Climate Emergencies and Net Zero – what you need to know

Global scientific data supports action

The action follows a highly critical 33 page report publicised in 2018 by the Intergovernmental Panel on Climate Change (IPCC). The IPCC is the United Nations body for assessing the science related to climate change.

The report focused on the impact of limiting global warming to 1.5°C. Limiting warming to 1.5°C rather than 2°C significantly reduces the climate change risks according to Professor Jim Skea, who co-chairs the IPCC.

What’s alarming is the scale of the challenge ahead of us to ensure we achieve these targets and do not allow the situation to escalate further.

Five steps to achieving the 1.5°C have been announced:

  1. Global emissions of CO2 need to decline by 45% from 2010 levels by 2030
  2. Renewables are estimated to provide up to 85% of global electricity by 2050
  3. Coal is expected to reduce to close to zero
  4. Up to seven million sq km of land will be needed for energy crops (a bit less than the size of Australia)
  5. Global net zero emissions by 2050.

Paris Agreement

The Paris Agreement brings together nations towards a common cause to undertake ambitious efforts to combat climate change. It was originally signed by 196 countries back in 2016.

In line with the IPCC report its core aim is to keep the global temperature increase this century well below 2°C above pre-industrial levels. In particular, to pursue efforts to limit the temperature increase even further to 1.5°C.

2019 – a watershed year for climate change?

Together with the impact of Greta Thunberg – the 16 year old Swedish activist – there have been a number of key factors driving the climate change movement this year. At Glastonbury festival in June 2019, 2,000 festival goers joined protestors to stage a procession across the site.

At the United Nations Climate Action Summit in late September you may have missed the news that Russia, the world’s fourth largest polluter will finally join the agreement. This announcement was overshadowed by the stirring “You have stolen my dreams” headlines surrounding Greta Thunberg’s appearance. Hailed as “the voice of the planet” she’s already been nominated for the Nobel Peace Prize.

Despite the raised awareness there are real fears that most of the world’s biggest firms are ‘unlikely’ to meet the targets set. Only a fifth of companies remain on track according to fresh analysis by investment data provider Arabesque S-Ray. Of 3,000 listed business only 18% have disclosed their plans.

UK reaction

In reaction to the IPCC report, UN Paris Agreement and other related research findings and movements, the UK public sector is taking positive, proactive steps to mitigate climate change risks.

Councillor Carla Danyer led the charge in Bristol by first declaring a climate emergency and this has sparked a wave of similar responses.

In June 2019, the UK became the first major economy to pass a net zero emissions law. The new target will require the UK to bring all greenhouse gas emissions to net zero by 2050. Net zero means any emissions would be balanced by schemes to offset an equivalent amount of greenhouse gases from the atmosphere, such as planting trees or using technology like carbon capture and storage. Other countries setting similar targets include Ireland, Denmark, Sweden and France as well as the US state of California.

Many UK councils, NHS Trusts and universities have publically declared their long term targets. Some aiming for speedier action by declaring net zero 2030 targets. These include Ipswich Borough, Vale of Glamorgan and Telford & Wrekin councils.

Unsurprisingly, Bristol University is one of the leading educational facilities leading the way. To date they’ve cut carbon emissions by 27% and are well on their way to achieving their target to become carbon neutral by 2030. The University of Cambridge, along with others, has set a net zero target of 2038 and has announced it is adopting science-based targets. On one website – climateemergency.uk – 228 councils are listed as having signed up to the targets.

In Boris Johnson’s first speech as Prime Minister, he affirmed the UKs commitment to a net zero future. Johnson proclaimed “Our Kingdom in 2050… will no longer make any contribution whatsoever to the destruction of our precious planet brought about by carbon emissions,” he said. “Because we will have led the world in delivering that net zero target.”

Steps towards a better future

According to the Centre for Alternative Technology (CATs) Zero Carbon Britain research a modern, zero emissions society is possible using technology available today.

Below we’ve outlined some key initiatives that can help the UK achieve its net zero ambitions:

  • Businesses implementing science-based targets.
  • Improving built environment efficiencies. Upgrading old buildings and ensuring new buildings must meet higher energy efficiency standards.
  • A shift to electric vehicles and the continued battery storage revolution.
  • Decentralised energy. Home and local energy generation.
  • Shift to renewable energy sources.
  • New policy.

