Guidance on the CRC Energy Efficiency Scheme Footprint reports

Guidance on the CRC Energy Efficiency Scheme Footprint reports

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Guidance on the CRC Energy Efficiency Scheme Footprint reports Preparing and submitting your footprint report. List of abbreviations AMR Automatic Meter Reading CCA Climate Change Agreement CRC CRC Energy Efficiency Scheme DECC Department of Energy and Climate Change EGC Electricity Generating Credits EU ETS European Union Emissions Trading System HHM Half hourly meter kwh Kilowatt hour MWh Megawatt hour SGU Significant Group Undertaking tco 2 Tonnes CO 2 TUI Target Unit Identifier Environment Agency Footprint Report 3

Contents Section 1 Preparing your footprint report... 6 What is the footprint report?... 6 Do I need to submit a footprint report?... 6 When is the footprint year?... 7 Section 2 How to calculate your CRC footprint emissions... 9 Starting point: Total energy use emissions... 9 Step 1: Determining your relevant emissions... 11 Step 2: Calculating your total footprint emissions... 12 Step 3: Calculating your regulated emissions... 13 Step 3.1 - Accounting for your regulated emissions... 13 The Residual Percentage rule (90 per cent rule)... 17 Step 3.2 - Including residual supplies... 17 Step 4: Calculating your CRC emissions... 20 Summary... 21 Section 3 - I am ready to submit my footprint report... 23 What information do I need to submit?... 23 The CRC Registry... 23 Step 1: Getting in to the system... 24 Step 2: Reporting designated changes... 24 Step 3: Review and claim CCA exemptions... 26 Step 4: Report metrics (energy supply)... 29 Step 5: Report metrics (emissions)... 31 Step 6: Calculated emissions... 32 Step 7: Residual emission figures... 33 Step 8: Other fuels... 35 Step 9: Footprint report summary... 36 Penalties for failure to provide a footprint report by the reporting deadline... 37 Section 4 Supporting information... 38 Where can I get more help?... 38 Annex 1 Core supplies... 39 Core electricity supplies... 39 Core gas supplies... 40 Environment Agency Footprint Report 4

Figures Figure one: Footprint report timeline - Phase 1 (introductory phase) Figure two: Footprint report timeline - Phase 2 Figure three: Step-by-step method for determining your CRC emissions Figure four: Illustration of regulated emissions as a proportion of total footprint emissions Figure five: Calculating your emissions flowchart Table Table one: The CRC fuel list Boxes Box one: Aligning EU ETS and CCA reporting periods Box two: Core supplies Box three: Residual supplies Box four: Worked example where some residual supplies need to be included Box five: Worked example where residual supplies do not need to be included. Box six: Worked example where core supplies are greater than the residual percentage Box seven: Worked example of calculating your CRC emissions Environment Agency Footprint Report 5

Section 1 Preparing your footprint report What is the footprint report? Once you have determined that your organisation qualifies as a participant in the CRC Energy Efficiency Scheme (CRC), you will register the organisation on the webbased CRC Registry. By the last working day in July following the footprint year in each phase, you must submit a report of all the energy supplied during the footprint year (see separate guidance on supply rules. You must then identify those emissions that you are required to include within your CRC scheme coverage - your CRC emissions. The CRC Registry will convert your fuel supply data into CO 2 emissions. You will report your actual CRC emissions in each subsequent annual reporting year for that phase. The purpose of the footprint report is to demonstrate that at least 90 per cent of your energy supply is covered by the following three measures to mitigate the effects of climate change: the EU Emissions Trading System (EU ETS) a Climate Change Agreement (CCA) CRC. Do I need to submit a footprint report? If you hold one or more CCAs and you are able to claim exemption from CRC (see EU ETS and CCAs) for further guidance on CCA exemptions), you may do this at the point you register. An organisation that is exempt from participating in CRC and which claimed its exemption (either a general CCA exemption or a group CCA exemption) when it registered does not need to submit a footprint report. If, however, you claimed member CCA exemptions for one or more members of your organisational group but the remainder of the organisation is not exempt, you do need to submit a footprint report. However, if at the time of registration you had insufficient information about your total footprint emissions to claim a CCA exemption, you may do this when submitting your footprint report. However you do need to submit a footprint report if you are claiming a CCA exemption as part of the footprint reporting process (see EU ETS and CCAs). Environment Agency Footprint Report 6

When is the footprint year? For Phase 1 (the introductory phase), the footprint year runs from 1 April 2010 to 31 March 2011. This is also the first annual reporting year (see annual report) for Phase 1. You must submit your footprint report for Phase 1 by the last working day in July 2011 (29 July 2011). You will need to submit a footprint report for each CRC phase. The footprint report for Phase 2 is due by the last working day in July 2012 (31 July 2012). Please see the Phase 1 and Phase 2 timelines provided below. Figure one: Footprint report timeline - Phase 1 (introductory phase) Environment Agency Footprint Report 7

