PLC Environment reports:
According to the Local Government Chronicle, only a third of the councils that are required to register for the CRC Energy Efficiency Scheme have done so already despite the deadline being 30 September this year.
For the uninitiated, the CRC is a new mandatory carbon trading scheme for the public and private sectors in the UK. The scheme came into operation on 1 April 2010 and organisations that fail to register by 30 September could face a fine of £5,000, plus an additional fine of £500 per working day of delay, up to a maximum of 80 working days. The maximum fine is £45,000. The scheme has generated an enormous amount of criticism and the new government has said it will review it, but in the meantime it’s full steam ahead.
So who has to register? An organisation must participate in the first phase of the CRC if it:
- Was supplied with electricity by at least one settled half hourly meter (settled HHM) during the 2008 calendar year; and
- Was supplied with over 6,000 MWh of half hourly electricity through all of its half hourly meters (HHMs) during that year.
The government has estimated that if your electricity bill is around £500,000 or more per year, it’s likely you will need to register. Smaller organisations with lower electricity consumption, which do not meet the second criterion, may still need to make something called an information disclosure. Failure to do so is also subject to a fine.
Some public sector organisations have to participate in the CRC regardless of whether they meet the qualification criteria (such as central government departments). Other public sector organisations (such as local authorities) will have to participate in the CRC only if they meet the qualification criteria. Public bodies such as fire and police authorities, healthcare organisations, executive agencies and NDPBs may also need to participate in the scheme.
So what do you need to do in order to decide if you need to register? Three basic steps:
- Step 1: Establish what your organisational structure is. This might not be as simple as you think and you may need to get your lawyers involved.
- Step 2: Decide what electricity supplies your organisation is responsible for. Note that landlords will be liable for their tenants’ emissions if they are the ones responsible for supplying energy directly to their tenants – even if they have no control over how energy efficient their tenants are and despite the fact that they may not be able to recoup CRC costs from their tenants under the terms of their leases (depending on how these have been drafted). Note also that local authorities may also be responsible for emissions from schools and PFIs.
- Step 3: Decide whether your organisation meets the qualification criteria.
This is quite a handful and time is rapidly running out as the 30 September deadline looms. And once you have registered, the real fun and games begin, with footprint and annual reports having to be submitted, allowances having to be bought and naming and shaming in a publicised league table.
Which is why PLC has produced the CRC Survival Kit to help the public and private sector understand how the CRC works and how to comply with it. The Kit includes materials aimed specifically at the public sector.