As 2017 draws to a close we’re sure the last thing you are thinking about is The Carbon Reduction Commitment (CRC) Energy Efficiency Scheme, but there are a few steps that you could be taking to make life easier for the next submission and why it shouldn’t be completely swept under the rug until spring. The good news is you should be able to read this blog before you’ve finished that mince pie!
The main thing to do is be organised! So we’ve created a short list as a reminder to help you plan for the 2017/2018 compliance…
- Before you think about 2017/2018, ensure that your evidence pack for 2016/2017 is up to date now so you can demonstrate compliance if contacted by the Environment Agency
- Ensure you keep CRC contacts up to date in the CRC registry, as when 2017/2018 compliance comes around you need to ensure that you can access the registry so the submission runs smoothly
- Ensure that you keep on top of any changes to company structure and where needed notify of any designated changes within 3 months
- If collating your data from energy company statements, remember to send out supplier statement requests by the end of March
- Begin data calculations as and when data is received, suppliers should return statements by mid-May if requested prior to the March deadline
- Consider if you are going to take part in forecast allowance purchasing; this allows you to purchase allowances for use for the 2018/2019 submission at a discounted rate.You’ll need to order the allowances in April 2018 and to pay for these in June
- Make sure you have the important submission deadline in your diary – the last working day in July.This is also the last day you can order buy to comply allowances.
- When you order your allowances, make sure that you have ordered enough to cover your annual report submission – particularly important if you have had to resubmit or you forecast purchased and are intending to use these.
- Prep your finance team, as the Buy to Comply allowances will need to be paid for between 01/09/2018 and 19/09/2018 and will be allocated by mid-October
- Remember once you’ve paid for the allowance you still need to surrender the Buy to Comply allowances by the end of October – a simple last step that often catches people out!
All of these steps should help you ensure that you are prepared to comply but also help avoid any enforcement action. A number of CRC enforcement notices and penalties have been issued this year to businesses across a wide range of sectors including manufacturing, technology, hotels, real estate, leisure centres, testing/ analytics, universities and retail stores. The businesses were fined up to £13,500, the main reasons for which were; failure to surrender sufficient allowances and failure to submit an annual report.
On the subject of enforcement, the consultation is also currently open until 15th January 2018 on “The Environment Agency’s new Enforcement and Sanctions Policy (ESP)”.
Looking further forward, although the Carbon Reduction Commitment (CRC) Energy Efficiency Scheme will be abolished, it is still in force until the end of compliance activities in October 2019. And in 2019, we are expecting the launch of a new energy and carbon reporting scheme; this is currently open for consultation and I’d encourage you to respond as it may well affect your business in the future. You can see the consultation here.
As Phase 2 is now in full swing you have probably got everything down to a tee but if you do need any help or advice, please do not hesitate to get in touch.