Wednesday, 22 April 2009

The Carbon Reduction Commitment – A New Role for Environmental Managers

The original version of this article appeared in the April (No. 76) issue of the IEMA journal 'the environmentalist'.

On 12th March the UK Department for Energy and Climate Change released the draft user guide for the Carbon Reduction Commitment (CRC). In this article, we provide an introduction to the CRC and explain what it means for environmental managers.

In a recent newspaper interview, Energy and Climate Change Minister Joan Ruddock asserted that the government had thoroughly announced this impending legislation and that businesses are well aware of their obligations. Based on feedback from Carbon Clear’s ongoing winter and spring workshop series, we are not so sure.

Approximately 20,000 UK firms will have to submit a CRC information disclosure to the Environment Agency by Summer 2010, while roughly 5,000 will have to pay registration fees and participate in the full scheme.

CRC information notices and registration requests are sent to the billing address on record with each company’s electricity provider. As a result, government information on the CRC is now landing on the desk of the facilities manager or the accounts payable department, not with the energy or environment manager.

Despite its innocuous-sounding name, companies should not take the Carbon Reduction Commitment lightly. As with any new regulatory requirement, failure to prepare poses serious financial and reputational risks. At the same time, environmental managers are well-placed to help their companies use the CRC to achieve real emissions reductions, cut costs, and identify new sources of competitive advantage.

The CRC in A Nutshell
The Carbon Reduction Commitment is designed to help the UK Government meet the 80% greenhouse gas reduction target set out in the Climate Change Act. It is a mandatory, auction-based emissions trading scheme targeted at large, non-energy-intensive companies - supermarkets, office blocks, and the like. Every company, charity, and government body with at least one half-hourly electricity meter needs to be aware of the CRC.

Like the EU Emissions Trading Scheme (EU-ETS), the CRC uses market forces and competition to drive corporate carbon reductions at the lowest overall cost (see our article “Emissions Trading, Going Global?” in issue 60 of the environmentalist). In the introductory phase of the CRC (April 2010-March 2013), participants will buy emissions allowances equal to their carbon footprint at a price of £12 per tonne CO2.

But once the CRC enters the “capped” phase in April 2013, government will limit the number of allowances and auction them to the highest bidder. At the end of the recording year, firms that end up with more allowances than they require to meet their obligations can sell them into the secondary market, while firms with a shortfall will have to purchase more or face a punitive fine.

One of the innovations in the design of the CRC is that revenues raised through the Government’s sale or auction of allowances are recycled back to participants via a publicly viewable league table. Companies with a better-than-average league table score may receive more money back than they put in, while those that score poorly will receive less. In addition, we anticipate that customers will use the league table to help identify lower-carbon suppliers of goods and services.

In the first year of the CRC, a company’s ranking in the league table is determined solely by how much of the organisation’s emissions are covered by voluntarily installed automatic metering (AMR), and how much of the organisation’s emissions are covered by a Carbon Trust Standard or Energy Efficiency Accreditation Scheme certificate. In subsequent years, league table rankings will be based primarily upon the organisation’s absolute emissions reductions compared to all other participants, and the relative improvement in emissions compared to company growth.

Your CRC Carbon Footprint
The carbon footprint that an organisation reports under the CRC is only a subset of the total organisational footprint included in an ISO 14064 or WRI/GHG Protocol emissions inventory (see our articles “Whose footprint is it anyway?” in issue 53 and “Counting the cost of outsourcing” in issue 55 of the environmentalist). In particular, the CRC only focuses on what ISO 14064 calls direct and energy-indirect emissions (Scopes 1 and 2 under the GHG Protocol). These are emissions from on-site energy production and emissions from purchased electricity and gas. Supplier and customer emissions are excluded.

Next, the CRC excludes emissions from transport vehicles and the onward supply of energy to other organisations. The next set of exemptions are for organisations that are fully or part-covered under a Climate Change Agreement (CCA) or the EU ETS. Excluding these emissions from the CRC footprint ensures that organisations are not forced to report emissions that are already regulated.

Carrots and Sticks
The CRC could have major financial implications for companies, especially in a challenging economic climate. DECC expects the CRC to lower annual corporate energy bills by nearly a billion pounds by 2020 as companies find the most cost effective ways to reduce their emissions. These savings translate into improved profitability and a stronger economy. Moreover, lower emissions means a smaller outlay for allowances in subsequent years, and the CRC’s recycling mechanism means that companies that perform above average on the league table may get back from the scheme more money than they put in.

