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ACCA's response to this document, issued by the Department of the Environment, Transport and the Regions (DETR), the National Assembly for Wales and the Scottish Executive.

Copies of the document are available on the DETR’s website: www.environment.detr.gov.uk/conindex.htm

• The six steps:
  ACCA believes that an approximate timescale should be included for each step to give reporters (particularly first time reporters), an indication of how long each step is likely to take. Although ACCA understands that individual companies will take different times to complete each step, we believe some guidance is necessary to help them manage the process more effectively.
  
  
• Best practice examples:
  Examples of existing reported information should be included throughout the guidelines. This would benefit first time reporters who would be provided with a source of practical examples for target-setting and environmental performance indicators for water use
  
  
• Typing error: 
  A reference is made to step 7 on p18. This should be step 6?
  
  
• Payback:
  ACCA believe that 'payback period' is the wrong method to use for evaluating investments. We recommend that an 'internal rate of return' method would be of greater benefit for the company to follow and more appropriate to use in these guidelines.
  
  
• Useful information:
  This section of the guidelines should be developed to include more detailed information on environmental reporting guidance. In addition to including the guidance already produced by DETR, the ACCA environmental reporting awards website (www.accaglobal.com/soc_env.html) should also be included for its detailed information on this topic.

Finally, the Global Reporting Initiative (GRI) has recently launched the June 2000 Guidelines, which provide a detailed framework for organisations to follow to help them report on the three elements of sustainability. I understand the DETR believe this is a good initiative and indeed some British companies are following the Guidelines already.

As well as reporting on the use of water by organisations internally, the GRI also includes reporting on organisational discharges to water sources external to the company. Maybe the DETR guidelines could consider widening the scope of their guidelines to be more compatible with the GRI? I have included a copy of the GRI Guidelines for your perusal. The GRI should also be included in the 'useful information' section (www.globalreporting.org).

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