The Aldersgate Group issued a green policy manifesto to Boris Johnson on 1 August 2019. They are a politically impartial, multi-stakeholder alliance championing a competitive and environmentally sustainable economy. Members of the group include Friends of the Earth, BT, M&S, Tesco, National Grid and Sky. Their green manifesto focuses on 4 key areas for the government to take decisive action and provide greater policy detail:

  • Delivering a Clean Growth Strategy Plus (CGS+) that matches the ambition of the net zero target. This should consist of a targeted update to the existing Clean Growth Strategy to increase ambition where required (for example on zero emission vehicle roll-out). Plus it should incorporate concrete policies that accelerate private sector investment to decarbonise priority sectors. These include surface transport, buildings and support the competitiveness of industry during this transition.
  • Passing an ambitious Environment Bill that safeguards environmental protections currently enshrined in EU law. They believe it must set ambitious and legally binding targets for environmental improvements in line with the vision of the 25 Year Environment Plan.
  • Implementing the Resources and Waste Strategy, through the introduction of detailed regulatory measures and fiscal incentives that drive greater resource efficiency and cut waste across the economy.
  • Building on the Green Finance Strategy, to rapidly grow private capital flows into the green infrastructure required to deliver the UK’s net zero target and the objectives set out in the 25 Year Environment Plan.

Our view

At EIC we believe new government policy is one of the most important steps needed to turn sentiment into action. Legislation relating to major energy users such as ESOS and SECR are steps in the right direction but they aren’t enough. Without doubt more effective policy is needed, to not only ensure energy and carbon is measured, but also that carbon reduction strategies are developed and implemented across the UK. Too often business cases for energy and carbon reduction are created and filed, never to be signed off.

The end of CRC

The final reporting period for the Carbon Reduction Commitment Scheme (CRC) concluded in March this year. Qualifying companies now only have to manage the final elements of the scheme: ensuring they have purchased and surrendered sufficient allowances to finalise Phase 2 reporting.

The CRC scheme ran for eight years, from April 2010 to March 2019. It covered approximately 10% of the UK’s carbon emissions, and raised roughly £790 million annually for the exchequer.

Qualifying businesses

Qualification criteria for CRC Phase 2 was determined as organisations with at least one half-hourly meter using 6,000 megawatt hours or more of qualifying electricity. This was a simpler method of working out relevant organisations and was implemented following Phase 1 feedback that the system was too complex. The seemingly sensible criteria did a good job of identifying significant energy consumers with a test that was simple.

An issue arose however with qualification being considered only in the period April 2012 to March 2013, and then lasting for all subsequent years in the phase. As time went on, there was an increase in companies who qualified, but had subsequently sold off the (usually industrial) sites that made them qualify for the scheme. This left comparatively low energy users stuck in a scheme for which they were no longer suitable. The qualification criteria became less effective over time. We learnt that rolling qualification criteria for schemes helps to avoid this problem and keep qualifying members relevant.

The impact of ‘greening the grid’

The CRC scheme also changed significantly due to the “greening of the grid”. The government’s electricity conversion factors, which denote the amount of carbon dioxide equivalent emissions associated with consuming a fixed amount of electricity, fell approximately 15% year on year over the last three years of the scheme.

This meant that in three years the number of allowances required to cover a fixed amount of electricity, halved. Some members of the scheme were caught out by this, and held a large number of prepaid allowances which were no longer needed due to the drop in conversion factors that was not forecast. This also had a big impact on the total tax revenue generated by CRC, and if the scheme were to continue, we would expect this to be addressed in a review. We learnt that if part of a carbon scheme’s purpose is to raise tax, then there are factors that can unexpectedly influence this.

The future of compliance

Now the CRC scheme is closed, we see a new future opening for carbon compliance. The tax-raising component of CRC has been incorporated into the Climate Change Levy as an increased flat rate across business energy bills in the UK for firms who pay 20% VAT. This is charged per kWh of energy, and so tax revenues are easier to forecast and less likely to change. However, this has shifted the tax burden initially placed on high emitters to being evenly spread across a wider group of energy bills.

