3rd party. (Although there is no legal requirement to have SECR audited by a 3rd party it is considered best practice and noted as such within the legislation).
Must report clearly on the methodologies used, if reporting under SECR.
Other Useful Nuggets
Scopes 1, 2, 3. These are now commonly used categories for greenhouse gas emissions (GHG) – but plenty of scope for confusion and the govt guidance is not entirely clear:
- Scope 1 = direct emissions from resources owned & controlled by the school. E.g. minibus fuel; heating fuel.
- Scope 2 = indirect emissions from the generation of energy used by the school but by resources not owned by the school. E.g. purchased grid power.
- Scope 3 = any emissions arising from the operation of the school not included in scopes 1 and 2.
Scopes 1 and 2 can be determined reasonably practically. Scope 3 is more difficult. SECR requires scopes 1 and 2 to be covered in full but makes some allowance for exclusion of Scope 3 emissions where these are from resources not controlled or owned by the school. E.g. fuel used by parents bringing children to school would be an exemption.
The first reporting year is the ‘base year’: the benchmark against which progress in subsequent years will be measured. But the reporting process also has to take due account of any significant changes in the scale or operation of the school year on year, to keep the annual comparisons meaningful.
- Set pragmatic targets for improvement: best to discuss with staff and students.
- Absolute = applies even if the school grows in size.
- Intensity = applies in proportion to size of school and therefore changes if the school changes. Hence the term ‘intensity ratio’.
Fortunately James and his team had been diligently recording the energy usage data for years, so it was not going to be difficult to sort out scopes 1 and 2 retrospectively.
James was about to pick up the phone to call the company he had in mind to assist with the analysis and drafting of the report, when who should call but the COO herself:
“James, great news. I’ve just heard from the Admiral.” (The Admiral, Dear Reader, was one of the governors. No longer serving, but still with plenty of strings to pull in the local area). “The base commander has agreed to let us use their old sports hall for the duration of the exams, just until the new build is finished. So it looks like you’re off the hook on Operation Long Shot. But that will give you a bit more time to focus on the other fast ball I’ve just sent you.”
“Good result!” said James. “Pity, though. It would have been so cool to use the carrier.”
“Nothing. Nothing. Just a wild flight of fancy…”