In Phase 2 and subsequent phases, the footprint year will be one year before the first annual reporting year; for Phase 2 the footprint year starts in April 2011, while the first annual reporting year starts in April 2012. Figure two: Footprint report timeline - Phase 2 Note: the timeline will follow a similar sequence in Phase 3 and subsequent phases. Environment Agency Footprint Report 8

Section 2 How to calculate your CRC footprint emissions Although the CRC Registry will calculate your total footprint emissions from the energy supply data (such as data in units of kwh, litres or tonnes) you provide when submitting your footprint report, it is considered best practice to also calculate your emissions outside of the CRC Registry and to keep these calculations as part of your evidence pack. The explanation below takes you through this process step by step and details the information you will require at each stage. Before you submit your footprint report through the Registry, you will be asked to confirm that the figures calculated by the Registry are correct. If the figures you calculated do not tally with those calculated by the Registry, you will be able to check your Registry submission and your own records against each other and identify any errors or inaccuracies. Different energy supplies produce different levels of CO 2 emissions for each unit of energy generated, and CRC recognises this. Therefore, energy supply is translated into CO 2 emissions using emission factors. A list of standard emissions factors for CRC has been published by the Department of Energy and Climate Change (DECC). CRC Energy Efficiency Scheme Order: Table of Conversion Factors. Version 1: Published 22 January 2010. For further information, and a reproduction of the table of factors, please refer to the guidance note conversion factors and emission factors. Please note that the emission factors may be revised prior to the start of a new phase so you should make sure you have the up-to-date version. Starting point: Total energy use emissions Start by considering the emissions associated with all the supplies of energy your organisation or group is responsible for under CRC. These are your total energy use emissions. Qualification for CRC is based solely on electricity supply. However, once you are participating in CRC, you are required to consider all relevant energy supplies for which your organisation is responsible when you determine your CRC emissions. Responsibility for supply is discussed in the guidance note supply rules. To calculate your total energy use emissions, you need to multiply the total for each supply of energy by the corresponding emission factor. You can either do this yourself, using the factors listed on the DECC website (also see conversion factors and emission factors), or use one of two tools that the Environment Agency has made available: the source list tool or the Emissions calculator, which is built into the online CRC Registry. Environment Agency Footprint Report 9

To help you with the task of recording your energy supplies and the resulting emissions, we have provided a tool, in the form of a spreadsheet, known as the source list tool. The source list tool allows you to break down your energy supplies by source (such as electricity), supply type (for example half-hourly metered) and by undertaking. We offer the source list tool only to support participants and recognise that other similar tools are available. There are also other tools we expect will be available that will allow greater manipulation, quasi-real time or automatic updating and scenario planning. The source list tool is not intended as a replacement for any of these tools, which participants may find useful in aiding their CRC compliance and wider carbon management. Where you do not have a full record of your energy supplies in CRC you may use estimated data. Detailed guidance on which estimation techniques it is appropriate to use is given in a separate note estimation techniques. From your total energy use, you will be able to determine your CRC emissions, as shown in Figure three. Figure three: Step-by-step method for determining your CRC emissions The process of calculating your relevant emissions, total footprint emissions, regulated emissions and CRC emissions referred to in the figure above are detailed in steps one to four below. Environment Agency Footprint Report 10

A flowchart of the process detailed in the steps below is provided at the end of this section in figure five. Step 1: Determining your relevant emissions In this step, you must exclude emissions related to energy supplies that are excluded from CRC or are not your responsibility under CRC. You can also remove emissions equal to any Electricity Generating Credits (EGCs) that you hold. Energy supplies that are excluded from CRC are those used for: transport domestic use use outside of the UK public lighting (Northern Ireland only). Energy supplies that are not your responsibility under CRC are those not for your own use (unconsumed supply see supply rules) (although there is an exception if you supply someone who occupies your premises with your permission). Please note that you will not need to keep energy supply data or emissions data related to your excluded supplies. However, please be aware that you will need to be able to justify (with information contained in your evidence pack) the amount of excluded supplies where these have been estimated from part of a larger supply used for wider purposes. Please see supply rules for further information on excluded sources. You should deduct emissions equalling any EGCs that you hold for electricity you have generated on-site. EGCs will be provided to electricity generating facilities that meet the EGC eligibility criteria, as outlined in the separate guidance note on electricity generation. The CRC Registry will convert your EGCs, entered as kwhs, into emissions (tco 2 ) and deduct the emissions for you (see Section 3, Step five). Example of excluded supplies Group AB has two undertakings, Undertaking A and Undertaking B. Group AB, as the primary member, has calculated that the group s total electricity supply for 1 April 2010 to 31 March 2011 is 22,000,000kWh from all undertakings within the participant group. However, some of the electricity supplies to Undertaking A include electricity for use in domestic residential accommodation. The supply of electricity to the domestic accommodation totals 5,000,000kWh over the period 1 April 2010 to 31 March 2011 (the footprint year). Also, Undertaking B uses some of its supplies of electricity to charge a number of road-going electric vehicles. The supply of electricity for powering transport totals 2,000,000kWh over the same period. Environment Agency Footprint Report 11