The reporting side of CRC has been followed by the new Streamlined Energy and Carbon Reporting (SECR) scheme. This has a larger footprint of approximately 11,000 qualifying firms, and the new qualifying criteria is attached to accounting standards which is both simple and applicable year on year. We welcome the increased attention on emissions that will be generated by the SECR scheme.

Talk to the EIC team

EIC can offer a full review of your organisation to assess your legal obligations and compliance status. We offer ESOS, SECR, Air Conditioning Inspections, Display Energy Certificates and much more, see our full suite of services here. We’ll provide you with a Compliance Report that will summarise our findings, explain the legislation, and outline your next steps.

Our in-house team includes qualified ESOS Lead Assessors and ISO 50001 Lead Auditors, as well as members of the Chartered Institution of Building Service Engineers (CIBSE), the Register of Professional Energy Consultants (RPEC), and the Energy Institute. Call us on 01527 511 757 or contact us here.

CO2 limits amendments to Capacity Market

Importantly, the regulation has introduced new requirements for capacity mechanisms regarding CO2 emissions limits.

The new requirements

Any generation capacity that started commercial production from 4 July 2019 that emits more than 550g of CO2 emissions per kWh will not be eligible to receive payments or commitments for future payments under a capacity mechanism.

In addition, from 1 July 2025, generation capacity will be ineligible for payments and commitments for future payments under capacity mechanisms if it;

  • began commercial production before 4 July 2019 and emits;
  • more than 550g of CO2 emissions per kWh and
  • more than 350kg CO2 of fossil fuel origin on average per year per installed kWe.

Member States of the EU will be required to adapt their capacity mechanisms to comply with the new rules by 31 December 2019.

What will be affected?

The emissions limits are expected to affect coal, diesel and potentially older inefficient gas generation. The changes will also prevent existing diesel and other generating components that do not meet emissions limits from being utilised as part of a DSR (Demand Side Response) CMU (Capacity Market Unit).

The Government will be consulting on the following points:

  • Whether emissions limits for existing generation should take effect on 1 July 2025, or 1 October 2024.
  • What length of agreements should be awarded in the upcoming T-3 and T-4 auctions to refurbishing fossil fuel generation that will not meet the emissions limits.
  • How best to deal with false or inaccurate Fossil Fuel Emissions Declarations and the recovery of capacity payments in such cases.

The consultation will run from 22 July 2019 until 6 September 2019.

Ongoing Capacity Market issues

The Capacity Market continues to be under suspension, following the ruling from the European Court of Justice in November 2018. The investigation by the European Commission is expected to conclude by the end of the year. Until a final decision is reached, National Grid are running the scheme as normal, short of making payments, to ensure that capacity providers may be eligible for deferred payments after the standstill period.

In the short-term the Capacity Market charge will still be levied on customer’s bills, currently accounting for 0.3p/kWh, approximately 2.5% of a bill. This means that consumers will likely see little immediate change.

Stay informed with EIC Insights

Our Market Intelligence team keep a close eye on the energy markets and industry updates. For the most-timely updates you can find us on Twitter and LinkedIn. Follow us today.

Visit our web page to find out more about EIC Market Intelligence and how we keep our clients informed at a frequency to suit them.

Net Zero UK

The action will require the UK to reduce net greenhouse gas emissions to nothing over the next 30 years. This is a more ambitious target than the previous, which was at least an 80% reduction from 1990 levels.

The decision follows the Net Zero report, by the Committee on Climate Change (CCC), which was commissioned by the government to reassess the UK’s long-term emissions targets. The report recommended the 2050 net zero target for the UK, while issuing a 2045 target for Scotland and a 95% reduction in greenhouse gases by 2050 for Wales.

Representatives of the Scottish and Welsh governments have already announced intentions for the nations to aim for these targets, with the Welsh government aiming to go further than the CCC advice; targeting net zero emissions no later than 2050.

Is this achievable?

The report by the Committee on Climate Change states that the net zero target is possible with known technologies, alongside behavioral and societal changes in people’s lives. The organisation has forecast that that the target is also within the expected economic cost that Parliament accepted when legislating the previous 2050 target under the Paris Agreement.

