CRC Manual

Introduction
The Carbon Reduction Commitment Energy Efficiency Scheme (CRCEES) is a mandatory scheme for st large organisations in the UK since it came into force on 1 April 2010. Although mandatory, the CRC involves self-certification of emissions backed up by spot audits by the Environment Agency (EA). The purpose of this manual is to give a detailed explanation of the numerous processes necessary for compliance and to support organisations producing their evidence packs and preparing for auditing. The Environment Agency intends to audits every organisation at least once per phase.

1) 2) 3) 4) 5)

6)

7)

8) 9)

Organisational Structure Scoping Management Structure Roles and Responsibilities Data collection and management a. Manual meter reading programme b. AMR installation programme c. Annual Statement Retrieval Process d. Downloading AMR data from energy websites e. Downloading meter information from websites f. Estimating consumption g. Identifying core and Residual Gas h. Identifying core and Residual Electricity i. Compiling Residual Fuels data j. Renewables installation and data collation k. Data reconciliation Reporting a. Comments box for the CRC annual report b. Excluding Residual Supplies c. Calculating AMR % d. Early Action Metric e. Growth Metric f. Calculating FITs and EGCs Evidence Pack a. File structure b. File naming conventions Audits Appendix

1) Organisational Structure

The organisational structure will act as a visual tool to both help auditors understand the complexity of the organisation and assist internally with controlling and collating information across all significant areas. For local authorities, this could take a format similar to the one shown below in figure 1.

Council

Schools

Pension Scheme Investment Property Portfolio

External Bodies

Joint Venture Schemes

Waste PFI Maintained Schools with Council as Landlord Maintained Schools PFI Operated Academies

Included

Not included

Figure 1.

2) Scoping
In order to make the clear the responsibilities for the organisation, the legal department should be involved. It is useful to have a written statement of organisational responsibilities, see Example 1.

Organisational Structure of the Council The Council is a public body which, for the purposes of the Carbon Reduction Commitment Energy Efficiency Scheme, will also report on energy usage and carbon emissions for the Learning Trust, all schools that are managed by the Learning Trust, all state funded schools, all academies or city technology colleges that are geographically located in the area for which the Local Authority exercises educational functions, The Housing Association, all of the nondomestic buildings associated with The Housing Association (consisting of ..) Example 1. Organisational structure of council, written statement.

3) Management Structure
Internally, it is important to establish the specific responsibilities of the key personnel involved in the CRC. This must also be understood in a broader sense within the company. For example, in figure 2, the Senior Officer (for CRC) is not directly responsible for the Primary or Secondary Contact, so procedures to facilitate communication could be established.

Chief Executive

Corporate Director Finance Property & Performance Senior Officer

Corporate Director Customer Service & Transformation

Corporate Director People, Policy & Law

Head of Finance (CAS, ES & CDs) Finance Officer

Head of Business Support & Facilities Management

Energy Manager

Primary & Invoicing Contact

Energy Officer

Secondary Contact

Figure 2.

4) Roles and Responsibilities

Table 1 is a fairly typical example of how the workload could be shared for the CRC.
Name(s) Title Energy Manager Energy Management Assistant Estates Maintenance Staff Estates Operations Administrator Role Managing CRC reporting: Oversees energy data collection and storage; energy budget; data analysis and verification. Data collection and checking; Recharges electricity internally and externally to tenants Meter readings: Reads electricity sub meters, main gas meters and oil dips Invoicing: Controls oil invoice data and meter read data filing. CRC primary contact

Finance Manager (Estates) Finance Assistant Financial Controller Chief Executive Table 1.

Internal auditor for CRC: Oversees energy accounts. Data Validation: Checks and files electricity and gas invoice data, and recharges oil and gas. Internal auditor: Oversees strategy, policies and procedures for CRC. Senior Contact: Oversees CRC

CRC secondary contact; Invoice Contact

Senior contact

A more comprehensive approach would be to use RASCI modelling. This is a relatively straightforward technique that could have been used at the start of the CRC to identify roles and responsibilities, but is still useful in case of an organisational change or in the event of new staff. RASCI is an abbreviation for: R = Responsible owns the task A = to whom R is Accountable who will sign off on work before it is effective. S = Supportive can provide resources or play a supporting role in implementation. C = to be Consulted has information and/or capability necessary to complete the work. I = to be Informed must be notified of results, but need not be consulted.

Table 2 shows a typical RASCI chart.