So removing excluded supplies: 22,000,000 5,000,000 2,000,000 = 15,000,000kWh Group AB s relevant emissions, in tco 2, will be: 15,000,000kWh x grid average emission factor (0.541)] / 1,000 = 8,115tCO 2 The next step is to calculate your total footprint emissions. You must consider whether your organisation or any part of it has a CCA exemption (see EU ETS and CCAs). If no member of your organisation has a CCA exemption, then continue from Step 3 - Calculating your regulated emissions. Step 2: Calculating your total footprint emissions In this step, you must remove all (100 per cent) of emissions from CCA exempt members. Your footprint emissions include all of your relevant emissions minus emissions from CCA exempt members. Before you work through this step, you should review the separate guidance on Climate Change Agreements (see EU ETS and CCAs) to establish if you qualify for one of the CCA exemptions from CRC. In preparing to register for CRC, you will have considered whether your organisation, or any part of it, has a CCA. You should claim any exemption at the time that you register. However, you have the option to claim an exemption as part of the footprint report if you do not have enough data available to make a claim when you register. Your obligations at this stage will depend upon which type of exemption you have claimed, and when you claim it, as explained below: If you are a single entity participant, more than 25 per cent of your relevant emissions are covered by a CCA, and you claimed a general exemption at registration, you will be exempt from CRC for all your emissions for as long as the exemption remains. If you claimed this exemption at registration you do not need to submit a footprint report. However, if you claimed this exemption as part of your footprint report you must calculate your footprint emissions and submit a footprint report. You will not be required to submit an annual report. Environment Agency Footprint Report 12

If any member of your organisational group has more than 25 per cent of its relevant emissions covered by a CCA, that member has a member CCA exemption and is treated as exempt for as long as that exemption remains. When working out your group s total footprint emissions, you will need to exclude 100 per cent of the emissions from group members that have a member CCA exemption. If, after the removal of the energy supply of members with a CCA exemption, your remaining organisation has less than 1,000MWh of half-hourly electricity remaining in CRC, your entire organisation will have a group CCA exemption and be exempt from CRC for all the groups emissions for as long as the exemption remains. If you claim a group CCA exemption at registration, you do not need to submit a footprint report. However, if you claim as part of your footprint report you must calculate the footprint emissions and submit a footprint report. You will not be required to submit an annual report. Step 3: Calculating your regulated emissions In this step, you can remove up to 10 per cent of your total footprint emissions but not where these are from core supplies or covered by EU ETS or CCA. At least 90 per cent of your total footprint emissions must be regulated under EU ETS, CCA or CRC. This step has been divided into two parts: Step 3.1 - Accounting for your regulated emissions Step 3.2 - Including your residual supplies as part of your regulated emissions Step 3.1 - Accounting for your regulated emissions At least 90 per cent of your total footprint emissions must be regulated by CRC, EU ETS or CCAs. These are your regulated emissions. Emissions from core CRC supplies and EU ETS and CCA emissions (excluding all emissions from group members that have a CCA exemption) are always included as part of your regulated emissions. Where these total 90 per cent or more of your footprint emissions, you do not need to include any emissions from residual supplies as part of your regulated emissions. Where they make up less than 90 per cent of your footprint emissions, you need to include a sufficient amount of emissions from residual supplies in your regulated emissions to ensure that 90 per cent or more of your footprint emissions are regulated emissions (see page 17 - The residual percentage rule). Organisations with emissions covered by EU ETS or CCAs can use the data collected in the most recent annual period in these other schemes to report EU ETS emissions and CCA emissions (excluding emissions from group members that have a CCA exemption) as if they were the CRC footprint year data for the purposes of collating their footprint report. This is explained further below. Environment Agency Footprint Report 13