The report does come with the caveat that net zero is only possible if clear, sensible and well-designed policies to enable reductions in emissions are introduced across the country in a strict timeline. The CCC highlights that current policy would not meet even the previous target.

STAY INFORMED WITH EIC INSIGHTS

Our Market Intelligence team keep a close eye on the energy markets and industry updates. For the most timely updates you can find us on Twitter and LinkedIn Follow us today.

Visit our webpage to find out more about EIC Market Intelligence and how we keep our clients informed at a frequency to suit them.

Increase in carbon costs likely as EU cut supply of allowances

The European Commission has published the annual surplus indicator for the EU Emissions Trading System (ETS) Market Stability Reserve. As long as the surplus exceeds the level set in the legislation, a total of 397 million allowances will be placed in the reserve, 24% of the total permits currently in the market. This is an increase on the 2018 publication, which saw almost 265 million allowances placed into the reserve in January 2019. The allowances will be placed into the reserve in the period of September 2019 to August 2020.

 

Purpose of the Market Stability Reserve

The Market Stability Reserve (MSR) was introduced to address the large oversupply of carbon allowances that built up following the 2008 global financial crisis. This saw carbon prices reach all-time lows for an extended period of time and by the end of 2016, the European Emissions Trading Scheme had an oversupply of 1.7bn tonnes worth of EUAs. The oversaturation of allowances provided a weaker incentive to reduce emissions.

The MSR will see 900 million allowances, which were removed between 2014 and 2016, transferred to the Reserve, rather than be auctioned in 2019-20. After this, unallocated allowances will also be transferred to the reserve.

Each year, the Commission will continue to publish the total number of allowances in circulation by 15 May. This will allow them to examine whether more allowances should be placed into the reserve or whether allowances should instead be released. This will allow the Commission to better regulate the allowances available.

 

An impact to carbon prices

The restriction of carbon allowances as part of the Market Stability Reserve has been the cause of substantial price increases since 2017. The cost of carbon is currently at €26/tCO2e, having doubled in value year-on-year.

The impact of further allowances placed in the reserve is likely to see continued price rises, as the MSR continues to restrict the availability of supply to the market. The introduction of the reserve caused prices to rise from €4 to over €25 in eighteen months. With the volume of allowances into the EU ETS system remaining tightly restricted, there is the likelihood of further price rises, notably towards the all-time high of €30/tCO2e, last seen in 2008, shortly after the EU ETS was created.

A further increase in carbon prices, particularly if prices were to break to new highs at over €30/tCO2e, would provide a strong bullish signal to the wider energy mix, and likely result in higher wholesale gas and power prices.

 

Stay Informed with EIC Insights

Our Market Intelligence team keep a close eye on the energy markets and industry updates. For the most timely updates you can find us on Twitter and LinkedIn Follow us today.

Visit our webpage to find out more about EIC Market Intelligence and how we keep our clients informed at a frequency to suit them.

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.

Click here to learn more about the Streamlined Energy and Carbon Reporting scheme.

Energy Policy Dates for 2019

As we look ahead to 2019, we’ve outlined key energy industry changes and dates to take action by.

EU ETS – Market Stability Reserve (MSR)

1 January – MSR Implementation

The European Commission is introducing a solution to the oversupply of allowances in the carbon market, which will take effect in January.

EU carbon allowances, or European Allowances (EUAs) serve as the unit of compliance under the European Emissions Trading Scheme (EU ETS). In response to a build-up of these allowances, following the 2008 global financial crisis, the European Commission has introduced a long-term solution known as the Market Stability Reserve (MSR). With Brexit looming, there’s uncertainty as to whether these changes will affect the UK.

 

Energy Price Cap

1 January – Price Cap implementation

Price protection for 11 million customers on poor value default tariffs will come into force on 1 January 2019. Ofgem has set the final level of the price cap at £1,136 per year for a typical dual fuel customer paying by direct debit.

When the price cap comes into force suppliers will have to cut the price of their default tariffs, including standard variable tariffs, to the level of or below the cap, forcing them to scrap excess charges. The cap will save customers who use a typical amount of gas and electricity around £76 per year on average, with customers on the most expensive tariffs saving about £120. In total, it is estimated that the price cap will save consumers in Great Britain around £1 billion. Read more here.