Activity Activity 1 Activity 2 Activity 3 Activity 4 Table 2. Data Officer R A RA A Energy Manager R R Finance Assistant A S I Legal Adviser C I C Chief Executive

5) Data collection and management

a. Quality Control of Meter Reading Accuracy
Many organisations may already have a meter reading programme for their estate. Although this may been seen by some as unnecessary, since most organisations are slowly transferring all of their meters to AMR, for some public sector organisations, such as local authorities, they may decide that in the case of schools (especially if they are potentially migrating to academy status) it may not make financial sense to install AMR but instead continue to take manual reads and collate the data for the purposes of the CRC. Below is a procedure that has been written that uses a macro to collate all of the schools data into one master spreadsheet. This process will take place at the end of the financial year, when all the consumption data has been collected.

Procedure for Schools Template Collation The monitoring spreadsheets for all schools can be found at the following file path: C:\Energy\... The spreadsheet where the macro will place this information is labelled For CRC Master. This is located at - C:\Energy\... From each monitoring spreadsheet the macro will extract: School Name MPAN MPAN kWh - Total electricity consumption MPRN MPRN kWh - Total gas consumption Oil Litres LPG Litres

Step-by-step instructions: 1. Navigate to the file path above and open For CRC Master. NOTE: For the macro to work this file must be open at all times. 2. Open the first schools monitoring spreadsheet, Every monitoring spreadsheet must take the following format: Extracted Data School MPAN MPRN MPAN kWh MPRN kWh Oil Litres LPG Litres Sheet Name Sheet 1 Sheet 1 Sheet 1 Sheet 2 Sheet 2 Sheet 2 Sheet 2 Cell B4 E8 J8 B29 E29 H29 N29

3. To select the macro to run click on the green Play button (below) in the toolbar at the top of the screen. Alternatively, using the toolbar menu select Tools Macro Macros

4. From the menu select the macro SCHOOLSMASTER.

* See appendix for Macro 1.

5. Select Run. 6. The macro will extract the information and then save and close the monitoring spreadsheet. After the information has been placed into For CRC Master, it will take the following format. SCHOOL School A MPAN 1.30001E+12 MPAN KWH 83605 MPRN 17043801 MPRN KWH 2232236.515 OIL 2000 LPG 5000

8. The MPAN column needs to be formatted to number with zero decimal places. 9. Repeat this process for every school.

b. AMR installation programme

An AMR installation programme across all sites has already been implemented by many organisations in order to increase the accuracy and reliability of their electricity and gas consumption data. Transferring all meters to AMR may be a slow and difficult process, with potential unforeseen issues arising and causing significant cost in terms of time, money and personnel. Below is a process for developing an AMR installation procedure. This procedure will vary from organisation to organisation, since it may be the case that for certain sites it may not be deemed cost effective or worthwhile. The installation dates and consumption data should be made available to personnel for the purposes of the CRC. Process for AMR installation The overview spreadsheets for AMR installation can be found at the following file path: C:\Energy\... Initial steps: 1. Identify all potential sites 2. Determine: a. Yearly Consumption b. Profile Class c. Location d. Issues with change-over, e.g. cost to downtime, security risks, etc. e. Onsite liaison officer 3. Highlight potential AMR sites 4. Give justification for those sites that will not have AMR installed 5. Send notification of meter changes to all liaison officers, 6. Go to tender. 7. Select procurement process. 8. Use the Buying Solutions AMR Framework guidelines, which can be found at:

http://www.buyingsolutions.gov.uk/frameworks/list.html
9. Make a note of the installations in a spreadsheet and save in the following file path C:\Energy\...

c. Annual Statements
In Guidance on the CRC Energy Efficiency Scheme Estimation techniques Published March 2010, (http://publications.environment-agency.gov.uk/PDF/GEHO0310BRYZ-E-E.pdf) page 9 describes the acceptable estimation method Estimate energy bills below:

Technique 1: Estimated energy bills You can use estimated bills from suppliers to establish energy supply for electricity or natural gas (in most cases this will be for natural gas). Suppliers may send these because they are unable to provide bills based on actual supply data for the entire CRC reporting year.
Annual statements should be requested for all meters because: 1) It allows for an additional comparison of data, which: a. Ensures that your data is accurate b. Ensures that the energy companies data is accurate 2) It is recommended by the EA, and should be used above all other estimation techniques where possible. Every year, all requests should be made six weeks before the end of the financial year, to allow for the annual statements to be received as quickly as possible. In some cases, especially in the case of schools, you will need to first receive a letter of authority before you can receive the annual statement. Below is a procedure for retrieving annual statements and some template emails requesting the relevant data: Process for Annual Statement Retrieval The overview for Letters of Authority (LOA) and Annual Statements can be found at the following file path: C:\Energy\... Step-by-step instructions: 1. Compile a list of all out of contract sites which will need a LOA for each gas and electricity account. A list of contacts for each site can be found at: C:\Energy\... 2. Send an email request is sent to the nominated CRC contact. The following text (below) can be used as a template:

Dear Sir/Madame I am writing from the [Energy Management Unit] at [INSERT ORGANISATION NAME HERE]. As part of the Carbon Reduction Commitment (CRC) Energy Efficiency Scheme, [INSERT ORGANISATION NAME HERE] is required to report our annual energy consumption for the st st footprint year 1 April 2010 31 March 2011 and subsequent years. We must by law report on the energy consumption for state-funded schools, all academies, all foundation schools and all city technology colleges that are geographically located in the area for which [INSERT ORGANISATION NAME HERE] exercises educational functions. A number of the schools in the county borough that we have to account for, including [INSERT SCHOOL HERE], fall outside of our energy contract. We would be grateful if you would supply us with all of the following documents: A letter of authority granting us access to all gas and electricity meters that you use, including the MPRNs and MPANs of all meters. Invoices for all utility bills. An overview of the consumption of all electricity and gas meters used by [INSERT SITE HERE]

Thank you in advance,

3. Follow this up as appropriate until the correct documentation has been made available, 4. Upon receiving the LOAs, request Annual Statements from the relevant energy supplier. [NB: In many cases the energy supplier may have changed through the year, or there may be multiple or unknown suppliers, If there is doubt, send the requests to all suppliers.] The following text (below) can be used as a template.

To Whom It May Concern As part of the Carbon Reduction Commitment (CRC) Energy Efficiency Scheme, [INSERT ORGANISATION NAME HERE] is required to report our annual energy consumption for the period [START PERIOD] to [END PERIOD]. A number of the sites in the area that we have to account for fall outside of our energy contracts and I am therefore writing to request the annual energy statement (aligning period quoted above) for each sitel and meter in the attached spreadsheet for energy provided by your company. Site Name MPAN/MPRN

Letters of authority (which include the MPANs/MPRNs) have been provided for the above sites, allowing our organisation access to their energy accounts and annual statements. I would be grateful to receive copies of the annual statements in Excel format for the above meters. Please acknowledge receipt of this request and provide me with the contact details of the person dealing with my request.

Thank you in advance,

5. The request will take up to 6 weeks from the end of the period requested. Upon receipt of the Annual statements, check against benchmarks (previous years consumption figures, direct comparison, pro rata calculations where available) for possible anomalies. 6. Record the data as appropriate and file the document appropriately.

d.

Downloading AMR data from energy websites

Many organisations may already have a AMR installed in a significant proportion of their estate. This data is extremely useful for analytical purposes, and it is strongly recommended that you utilise this data to highlight any trends or possible discrepancies and focus on reducing your emissions through improved energy efficiency. Below is a procedure that has been written to download AMR data from the electricity meters provided by British Gas. This process needs to take place at the end of the financial year, when all the consumption data has been collected, but it is recommended that for analytical purposes it is downloaded quarterly and compared with the previous years data for analysis.

Procedure for Yearly Electricity AMR data downloads Step-by-step instructions: Electricity AMR data is obtained from the British Gas AMR website (https://energy360data.co.uk/energy360/index.html) To obtain the necessary electricity AMR data from energy360data.co.uk, follow these steps i. Login. Login details should be made available to the Energy Management team, and should be stored in the following file path: C:\\Energy\... ii. iii. iv. v. vi. Select Reports and then Saved Reports Select the sites and period you wish to download. Note - leave the * in the search box to search all sites. When the report is displayed on the screen, select Report in the toolbar menu at the top of the page. Then select Export as .csv Once exported in CSV format this will show the monthly electricity consumption of all sites which when totalled will be the final figure. The report should be saved in the following file path:

C:\\Energy\...