Box one: Aligning EU ETS and CCA reporting periods Note on aligning EU ETS and CCA reporting periods with CRC The reporting period for CRC (April-March) is different to that for the EU ETS and the target year for CCAs. For EU ETS, the reporting year is January to December. Therefore, to report your emissions and claim exemption in CRC, you may use figures from the latest year. Hence, for the footprint year in Phase 1 of CRC, you may use data from 1 January to 31 December 2010. Alternatively, you can use the emissions data in respect of the amount of electricity, gas and fuel supplied at the EU ETS installation(s) during the footprint year (1 April 2010 to 31 March 2011). The CCA target period for the footprint year in Phase 1 is 2010. The target period can start in October, November or December 2009 (up to 1 Jan 2010) and will finish by the end of the calendar year 2010. You may use data from the target period to report your CCA emissions and must use it when determining whether you can claim a CCA exemption in CRC. Alternatively, you can use the emissions data in respect of the amount of electricity, gas and fuel supplied at the CCA facilities during the footprint year (1 April 2010 to 31 March 2011). The figure below shows which of your footprint emissions make up your regulated emissions. Environment Agency Footprint Report 14

Figure four: Illustration of regulated emissions as a proportion of total footprint emissions Box two: Core supplies What are core supplies? Core supplies refer to the amount of electricity and gas supplies that are measured by certain types of meter (see Annex 1 Core supplies). You must include all emissions from energy supplies that are classed as core supplies including those covered by EU ETS or CCAs in your regulated emissions. This will be the case even if, together with your total EU ETS and CCA emissions, these exceed the residual percentage (that is 90 per cent) of your total footprint. Core supplies include the following: all electricity consumed through half-hourly meters (HHMs) all electricity consumed through Automatic Meter Reading (AMR) meters all electricity consumed though non-domestic meters dynamic pseudo half-hourly supply all gas consumed through daily-read gas meters all gas consumed through remotely read hourly meters all non-daily metered gas supplies of more than 73,200kWh a year (through a meter known as a large gas point meter ). Environment Agency Footprint Report 15

Box three: Residual supplies What are residual supplies? Residual supplies are any CRC-eligible energy supply, other than the core supplies (for example, liquid petroleum gas, fuel or gas oil, petrol or industrial coal). Residual supplies also include all electricity and gas supplies not included in the definition of core supplies, provided the supply arrangements meet the definition of a supply or self-supply (see supply rules). To help you to identify residual supplies that you may need to include, a list of fuels that are included in CRC is shown in table one 1 together with their respective units of measurement. Fuel type Aviation spirit Aviation turbine fuel Basic oxygen steel (BOS) gas Blast furnace gas Burning oil/kerosene/paraffin Cement industry coal Coke oven gas Commercial/public sector coal Coking coal Colliery methane Diesel Electricity Fuel oil Gas oil Industrial coal Lignite Liquid petroleum gas (LPG) Peat Naphtha Natural gas Other petroleum gas Petrol Petroleum coke Scrap tyres Solid smokeless fuel Sour gas Waste Waste oils Waste solvents Table one: The CRC fuel list Measurement unit Tonnes Tonnes kwh kwh Litres Tonnes kwh Tonnes Tonnes kwh Litres kwh Tonnes Litres Tonnes Tonnes Litres Tonnes Tonnes kwh kwh Litres Tonnes Tonnes Tonnes kwh Tonnes Tonnes Tonnes 1 The CRC Energy Efficiency Scheme Order 2010, Schedule 1. Environment Agency Footprint Report 16

The residual percentage rule (90 per cent rule) What is the purpose of the 90 per cent rule? To reduce the administrative effort on CRC participants for monitoring small sources of emissions, some small energy supplies do not need to be accounted for under the CRC scheme. This will be possible as long as at least 90 per cent of your total footprint emissions, and all core supplies, are still regulated by the EU ETS, a CCA or CRC. This percentage is known as the residual percentage. Calculation of the residual percentage Once you have established your total footprint emissions, you will need to establish, for your organisation as a whole, whether 90 per cent of your total footprint emissions are regulated by the EU ETS, CCAs or CRC. Note: When calculating your coverage against the 90 per cent rule, you must make sure you do not double count any emissions that are included in the EU ETS and a CCA. If your emissions from core CRC supplies, and EU ETS and CCA emissions total in excess of 90 per cent of your total footprint emissions (for example 93 per cent) then you do not have to include any residual supplies, but you must include all of your core sources and will, therefore, be required to meet 93 per cent coverage. Step 3.2 - Including residual supplies as part of your regulated emissions If, having included all your emissions from core supplies and EU ETS and CCA emissions, you find that you have not yet reached the point where 90 per cent of your total footprint emissions are regulated, then you must include some of your residual supplies until your organisation s combined EU ETS, CCAs and CRC coverage level is above 90 per cent of your total footprint emissions. Your residual supplies are explained in box three. If you need to include residual supplies in CRC to reach the residual percentage, you will need to compile a list of those residual energy supplies. This is known as the residual measurement list. Section 3, step 7 explains how to compile and submit this information as part of your footprint report. Once your organisation has achieved the 90 per cent threshold, you can choose to voluntarily opt in residual supplies, until 100 per cent of your total footprint emissions are covered. The examples below show two ways in which a participant may meet the obligation under the 90 per cent rule. Box four: Worked example where some residual supplies need to be included Environment Agency Footprint Report 17

