Updates to the SECR Scheme

The Streamlined Energy and Carbon Reporting Scheme (SECR) came into force at the start of this month. Quoted companies and large unquoted companies and LLPs are affected, and will now be required to make a public disclosure within their Directors’ Annual Report of their UK energy use and carbon emissions.

 
Over the last few months the ETG (Emissions Trading Group) have been consulting with various parties and collating feedback and queries regarding the guidance for the scheme. As a result, a number of minor updates have been made to the SECR section (Chapter 2) of the Environmental Reporting Guidance.

 

A guide to the updates

All of the updates can be found in Chapter 2 of the Environmental Reporting Guidance.

Below is a summary of the changes:

  • Page 14, 20, 36 – hyperlinks for ISO 14001, BS 8555, ISO 14064-3 and ISO 14064-1 have been updated.
  • Page 26 – reference to public sector has been expanded (first paragraph and footnote 22) and also for charitable organisations (second bullet point).
  • Page 26 – new paragraph inserted to ensure that guidance is not seen as a substitute for the SECR Regulations.
  • Page 30 – reference to corporate group legislation has been expanded (sections 1158 to 1162 of Companies Act 2006) in the last paragraph of section 2.
  • Page 33 and 39 – amended reference to NF3 to reflect that it is not currently listed as a direct GHG in section 92 of the Climate Change Act.
  • Page 45 – footnote 39 referencing Government consultation published on 11 March 2019 on the recommendations made by the Independent Review of the Financial Reporting Council.
  • Pages 50-56 – changes to reporting templates to recommend grid-average emission factor is included as the default by those organisations that choose not to dual report.


Our view on the changes

These updates provide useful clarification on outstanding queries raised by EIC such as dual reporting of electricity. Dual reporting remains voluntary but doing so allows companies to demonstrate responsible procurement decisions. For example, those selecting to procure electricity from renewable sources with a lower emissions factor can demonstrate this within their energy and carbon report if they choose to dual report.

EIC work closely with the ETG and BEIS to help the group reach key decisions regarding carbon compliance scheme development and implementation, including SECR, and will continue to do so. As a result we are able to ensure all of our customers receive the most up-to-date information and we are always on hand to support with SECR compliant reporting.

If you’d like to know more about the Streamlined Energy and Carbon Reporting scheme take a look at my previous blog 7 facts about SECR. Alternatively, you can download our SECR factsheet here.

7 things you need to know about SECR

    1. SECR stands for Streamlined Energy and Carbon Reporting, a new UK Carbon Reporting framework. Companies in scope of the legislation will need to include their energy use and carbon emissions in their Directors’ Report as part of their annual filing obligations.

 

    1. It starts on 1 April 2019 and companies will need to report annually, reporting deadlines align with the company’s financial reporting year.

 

    1. The scheme affects UK quoted companies and ‘large’ unquoted companies and LLPs, defined as those meeting at least two of the following; 250 employees or more, annual turnover of £36m or more or an annual balance sheet of £18m or more.

 

    1. It will affect over 11,000 firms from high street retailers to manufacturers.

 

    1. SECR requires companies to report the following: their Scope 1 (direct) and Scope 2 (indirect) energy and carbon emissions (electricity, gas and transport as a minimum). Previous year’s figures for energy and carbon. At least one intensity ratio (e.g. tCO2/turnover). Detail of energy efficiency action taken within the reporting year. Reporting methodology applied.

 

    1. Not meeting the reporting requirements can result in accounts not being signed off and missing the filing deadline could lead to a civil penalty. So it’s important for organisations to fully align communications between their energy and finance teams and to get a head start where possible!

 

  1. There is an overlap with other reporting and compliance schemes such as ESOS so savvy businesses can save time and hassle by using data collection from one to support compliance with another.

Find out more by downloading our SECR factsheet here https://hubs.ly/H0h2jWT0

Is the Triad past its peak?

The Triad season has concluded for another year and the three Triad dates, as published by National Grid, are listed in the table below. EIC have once again called an alert on each of these days.

 

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The Triad season runs from the start of November to the end of February every year. In this period, National Grid identifies the three highest half-hour periods of demand. Each Triad needs to be at least ten clear days apart from each other.

These three Triads form the basis of National Grid’s electricity transmission charges. For half-hourly consumers with direct pass-through of transmission costs, these Triad points are of particular importance. If these consumers can predict when the Triads will occur and reduce their demand when they happen then their final transmission costs can be significantly reduced.

