TCFD: 4 key points from the recommendations

The Task Force on Climate-related Disclosures (TCFD) was established in 2015 by the international Financial Stability Board. It is based on the growing consensus that climate change has immediate effects on economic decisions. Investors are growing more aware of climate-related risks and putting more faith in organisations that are planning ahead.

In a recent series of environmental measures from the government, Chancellor Rishi Sunak announced plans to make alignment with the TCFD guidelines mandatory. This will apply to most sectors of the economy by 2025 including listed companies, banks, and large private businesses. This part of the green recovery plan aims to bolster the UK’s position as a global leader for green finance.

“By taking as many equivalence decisions as we can in the absence of clarity from the EU, we’re doing what’s right for the UK and providing firms with certainty and stability.”
– Chancellor Rishi Sunak

Can increased transparency help achieve net zero and a stable green economy? We look at the key points and benefits of the guidelines for the TFCD.

What are climate-related risks?

The Task Force broke down climate-related risks into two major categories:

  • risks related to the transition to a lower-carbon economy, and
  • risks related to the physical impacts of climate change.

Transition risks include shifts in policy and litigation, market, technology and reputation. Organisations are already seeing this impact with climate-related litigation and policy changes rising. Costs of operation, raw materials, and products are all vulnerable to shifts in policy, technology, and markets. And changes in consumer preferences and customer behaviour must also be taken into account.

Physical risks involve the effects of climate change on the natural world. These are broken down into two categories: acute and chronic risk. Acute risk involves extreme weather events such as wildfires or floods. Chronic risk refers to longer-term shifts in climate patterns. These could affect anything from an organisations supply chain to their employees’ safety.

two people working on a white board

What are climate-related opportunities?

In light of the potential risks posed by climate change, the TCFD also recommends several opportunities. These are solutions that can reduce risk and provide organisations with long-term stability.

  • Resource efficiency: Making your buildings and transportation as efficient as possible by integrating intelligent energy management, reducing water usage and consumption, and recycling.
  • Energy source: Implementing the use of clean energy sources through procurement or onsite generation and taking advantage of policy incentives.
  • Products and services: Developing low-emission goods or services and/or innovative climate-related products.
  • Markets: Having access to new markets and assets and use of public-sector incentives.
  • Resilience: Boosting financial and reputational stability by adopting sustainable solutions such as energy efficiency and supporting renewable energy.

What are the recommended disclosures?

There are four recommendations laid out by the task force for disclosures.

  • Governance: Disclosure of the board’s oversight on, and management’s role in, assessing and managing climate-related risks and opportunities.
  • Strategy: Disclosure of the short and long term climate-related risks and opportunities, their impact on the organisation, and the resilience of the strategy in place to manage those risks and opportunities.
  • Risk Management: Disclosure of the organisation’s process for identifying, assessing and managing risks, and how this is integrated into the organisation’s overall risk management.
  • Metrics and Targets: Disclosure of the metrics used to assess risks – Scope 1, Scope 2, and Scope 3 greenhouse gas emissions, the risks they pose, and the targets in place to manage risks and opportunities.

What are the benefits of implementing TCFD?

In the future green economy, disclosures like these will be crucial for a company’s sustainability and resiliency. Implementing TCFDs will help companies to identify and assess the risks posed by climate change. They can then address their structural weaknesses and implement mitigation and adaptation efforts to future-proof their business. Organisations that do this will have a competitive advantage over those that don’t when it comes to future funding and investments.

At EIC we are experienced in helping clients mitigate climate-related risks. Through our unrivalled energy management services and cutting-edge technology, we can help with most of the TCFD’s recommendations. From resource efficiency and clean energy to your carbon compliance, our goal is to simplify your sustainability journey. For more information on future-proofing your organisation, contact us at EIC.

Explaining TM44 Inspections: The what, who, when and why

EIC explores the purpose of TM44 inspections, why your organisation might need one and how EIC can help you get one.

 

What is TM44?

TM44 is the accepted guidance for the UK for judging the efficiency of air-conditioning units. The key role of the guidance is to support inspections to comply with the Energy Performance of Buildings Directive (EPBD). However, they can provide assistance to any building owner or manager desiring further data on the efficiency of their air-conditioning system. The EPBD1 was initiated in 2003 and replaced a decade later by a recast Directive2.

The legislation required that European members devise ‘measures to establish a regular inspection of air-conditioning systems of an effective rated output of more than 12 kW’.

 

Who needs a TM44?

Not all air-conditioning systems are equal; TM44 focuses on those that use refrigerants for cooling, and parts of other cooling methods such as cooled decks/ceiling slabs or those using aquifers for cooling.

The 12kW figure is a good rule of thumb, making any building owner or manager with a system of that scale subject to TM44. It is important to note that this applies to single large-scale units with an output of 12kW and to individual units that together reach or exceed 12kW.

When is a TM44 necessary?