Worked example 1 In Organisation B, 80 per cent of footprint emissions are covered as follows: Core CRC supplies 70 per cent CCA 5 per cent EU ETS 5 per cent The remaining 20 per cent of its emissions are from residual supplies. Therefore, Organisation B will need to include at least half of its residual supplies, in terms of their contribution to emissions, to bring it up to the residual percentage threshold. Emissions t/co 2 Percentage of footprint EU ETS emissions 10,000 5 CCA emissions (not covered by EU 10,000 5 ETS) Core supplies emissions 140,000 70 Residual supplies emissions 40,000 20 Footprint emissions 200,000 100 Box five: Worked example where residual supplies do not need to be included Worked example 2 Organisation C has 90 per cent of its footprint emissions covered as follows: Core CRC supplies 70 per cent CCA 10 per cent EU ETS 10 per cent Therefore, Organisation C can choose whether to include emissions from its residual supplies in CRC. Emissions t/co 2 Percentage of footprint EU ETS emissions 20,000 10 CCA emissions (not covered by EU 20,000 10 ETS) Core supplies emissions 140,000 70 Residual supplies emissions 20,000 10 Footprint emissions 200,000 100 Environment Agency Footprint Report 18

Box six: Worked example where core supplies are greater than the residual percentage Worked example 3 Organisation D has 96 per cent of its footprint emissions covered as follows: Core CRC supplies 96 per cent Organisation C must include at least 96 per cent of its total footprint emissions and can choose whether to include emissions from its residual supplies in CRC. Emissions t/co 2 percentage of footprint Core supplies emissions 192,000 96 Residual supplies emissions 8,000 4 Footprint emissions 200,000 100 You may need to update your residual measurement list or create a new one under certain circumstances (for example if you purchase an undertaking). Please refer to guidance note residual measurement list for further information. You must re-assess your residual measurement list when submitting the footprint report for every new phase to ensure that the percentage of footprint emissions that are regulated emissions does not decrease. Environment Agency Footprint Report 19

Step 4: Calculating your CRC emissions In this step, you must remove all emissions coved by EU ETS and emissions covered by CCAs which have not already been removed where the group member is exempt. Once you have calculated your regulated emissions, by ensuring at least 90 per cent of your total footprint emissions are covered by EU ETS, CCA or CRC, you can calculate your CRC emissions. You will report your CRC emissions in all subsequent annual reports for each annual reporting year of that phase. You will not be allowed to remove supplies (whether core or residual) over the course of a phase (other than if that supply is transferred to another organisation/another form of regulation such as when an undertaking or Significant Group Undertaking (SGU) is sold, or a particular supply enters a CCA see changes to CCAs. Your CRC emissions are your regulated emissions minus any emissions covered by EU ETS and/or CCAs. Box seven: Worked example of calculating your CRC emissions Worked example 4 For the footprint year in Phase 1 Organisation G has regulated emissions that cover 96 per cent of its total footprint emissions, broken down as follows: Core CRC supplies 420tCO 2 (79 per cent) CCAs 60tCO 2 (11 per cent) EU ETS 30tCO 2 (6 per cent) Residual supplies 20tCO 2 (4 per cent) Total 530tCO 2 (100 per cent) Organisation G does not need to include any residual supplies in its regulated emissions to meet the residual percentage as its emissions covered by EU ETS, CCAs and CRC equal 96 per cent of its total footprint emissions. To calculate its CRC emissions, Organisation G must remove all emissions covered by the EU ETS and CCAs. Organisation G s CRC emissions are therefore: CRC emissions: 420tCO 2. Environment Agency Footprint Report 20

Recording your CRC emissions Once you have worked out your CRC emissions, you need to compile a list of all energy supplies included and add this to your evidence pack. These will be the emissions that you have to report on and purchase allowances for. Do not include the supplies covered by EU ETS and CCAs in your CRC emissions source list. Summary The following flowchart summarises the process of calculating your CRC emissions. This is, in effect, the same process as shown in Figure three but shown in a different configuration. Environment Agency Footprint Report 21

Figure five: Calculating your emissions flowchart Environment Agency Footprint Report 22

