Aardvark News
Carbon Facts - Issue 3
Carbon Reduction – Commercial Returns
Welcome to Issue 3 of Carbon Facts - Aardvark's regular series of key updates on the Carbon Reduction Commitment.
Summary
The Carbon Reduction Commitment roll out has begun; organisations with half-hourly meters have now received forms from the Environment Agency.
As a quick reminder of the qualifying criteria - The scheme will come into force on 1st April 2010. The threshold for the scheme is using more than 6000MWh of electricity in 2008 through at least one half hourly electricity meter; you may be exempt if you are in a CCA or EUETS scheme.
Our team can quickly work with you to assess CRC liabilities and reduction potential, help with Registration and preparation of the Evidence Pack and our in-house Carbon Trust Standard Company Verifier can determine the potential of any Early Action Metrics you may have undertaken.
Did you know?
1. CRC Survey Results
In our July survey of commercial and public sector CRC-obligated organisations, the following were ranked as causing major concern at this early stage of CRC:
· Qualification issues for CRC, where to get the data, how accurate is it and then forecasting the liability;
· Undertaking analysis of existing leases and the impact this may have on acquisitions and disposals linked to the strategy of dealing with tenants – passing costs on and then reimbursing or just taking the hit;
· Setting up and agreeing a CRC internal action plan.
We know that many have similar concerns, but addressing these three concerns are good places to start with a CRC programme.
2. Early Action Metrics
The registration pack will soon be arriving; our source in the EA says mid-October, so preparing the Evidence Pack needs careful consideration.
At this point, the Early Action measures to reduce the Year 1 liability should not be overlooked. According to our Carbon Trust Standard Company Verifier there are many organisations that can demonstrate that they have and are implementing a planned programme of reduction and “early action” measures that would qualify. Undertaking a pre-assessment may yield surprising results.
3. Landlord : Tenant Update
The Government rejected, in the Spring consultation, the possibility of CRC-obligated landlords and tenants transferring responsibility for CRC between themselves once per phase as being too complicated for the Government to administer.
Also in discussion is the prevention of landlords assigning CRC obligations to non-CRC-obligated tenants, as changes in legal title would occur in too great a volume and frequency for the administrator to regulate and amend footprints and rolling baseline performance data for calculating entitlements to recycling payments.
The Government is currently prepared to recalibrate performance data in the event of "significant organisational changes" i.e. the sale of shares of a qualifying CRC organisation or Principal Subsidiary. Yet, there is no plan to treat the disposal of a large underlying asset, rather than shares, as "a significant change", so sellers would gain, when selling to a CRC-obligated organisation.
And Finally:
A report published by MPs on the Environmental Audit Committee 5 August 2009 warns that the Government is not on track to meet targets for cutting its own emissions and could have to pay money to large private sector firms - who may have done more to reduce their emissions - within the CRC. The Committee's latest report on Greening Government also shows that the proportion of renewable energy used by Government departments has dropped in the last year.
The Aardvark team have extensive experience of carbon management for CCA, EUETS and through working with energy intensive organisations and property clients over the last 10 years. We are currently tracking 56,000 tonnes of CO2e emissions from 38,256 sources associated with 1,402 property based assets - bringing down liabilities and making commercial reductions at www.tc2.org.uk
We recently explained to a parent company which owns 38 UK companies how their internal corporate greenhouse gas accounting could achieve the CRC Early Action Metric, so reducing their liability and enhancing their reputation; we previously had the task of confirming that their liability would be over £700k p.a..
The Aardvark team are holding CRC clinics in London, Liverpool, Cambridge and Bristol in October in October and November; if you would like us to visit your office, please contact us.
Aardvark has developed a CRC Liability League Table Repayment Calculator - please contact the Aardvark team for further information (contact details below).
Please contact either Mark Clayton or Phil Cookson on 01984 624989 or email markclayton@aardvarkem.co.uk or philcookson@aardvarkem.co.uk
In the meantime, watch out for Issue 4 of CRC Facts
Wednesday, 19 August 2009