Inspections timings are relevant here since each mandatory inspection must take place within five years of the previous one. According to TM44 guidance, the initial inspection must satisfy the following criteria:

  • Any system that began service on or after 1st January 2008, must have undergone an initial inspection within five years of the date service began.
  • Systems whose output exceeds 250kW must have undergone inspection no later than 4th January 2009.
  • Systems with a service start date prior to 1st January 2008 and whose output exceeds 12kW must have received inspection by 4th January 2011.

From 6 April 2012, all TM44 air-conditioning inspection reports have been required to be lodged on the Ministry of Housing, Communities & Local Government Energy Performance of Buildings Register where a report and certificate are generated. Accredited assessors and members of the public may access this site to view and download their TM44 certificates and reports.

 

Why is TM44 important?

There are several benefits to having a TM44 inspection. Firstly, a company can avoid penalties for non-compliance. These penalties are costly, inviting a £300 fine per offence – meaning either a non-complying building or multiple units inside a single structure whose combined output is more than 12kW, and if an organisation fails to supply a copy of their inspection report within seven days of request by an enforcement authority, they can incur an additional fixed penalty of £200 per building or unit. Enforcement Officers can check at any time whether a building or unit is compliant.

TM44 is an excellent data gathering opportunity about a major source of utility costs, offering insight on how to:

  • Improve efficiency
  • Reduce electricity consumption
  • Decrease operating costs
  • Diminish carbon emissions
  • Reduce maintenance needs
  • Improve controls and settings
  • Identify technical flaws

The report will also highlight opportunities such as:

  • Improvement to operation
  • Improvements to replace less efficient systems
  • Replacement of oversized systems (scale of the system relative to cooling load)

When viewed with these gains in mind, TM44 can be thought of a necessary process that yields significant benefits down the line.

 

Securing your TM44 with EIC

The EIC team were among the first to receive UK accreditation for the delivery of airconditioning inspections and actively follow any legislative changes so they can keep businesses ahead of the game.

The team can also provide Wrap Reports as standard, offering an overview of essential report findings including reference pictures, additional relevant data and a complete asset list of equipment found.

Alongside this extensive experience, clients will receive additional complimentary intelligence in other areas of sustainable improvement. EIC’s expertise in other fields like Energy Contract Procurement and Intelligent Building Management will position organisations to undertake other sustainable development projects seamlessly, with guidance and security.

For a full breakdown of EIC’s compliance services, and how your organisation can acquire TM44 Certification, get in touch with the EIC team here.

 

1(2002/91/EC)

2(2010/31/EU)

3(Statutory instrument 2012 N0 3118)

 

 

Pause for thought: CCA extension consultation closes

Following the closure of the government’s consultation on reforms and an extension to the Climate Change Agreements (CCA) scheme on Thursday, EIC explores the success of the scheme so far and the opportunity that this extension presents to business leaders.

Laying a foundation

During the Spring Budget announcement, Chancellor Sunak made it clear that while the economy would be strained during and after lockdown, its recovery could not come at the expense of UK climate goals.

Little over a month after the budget announcement, the Department for Business, Energy and Industrial Strategy (BEIS) proposed an extension to the Climate Change Agreements (CCA) scheme.

No doubt, this move was designed to engage with businesses that already fit the criteria of the scheme but were unable to join it previously and in doing so allow them to benefit from the reduced CCL cost and the environment to benefit from reduced carbon emissions.

2017 saw the Government aim its sights at a 20% improvement in commercial and industrial energy efficiency by 2030, this goal has informed the consultation with that target being upheld in regards to the extension.

The popularity and effectiveness of the scheme are undeniable, with recent analyses demonstrating that 80-100% of businesses were participating in most eligible sectors.

A consensus of this magnitude inspires hope for the UK’s climate goals, given that, of the UK’s total greenhouse gas emissions, 25% are business-driven. An evaluation for the 2017 Clean Growth Strategy also showed that up to 22m tonnes of CO2 could be saved through investments in energy efficiency technology.

looking through a gate and seeing horsesAn open forum

The BEIS has made clear that facilities that do meet the current criteria would now be able to join the scheme for the first time since its initial closure in October 2018.

The Target Period being proposed, in addition to remaining in line with periods 1-4 of the scheme (running from the 1st January 2021 until 31st December 2022), will be supported by a variation of the certification period. Initially planned to end in March 2023, it would be pushed back to June of the same year to allow participants to gain certification for CCL discounts between April and June 2023. The added certification period, for which facilities will only be certified having met obligations in Target Period 5, will begin on 1 July 2023 and end on 31 March 2025.

The CCA’s closing in 2018 had shut out new entrants to the scheme; however, businesses fitting the eligibility now have an opportunity to recoup up to 92% on electricity and 83% on gas CCL charges.

Applications to the CCA can be long-winded and complex, however, the return on an initial investment of time is huge. Especially considering that an average energy-intensive business the added certification period, for which facilities will only be certified having met obligations in Target Period 5, will begin on 1 July 2023 and end on 31 March 2025.

