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Coverage & Reporting in CRC Ian Trim Senior Policy Advisor 26 March 2009 Agenda • Qualification • Emission Coverage • Reporting Obligations • Penalties Qualification 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 Legally required to submit an information disclosure • Web based tool • disclose identification information • Access the same Web based tool • submit list of HH meters settled on HH • Follow guidance and complete market information disclosure • disclose total HH electricity consumption Emission Coverage - Exclusions • Excluded from Footprint report and CRC: • Onward supply and storage • Transport • Electricity imported for generation purposes • 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 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 CRC Emissions 4. MUST remove all emissions covered by CCAs and EU ETS. Reporting • 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 • • • • • Report on CRC Emissions • Provide information for the PLT Set emission coverage Identify CRC Emissions Demonstrate ‘90% rule’ Evidence of CCA exemption NOTE: Not linked with PLT and revenue recycling NOTE: Cancel allowances at the same time 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 Penalties • 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 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 Incorrect Reporting 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 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 Failure to records keep adequate 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 Fine of £5 per tCO2 of total emissions reported in the most recent annual report Publication of non-compliance