 

Demand continues to decline

Total UK winter electricity demand for 2018/19 (Nov-Feb) has declined by 19% since 2009/10 as a result of energy efficiency, demand side management, and warmer weather trends. Consequently, these trends, supported by targeted demand-side management schemes such as the Triad, have created a declining trend in the Triad peak demand and, more recently, a flattening of the profile seen during the peak periods.

Another factor contributing to the decline in demand is the steady increase in installed wind capacity over the past decade. Most of this capacity is connected to the Grid so does not impact demand. However, around 6 GW (~30%) of wind capacity is embedded so is connected to local distribution networks. Embedded wind generation is invisible to National Grid and can instead influence outturn demand. Average embedded wind output has increased by more than 1 GW over the past 10 years which has contributed to the decline in average demand seen in the graph below.

 

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Throughout the past winter embedded wind generation varied by 3 GW, depending on nationwide wind conditions, which led to a demand swing of the same amount. Embedded wind generation is having a growing influence on Triad forecasting as the increasing demand swing reduces the risk of a Triad occurring on days with high wind output. This was demonstrated during the previous winter as all three Triads occurred on days when embedded wind output was less than 1 GW.

 

Errors in National Grid forecasting increase

This winter, National Grid demand forecasts showed a significant error against outturn demand. The graph below shows that across the Triad period National Grid day-ahead forecasts averaged 2.4% higher than demand outturn on 76 days and 1.3% lower than demand outturn on 6 days. Furthermore, on EIC alert days National Grid day-ahead forecasts were 3.6% higher than actual demand levels. This equates to a difference of 1,600 MW which is the equivalent of 2 million microwaves or half a million kettles being used at the same time. In comparison, the average day ahead error for the last Triad period was 1.5%, which shows that uncertainty in forecasting has increased.

 

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Warmer weather trends

Another contributing factor to the fall in peak demand was milder temperatures, with an average UK temperature of 5.7°C this winter. This is higher than the previous winter average of 4.1°C and the 10-year average of 4.7°C. There has only been one milder winter in the past 10 years; in 2015/16 when the average temperature was 6.2°C. The graph below shows the link between low temperatures and high demand. This winter there were only 36 days below seasonal average temperature, whereas last winter there was 61. Nearly half of these days fell within the same cold spell at the end of January so only one Triad fell during this period. This meant there was an increased chance that the remaining two Triad dates would fall on milder days with low wind. This was the case with the Triad on 10th December as the temperature was above seasonal average but wind output was only 1.7 GW.

 

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Demand Side Response

National Grid estimate that demand side response (DSR), where consumers reduce energy usage during peak times, can lower national demand by up to 2 GW. The impact of DSR is typically larger during periods of cold weather and when all suppliers have issued a Triad warning. However, as we have seen from the December Triad, a lower level of demand response on milder days can inadvertently increase the risk of that day being a Triad.

The implementation of DSR has also affected the timing of the peak demand period. The graph below shows that the evening peak on Triad alert days was both longer and flatter than on non-alert days. When EIC issued a Red or Amber alert the evening peak typically lasted from 4pm to 8pm and was 4 GW higher (~10% increase) than afternoon demand (12pm to 2pm). Whereas on Green alert days the evening peak occurred between 5pm and 7pm and was 5.7 GW higher than afternoon demand (~15% increase). This suggests that a large number of businesses are reacting to Triad alerts by reducing demand during the typical evening peak.

 

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The flattening of the evening peak on Triad alert days created problems with several suppliers’ Triad forecasts. The table below shows that six large suppliers all incorrectly predicted the peak time period on a number of occasions. For example, on 3rd January all six suppliers in the table below recommended reducing demand at some point between 4:30pm and 7pm. However, the peak half-hourly period fell between 4pm and 4:30pm before many businesses started to reduce demand. EIC managed to correctly predict the timing of the peak half-hourly period for all 24 of the alerts issued, eliminating the risk to our customers of reducing demand at the wrong time and potentially missing a Triad.

 

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Uncertain future for Triads

As a result of the success of the Triad scheme in reducing peak demand as well as other fundamental changes to supply and demand, we have now reached a point where Ofgem are considering a different charging methodology. The Targeted Charging Review aims to introduce a charge that Ofgem consider is fair to all consumers and not just those able to reduce consumption during peak periods. Ofgem’s preferred option is for a fixed charge, however there is also the potential for a capacity based charge.