Section 3 I am ready to submit my footprint report What information do I need to submit? You have determined your CRC emissions using the data collected in the footprint year. By the last working day in July following the footprint year, you have to submit your footprint report using the online CRC Registry. You will need to provide: your regulated emissions (as calculated in Step 3 of Section 2) your CRC emissions (as calculated in Step 4 of Section 2) details of any exemptions through CCAs being claimed as part of the footprint report the supply you have received of any fuels which do not appear in the fuels list (Step 8 of Section 3). The CRC Registry The CRC Registry will lead you through the process of submitting the information required to make your report. It is important that you have assembled the information required before you start, as described in Section 2 of this guidance document. The sections that follow provide a step-by-step process for submitting your footprint report. Example CRC Registry screen shots have been provided to demonstrate the information and data that you, as a CRC participant and user of the Registry, will need to input. We have illustrated the description of the CRC Registry process for submitting your footprint report with some screen shots from the prototype system. This system is still under development. The screens and the terminology may look slightly different when you come to submit your report. Environment Agency Footprint Report 23

Step 1: Getting into the system You can only submit your footprint report using the CRC Registry. You will need to have been set up on the CRC Registry as a primary contact, a secondary contact or an account representative to submit a footprint report. Each user within a participating organisation will have been set up with rights appropriate to their role at the time of registration. Your senior officer contact cannot submit your report unless also set up as one of the above contacts. You do not need to complete your footprint report in one go. Once you have logged in, you will be able to save your report partway through and return to it, at the same point, at a later date if you wish. However, you will not have complied with the obligation to submit a footprint report until the point at which you submit the completed report. The system will provide you with confirmation that the report has been successfully submitted and will present you with a copy of the information that you have input. You must have completed and submitted the report by the last working day of July or you may be liable to a civil penalty; for this reason it is recommended that you prepare in advance rather than wait until the second half of July. Once you have logged into the Registry: 1. Select CRC to be taken to the CRC Homepage. 2. Select: Existing users. Enter your User ID and Password to log in. 3. You will see the Participant homepage. 4. Select I want to submit a footprint report. You will then be directed to the first screen. Step 2: Reporting designated changes 5. You have now been directed to a screen headed designated changes displaying a message, as shown below. Environment Agency Footprint Report 24

Designated changes On this screen, you should report designated changes, such as large-scale organisational changes during the footprint year, featuring the sale or acquisition of participants or SGUs, mergers or, in the case of government departments, information on any machinery of government changes In Phase 1, you will need to record in the footprint year any changes that take place between registration and the end of the footprint year on 31 March 2011. In future phases, the requirement will be to record changes during the footprint year in the footprint report. Changes that take place during the annual reporting year will need to be notified in the annual report for the year in which the change took place. You are required to notify us of such changes within three months of the change taking place. If you have already done so, you should still briefly describe the change here. If you have not done so you should note the change on this screen and the fact that you have not submitted a notification. You should submit a notification as soon as possible so that we can make any necessary changes to your baseline figures in the Registry. If you delay in making a notification it may affect your ability to complete your annual report properly and your position in the league table. Please refer to guidance notes Changes to organisational structure - private sector and Changes to organisational structure - public sector for further information. If you need to report a change, then you must describe it by typing the following information (as appropriate) about each change into the text box provided: The nature of the change what happened? Did you buy or sell an undertaking? Which parties were involved? Environment Agency Footprint Report 25

Which SGU/organisation was bought or sold? Who was it you sold to/acquired from? When did each change take place? Click Next to submit the information. If there are no changes, click Next. You will then be directed to the next screen - CCA Exemption Status'. Step 3: Review and claim CCA exemptions 1. Review CCA exemptions claimed at registration In the screen below, you will see the list of exemptions that have been claimed for your organisation (at the time of registration) or for each undertaking that makes up the participant group. You may select any undertaking to view the CCA claimed for it or to add a further CCA. 2. Select either Previous to return to Designated Changes or Next to continue. 3. If you have selected an undertaking or SGU, you will see the CCA Exemption Status for that undertaking or SGU or, if you are a single entity, your whole organisation. Environment Agency Footprint Report 26

If you click on Review you will see the following screen: 4. Note: the status of your CCAs at the time of your footprint report may be subject to verification during an audit. For further guidance on CCAs see the separate document EU ETS and CCAs. 5. You now have the opportunity to add any CCA exemptions that were not claimed at registration. 6. For each additional CCA, enter the CCA reference - known as the Target Unit Identifier (TUI) - the name of the company to which it applies and the tonnage of CO 2 that it covers. 7. Select either Previous or Next. Environment Agency Footprint Report 27

