Global Warming

The CRC Energy Efficiency Scheme – A Review

We are now well on the road to the end of the first year of the CRC Energy Efficiency Scheme.

We’ve had the scare stories, the organisations failing to register, or fewer organisations registering than were first thought. First estimates from the Government suggested 5000 plus organisations would be full participants with a further 20,000 as information disclosures.

We’ve had over 3,700 full participants register, what does this communicate to us?

For me, based on my research, it tells me that a lot of organisations were confused as to what they needed to do. For example, a car dealership, an example DEFRA used in their literature, if that dealership was a single franchise, SEAT for example, then if a single SEAT dealer anywhere else in the UK had a half hour meter then ALL SEAT dealerships and SEAT companies were in, under the banner of SEAT, who had the responsibility of collating this information. That’s nice and simple, until you then look at if that same dealership had say SEAT and VW at the same premises, they’re out? Add to that the ability to register independently so the SEAT brand did not have to account for everything that traded under its name . . . confused . . . therein lies the problem!

At least the Con/Dem co-alition government has pushed back the full implementation of phase 1 of the CRC by 12 months, the same for Phase 2.They are also looking at making the scheme simpler, firstly by making it a Tax, no payments from the pot for those that reduce emissions the most, Good or Bad?

For me it’s a bit of good and bad, organisations no longer being rewarded for reducing emissions will need to find some other motivation to reduce emissions! The good side is that it is giving these organisation more time to get to grips with the scheme, however, as experience has shown, a lot of organisation left it to the last minute before registering for the CRC, will they do the same again?

Initially Phase 1 reporting is primarily about Scope 1 & 2 emissions, Scope 1 being based on energy you produce, for example if you had a wind turbine and selling electricity back to the grid, Scope 2 is for energy you purchase.

However Phase 2 of the CRC is interesting, as it suggests that Scope 3 emissions will be included in a company’s declaration, a good way of introducing mandatory emissions reporting for all via the back door. Scope 3 covers everything from Travel to Suppliers.

If we look at suppliers for a large organisation, this could easily be in the thousands, a local authority I recently met with, have in excess of 5000 suppliers, under phase 2 they will need to liaise with all 5000, collate the emissions data for those 5000 and submit under the local authorities umbrella.

This will be an administrative nightmare for the unprepared, both the supplier and the large organisation. This will mean that for those who tender for work from larger organisations it will no longer be just a tick box exercise for environmental policy, such as ISO14001, it will be a detailed report on emissions and those not able to submit such a report, will ultimately, not win any business.

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Ignorance is NO Excuse!

The amount of times I hear business owners say ” I didn’t know we needed to be” or ” I thought it only applied to large companies” is staggering.  There really is no excuse for ignorance of what environmental legislation affects their business. The buck stops with them! 

A recent case concerning Anderton Concrete Products Ltd highlights this ignorance, the following is directly from the EA:

Concrete company fails to comply with packaging regulations

Leicestershire concrete manufacturer ordered to pay over £50,000 fines and costs for failing to register and recycle packaging waste.

Anderton Concrete Products Ltd, pleaded guilty today (28 Jan 2011) at Coalville Magistrates’ Court to 18 offences under the Packaging Regulations, and asked for a further 12 to be taken into account.

The organisation was fined £36,000, ordered to pay £5,712.55 in costs, £8,408 in compensation, and a £15 victim surcharge.

The company, of Leicester Road, Ibstock, Leicestershire, should have been registered with the Environment Agency or a compliance scheme since the year 2000 and was obliged to recover and recycle packaging waste, as well as filing a certificate at the end of each year to confirm it had met these obligations. 

However, the company did not register with a compliance scheme until 2010.

The court heard a routine check by the Environment Agency in January 2010 established that the company should have been registered in previous years.

The company’s explanation for failing to comply with the packaging waste regulations was that it was unaware that it was an obligated company under the regulations.

By failing to register, the company had avoided fees and other costs of £23,615.

Speaking after the case an Environment Officer said: “The packaging regulations are designed to reduce the amount of packaging used by businesses and increase the amount of packaging waste recycled. This case highlights the need for businesses to make sure they understand their responsibility.”

In mitigation, the court heard that the company had entered an early guilty plea, had cooperated fully with the investigation and were not aware that the company were obligated under the regulations.  It was an oversight not a deliberate intention to evade the regulations. In addition, the company is now fully compliant.

The charges were brought by the Environment Agency under the Producer Responsibility Obligations (Packaging Waste) Regulations 1997, 2005 and 2007 (as amended).

As you can see, not knowing really is a costly business.

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EU report supports Mandatory Emissions Reporting

The EU should adopt mandatory greenhouse gas emissions reporting framework for businesses, according to a recent study published by the European Commission’s environment department.

The 239-page study conducted by consultancy ERM analyses a range of corporate carbon reporting methodologies. Of the 80 in use globally, nine are assessed in detail including ISO 14064:2006 and the French Bilan Carbone method.

ERM identifies problems in the existing voluntary approach, not least that the results of different methodologies cannot be easily compared. Few methods fully integrate corporate target setting, and guidance is often missing for specific sectors.

A major GHG reporting scheme such as the Carbon Disclosure Project (CDP) is more suited for large companies and does not oblige firms to report CO2 from their supply chains, called scope 3 emissions in the first round of CRC implementation. Although phase 2 does infact suggest that scope 3 emissions will be included. However, Its reliability may also be questionable, as participants are not required to verify their emissions, says ERM.

Any new scheme backed by the EU would have “a significant risk of low uptake” if it is only voluntary, according to the consultancy. This is partly because leading ones, such as the carbon dsiclosure project, are widely used in some sectors already. The UK government published revised voluntary reporting guidelines in Spetember 2009, with the Scottish governments Zero Waste plan requesting that public sector organisation report their emissions voluntarily from Jan 2011.

To maximise participation rates and ensure a level playing field, a mandatory approach will be needed, says ERM. A new scheme must also include “strong measures aimed at setting corporate GHG reduction targets”.

This year, 2011, the commission will publish a corporate environmental impact assessment method which will take into account the study’s advice on carbon emissions. An impact assessment method for products will also be published ahead of the 2012 review of the EU’s sustainable consumption and production strategy.

Mandatory emissions reporting is now a question of when rather than if.

Following the UK governements report in December 2010 to parliament on how effective reporting is in the battle of emissions reduction it seems certain that we will see the introduction of legislation of some sort to enforce reporting. The Climate Change Act 2008 requires this legislation to be inplace by 6th April 2012, or an explanation why it hasn’t been introduced. The mechanism for reporting will be the companies act 2006, section 416 (4), the directors report.

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