CRC (Carbon Reduction Commitment) Energy Efficiency Scheme - reminder of registration deadline

A reminder that the registration deadline for CRC is 30 September and that any organisation with at least one half hourly settled electricity meter during 2008 must register. This is even if the organisation is below the threshold for inclusion or has a Climate Change Agreement.

Many printing companies will have a least one half hourly electricity meter as these must be installed where the peak electricity demand reaches more than 100 kWh - such meters normally have numbers (MPAN) starting with 00, recorded both on the meter and the invoice.  Additionally the Environment Agency (EA) wrote to all the account addresses of the 20,000 or so such meters in the UK twice during 2009 with information on CRC and the purchase recorded through each meter for calendar year 2008 required for CRC registration.  Further information can also be acquired from your electricity supplier.

Press coverage last week highlighted the low number of registrations received to date and the automatic fines to be levied for non registration of £5,000 plus potentially £500 per day of non compliance.

Members should also be aware that the registration process has an automatic delay built in while the EA verify lodged details. Feedback suggest this step is taking around two weeks during which time the registration process cannot be completed - accordingly the registration process cannot be left until the last moment. Inquires to the helpline are also taking around two weeks to secure a response, though as the EA are legally the scheme administrators, a number of members have also chosen to seek independent legal advice on how certain aspects of the scheme affect them when there are uncertainties. 

Key to registration is a proper understanding of the organisational structure as CRC responsibility rests with the highest legal entity in the UK; all companies in the same ownership are aggregated together for CRC purposes, even though there may be no operational contacts between different organisations in the same ownership. 

Printing companies with a Climate Change Agreement can claim an exemption from the CRC but they must still register. The type of CCA exemption being claimed varies dependent on the individual organisational structure;

General CCA exemption - claimed by an organisation comprising a single legal entity where more than 25% of the organisations emissions are covered by a CCA.

Group CCA exemption - claimed when after removing CCA exempted emissions, then the remaining qualifying half hourly purchased electricity in 2008 elsewhere in the group is less than 1,000 MWh.

Member CCA exemption - claimed where an individual member (or members) of a CRC group can claim a CCA exemption, but the remainder of the group is still fully obligated in CRC (ie the Group CCA exemption cannot be claimed as the remaining half hourly electricity in 2008 was greater than 1,000 MWh).

For additional information please contact Steve Walker at the BPIF on 01676 526 050, though definitive answers to questions can only be provided by the scheme administrator (the EA), or the scheme legislator (DECC). Their websites contain large amounts of guidance.  

www.environment-agency.gov.uk/static/documents/Business/Carbon_Reduction_Commitment_guidance_map.pdf

This page also contains a link to a helpful glossary of terms.

Please don't forget you are required to maintain an evidence pack to justify CRC actions and reports.

For members unable to claim a complete exemption from CRC, then the first reporting period covers April 2010 to March 2011, with the report required by the end of July. This is also the period during which obligated organisations will be expected to estimate their requirement for CRC allowances for the forthcoming year and purchase them from Government at a fixed price of £12 per allowance. Alternately organisations can take the more risky approach of relying on the secondary market to fulfil their requirements for the 2011-12 reporting period.