8. You will now be asked to re-confirm your exemptions. 9. You should click on the appropriate radio button to indicate your CCA status at the time that you submit your footprint report. I am not eligible for any exemptions. I am claiming a general CCA exemption (if you are a single entity organisation with up to 25 per cent CCA coverage). I am claiming a group CCA exemption (if, once the energy use of exempt group members has been removed, your remaining organisation has less than 1,000MWh of qualifying half-hourly electricity remaining in CRC, your entire organisation will be exempt). I am claiming member CCA exemptions (If any member of your organisational group has greater than 25 per cent of its emissions covered by a CCA, that member is treated as exempt when working out your group s total footprint emissions). 10. If you select Next, the system presents the screen headed Report metrics (energy supply). Environment Agency Footprint Report 28

Step 4: Report metrics (energy supply) Note: the values to be entered are for supply, not emissions your data will be converted to CO 2 emissions values by the Registry. The following fields are displayed: o Core supplies of electricity (but not supplies covered by EU ETS or CCA). o Core supplies of gas (but not supplies included in EU ETS or CCA). o Other supplies of fuels (such as residual energy supply) as listed in the CRC fuels table (see table one in section 2). 11. Enter your core supplies of electricity, gas and all other supplies of fuels into the corresponding fields, ensuring the figures are in the correct measurement units (kwh, litres or tonnes). Environment Agency Footprint Report 29

Please note that this screen is for demonstration purposes only. The emission factors which will be used for calculation and shown on the finished screen will be those published by DECC (in CRC Environment Agency Footprint Report 30

Energy Efficiency Scheme Order: Table of Conversion Factors. Version 1: Published 22 January 2010 2 ). 12. If you select Next, the system presents the screen headed Report Metrics (Emissions). Step 5: Report metrics (emissions) The next screen Report Metrics (Emissions) allows you to record: Your emissions from sources which are to be deducted from your CRC emissions, such as total emissions from EU ETS and CCA sources if appropriate. The amount, in kwh, of any electricity generating credits you have (see electricity generation). Please enter the amount in kwh of electricity that you have generated and self-supplied on the same site where you have received ROC/FIT subsidy for that electricity. Please refer to the guidance note supply rules for further information on self-supply. 2 http://www.defra.gov.uk/environment/business/reporting/conversion-factors.htm Environment Agency Footprint Report 31

If you select Next, the system presents the next screen headed Calculated Emissions Step 6: Calculated emissions The system then calculates and displays the relevant emissions for your organisation. These are made up of: your total footprint emissions your regulated emissions Environment Agency Footprint Report 32

the percentage of your total footprint emissions covered by your regulated emissions. 13. You should check that the emissions figure matches the emissions figures that you calculated outside of the Registry (see Section 2). Please note that you must re-assess your residual measurement list at every footprint year to ensure that the percentage of your footprint emissions that are regulated emissions does not decrease. Therefore, the final paragraph on the above screen is not relevant for Phase 1. Please refer to guidance note residual measurement list for further information relevant to future phases. If you select Next, the system presents the next screen headed Residual Emission Figures Step 7: Residual emission figures The system will then display a message stating Your current regulated emissions coverage is xx per cent. Do you wish to include any residual supplies? Environment Agency Footprint Report 33

Remember that your total coverage, including residual emissions, must amount to 90 per cent or more of your total footprint emissions (the residual percentage rule 90 per cent rule). Please refer to section 2 of this guidance for further information on the residual percentage rule. 14. If the figure given for regulated emissions is below 90 per cent, you should select Yes to add more emissions from your residual emissions to meet the 90 per cent minimum. You can voluntarily enter residual emissions up to 100 per cent of your total footprint emissions if you wish. If you select Next, the following screen appears: Residual Measurement List In future phases, this screen will prompt you to enter residual supplies, if relevant, to meet the percentage required. This may be more than 90 per cent. This is not relevant for Phase 1. Please refer to guidance note residual measurement list for further information relevant to future phases. To add emissions from your residual measurement list: 15. Enter the type of fuel used in Description. Remember that these should be fuels that appear on the CRC fuels list. (Please refer to the list of standard emission factors for CRC published by DECC: CRC Energy Efficiency Scheme Order: Table of Conversion Factors. Version 1: Published 22 January 2010. 16. Enter the emissions in Tonnes of CO 2. You can use the emissions calculator to calculate the emissions arising from fuel usage data. 17. Click Add to increase the total residual supply emissions. Environment Agency Footprint Report 34

