7.4 Lessor Accounting for Emissions From Leased Assets
Like lessees, lessors have to consider their consolidation approach
and type of lease to properly account for GHG emissions from leased assets.
Correctly identifying these factors will prevent and avoid double counting. For more
information about consolidation approaches, see Chapter 2. For more information about lease
classifications (which companies are advised to determine in a manner consistent
with their audited financial statements), see Section 7.1 and Deloitte’s Roadmap Leases.
The table below, which is adapted from Table A.2 of the Scope 3 Standard, presents
various considerations for lessors related to the classification of GHG emissions
from leased assets into Scopes 1, 2, and 3.
Consolidation Approach Used
|
Type of Leasing Arrangement
| |
---|---|---|
Finance/Capital Lease
|
Operating Lease
| |
Equity share or financial control
|
Case A: Lessor does not have ownership or financial
control. Therefore, GHG emissions associated with fuel
combustion and the use of purchase electricity are accounted
for in Scope 3, Category 13 (downstream leased assets).
|
Case C: Lessor has ownership and financial control.
Therefore, GHG emissions associated with fuel combustion are
accounted for in Scope 1, and those associated with the use
of purchased electricity are accounted for in Scope 2.
|
Operational control
|
Case B: Lessor does not have operational control.
Therefore, GHG emissions associated with fuel combustion and
the use of purchased electricity are accounted for in Scope
3, Category 13 (downstream leased assets).
|
Case D: Lessor does not have operational control.
Therefore, GHG emissions associated with fuel combustion and
the use of purchased electricity are accounted for in Scope
3, Category 13 (downstream leased assets).5
|
As illustrated in the table above, if a reporting company is the lessor in an
operating lease as defined in the Scope 3 Standard and uses the equity share or
financial control approach (Case C), it would account for (1) the direct GHG
emissions from the leased asset in Scope 1 and (2) the indirect GHG emissions from
the leased asset that are associated with the use of purchased electricity in Scope
2. This is because the lessor has accounting ownership and financial control of the
asset.
As further illustrated in the table above, if a reporting company is
the lessor in a finance/capital lease and uses the equity share (Case A) or
financial control approach (Case B), or is the lessor in an operating lease and uses
the operational control approach (Case D), the reporting company is not considered
to have accounting ownership, financial control, or operational control of the
asset. Accordingly, the reporting company would record both the GHG emissions that
are an output from the leased asset and the GHG emissions from the leased asset that
are associated with the use of purchased electricity in Scope 3, Category 13. This
is because in Cases A, B, and D of Table 7-2 (which correspond to Cases A, B, and D of Table 7-3), the
lessee has accounting ownership or control of the leased asset and would therefore
report the same GHG emissions in Scopes 1 and 2, respectively, rather than Scope
3.
Connecting the Dots
The lessee accounting illustrated in Table 7-2 is the
inverse of the lessor accounting illustrated in Table 7-3. For example, the lessee’s
lack of accounting ownership and financial control in Table 7-2, Case C,
means that the lessor in the same arrangement does have accounting ownership
and financial control (see Table 7-3, Case C). Therefore, whereas the lessee
in the arrangement would account for the GHG emissions related to the leased
asset in Scope 3, Category 8 (upstream leased assets), the lessor in the
arrangement would account for those emissions in Scopes 1 and 2. Similarly,
in each of Cases A, B, and D of Table 7-2, whereas the lessee would
generally account for the GHG emissions related to the leased asset in
Scopes 1 and 2, the lessor would generally account for those emissions in
Scope 3, Category 13 (downstream leased assets).
A lessor’s chosen organizational boundary may affect whether the lessor reports
direct GHG emissions from the leased asset and indirect GHG emissions from the
leased asset that are associated with the use of purchased electricity in (1) Scopes
1 and 2, respectively, or (2) Scope 3. For example, the lessor in an operating lease
that applies the operational control approach (Table 7-3, Case D) generally does not
operate the leased asset it owns and therefore typically does not implement its
operating policies with respect to the asset (i.e., the lessee has full operational
control). Since the lessor does not control the asset from an operational
standpoint, direct GHG emissions from the leased asset and indirect GHG emissions
from the leased asset that are associated with the use of purchased electricity
would be excluded from the lessor’s Scope 1 and Scope 2 inventories and included in
its Scope 3 inventory.