 

Ofgem’s Targeted Charging Review (TCR) – the end of Triad season?

4 February – Consultation conclusion

Ofgem has launched a consultation, due to conclude on 4 February 2019, into how the costs of transporting electricity to homes, public organisations, and businesses are recovered. Proposed changes could remove the incentive for Triad avoidance.

Costs for transporting electricity are currently recouped through two types of charges:

  • Forward-looking charges, which send signals to how costs will change with network usage
  • Residual charges, which recover the remainder of the costs

In order to ensure that these costs are shared fairly amongst all users of the electricity network, Ofgem are undertaking a review of the residual network charges, as well as some of the remaining Embedded Benefits, through the Targeted Charging Review (TCR). Ofgem are exploring the removal of the Embedded Benefit relating to charging suppliers for balancing services on the basis of gross demand at the relevant grid supply point. This is important as it would eliminate the incentive of Triad avoidance.

 

Brexit

29 March – Scheduled date to leave the EU

Whilst not a specific energy policy announcement, the UK’s departure from the EU is a significant event that has raised a lot of questions concerning UK energy security.

We put together a Q&A on how Brexit may impact the UK energy industry and climate change targets. Read more here.

 

Closure of the Feed-in Tariff (FiT) scheme

31 March – Scheme Closes

The Government has confirmed plans to remove the export tariff for solar power, which currently provides owners of solar PV panels revenue for excess energy that they generate. This will coincide with the closure of the Feed-in Tariff (FiT) scheme.

The FiT scheme was introduced in April 2010 in order to incentivise the development of small scale renewable generation from decentralised energy solutions such as solar photovoltaics (PV), wind, hydro, anaerobic digestion and micro Combined Heat and Power (CHP). Generators were paid a fixed rate determined by the Government, which varied by technology and scale.

The scheme will close in full to new applications from 31 March 2019, subject to the time-limited extensions and grace period.

 

Streamlined Energy and Carbon Reporting (SECR)

1 April – SECR implementation

Streamlined Energy and Carbon Reporting (SECR) is on the way, due to come in to effect from 1 April 2019. The introduction of this new carbon compliance scheme aims to reduce some of the administrative burden of overlapping schemes and improve the visibility of energy and carbon emissions when the CRC scheme ends.

EIC can help you achieve compliance. Read more about Streamlined Energy and Carbon Reporting (SECR) by clicking here.

 

UK Capacity Market

Early 2019

The UK Capacity Market is currently undergoing a temporary suspension, issued by the European Court of Justice (ECJ), on the back of a legal challenge that the auction was biased towards fossil fuel generators.

The ECJ’s decision means that payments made under the Capacity Market (CM) scheme will be frozen until the UK Government can obtain permission from the European Commission to continue. In addition, the UK will not be allowed to conduct any further CM auctions for energy firms to bid on new contracts.

The UK government has since iterated that it hopes to start the Capacity Market as soon as possible and intends to run a T-1 top-up auction next summer, for delivery in winter. This is dependent on the success of a formal investigation to be undertaken by the European Commission early in the New Year.

 

Spring Statement and Autumn Budget

The UK Government’s biannual financial updates are always worth looking out for.

The Spring Statement will be delivered in March and the more substantial Autumn Budget is scheduled for October. The 2018 budget had a very heavy focus on Brexit, with very little to say concerning energy policy. It is likely this will be the case for the Spring Statement and potentially going forward.

 

Energy Savings Opportunity Scheme (ESOS)

5 December – ESOS Phase 2 compliance deadline

ESOS provides a real chance to improve the energy efficiency of your business, on a continual basis, to make significant cost savings.

In Phase 1 of ESOS we identified 2,829 individual energy efficiency opportunities, equivalent to 461GWh or £43.9m of annual savings across 1,148 individual audits. Our team also helped over 300 ESOS Phase 1 clients avoid combined maximum penalties of over £48million.

With EIC you can achieve timely compliance and make the most of any recommendations identified in your ESOS report.

 

Stay informed with EIC insights

Our Market Intelligence team keep a close eye on the energy markets and industry updates. For the most timely updates you can find us on Twitter and LinkedIn Follow us today.

