Sarah’s Clause linked in international Scope 3 Guidance for Telecommunications Operators

We published [Sarah’s Clause] Allocating Scope 1, 2 and 3 Emissions for Leased Assets in May 2023. Sarah’s Clause allocates responsibility for measuring and reporting the scope 1, 2 and 3 emissions of leased assets between the Lessor and Lessee. 

Sarah’s Clause is now recommended as a resource to help companies clarify their emissions management obligations in the Scope 3 Guidance for Telecommunications Operators published by the global telecommunications networks GSMA, GeSI and ITU-T (page 53). 

Why is Sarah’s Clause needed?

Responsibility for recording and reporting GHG emissions for leased assets is unclear in most asset lease agreements. This ambiguity can lead to duplication or non-recording of emissions, and confusion over who is responsible for ultimately reducing the climate impact of particular assets. 

Sarah’s Clause addresses this issue, and meets a need for contractual wording identified in the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard Revised Edition 2015:

‘To clarify ownership (rights) and responsibility (obligations) issues, companies involved in joint operations may draw up contracts that specify how the ownership of emissions or the responsibility for managing emissions and associated risk is distributed between the parties.’ (page 20). 

All sectors can benefit from Sarah’s Clause

The Scope 3 Guidance explains the practical application of Sarah’s Clause for the telecommunications industry, but other sectors may also benefit from the explanation. Sarah’s Clause has been written generically, for applicability to any industry and type of leased assets.