On the other hand, getting it wrong poses risks. Approximately 20,000 companies with at least one half-hourly meter will be required to submit an initial Information Disclosure – failure to do so will result in a one-off fine of £1,000. The 5,000 or so organisations required to participate fully in the CRC will face an immediate fine of £5,000 if they do not register by the deadline, and will face an additional fine of £500 for each subsequent day of delay.

Failure to provide a footprint report by the deadline also results in an immediate fine of £5,000, and a further fine of £0.05 per tonne of CO2 per day, rising to £0.10 per tonne of CO2 per day after 40 days. Once the scheme is up and running, failure to provide an annual report results in the same level of fines, plus a bottom ranking in the league table.

Where emissions are incorrectly reported, a fine of £40 per tonne of CO2 incorrectly reported will be levied. Failure to purchase sufficient allowances will also incur a £40 per tonne CO2 fine. Outright falsification of evidence is considered a criminal offence, punishable by imprisonment of up to three years and a fine of up to £50,000.

Implications for Environment Managers
This is only a summary as the CRC guidance document is 84 pages long, and the background consultation document tops out at over 200 pages of detailed explanation. However this brief overview demonstrates how important it is for environmental managers to understand the requirements and to lead their organisations’ response to the CRC.

Under the CRC, environmental management is elevated to a strategic role that, if executed properly, can deliver measurable competitive advantage to the company. But if the requirements are not properly addressed, significant costs will be incurred.

The financial carrots and sticks in the CRC and the reputational spur of a public league table may make a number of otherwise borderline or low-priority environmental initiatives more attractive. For instance, environmental managers may now be able to fast track boiler retrofit or lighting replacement schemes that might otherwise be starved of investment, or get the go-ahead to install onsite renewables where the cost of carbon under the CRC makes them economical.

The CRC may also spur the formation of cross-functional teams that integrate environmental management into every corner of the organisation. For example an organisation’s CRC team might include:

  • the environment manager: to identify best practice emissions reduction measures, co-ordinate the team, calculate the organisation’s carbon footprint and manage reporting and record-keeping with the facilities manager;
  • facilities: to implement technology-based energy saving measures throughout the company;
  • human resources: to help develop a staff “green team” to mainstream low-carbon thinking into the corporate culture;
  • finance: to evaluate the trade-off between energy efficiency investments and purchasing allowances, and then find the required cash. For example, a company with a 100,000 tonne CRC footprint will need to come up with £240,000 to purchase allowances during the first compliance period;
  • communications: to manage the media response to the company’s public league table ranking relative to its competitors which could be brand enhancing or damaging; and
  • a director-level representative to raise the profile and priority of the initiative and report progress to the Board of Directors.

A Model for the Rest of the World
The UK is the first nation to implement a national beyond-Kyoto cap and trade emissions scheme. It is unlikely to be the last. Just two days before DECC released their guidance document, the U.S. Environmental Protection Agency announced that it is planning its own emissions reporting system.

This reporting scheme, a precursor to national cap-and-trade, targets approximately 13,000 facilities (rather than organisations) across all sectors, responsible for between 85-90% of the country’s greenhouse gas emissions. As proposed, the regulation requires the reporting of only direct GHG emissions (scope 1) but is asking for public comment on including energy indirect emissions (scope 2) among other aspects in its lengthy 1,410 page proposal. The final rule is expected within the year, followed by a cap and trade scheme to be in place by 2012. EPA’s enforcement action could result in a fine of up to $32,500 per day for violators.

Our informal enquiries indicate that other nations are watching the UK and USA closely to determine whether some version of the CRC or the imminent USA programme will work in their own countries and how a global system of reporting and trading of GHG emissions may function in a global marketplace.

Government regulation on corporate carbon emissions is not the only reasons firms may wish to support green initiatives in the midst of an economic downturn. As we described in our article “The end of the low-carbon agenda” in issue 72 of 'the environmentalist', environmental programmes also help to demonstrate the company’s commitment to sustainability, improve staff morale and retention, and attract new customers. Regulations like the Carbon Reduction Commitment provide an added incentive, and help environmental managers quantify the potential risks and benefits in a language that other parts of the company can easily understand.

Suzy Hodgson, AIEMA, is a principal consultant and Jamal Gore, AIEMA is the managing director at specialist carbon management company, Carbon Clear Limited.