Visit our website to find out more about EIC Market Intelligence and how we keep our clients informed at a frequency to suit them.

EU temporarily suspend UK carbon permit processes

EU temporarily suspend UK carbon permit processes

The European Commission has implemented a “no-deal” Contingency Action Plan across specific sectors to help mitigate the continued uncertainty in the UK surrounding the ratification of the Withdrawal Agreement.

The main talking point, regarding energy policy, is the Commission’s plans for the UK’s access to the EU Emissions Trading Scheme (EU ETS).

EU carbon allowances, or European Allowances (EUAs) serve as the unit of compliance under the EU ETS. EUAs are auctioned for use by energy-intensive industries that fall under the scheme, namely power generators, oil refiners, and steel companies, entitling them to emit one tonne of CO2.

How this affects the EU ETS in the UK

The Commission has adopted a number of actions in the area of EU climate legislation to “ensure that a “no-deal” scenario does not affect the smooth functioning and the environmental integrity of the Emissions Trading System.”

This involves a decision to temporarily suspend the free allocation of emissions allowances, auctioning, and the exchange of international credits for the UK effective from 1 January 2019.

The Commission has also elected to allow an appropriate annual quota allocation to UK companies for accessing the EU27 market, until 31 December 2020. This will be supplemented through regulation to ensure that the reporting by companies differentiates between the EU market and the UK market to allow a correct allocation of quotas in the future.

The full Contingency Action Plan can be read here.

Stay informed with EIC insights

Our Market Intelligence team keep a close eye on the energy markets and industry updates. For the most timely updates you can find us on Twitter and LinkedIn Follow us today.

Visit our website to find out more about EIC Market Intelligence and how we keep our clients informed at a frequency to suit them.

ESOS Phase 2 – stay ahead of the deadline

The compliance date for ESOS Phase 2 is fast approaching. Make sure you’re on track to meet the 5 December 2019 deadline.

With under a year to ensure your compliance with ESOS Phase 2, it’s critical to make sure you’re ready to complete all compliance activity within the next 12 months.

The qualification date is 31 December 2018. This means that if you know your business will fit the ESOS criteria, you can start some compliance activities now.

ESOS applies to large organisations, classified as those with:

  • More than 250 employees or;
  • A turnover of more than €50,000,000 and an annual balance sheet total of more than €43,000,000 or;
  • Part of a corporate group containing a large enterprise.

ESOS compliance can help you get a head start with upcoming Streamlined Energy and Carbon Reporting (SECR) compliance – find out more here.

 

Three reasons to comply with ESOS Phase 2

1 – avoid paying over the odds

Many organisations delayed the start of their compliance journey until close to the Phase 1 deadline. This led to a squeeze in service provision, leading many suppliers to increase the cost of their services. Environment Agency (EA) data shows a significant spike in compliance notifications around one month prior to the 5 December 2015 deadline. What’s more, 33% of all who complied by July 2016, did so in the final week of Phase 1. A further 30% of notifications were logged by the end of January 2016.

Had demand for ESOS compliance support been smoothed over the course of 2015, costs may have been more reasonable as the deadline approached.

The lesson here is not to wait until the final months of 2019 to get started with Phase 2.

 

2 – ESOS Lead Assessor numbers are limited

There were almost 950 ESOS Lead Assessors accredited across 14 approved registers by the Phase 1 deadline. BEIS suggests there were enough Lead Assessors to help organisations reach compliance. By 5 December 2015 there were 7.3 qualifying undertakings per Lead Assessor. This is based on an estimated 6,933 organisations that met the ESOS qualification criteria.

However, this doesn’t take into account the Lead Assessors that become accredited purely to certify their own organisations alone. So, in fact, the 900+ Lead Assessors would’ve been spread far more thinly. There’s also a broad scope of the size of organisations (by employee size) and number of sites per qualifying business, meaning not every organisation would have been as easy, or as quick, to assess as another.

Our advice would be to seek guidance from compliance partners you already know who have a proven track record with Phase 1 compliance.

 

3 – Acting now enables you to seize your energy saving opportunity

Delaying compliance for as long as possible means by the time you comply you’ll simply be ticking a box and more than likely paying an unreasonably high cost.