Below is a procedure that has been written to download AMR data from the gas meters monitored by pulse 24. This process can be completed either at the end of the yearly or on a monthly basis. Procedures for Yearly Gas AMR data download Step-by-step instructions: Gas AMR data was obtained from Pulse 24 website (https://amr.pulse-24.co.uk/login.php) To obtain the necessary gas AMR data from pulse-24amr.co.uk follow these steps i. Login. Login details should be made available to the Energy Management Team, and should be stored in the following file path: C:\\Energy\... ii. Change the Date Period: i.e. From: 01/04/2011 To:31/03/2012 iii. Change the Zoom Level to Month iv. Select the first site and then Confirm v. A graph is displayed showing the monthly consumption totals in kWh. vi. The total consumption for the period selected is displayed on the right hand side under Data Summary vii. Manually extract the data from the website into a spreadsheet viii. Repeat this process for every site.

e. Downloading meter information from websites

Almost all organisations will not have AMR on all of their meters. Data for metered supplies is necessary for billing purposes on a monthly basis, but is also needed on annual basis for the purposes of the CRC. The two procedures below have been written to detail the steps taken to download monthly gas meter data provided by Corona in the first instance, and then subsequently reformat the information so that it is more suitable for the CRC second instance. Unlike AMR data, monthly data may have numerous incongruities when compared with the previous month. For this

reason it is good practice to address these throughout the year to avoid additional issues during the reporting process. Corona Download Process An email from ebilling@coronaenergy.co.uk will notify you that the invoices are ready for download. If you do not receive the monthly invoice contact ., Account Manager, on ., or email at .@coronaenergy.co.uk You can access the website at https://ebilling.coronaenergy.co.uk/login.php, Login. Login details should be made available to the Energy Management Team, and should be stored in the following file path: C:\\Energy\... Once the customer invoice homepage is loaded, select the period that you wish to download the invoices for. When the data has been uploaded, check the date of the invoices and then select those that you wish to download. These will be highlighted in orange. Once you have selected all the invoices that you require for that month, select download in .xls format. Check this against the paper bills received to ensure that all the billing is accurate.

Only the consumption data is needed from the invoice for CRC purposes. The procedure below can be used to filter the invoices to only extract relevant CRC information. Once the invoice has been edited the information is copied onto a master spreadsheet which contains invoice information from every month side by side.
Step by step instructions 1. 2. 3. 4. 5. 6. Corona monthly bill is downloaded Saved in following file path: Y:\Shared\Carbon\Energy\Gas[YEAR] Open the file Click Details tab. Run macro Reformat Corona. [See appendix for macro 2] Sort Column A ascending. When prompted Expand the selection.

7. Open Corona Yearly Compilation 11 to 12, found at Y:\Shared\Carbon\Energy\Gas\Gas 11. 8. Copy all information from Sheet 2 (Columns A to G). 9. Paste into Corona Yearly Compilation 11 to 12. 10. Save and close the BG monthly invoice. 11. After month 1 (April), leave a 1 column gap and paste the information into Corona Yearly Compilation 11 to 12. 12. Sometimes there is additional or missing meter data, resulting in different meters on the same row. In order to compile the information, here are two suggested methods:: a. Where there are two different MPRNs on one row, add in a row such that the meters remain in order and in line with each other. b. Compile a list of all of the meters (using the Unique Value filter tool in excel), then use a VLOOKUP to extract the consumption data from each month. 13. Save and close Corona Yearly Compilation 11 to 12.

f. Estimating consumption
10% Uplift In the CRC EES there is a penalty of 10% uplift for any yearly data that is deemed by the environment agency to be estimated. Yearly data is deemed estimated if there is less than 6 months of actual data for a given meter within the relevant year. Figure 3 would be deemed as actual data for the whole year.

More than 6 months

April 2010

April 2011

Key:

Estimated Bill Actual Reading

Figure 3

In figure 3, this meter would be considered actual yearly data because the 2 actual reads account for a period of more than 6 months. One or more of the 4 estimation techniques (estimated bills, pro rata calculation, direct comparison or benchmarking, cost of supply) would be used to estimate the data for the rest of the year but the meter would be deemed as having actual data for the entire year. This would not be the case in figure 4, since the actual reads both need to be taken within the same reporting year. :
More than 6 months

April 2010

April 2011

Key:

Estimated Bill Actual Reading

Figure 4 In figure 4, there is only one actual reading for the meter taken within the year, and so the data would be considered estimated yearly data. In this case the data would be subject to a 10% uplift.

