As the Trust Estates Manager, it was my responsibility to register for Phase 2 of the CRC Scheme, ensuring that an accurate qualification assessment had been conducted.
When registering for Phase 2, it became difficult to determine supply responsibility for the energy provided to the Trust’s Private Finance Initiative (PFI) hospital, which accounted for a significant proportion of total qualifying supply. As part of the PFI contractual agreements, the Special Purpose Vehicle (SPV) has responsibility for the administration of contracts for the supply of natural gas and electricity and the costs are passed on to the Trust.
I commissioned Carbon Credentials to conduct a detailed analysis of the Trust’s Phase 2 Registration, with a view to independently verify responsibility of the PFI supply and how this may impact upon Registration.
Carbon Credentials conducted the Phase 2 Registration Analysis as part of the delivery of a Year 3 (2012/13) CRC Internal Audit. A full review of organisational boundaries and corresponding contractual arrangements was performed. This took into consideration specific supply arrangements with other entities on the PFI site, the quantity of supply provided to the Trust and the SPV and the current metering and charging arrangement in place.
Once all site arrangements were mapped against the available guidance on Phase 2 qualification, PFI arrangement and contract details and Landlord/Tenant relationships, Carbon Credentials issued me with a Phase 2 Analysis report detailing their opinion as to which entity was responsible for registering the supply.
The outcome of the exercise confirmed the Trust’s view that the SPV was responsible for the incoming supplies and would therefore be required to register them as part of their Phase 2 qualification. This outcome meant that the Trust’s qualifying supply reduced significantly, although not low enough to bring us out of Phase 2 of the CRC Scheme. As a note, the Trust’s associated CRC costs would still be passed on by the SPV.
Since completion of this project, we have continued to engage Carbon Credentials to provide ongoing CRC compliance support. This has led to them informing us of recent changes to the legislation, where any site with an EU ETS facility can now exclude all gas and electricity from future CRC reporting requirements.
Carbon Credentials was very quick to inform us of this change in legislation and the impact this would have on our qualification to Phase 2 of the Scheme. As the supply previously under question falls within a site with an EU ETS facility, we were able to exclude this from our Phase 2 registration analysis. This new ruling also meant that we could exclude all other site supplies from our final qualification assessment, resulting in the Trust falling under the 6,000 MWH consumption threshold and therefore coming out of Phase 2 of the CRC Scheme.