Acting now allows your organisation to really invest in the compliance process by ensuring you have strong and accurate reporting of your energy consumption data. Accurate data is the start of being able to visualise and truly understand when, where, and how you use energy and, more importantly, how you can improve your efficiency to increase savings. EIC can assist you with implementing any energy saving measures identified as part of your ESOS recommendations report. We’ll also ensure these measures work in harmony with each other as part of a bespoke, joined-up Strategic Energy Solution.

 

Why make EIC your trusted compliance partner?

Whether it’s ESOS, SECR, or CCAs, EIC will work with you to reach compliance deadlines and targets. In Phase 1 of ESOS our team identified 2,829 individual energy efficiency opportunities, equivalent to 461GWh or £43.9m of annual savings across 1,148 individual audits. We also helped over 300 ESOS Phase 1 clients avoid combined penalties of over £48m, based on maximum fines.

With under a year until the ESOS Phase 2 deadline, we’re urging you to make a start with compliance. To find out more about how we can help you comply, call us on 01527 511 757 or email esos@eic.co.uk

Update on EU ETS

The Government has directed the Environment Agency (EA) to proceed with preparations for the next phase of emissions trading which will operate from 2021 – 2030. Due to ongoing Brexit negotiations the full detail of the future scheme is not yet known. However, one thing we do know is that NIMs will take effect from January.

In preparation for future reporting, the EA has notified participants in EU Emissions Trading Scheme (ETS) Phase 3 that the data collection exercise, National Implementation Measures (NIMs), will take place between January 2019 and September 2019.

 

What is the EU ETS?

The European Union Emissions Trading Scheme started in 2005 and is the world’s largest carbon-trading scheme. It was introduced to help the EU meet its targets under the Kyoto Protocol which stipulates an 8% reduction in greenhouse gas emissions from 1990 levels. Organisations that meet the qualification criteria – typically large combustion sector and manufacturing processes – are obligated to take part.

The scheme works on a ‘cap and trade’ basis, so there is a ‘cap’ or limit set on the total greenhouse gas emissions allowed by all participants. This cap is converted into tradable emission allowances and provides an incentive for installations to reduce their carbon emissions, giving them the opportunity to sell their surplus allowances.

Participants in the carbon market are allocated traded emissions allowances via a mixture of free allocation and auctions. For each one allowance, the holder has the right to emit one tonne of CO2 (or its equivalent). Those covered by the EU ETS must monitor and report their emissions each year and surrender enough allowances to cover their annual emissions.

 

What are NIMs?

There is a requirement to benchmark participants in the ETS to ensure a fair and equitable distribution of free carbon allowances. The NIMs is a method of benchmarking the emissions of participating installations.

The NIMs data collection requires gathering energy or production data over four years (2014 – 2018), which must be collated, verified by an approved body, and submitted by 31 May 2019.

 

EIC is here to help

We’re experienced in managing EU ETS compliance across a broad range of sites and industries. We’ve also worked with the Environment Agency in the delivery of legislative compliance across all carbon schemes and systems, including ESOS.

We can assist with your EU ETS and NIMs requirements; we’ll review the data held on record and complete the necessary submission to your appointed verifier and the verified data to the Environment Agency. We would also deal with any correspondence between the verifier, Environment Agency, and your organisation.

An insight into SECR

SECR will require all quoted companies, large UK incorporated unquoted companies, and limited liability partnerships (LLPs) to report their energy use and carbon emissions relating to gas, electricity, and transport, and apply an intensity metric, through their annual Directors’ reports.

 

Summary of the Government’s proposed SECR framework

From April next year, large organisations in the UK will need to comply with the SECR regulations. The new scheme is part of the Government’s reform package.

Its aim is to reduce some of the administrative burden of overlapping carbon schemes and improve visibility of energy and carbon emissions. As such, it will be introduced to coincide with the end of the current Carbon Reduction Commitment (CRC) Energy Efficiency Scheme.

SECR will build on the existing mandatory reporting of greenhouse gas emissions by UK quoted companies and the Energy Savings Opportunity Scheme (ESOS).

 

Who needs to comply with SECR?

