Participants have to purchase allowances for all of their CRC Energy Efficiency Scheme emissions, not just those from half-hourly metered supplies, and not only electricity consumption. CRC Energy Efficiency Scheme emissions must include all of the energy from ‘core sources’ unless they are covered by the European Union Emissions Trading System (EU ETS) or Climate Change Agreements (CCAs). ‘Core sources’ are all emissions from the following sources:
- all electricity consumed through half hourly meters (HHM) (including pseudo HHM)
- all electricity consumed through Automatic Meter Reading (AMR) meters
- all electricity consumed through profile class 5 –8 meters (these are non-domestic meters capable of measuring the maximum demand of a non-domestic site)
- all daily read gas meters
- all gas consumed through AMR meters
- all non-daily meters with gas consumption of more than 73,200kWh per annum.
Participants will be required to ensure that at least 90 per cent of their total footprint emissions are regulated by either the CRC, EU ETS or CCA. If, having included all the core sources, the percentage of emission coverage has not yet reached the point where 90 per cent of total footprint emissions are regulated, then it must include some additional sources (from the Residual Measurement List) until the participant’s combined EU ETS, CCAs and CRC coverage level is above the 90 per cent threshold.
Organisations that buy energy through a third party provider or as part of a facilities management agreement, will retain responsibility for emissions of the energy they have received. However, where a landlord organisation receives an electricity supply and provides some or all of that supply to its tenant, the landlord remains responsible for the supply received.
Emissions covered by EU ETS are excluded from the scope of the CRC. This ensures that no participant will face double regulation of the same emissions. Although EU ETS emissions are not included in the CRC, and participants will not have to buy allowances to cover those emissions, they will need to be considered for the purpose of identifying the applicable percentage of the CRC emissions coverage (90 per cent rule) during the footprint year.
The participant must inform the administrator if at any time commitments to EU ETS change or cease.
Energy used for transport is excluded from the CRC. Half hourly electricity used during the qualification period to power transport equipment will need to be removed from the total when assessing qualification. The organisation does not qualify for the CRC, if the remaining half hourly electricity consumption falls below the threshold of 6,000 MWh.
The definition of transport under the CRC is divided into four basic areas, these comprise of:
- Road going vehicles
- Shipping
- Aviation
- Rail
Anything that does not fall within the scope of the above four categories will be included in the CRC and therefore needs to be considered when assessing qualification and calculating emissions as appropriate during participation. A detailed definition of each of these categories can be found in Chapter 5 of the Government Response to Consultation October 2009.
There is specific guidance on CCA exemptions, on our CRC guidance page:
Your organisation will be eligible to claim a full or partial exemption from the CRC Energy Efficiency Scheme if enough of its total emissions are covered under a CCA. Even if you do not qualify for one of these exemptions, you do not need to include your CCA sources within CRC.
There are three forms of exemption associated with CCAs:
i) Single entity exemption
A single entity organisation with no subsidiaries will have full exemption from the CRC scheme if more than 25 per cent of its energy use emissions are covered by a CCA. This exemption applies to all energy use emissions.
ii) Group member exemption
If any member of an organisational group has more than 25 per cent of its emissions covered by a CCA, then that member has full exemption from the CRC Energy Efficiency Scheme. This exemption applies to all of this member’s energy use emissions.
iii) Residual group exemption
If, after the removal of your group members’ energy use emissions, the remaining parts of your organisation have less than 1,000MWh of half hourly electricity remaining in the CRC, then the entire organisation will be exempt.
The above exemptions should be claimed when you register for the CRC Energy Efficiency Scheme, if data is available. An exemption can also be claimed as part of the footprint report assessment if data is not available for registration. The data supporting your exemption must be for the CCA target period ending in either the qualification year or the footprint year, as appropriate.
You will need the following evidence to claim CCA exemptions via the online registry:
i) Single entity participants need to disclose:
- the total energy use emissions;
- the total emissions covered by a CCA;
ii) Organisational groups need to disclose:
- the total emissions for each exempt group member;
- the total emissions covered by a CCA.
iii) To claim residual group exemption, organisations need to disclose:
- the total amount of half hourly electricity supplied to the group as a whole
- the remaining half hourly electricity after subtracting that of all exempt group members.
To claim full general or group exemption, you will need to collect and retain evidence to support the emissions data you provide. Evidence to support group member exemptions must be kept in the evidence pack and will be reviewed as part of a compliance audit.
If a part or the whole of your group has a CCA but is included in the CRC because it does not qualify for an exemption, you will be required to identify your CCA coverage as part of your footprint report each phase. However, you will not be required to include your CCA sources within your CRC emissions. This means you wont need to report on these annually or purchase allowances to cover the CCA emissions.
Organisations that have the data should claim any CCA exemption when they register for the CCA target period ending in the calendar year 2008. Organisations that do not have the data to claim exemptions at this point, should do so during their footprint report for the target period ending in the footprint year (ending between 1 April 2010 and 31 March 2011).
Organisations intending to claim exemptions in their footprint report should indicate this at registration. Failure to provide such indication at registration does not prevent an exemption from being claimed when submitting the footprint report.
When determining eligibility for a CCA exemption, participants must use total emissions data from the same period as the CCA target period.
Example: Organisation A has a CCA. The CCA target period is 1 October 2009 to 30 September 2010. Organisation A wants to claim a CCA exemption as part of the footprint report. Organsiation A will be recording its total footprint emissions as part of the footprint year (1 April 2010 to 31 March 2011).
The CCA target period ends in the footprint year. Organisation A should use total emissions data covering the CCA target period (1 October 2009 to September 2010) to calculate its CCA percentage coverage