Based on these figures, the opportunity presented by Sunak and the BEIS has the potential to dramatically change the landscape of the UK energy industry post-COVID-19. Alongside legislation like ESOS, MEES and SECR, the CCA calls for expertise rather than direct action. EIC oversees the entire CCA application process and subsequent management of the service following approval of the application. We will be able to show the fiscal savings based on individual business’s energy consumption and ROI against our typical fees.

EIC offers a comprehensive range of compliance services as well as ancillary strategies that can help improve your carbon profile while reducing utility costs.

 

An update on ESOS Phase 2

The ESOS deadline for Phase 2 was 5 December 2019. Unlike Phase 1, no extra time has been issued to allow for late submissions. Any qualifying organisations who did not complete their assessment and submit a compliance notification by the deadline are at risk of enforcement action. Penalties issued in Phase 1 for compliance failures ranged up to £45,000 with a potential maximum fine of £90,000.

Compliance Notices

ESOS Regulators are currently issuing compliance notices to all UK corporate groups who they believe should have participated but they haven’t yet received a notification of completion from.

If you receive this, you must inform the regulators whether you are;

  • in the process of completing your compliance, or
  • provide evidence you have already submitted your notification, or
  • advise that you do not qualify for ESOS

ESOS submissions

You can find a published list of all businesses who have made a submission via the ESOS notification system as of 1 February 2020 here.

Further evaluation on the effectiveness of energy audits and ESOS can be found here.

ESOS support

If you need urgent support with your Phase 2 compliance, talk to EIC today. Our dedicated team of ESOS Lead Assessors and highly trained Energy Auditors will work hard to help you comply as soon as possible, and support you in any conversations with the Environment Agency.

After ESOS compliance

It’s vital that you don’t let your compliance go to waste. ESOS aims to highlight where companies can make energy improvements, cut wastage and lower costs. Use these opportunities to improve your operations and make significant energy savings. The most common areas for energy savings are lighting, energy management through smarter energy procurement, metering, monitoring and controls, and air conditioning.

SECR

If your business complies with ESOS, it’s highly likely you will need to comply with Streamlined Energy and Carbon Reporting (SECR) too. SECR was introduced in April 2019 as a framework for energy and carbon reporting. Its aim is to reduce some of the administrative burden of overlapping carbon schemes and to improve visibility of energy and carbon emissions for large UK organisations.

SECR can also help businesses on their first steps to meet the UK’s 2050 Net Zero target. 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. They will also need to report any energy efficiency actions they have taken within each financial year. If the coronavirus is likely to cause a delay to your accounts, there is guidance here.

Talk to EIC on 01527 511 757 or email info@eic.co.uk if you need any further advice on ESOS or SECR. We’re here to help.

Consultation to improve MEES

The Department for Business, Energy & Industrial Strategy (BEIS) has published a consultation to seek views on proposed targets for the Minimum Energy Efficiency Standard (MEES). Currently MEES make it unlawful to grant new leases to properties with an Energy Performance Certificate rating of F and G.

The Government’s options

The Government has identified two potential trajectories for strengthening the PRS (Private Rented Sector) Regulations. These aim to unlock the economic opportunities of low carbon growth, and deliver important energy and carbon savings:

  • The Government’s preferred route is that all non-domestic privately rented buildings achieve a Minimum Energy Efficiency Standard of a B rating, by 1 April 2030. This is provided the measure (or package of measures) required to reach an EPC ‘B’ proves cost effective.
  • The alternative option is that all non-domestic privately rented buildings reach a ‘C’ rating by 1 April 2030, if cost effective.

In both cases, the Government recognises that not all buildings will be able to reach the required minimum standard. In this instance the Government proposes that landlords can continue to lease their building (from 2030) providing they can prove that the building has reached the highest EPC band that a cost-effective package of measures can deliver.

The impacts

BEIS estimates that using the ‘B’ rating EPC route, an investment of approximately £5 billion up to 2030 is required. The estimated average payback time would be 4-5 years. Their modelling suggests this will translate to £1 billion in bill savings for business in 2030. This would deliver an overall value of £6.1 billion to the UK economy. The annual benefit to businesses by using this option is projected to be approximately double that of the ‘C’ rating EPC.

Regardless of the option chosen, BEIS proposes that existing exemptions will continue to apply. This means that landlords will be required to carry out upgrades that are cost-effective, with an expected payback on energy savings of seven years or less. If the work cannot meet this criteria then landlords are able to register an exemption, valid for five years.

The proposed timescale

The Government has asked whether a single implementation date of 2030 is appropriate for landlords to meet the determined rating. As an alternative it has been suggested that incremental targets leading up to 2030 could be introduced. This would encourage landlords to improve the EPC rating of their buildings over time.

The consultation is expected to close on 7 January 2020.

Stay informed with EIC insights

Our Market Intelligence team keep a close eye on the energy markets and industry updates. For the timeliest updates you can find us on Twitter and LinkedIn. To find out more about our Minimum Energy Efficiency Standard (MEES) solutions click here.

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.

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 at our Streamlined Energy and Carbon Reporting (SECR) service page.