SECR qualification will follow the Companies Act 2006 definition of a ‘large organisation’, where two or more of the following criteria apply to a company within a financial year:

  • More than 250 employees.
  • Annual turnover greater than £36m.
  • Annual balance sheet total greater than £18m.

There is no exemption for involvement for energy used in other schemes – e.g. Climate Change Agreements (CCAs) or EU Emissions Trading Scheme (ETS).

 

What are the reporting requirements?

From 1 April 2019, affected organisations will be required to:

  • Make a public disclosure within their annual directors’ report of energy use and carbon emissions.
  • Report using a relative intensity metric e.g. tCO2/number of employees.
  • Provide a narrative on energy efficiency actions taken during the reporting period.

Reporting will align with an organisation’s financial reporting year.

 

Is anyone exempt from SECR?

Yes – those exempt from complying with SECR include:

  • Public sector organisations.
  • Organisations consuming less than 40,000kWh in the 12-month period are not required to disclose SECR information.
  • Unquoted companies where it would not be practical to obtain some or all of the SECR information.
  • Disclosure of information which Directors think would be seriously prejudicial to interests of the company.

 

There seem to be similarities to ESOS – can ESOS compliance help with SECR?

Yes. Though ESOS and SECR are separate schemes, and will continue as such, the information from your ESOS compliance can be used to support SECR reporting.

 

Where do I start with compliance?

The detailed guidance for SECR will soon be published. EIC can assist with compliance as well as providing bespoke reporting to ensure that you have real visibility of your energy and carbon emissions both at organisational and site level.

If you would like to know more about SECR, what it means for your business visit our Streamlined Energy and Carbon Reporting (SECR) service page.

What impact will Brexit have on UK climate change targets?

The energy sector in the UK had already seen significant changes with the Energy Act 2011 and various proposals for reform of the electricity market. The potential impacts of Brexit on the UK and global economy could be far-reaching. However, the direct impact on the energy industry is likely to be more muted.

 

How will Brexit impact on the carbon market and the EU ETS?

The Government has published plans for the implementation of a UK carbon tax in the case of a ‘no-deal’ Brexit.

Under a ‘no-deal’ scenario, the UK would be excluded from participating in the EU Emissions Trading Scheme (ETS). This would mean current participants in the EU ETS who are UK operators of installations will no longer take part in the system.

In this instance, the UK Government will initially meet its existing carbon pricing commitments through the tax system. A carbon price would be applied across the UK, with the inclusion of Northern Ireland, starting at £16/tCO2, marginally less than the current EU ETS price, maintaining the level of carbon pricing across the UK economy post-Brexit.

The tax would be applied to the industrial installations and power plants currently participating in the EU ETS from 1 April 2019.

The House of Commons Business, Energy and Industrial Strategy (BEIS) Committee has strongly recommended remaining in the EU ETS at least until the end of Phase III in 2020.

The UK’s 5th carbon budget, adopted in 2016, assumes continued participation in the EU ETS, and will need to be altered if the UK leaves the EU ETS.

 

Will Brexit affect the UK’s climate change targets?

The UK’s climate change targets are expected to continue unaffected by whatever Brexit deal is reached. The Climate Change Act 2008 established that such goals are undertaken on a national level.

However, there are several international issues in this area which will need to be settled. The UK’s emissions reduction target forms part of the EU target under the Paris Agreement and this will need to be withdrawn. The UK would also need to submit its own Nationally Determined Contribution under the United Nations Framework Convention on Climate Change (UNFCCC) processes.

 

What about renewable energy?

After Brexit, the UK will no longer be obligated by renewable energy targets as part of the EU Renewable Energy Directive. Additional freedom from State Aid restrictions has the potential to allow the Government to shape renewable energy support schemes.

The development of large-scale projects may be impacted by the availability of funding from EU institutions such as the European Investment Bank (EIB). However, renewable and low-carbon energy will remain a focal point of UK energy policy post-Brexit, with national and international decarbonisation obligations unaffected by their relationship with the EU.

As part of the European Union (Withdrawal) Act 2018, EU legislation will be initially transposed into UK law from 29 March 2019. For some elements of the EU law, the UK will need to reach an agreement with the EU in order to maintain the status quo.

 

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