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29 July 2010

CRC support from Comply Direct

Comply Direct recognises that every company is different and a one size fits all solution is rarely good for a customer. This is particularly true where energy and carbon management is concerned. The impending introduction of the Carbon Reduction Commitment (CRC) will make the landscape even more complex.

Comply Direct will be sending out an e-bulletin every quarter to provide up to date information focused around the CRC Energy Efficiency Scheme to those who will be affected by this complex piece of legislation.

Top tips for registration

The Environment Agency (EA) is strongly urging all those obligated companies that have not yet started the registration process to begin it as soon as possible. Recent statistics revealed that only 10% of the expected number of full participants has fully completed the registration. The EA will be available to work through any issues and problems you have with the registration and there is the opportunity to make amendments further down the line. The important point is to get the ball rolling and get started. 

You should ensure that all Meter Point Administration Numbers (MPANs) have been located and all data verified and signed off at a senior level. The validation of the registration can take up to six weeks and this must be completed before the 30th September in order to register on time. Comply Direct can help with registration as we are handling the registration process for a number of obligated companies.

Early Action Metric: AMRs

The Early Action Metric (EAM) is made up by two evenly weighted factors: these include achievement of an accreditation and installation of Automatic Metering Readers (AMRs).

The EAM for AMRs is calculated by the percentage of the organisation's emissions from electricity and gas (excluding those covered by mandatory HHMs) that are covered by voluntarily installed AMRs at the end of March 2011. The AMR will only be counted from the period of time that it has been installed. For example, an AMR installed as of 1st August 2010 would only score 67%, every month that goes by is a month lost (from the point of instalment). The calculation for the coverage of emissions by AMRs is:

1. Calculate total emissions from gas and electricity
2. Deduct total emission from half-hourly meters (HHMs)
3. Calculate % covered by voluntary AMR

Early Action Metric: accreditations

There are now three accreditations available that can be applied to the Early Action Metric and these are; The Carbon Trust Standard, CEMARS and the Kite Mark Scheme from BSI. In order to gain accreditation the requirements include:

1. Evidence of absolute/relative emissions reductions of at least 2.5%, year on year for at least two consecutive years
2. Evidence of measured reductions in terms of emissions
3. Have a high quality energy or carbon management approach
4. A high standard of data and evidence is required as part of the assessment process

The deadline to achieve an accreditation that is applicable to the first year of CRC is 31st March 2011. The timescale to achieve accreditation is roughly 6-12 weeks depending on how accessible and organised your data is. Gaining an accreditation should ensure you a top half position in the performance league table, especially as latest figures show that only 10% of estimated participants have one fully in place at this point in time.

New government

Many are concerned at the lack of interest the new coalition government has expressed in The CRC Energy Efficiency Scheme. However, the lack of comment would appear to be down to the government simply not having had time to review CRC and therefore at this stage they are refusing to comment. It does seem clear that the new coalition government is committed to being green and addressing climate change, so CRC is something that is not going to disappear overnight. 

It must be taken into account that a vast number of organisations obligated under CRC have invested a lot of money into the preparation and planning to fulfil their obligation. Comply Direct believes that given we are so far down the track it would be extremely difficult for the government to drop the fundamentals of CRC at this late stage. Once the new government has had time to review the legislation it is likely that changes could be applied, but that they will be implemented as phase two and based around simplified measures.

Wish list of changes to CRC

If only we could:

1. Use emissions reductions for generation of renewable energy (seems wrong for investments to generate own renewable energy not recognised)

2. Have more recognition of growth metric (companies not penalised so heavily for being successful and growing). Removal of tenants obligation for landlords (as there is little control on usage)

3. Gain more reward for those companies that have achieved emissions reductions in recent years (the league table will favour those with the biggest wastes still to address).

4. Remove any incentive to switch operations outside the UK to cut emissions.

The Comply Direct offer

We are flexible in our approach and capable of supporting obligated companies with CRC. Whether you need help with registration, annual reports, evidence packs, EA audit support, carbon allowance strategy, emission reduction plans, data validation, early action metrics, league table positioning strategy etc, we can help. Just contact us for more details.

www.complydirect.com