AMR for non-contracted schools Key points regarding non-contracted schools: You cannot guarantee non-contracted schools will submit actual data Non-contracted schools account for approximately .% of the total consumption for the council Non-contracted schools account for approximately ..% of the Councils carbon emissions The Councils carbon allowances will cost approximately . in year 1 (at 12 per tCO2) and may rise to (if the price of carbon rises to 16 per tCO2) in the next 2 years. Non-contracted schools will cost up to an additional . due to the 10% uplift in year 1 (at 12 per tCO2) and potentially . thereafter due to an increase in the cost of carbon allowances.

g. Identifying core and Residual Gas

Residual Gas in the CRC In Guidance on the CRC Energy Efficiency Scheme Footprint Report May 2011, (http://publications.environment-agency.gov.uk/PDF/GEHO0311BTMD-E-E.pdf) page 29 describes what is considered a core gas supply. Core gas supplies A core supply of gas means a supply measured by a meter which is: a daily meter an hourly meter a large gas point meter. A meter, as used above, includes any ancillary device used in connection with that meter, which allows the amount of the supply measured by that meter to be read. Daily meters A daily meter is a meter that is able to measure gas supplied at least daily and is read in: Great Britain by an authorised supplier or an authorised transporter under section 48(1) of the Gas Act 1986, or in Northern Ireland by a licence holder under Article 3(1) of the Gas (Northern Ireland) Order 1996. Hourly meters An hourly meter is a meter that is able to measure gas at least hourly and, in respect of a phase, has been read remotely. Read remotely has the same meaning as that given in Non-settled HHMs above. Large gas point meters A large gas point meter means a meter that, during a footprint year of a phase, measured greater than 73,200kWh annual quantity of gas supplied.

From this guidance we can establish that all gas meters that consume less than 73,200kWh in the footprint year are considered to be residual supplies for the purposes of the CRC. However, it also states that a core supply of gas means a supply measured by a meter which is an hourlyan hourly meter is a meter that is able to measure gas at least hourly , and so any gas meters that have automatic meter readers (AMR) are to be considered core supply for the purposes of the CRC. You should base your justification on this guidance, and stored the information in the following file path: C:\\Energy\...

h. Identifying core and Residual Electricity

Profile class of residual meters The first two digits of a full MPAN reflect its profile class. The profile classes are shown in table 3 below. 00 Half-hourly supply 01 Domestic Unrestricted 02 Domestic Economy 7 03 Non-domestic Unrestricted 04 Non-domestic Economy 7 05 Non-domestic, with MD recording capability and with a load factor less than or equal to 20% 06 Non-domestic, with MD recording capability and with a load factor of between 20% and 30% 07 Non-domestic, with MD recording capability and with a load factor of between 30% and 40% 08 Non-domestic, with MD recording capability and with a load factor greater than 40% Table 3. A complete list of meters sorted by profile class can be found at: C:\\Energy\... In Guidance on the CRC Energy Efficiency Scheme Footprint Report May 2011, (http://publications.environment-agency.gov.uk/PDF/GEHO0311BTMD-E-E.pdf) page 28 describes what is considered a core gas supply. The relevant points are highlighted below:

Core electricity supplies A core supply of electricity is where the supply is measured or recorded by the following: a settled Half hourly meter (HHM) a non-settled HHM a non-domestic meter a dynamic supply. Settled HHMs A settled HHM is a meter that is able to measure electricity supplied at least every half hour. It enables the supplier to comply with provisions of its licence to determine charges between that supplier and another licence holder in respect of the transmission and trading of wholesale electricity. A licence means: In Great Britain, a licence within the meaning of section 6(1) of the Electricity Act 1989. In Northern Ireland, a licence within the meaning of Article 10(1) or (2) of the Electricity (Northern Ireland) Order 1992. Non-settled HHMs A non-settled HHM is a meter that is able to measure electricity supplied at least every half hour and, in respect of a phase, has been read remotely. Read remotely means the meter is read remotely by the business or organisation supplied (or by a person acting on its behalf e.g. the supplier) at any time during the qualification year for the phase or a year of that phase. Non-domestic meters A non-domestic meter means a meter that is designed to measure supplies to non-domestic premises and is capable of measuring maximum electricity demand. Dynamic supply A dynamic supply means a supply where a device, which is not a metering device, records daily electricity supply to one item of a set of equipment on premises and Environment Agency Footprint Report 29 v3-GEHO0311BTMD-E-E that record is used to determine the half-hourly supply of electricity to the whole set of equipment.

i. Compiling Residual Fuels data

Residual Fuels Check Process To ensure that all residual fuels used are captured for CRC, a request should be sent to all Heads of Department, explaining what information is required for the purposes of CRC. The relevant personnel are: Department Head of Department Email Address

