The end of the CRC scheme means something for every business with an electricity supply to their premises. In fact, the end of the CRC and the introduction of Streamlined Energy and Carbon Reporting (SECR) extends to other fuels and transport as we see cost impacts and reporting requirements broaden to a wider audience. At present, many companies are required to report their energy and carbon emissions across a number of mandatory intersecting regulatory schemes, including the CRC Scheme, the Energy Savings Opportunities Scheme (ESOS), and GHG emissions reporting (Mandatory Energy Reporting – MER). The Government’s aim is to reduce the administrative cost and burden on businesses by simplifying requirements and reducing scheme overlap while combining elements of schemes to improve effectiveness.
New Beginnings
With CRC’s replacement, SECR, due to commence in April 2019, the main factors your organisation should anticipate are:
- New reporting will cover electricity, gas, and transport
- Scope 1 and 2 GHG emissions reporting associated with UK use
- Inclusion of an intensity metric (KPI), such as kWh/per unit of production or kWh/m2 floor area
- A requirement to publish a narrative that provides a high-level overview of energy efficiency measures
Unlike CRC, the SECR is focused entirely on business, and unlike GHG reporting, it extends to unquoted companies. Therefore, the focus is on business, but with a wider qualification criterion. The public sector will see a wider voluntary scheme as outlined below.
CRC Swansong
With the final reporting year for CRC now underway, if you are part of Phase 2 of this scheme, your organisation will still need to submit a:
- Final report submitted by 31st July 2019 to cover April 18 to March 2019
- Final payment for CRC compliance allowances in September 2019
- Registration for Phase 3 if you qualify for the next phase
The last point seems at odds with the proposed changes. Guidance suggests waiting until nearer the date for registration, but at present, it remains a legal requirement.
Sometimes Change Can Be Taxing
Whether or not you are part of the CRCEE:
- CCL will increase from April 2019
So, for those in the CRC scheme, many will see a slight reduction in payments, but for those organisations not part of CRC, or a scheme that exempts them from CCL payments, a significant cost increase is on the way.
Some Things Never Change
Swansong or not, like any swan, what may appear calm on the surface is driven by unseen frenetic activity.
Data capture and reporting requirements, although different, will remain. Organisations will still be required to engage in a broad range of data capture and reporting. Organisations previously not party to the CRC will also be under the spotlight.
What is clear is that, although CRC reporting and data requirements are being removed, many companies will need to implement or enhance existing processes and systems for energy data capture, reporting, analysis, and recommendations in order to comply.
A Central Data Source for All Compliance Schemes
What is critical to compliance with all remaining schemes is a robust process and systems for energy data capture.
Energy and sustainability managers require support across many schemes, and a central compliance advisory and data service to streamline compliance services will enable users to take advantage of this simplification. Key attributes are:
- Expert compliance advice to reduce compliance risk
- Streamlined reporting, data capture, and analysis services to minimise cost and simplify data management and reporting
- Meaningful analysis and recommendations to support compliance and wider sustainability objectives
- Support with communication of data, reporting, or energy efficiency recommendations to internal and external stakeholders
Public Sector
Although many public and higher education bodies have targets for carbon reduction in place, a lack of common objectives sees an uncoordinated approach to work more collectively to help the government achieve its own mandated emissions reduction targets. To bring commonality to the wider public sector (excluding central government departments) and higher education, the Clean Growth Strategy is planned to be introduced with a voluntary target and reporting. The proposed target in England is to secure a minimum 30% reduction in greenhouse gas emissions by 2020/2021, measured against a 2009/2010 baseline.