It is possible that next winter will be the last for Triad forecasting although at this point no timescales have been confirmed. The removal of the Triad scheme will increase costs for many business that currently benefit from Triad avoidance. An innovative way for these businesses to reduce future electricity costs is to invest in on-site generation and Intelligent Buildings solutions. EIC can help with this.

 

Next Steps

As the Triad dates have been confirmed for the 2018/19 season we are now able to calculate your Transmission costs for the next year. This forms part of our 360 Strategic Review which is the ideal first step to creating a Strategic Energy Solution for your business. It is key to unearthing hidden savings potential within your business. We’re offering businesses this insight for FREE. Claim yours here https://hubs.ly/H0gG7j20

 

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Our IoT-enabled Intelligent Buildings solution brings together the required technologies to integrate your critical energy systems with a single, remotely-managed platform. This means you can manage your buildings in real time, reacting to Triad alerts, saving valuable time, money, and hassle. Find out more here https://hubs.ly/H0gYtTJ0

UK and Europe strengthen electricity links against backdrop of Brexit uncertainty

The UK continues to press ahead with plans to significantly increase its Interconnector links with Continental Europe.

Negotiations over the UK’s exit from the European Union, currently scheduled for 29 March, have been turbulent to say the least, with the Prime Minister’s Brexit deal twice rejected by the House of Commons. However, this is having no real impact on energy infrastructure, with new developments strengthening electricity links across the Channel. More information on the impact of Brexit on the energy industry can be found here.

The first electricity link connecting Britain with Belgium became operational on 31 January 2019. The 1GW power link had been under construction since 2016, with funding provided by a joint venture between Britain’s National Grid and Belgian system operator Elia.

The Government wants to see all the current planned projects through to operation, the majority of which will not be completed until after the UK has left the EU. Business Secretary, Greg Clark had indicated he was keen for the UK to remain in the EU’s Internal Energy Market, although the final decision will depend on the conditions of any final withdrawal agreement.

 

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Following on from the Belgium link, two more links with France are under construction – ElecLink and IFA2 – with both scheduled to be operational by 2020. A North Sea Link with Norway is also progressing, expected to be fully commissioned in 2021.

As a consequence, over the next three years, Interconnector capacity between the UK and Europe is expected to more than double to over 8GW.

This will provide the British power market with access to greater supplies and improved flexibility in meeting peak demand. Tight surplus power margins triggered sharp spikes in Day-ahead power prices last winter, particularly during the Beast from the East cold snap. The threat of cold, windless days will remain a problem for the UK going forward. The incentive for investment in increased interconnection for the UK is clear.

 

Interconnectors

The UK now operates five interconnector links, including the Nemo Link. Three are with mainland Europe via France, Belgium and the Netherlands, and two are with Ireland. Total capacity across the links is now 5GW, with the completion of Nemo. A further 3.4GW of interconnector capacity is currently under construction.

 

UK links target France and Ireland

In addition to those under construction, a further four additional interconnectors with France are in the pipeline. A new 1.4GW FAB cable to Devon was granted planning approval earlier last year. The 2GW AQUIND Interconnector, planned for Portsmouth, received approval from energy regulator Ofgem in September 2017. Further connections include two 1.4GW projects, the GridLink Interconnector in Kent and the Channel Cable. Both are hoping to be online by 2022.

Developers are also looking to take advantage of high renewable availability in Ireland. Utilising the short distance between Wales and the Republic of Ireland, four interconnectors are planned across the Irish Sea. The GreenConnect, Greenlink and Greenwire North and South developments could add 3.5GW of transmission capacity between Britain and Ireland. Ireland is also planning its own direct link with France, but the Celtic Interconnector is only in the early planning stages.

 

Scandinavian connections

The UK also has early plans to tap into the Scandinavian energy market, hoping to take advantage of high levels of installed renewable capacity as well as hydropower reserves in the region. Two interconnector links are in planning with Norway. These will run to Peterhead in Northeast Scotland and Blyth in northern England – both with a capacity of 1.4GW.

A further 1.4GW Viking Link is in planning that will connect the UK with Denmark. Just last week the UK Government gave final approval of the project, which is scheduled to come online in 2023. Developer National Grid Viking Link Limited (NGVL) has explicitly stressed that the UK’s decision to leave the European Union “does not influence the plans to build and operate Viking Link between the UK and Denmark.”

An ambitious 1,000km IceLink interconnector is also in planning and will connect Scotland with Iceland. However, the €3.5bn project is only at the concept stage and it is expected to be at least ten years until this link could be operational.