If any department uses any of the additional fuels listed, they should complete the Residual Fuels Capture Spreadsheet (see appendix) detailing the amount of fuel used, what quantity if any was used for transport purposes, and a key contact officer.

j. Renewables installation and data collation

At present we are updating this process and still in need of example procedures. If you have already written a procedure that you would be willing to share with the network, please contact peter.chasmer@lgiu.org.uk

k. Data validation and reconciliation (DVR)

There may be numerous data sources that have been used to collate the footprint and annual reports for the purposes of the CRC. Where more than one data source has been made available, it is important to compare the data, checking for discrepancies and justifying which data source you will use. Table 4 highlights the main data sources. This justification needs to be consistent, logical and most of all must be documented for auditing purposes. Data Sources AMR from website Monthly data from website Manual meter reads from staff/contractors Manual electricity meter reads from schools. Robustness / Reliability The most reliable source. Independently stored and data is recorded halfhourly, allowing any anomalies/missing data to be reconciled easily. Reliable records using acceptable estimation techniques where necessary, however the data is still often only an estimate. Robust and reliable, although possibly expensive in staff costs and the data needs uploading / collating independently. Not very reliable. The MPANs are often mixed up with serial numbers, the readings may be wrong, there in little consistency between different schools. If training for the school staff is available the data can be deemed robust. Going forward you should implement an online meter-reading system with automatic data checking for signification deviations from standard. Unreliable. The same issues as above, but with the added issue that gas meters are recorded in either cubic feet or cubic meters, and often errors occur due to this. Going forward you should implement an online meterreading system with automatic data checking for signification deviations from standard. Reliable but not necessarily robust. The invoices will show how much has been bought, but not the amount used. It is recommended you report everything that is purchased.

Manual gas meter reads from schools.

Invoices for residuals Table 4.

l. Excluding Residual Supplies

After residual supplies have been identified (discussed in sections 5g, 5h and 5i) you must decide whether you wish to exclude any of the residual fuels. At least 90% of your total emissions must be included. Guidance regarding the 90% rule can be found on pages 12-19 of Guidance on the CRC Energy Efficiency Scheme Footprint Report May 2011. If you have opted to include residual supplies past 90% of your total emissions, you do not have to justify why this is the case, but you will have to record which residual supplies you include in your footprint report so that you can include the same residual supplies for the remainder of the phase.

m. Calculating AMR %
The environment agency has set out clear guidelines as to how to calculate the percentage of your emissions covered by voluntary AMR installed before 1 April 2011. It can be found at:

http://publications.environment-agency.gov.uk/PDF/GEHO0311BTLY-E-E.pdf
The environment agency also issued a clarification note, found at http://publications.environment-

agency.gov.uk/PDF/GEHO0511BTXN-E-E.pdf . Caption 2 highlights the key points.

We are aware that some organisations have misunderstood the rules that apply when calculating the benefit organisations can receive for voluntary automatic metering readings (AMR) within the Early Action Metric (EAM). They have considered that provided you install voluntary AMR by 31 March 2011 you will receive the same benefit as if you had the metering installed on 1 April 2010.This is not the case. You receive benefit from the percentage of your gas and electricity supplies measured through AMR and electricity supplied which is dynamic supply during the first year of the Introductory Phase (1 April 2010 31 March 2011). Consequently, the earlier you install such metering and measure supplies through these meters the greater benefit you will receive. This is in line with the intent to reward early action within the CRC Caption 2. The calculation that you use at the end of the year should be: total energy consumed through voluntary AMR x100 = % of emissions covered by voluntary AMR total energy that has passed through non HHM
st st

n. Early Action Metric

The Early Action Metric is based on two equally weighted elements: 1. the percentage of a participants emissions from electricity and gas (excluding those covered by mandatory half-hourly electricity meters) which is covered by voluntarily-installed automatic metering (AMR) by the end of March 2011. 2. the percentage of the Participants annually reported CRC Energy Efficiency Scheme emissions covered by the Carbon Trust Standard (CTS) or equivalent at the end of each year of the introductory phase. AMR consumption total: Total energy that has passed through non HHM: AMR %: Supporting documentation can be found at: Carbon Trust Accreditation (or equivalent) score: Supporting documentation can be found at: Early Action Metric score:

o. Growth Metric
At present we are updating this process and still in need of example procedures. If you have already written a procedure that you would be willing to share with the network, please contact peter.chasmer@lgiu.org.uk

