How to register your CCAs if you acquire an undertaking with a CCA after the qualification year but before you register for the CRC.
At the moment the proposed sale window is from 1 June 2012 to 31 July 2012 - this is dependant on the allocation regulations which have not yet been finalised?
The price of the allowances is currently set at £12 per tonne of CO2 for 2011/12 reporting year. This may change in future reporting years.
No, there is no requirement for you to order or surrender allowances during the introductory phase of the scheme. However, if you lose your CCA exemption please contact the CRC team for further guidance on how you need to proceed for the remaining years of the introductory phase.
Once the sale of allowances window has been opened in the registry, Account Representatives who have enrolled can log in to their account to order allowances. Once payment for allowances has been received in full we will allocate them to you and send you a confirmation e-mail. The Account Representative then needs to surrender the allowances. The allowances surrendered must equal the CRC emissions from the Annual Report for the relevant compliance year (i.e. in the 2012 sale you will be purchasing and surrendering allowances to cover your CRC emissions from your 2011/12 Annual Report).
You can place as many orders as you need to during the sale window. Please place these orders as early as possible so that you have as long as possible to pay for these allowances. Payment must have cleared by the last working day in July (31 July 2012). As an example, if your CRC emissions are 100,000tCO2 you could place one order for 100,000 allowances, 10 orders for 10,000 allowances, 4 orders for 25,000 allowances etc. However, you will only be allocated the allowances which are paid for by the last working day in July.
‘Known Facts Letters’ are the letters we post to the:
- Primary Contact, Secondary Contact and Account Representatives with a reference number on; and
- Senior Officer with a PIN number on. The Senior Officer must pass this PIN letter to the Primary Contact, Secondary Contact or Account Representative. to show that the nominated contact has been given the authority by the Senior Officer to act on behalf of the organisation.
Once the contact has both of these letters they can use them together with their government gateway username and password (if they are a primary/secondary contact) or digital certificate (if they are an account representative) to enrol (i.e. link their CRC account to their username and password or digital certificate).
Please click here for a screenshot guide of how to enrol as:
A ‘Compliance Account’ is the name given to your CRC account once your registration is completed, we have carried out anti money laundering checks on your organisation and your account representatives have enrolled in preparation for purchasing and surrendering allowances. Your Compliance Account is where allowances can be bought, traded and surrendered by the Account Representatives.
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.
Following the March 2009 Consultation, Government has now decided that the 2010/2011 year will be a reporting year only for Participants. You will not be required to purchase and surrender allowances to cover this report when you submit it.
Similarly, the first annual reporting year of subsequent phases will also be reporting-only years. However, the first annual reporting year each of these phases will be the same as the last year of the previous phase. So organisations already in the scheme may have compliance activities, including allowance trading, for the last year of the previous phase.
A participant organisation in the private sector can nominate any of its Significant Group Undertakings (SGUs) to participate in the CRC independently of the group. This is known as ‘disaggregation’. Any SGU that registers independently will be treated as a separate participant for the remainder of the phase. There are a number of conditions, which must be met for an SGU to participate independently.
These are set out in the CRC Guidance document, which also explains how to disaggregate. You can find a copy of this document on our guidance web page:
At disaggregation the CRC Registry will produce a new registration for the disaggregating SGU, which is part-populated with information already submitted by the parent for that SGU.
The information that the parent organisation has entered into the CRC Registry relating to existing CCAs for an SGU, will be carried across to the new SGU registration. That is, the information relating to individual agreements that have been listed under that SGU in the parent registration. The SGU registrant will, however, have to claim any CCA exemptions which apply to the new registration. Disaggregated SGUs will act as independent participants and must retain records of their CCAs in their own evidence pack.
Following disaggregation, and during the registration window, it will not be possible for a parent to return to its completed registration and to upgrade to a full exemption if it was not previously eligible. In other words, it cannot disaggregate those of its SGUs that do not have CCA member exemptions, leaving those parts that do, and to then claim for the remaining organisation a CCA group exemption or a general exemption on the basis that the remaining parent has less than 1,000MWh or has greater than 25 per cent CCA coverage).
Both the parent organisation and the disaggregated SGU(s) will be able to claim further exemptions when they submit their footprint report if they meet the appropriate criteria. Please refer to the guidance EU Emissions Trading System and Climate Change Agreements for an explanation. In summary, this allows a participant to claim further exemptions but only if it did not have sufficient CCA target data covering the CCA target period ending during the qualification period. Evidence for this must be retained in the evidence pack.
Please refer to Annex 2 of the guidance note Registering as a CRC participant for an explanation of how to account for undertakings that you have acquired or sold between the qualification year (2008) and the point at which you register.
In order to determine whether you qualify for a CCA exemption at registration for a newly acquired undertaking, you will need to obtain, from the seller of the undertaking, the CCA emissions data required to be reported under CCA for the target period ending in the qualification period (1 January 2008 to 31 December 2008 for phase 1).
If you decide that you do qualify for an exemption for the newly acquired undertaking, if the undertaking is an SGU or it has an SGU as its parent, you will need to report any CCA exemption under that SGU in the CRC Registry. Otherwise, you will need to record any exemption under the parent undertaking.
Please refer to the guidance EU Emissions Trading System and Climate Change Agreements for an explanation of (i) how to apply CCA target periods to CRC and (ii) what emissions information you will be required to submit in respect of your undertakings with CCAs.
You can claim a member exemption for 100 per cent of emissions from an undertaking that forms part of a group if more than 25 per cent of emissions from that undertaking were covered by a CCA during the target period ending in the qualification year. If the coverage is less than 25 per cent, you may still be able to claim a group exemption where another member/other member(s) of the group have a member exemption and the qualifying electricity supplied to the group in total, minus the qualifying electricity supplied to the group member(s) with a member exemption, is less than 1,000 MWh.
If you do not have an exemption, you cannot exempt all of the emissions from the newly acquired undertaking, but you can exclude the emissions directly covered by the CCA from your CRC emissions.
You will not need to report your exempt emissions in either your footprint or annual report, although you will need to retain details of these in your Evidence Pack. You will need to account for your excluded emissions in your footprint report, but you will not need to account for them in your annual report or to surrender allowances in respect of such emissions. As with exempt emissions, you will need to retain details of excluded emissions in your Evidence Pack. Please refer to the guidance EU Emissions Trading System and Climate Change Agreements and footprint report.
As the acquiring organisation, if you cannot obtain the CCA emissions data that you need for the qualification year, if applicable, you can claim a CCA exemption when you submit your footprint report. If you intend to do this, you should indicate so at registration. You can then compile the necessary information during the footprint year and claim your exemption when you submit your footprint report.