Once you have added enough residual emissions to meet the residual percentage (90 per cent), if you select Next, the system presents the next screen headed Other Fuels. Step 8: Other fuels You must use this screen to enter the supply you have received of any fuels which do not appear in the fuels list. This information will not be taken into account in your footprint report, but will be used to inform future phases of the scheme, when other fuels may be included. For each fuel that you list, you should provide a total for the organisation. It is sufficient to enter an estimated amount. Please provide the most commonly used description for each fuel and state the amount in the units that you would normally be supplied with within your organisation. If you do have supplies of other fuels, you will need to: 18. Enter the fuel type in the Description box. 19. Enter the amount and units of fuel with which you were supplied. 20. Click Add to add to the list. When you have finished, select Next If you do not have any supplies of other fuels, leave the fields blank and select Next. Environment Agency Footprint Report 35

Step 9: Footprint report summary The Registry will then display a footprint report summary as shown below. 21. Check that the totals shown are correct before you confirm and submit your footprint report. 22. If you wish, you may add further emissions from your residual measurement list select Previous and repeat sub-steps 23 and 24. 23. When you are satisfied that you have included all emissions that you wish to, select Submit. Your footprint report will be recorded in the CRC system. The CRC Registry will display a message: Submission complete. Your footprint report has been submitted and e-mails will be sent to your primary, secondary and senior officer contacts and account representatives. You should retain all data files, evidence of meter readings, energy bills, calculation of estimated supplies and workbooks such as the source list tool (if used) as part of your evidence pack for audit purposes. This is the end of the process for submitting your footprint report. Environment Agency Footprint Report 36

Penalties for failure to provide a footprint report by the reporting deadline You may be fined if you do not submit your footprint report or do not submit it by the deadline date. The penalties are as follows: An immediate fine of 5,000 for failure to provide a footprint report by the reporting deadline. A further fine of 500 for each working day for every subsequent day of delay up to a maximum of 40 working days, or 40,000 if the report is delayed for more than 40 days. Publication of the non-compliance on the CRC public pages. Environment Agency Footprint Report 37

Section 4 Supporting information For further guidance related to the footprint report, you may wish to review the following documents: CRC timeline supply rules meters and metering EU ETS and CCAs. Also relevant are: annual report evidence pack source list tool. Where can I get more help? The information and screen shots of the CRC Registry have been provided to help you understand what you need to do, but if you have any questions please contact the helpdesk crchelp@environment-agency.gov.uk, quoting your registration number. The CRC Registry will give you your registration number automatically when you register. You should direct any queries about particular supplies or meters to your energy supplier. Environment Agency Footprint Report 38

Annex 1 Core supplies Core electricity supplies A core supply of electricity is where the supply is measured or recorded by the following: a settled HHM a non-settled HHM a non-domestic meter a dynamic supply. Settled HHMs A settled HHM is a meter that is able to measure electricity supplied at least every half hour. It enables the supplier to comply with provisions of its licence to determine charges between that supplier and another licence holder in respect of the transmission and trading of wholesale electricity. A licence means: In Great Britain, a licence within the meaning of section 6(1) of the Electricity Act 1989. In Northern Ireland, a licence within the meaning of Article 10(1) or (2) of the Electricity (Northern Ireland) Order 1992. Non-settled HHMs A non-settled HHM is a meter that is able to measure electricity supplied at least every half hour and, in respect of a phase, has been read remotely. Read remotely means the meter is read remotely by the public body or undertaking to which the supply is made (or by a person acting on its behalf) at any time during the qualification year for the phase or a year of that phase. Non-domestic meters A non-domestic meter means a meter that is designed to measure supplies to nondomestic premises and is capable of measuring maximum electricity demand. Dynamic supply A dynamic supply means a supply where a device, which is not a metering device, records daily when electricity is supplied or not to one item of a set of equipment on Environment Agency Footprint Report 39

premises and that record is used to determine the half-hourly supply of electricity to the whole set of equipment. Core gas supplies A core supply of gas means a supply measured by a meter which is: a daily meter an hourly meter a large gas point meter. A meter, as used above, includes any ancillary device used in connection with that meter, which allows the amount of the supply measured by that meter to be read. Daily meters A daily meter is a meter that is able to measure gas supplied at least daily and is read in: Great Britain by an authorised supplier or an authorised transporter under section 48(1) of the Gas Act 1986, or in Northern Ireland by a licence holder under Article 3(1) of the Gas (Northern Ireland) Order 1996. Hourly meters An hourly meter is a meter that is able to measure gas at least hourly and, in respect of a phase, has been read remotely. Read remotely has the same meaning as that given in Non-settled HHMs above. Large gas point meters A large gas point meter means a meter that, during a footprint year of a phase, measured greater than 73,200kWh annual quantity of gas supplied. Environment Agency Footprint Report 40

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