p. Calculating FITs and EGCs

At present we are updating this process and still in need of example procedures. If you have already written a procedure that you would be willing to share with the network, please contact peter.chasmer@lgiu.org.uk

q. Commenting on your report

Plain text statement for Annual Report for the Carbon Reduction Commitment (CRC) As part of your annual report you are given the opportunity to comment upon any factor(s) that you consider might affect your position in the Performance League Table (PLT). The comments box allows a maximum of 2,000 characters to be entered. This information will be published as part of your entry in the PLT. The following examples are given by the Environment Agency as relevant comments: Organisational changes during the reporting period for which adjustments cannot be made, The loss of or withdrawal from a CCA Increased turnover or growth not accounted for in the growth metric for the reporting year to which your annual report relates.

You will not be able to see the PLT before commenting on your position, as comments are submitted as part of your annual report and the PLT will not have been calculated at the time of submission, nor will you be able to amend the comment after publication of the PLT. Your position in year 1 was entirely on the Early Action Metric (EAM). When commenting on your position in the PLT, you may wish to comment on the following: 1. Your AMR % coverage would have been higher if AMR target installation was achieved, giving you a higher EAM score. 2. Your CTS coverage of ..% has allowed us to improve the quality of our data and comply with the CRC. 3. Our estimated consumption data is as low as % of total consumption. This means that you avoided 10% uplift on estimated emissions for % of data, saving your council .,000 in unnecessary carbon allowances. The accuracy of your data is integral to your Carbon Reduction Strategy, as it allows you to identify areas of improvement and highlight sites that are achieving our target of ..% reduction by ... 4. Your Carbon Reduction Strategy has been updated as of to continue to aim to reduce carbon emissions and reach your target of ..% reduction by

5. You produced .kWh of electricity thorough wind turbines and solar PV in 2010-2011, and are planning additional Solar PV installation on sites by the end of first phase of CRC. 6. Your lead Councillors for Energy and Envrionment may wish to also make a statement.

6) Evidence Pack a. File structure

There is no set way of filing your documents, but it is essential that is must be structure in such a way that it is easy to navigate for all staff and also for external auditors. Figure 4 is an example of a possible file structure that could be used. It is recommended that the pathways are drawn out in order to understand where information sits on your system. It would also be useful to add hyperlinks to the diagram.

Evidence Packs

Key Personnel Information

MPRNs

Annual Report 2010 - 2011 Footprint Report 2010-2011

Participation in Scheme
Organisational Structure

Core Energy Supply Data Residual Energy Supply Date

Estimations

MPANs

Figure 4.

b. File naming conventions

To further improve the filing process, it is recommended that you create a convention for naming your files in order to ease the auditing process. Below is an example of one such convention. Evidence Pack Filing 1) The evidence pack can be found in the following file path: C:\\Energy\... 2) The next subfolders will contain the Evidence Pack pertaining to a specific reporting year. The name will have two components. The first part will signal the phase that the Evidence Pack relates to, the second part the specific year that the pack relates to. i.e. Phase12010 will be the Evidence Pack to 2010 11 in Phase 1 3) The naming of folders within the Main Folder will follow the suggested evidence pack template in the Environment Agency Guidance Document.

Section 1. Section 2. Section 3. Section 4. Section 5. Section 6. Section 7. Section 8. Section 9.

(Evidence Pack Status) (Key Emissions and Qualification data) (Organisation structure) (Responsibilities) (Emissions source list) (Footprint Report) (Annual Report) (Special events and changes) (Exemptions and Exclusions)
EA Template (TP) or supporting evidence (EV)

4) Individual files names will be composed of the following elements Phase1.2010.DOC.8.2.TP

Phase Number

Year of scheme Document (DOC) or Procedure (PRO)

Section number

5) The file name for each document will be shown in BOLD in the HEADER on each page st st 6) Definition of years:- 1 April 2010 to 31 March 11 year will be designated 2010, 2011/12 designated 2011, 2012/13 designated 2012 etc.