Although a lessor in Table 7-3, Case D, would generally report GHG emissions from the
leased asset in Scope 3, Category 13, such a lessor may report those emissions in
Scopes 1 and 2 if it can demonstrate that it has operational control over the leased
asset, in which case the lessor must disclose the background and reasoning that
support its conclusion. This treatment is consistent with lessee accounting for
leased assets. As noted in Section 7.3, if a
lessee in an operating lease that applies the operational control approach concludes
that it does not have operational control over the leased asset and therefore
reports emissions related to the leased asset in Scope 3 instead of Scopes 1 and 2,
the lessee must disclose the background and reasoning that support its conclusion.
For further illustration, consider Example 9, Case C, in ASC 842-10-55-117 through
55-123:
ASC 842-10
Example 9 — Contract for Energy/Power . . .
Case C — Contract Contains a Lease
55-117
Customer enters into a contract with Supplier to purchase
all of the power produced by an explicitly specified power
plant for 10 years. The contract states that Customer has
rights to all of the power produced by the plant (that is,
Supplier cannot use the plant to fulfill other
contracts).
55-118
Customer issues instructions to Supplier about the quantity
and timing of the delivery of power. If the plant is not
producing power for Customer, it does not operate.
55-119
Supplier operates and maintains the plant on a daily basis
in accordance with industry-approved operating
practices.
55-120
The contract contains a lease. Customer has the right to use
the power plant for 10 years.
55-121
There is an identified asset. The power plant is explicitly
specified in the contract, and Supplier does not have the
right to substitute the specified plant.
55-122
Customer has the right to control the use of the power plant
throughout the 10-year period of use because:
-
Customer has the right to obtain substantially all of the economic benefits from use of the power plant over the 10-year period of use. Customer has exclusive use of the power plant; it has rights to all of the power produced by the power plant throughout the 10-year period of use.
-
Customer has the right to direct the use of the power plant. Customer makes the relevant decisions about how and for what purpose the power plant is used because it has the right to determine whether, when, and how much power the plant will produce (that is, the timing and quantity, if any, of power produced) throughout the period of use. Because Supplier is prevented from using the power plant for another purpose, Customer’s decision making about the timing and quantity of power produced, in effect, determines when and whether the plant produces output.
55-123
Although the operation and maintenance of the power plant
are essential to its efficient use, Supplier’s decisions in
this regard do not give it the right to direct how and for
what purpose the power plant is used. Consequently, Supplier
does not control the use of the power plant during the
period of use. Instead, Supplier’s decisions are dependent
on Customer’s decisions about how and for what purpose the
power plant is used.
In the example above, Supplier can only use the power plant to deliver the specified
output on Customer’s terms. Customer determines whether and, if so,
when the power plant is used, as well as what amount of output the
power plant will produce. Because Customer obtains substantially all of the economic
benefits from the power plant (an identified asset) and has the right to direct its
use, the contract contains a lease. Under the assumption that Supplier applies the
operational control approach and has determined the lease to be an operating lease,
Supplier, as the lessor, would report the GHG emissions related to the power plant
in Scopes 1 and 2 instead of Scope 3 since the facts of the example indicate that
Supplier has operational control.
Footnotes
4
See footnote 2.
5
Sometimes, a reporting company that leases an asset
to another entity in an operating lease may be able
to demonstrate that the reporting company (lessor)
does have operational control over the leased asset,
especially when operational control is not perceived
by the lessee. In such a case, the reporting company
may report GHG emissions from fuel combustion in
Scope 1 and those associated with the use of
purchased electricity in Scope 2 as long as the
decision is disclosed and justified in the public
report.