Coverage & Reporting in CRC

Ian Trim

Senior Policy Advisor

26 March 2009

• Qualification

• Emission Coverage

• Reporting Obligations

• Penalties

Agenda

Organisations grouped together under their highest parent

Overseas company must nominate the UK CRC agent

Responsibility for emissions of the entire organisation or group

Particular circumstances may arise where entities otherwise legally separated will be grouped together

To identify which emissions

Counterparty to the energy supply contract

Qualification

1. Organisation has at least one Half-Hourly (HH) Meter settled on the HH Market

Assessment across the entire organisation

Need to monitor HH electricity consumption over the course of 2008

Legally required to communicate with the scheme Administrator

Qualification

2. Organisation HH electricity consumption exceeds 6,000 MWh over the course of 2008

• HH electricity use must include:

• Mandatory HH meters

• Voluntary HH meters

• Remotely read AMR

• Pseudo HH metering readings

Qualification

HH electricity consumption is above 6,000 MWh per year

HH electricity consumption is less than 6,000 MWh per year

Legally required to register

• Web based tool

• disclose identification information

• submit list of HH meters settled on HH

market

• disclose total HH electricity

consumption

Legally required to submit an information disclosure

• Access the same Web based tool

• Follow guidance and complete

information disclosure

Qualification

• Excluded from Footprint report and CRC:

• Onward supply and storage

• Transport

• Electricity imported for generation purposes

Emission Coverage- Exclusions

• Included in Footprint report, but not CRC

• EU ETS

• CCA

Emissions are not included in CRC, but will be considered for the purpose of identifying the ‘Applicable Percentage’ – the 90% rule

Emissions Coverage -Exemptions

• ‘Transport’ Exemption

• Exemption for any organisation whose HH

electricity used for transport takes them below

1,000MWh

• CCA Exemptions

• Group member exemption

• Residual Group Exemption

Emission Coverage – Core Sources

• All half hourly meters

• Meters profile classes 5 – 8

• Daily-read gas meters

• Non-daily metered gas > 73,200 kWh/annum

Emission Coverage – Footprint

• Identify their total energy use across the entire

organisation

• Including consumption covered by EU ETS and/or CCA

• Excluding energy use from other excluded activities

• Excluding energy use of emissions from subsidiaries

exempt on CCA grounds

• Footprint = Total Energy Use – Transport – Onward

supply – CCA Exempt subsidiaries

Emission Coverage – CRC Emissions & 90% rule

• 90% of Footprint must be regulated by either EU ETS,

CCA or CRC (the ‘Applicable Percentage’)

• Core Sources have to be included in CRC on

mandatory basis

• Must include non-core sources (‘Residual Sources’) to

reach 90% coverage

• Can include non-core sources (‘Residual Sources’) on

a voluntary basis if above 90%

• Residual Sources need to be recorded on the

Residual Source List

Emission Coverage

• CRC Emissions = Core Sources + Residual Sources

• For that Phase need to:

• Monitor emissions

• Report emissions

• Hold and cancel allowances – the ‘Performance

Commitment’

equal to CRC Emissions

Emission Coverage

All Energy Use Emissions

Relevant Emissions

Total Footprint Emissions

Regulated Emissions

CRC Emissions

1. MUST remove all energy use from excluded sources

2. MUST remove 100% of emissions from CCA exempt subsidiaries

3. CAN remove up to 10% of footprint emissions but not Core Sources, or covered by EU ETS or CCAs. Regulated Emissions must be at least 90% of relevant emissions

4. MUST remove all emissions covered by CCAs and EU ETS.

• Self Certification – no 3rd party verification

• Evidence Packs – to record energy use and provide audit

trail

• Emissions Reporting via an online Registry

• Two types of report:

• Once per phase – Footprint Report

• Annually – Annual Report

Reporting

Footprint Report Annual Report

31 July 2011 – once per phase 31 July 2011 - every year

• Set emission coverage • Identify CRC Emissions• Demonstrate ‘90% rule’• Evidence of CCA exemption

• Report on CRC Emissions• Provide information for the PLT

NOTE:Not linked with PLT and revenue recycling

NOTE:Cancel allowances at the same time

Reporting

Reporting – Electricity Credits

Electricity Generation Electricity Credits

• Conditions:

• On-site Electricity Generation

• Export Electricity to third parties

• Not Nuclear, EU ETS or RO

• Receive Electricity Credits:

• Grid average conversion factor

• Valid for the year when generation occurred

• Report Net electricity consumption

Reporting – Data Collection

• Electricity and Gas Bills

• Receipts of purchase of fuels

• Own Meter Readings

• Annual Statement of Consumption

• Requested in February

• Issued in May

• Govt issue guidelines on approximation techniques

• Failure to Register

• Failure to disclose information

• Failure to provide footprint report

• Failure to provide annual report

• Incorrect reporting

• Failure to hold and cancel sufficient allowances - the ‘Performance

Commitment’

• Failure to keep adequate records

Penalties

Penalties

Non-compliance Penalties

Failure to register

Immediate fine of £5000, imposed for failure to register by the deadline Further fine of £500 per working day for each subsequent working day of delay until last working day of July (the next reporting

deadline) Publication of non-compliance

Failure to Disclose Information

Where an organisation with a Half Hourly Meter (HHM) that does not meet the qualifying threshold fails to make an information disclosure, a one off fine of £1,000

Failure to provide Footprint Report

Immediate fine of £5000, for failure to provide a Footprint Report by the reporting deadline Further fine of £0.05 per tonne of carbon dioxide (tCO2) per working day for each subsequent day of delay up to a maximum of

40 working days. Total accumulated daily rate fine is doubled after 40 working days Publication of non-compliance

Failure to provide Annual Report

Immediate fine of £5000, for failure to provide a Annual Report by the reporting deadline Further fine of £0.05 per tonne of carbon dioxide (tCO2) per working day for each subsequent day of delay up to a maximum of

40 working days. Total accumulated daily rate fine and total emissions are doubled after 40 working days Publication of non-compliance Administrators will block the transfer of all allowances out of the participant’s registry account until report is received Bottom ranking on the Performance League Table

Incorrect Reporting

Fine of £40 for each tCO2 of emissions incorrectly reported, to be applied wherever there is a margin of error greater than 5% Publication of non-compliance

Failure to comply with the performance commitment

Must obtain and cancel the outstanding balance of allowances as soon as possible Fine of £40/tCO2 in respect of each allowance that should have been obtained and cancelled Publication of non-compliance Administrators will block the transfer of all allowances out of the participant’s registry account until all necessary allowances are

cancelled

Failure to keep adequate records

Fine of £5 per tCO2 of total emissions reported in the most recent annual report Publication of non-compliance