7) Audits
As of autumn 2011, the Environment Agency will start the process of auditing the participants of the CRC. Their process at present has been defined broadly, and is explained below. It is intended that every participant will be audited once per phase, which means that approximately one third of participants will be audited each year in the first phase. For the first year, and most probably subsequent years, the selection process will be risk-based. There are a number of factors that will be considered to identify the highest risk participants. They could include:

Total carbon emissions Total electricity consumption and number of MPANs Percentage of estimated data Size of company (turnover) Difference between expected emissions (based on registration and average emissions for similar organisations) and reported emissions Reputation Number of years since previous audit (obviously not relevant for the first phase)

There will be two levels to the actual audit process: desktop audit and site/full audit. The first step will be the desktop audit, which will consist of sending primary data to the Environment Agency along with any supporting evidence that they ask for. The information asked for may include, but is not limited to: Annual report Footprint report Estimated bills Data from your EMS Estimated data including estimation techniques Invoices for residual energy sources Evidence for de-energised meters Clarification on relationships with PFIs, landlord-tenant arrangements

The desktop audit will use a light-touch approach and is at the discretion of the regulator. If the regulator is satisfied then you will receive a pass. If further worked is required, you will be given a list of improvements, actions and a timeframe to complete these improvements. If the desktop audit yields unsatisfactory results, you will receive a full onsite audit lasting 2 days. If you have an onsite audit it will involve a much more thorough check of the entire evidence pack. This will include All energy data Internal processes and procedures All supporting evidence The structure and transparency of the evidence pack All estimations techniques used including justification Your internal audit and evidence of regular data checks including appropriate sign off from those people responsible and accountable. Under the terms and conditions of the CRC, an internal/self-audit is required by every participant on a regular basis and it is recommended this is done annually. The issue that most organisations will have with an internal audit will be that the auditing team will have not dealt with this kind of assessment before, and will most likely be unaware of the specific legislation for the CRC. Anyone in the organisation that is aware of the processes will probably have been involved in the production of the report and the underlying evidence, and as a result should not have any direct involvement in the audit. An audit should focus on 3 main areas: 1) Accuracy of data 2) Robustness of procedures and processes 3) Clarity and transparency of documented evidence 1) Accuracy of data You should first sense-check your data and highlight any supply that falls outside expected energy levels. This should include comparing sites with previous years information and a comparison with similar sites. You should compare your overall consumption with previous years, using NI185 and NI186 or similar reporting schemes. Also, compare your consumption to similar organisations. It will also be necessary to check the percentage of residual energy supplies, highlight anomalies and suggest possible causes.

As well as checking to approximate expected energy consumption, you will need to evaluate the estimation techniques you have opted for, which were discussed in section 5f, and justify and document why you used each method. 2) Robustness of procedures and processes This document should be used to ensure that all processes and procedures have been put in place to collect and collate the key information necessary for successful completion of the CRC. If your data is deemed to be inaccurate but you can show your methodology is sound and that you have appropriate checks in place then you will be in a better position to defend your integrity, good intentions towards the scheme and willingness to comply. As such, you should audit the data collection process for both core and residual source data, and improve any areas where you haven't produced enough evidence to show that the data is accurate. 3) Clarity and transparency of documented evidence You will need to have an explanation as to how this information is stored, highlighted in sections 8a and 8b. If your current filing system is deemed unstructured/unsatisfactory then not only will an EA audit become more extensive but it will become more difficult for you to store data over time.

Appendix
The appendix is available upon request.

8) Appendix
Macro 1

Macro 2

Macro 2 (cont.)

Residual Fuels list

Emissions factor kgCO2 per measurement unit 3128 3150 0.9960 0.9960 2.5320 2373 0.1460 2577 2932 0.1840 2.6390 0.5410 3216 2.7620 0.2520 2314 1203 1.4950 1357 3131 0.1836 0.1836 0.2057 2.3035 2981 1669 2810 0.2397 275 3026 1613 Core Supply / tCO2 Residual Supply / tCO2 -

Fuel type Measurement Aviation spirit Aviation turbine fuel Basic oxygen steel (BOS) gas Blast furnace gas Burning oil/kerosene/paraffin Cement industry coal Coke oven gas Commercial/public sector coal Coking coal Colliery methane Diesel Electricity Fuel oil Gas oil Gas oil Industrial coal Lignite Liquid petroleum gas (LPG) Peat Naphtha Natural gas <73200kWh (residual) Natural gas (core) Other petroleum gas Petrol Petroleum coke Scrap tyres Solid smokeless fuel Sour gas Waste Waste oils Waste solvents

Units tonnes tonnes kWh kWh litres tonnes kWh tonnes tonnes kWh litres kWh tonnes litres kWh tonnes tonnes litres tonnes tonnes kWh kWh kWh litres tonnes tonnes tonnes kWh tonnes tonnes tonnes

Quantity