Reporting and keeping records

Have the conversion factors for the various energy sources been specified?

Yes. These can be found here.

Government decided to use the fuel conversion factors listed in Defra’s Greenhouse Gas (GHG) Conversion Factors for Company Reporting whenever possible.

Participants will be obliged to determine emissions from energy supplies according to the emissions factors specified in the CRC fuels list. These amounts will then be converted by the CRC Registry into tonnes of carbon dioxide by the application of standard emissions factors.

Environment Agency will publish guidance on how to convert other measurement units into the units required for data entry for the CRC registration. The CRC Registry will then convert these values into tonnes of CO2.

Will organisations that buy green electricity tariffs or carbon offsets still have to report?

Yes, organisations that buy renewable or ‘green’ electricity via the grid will have to include and report this electricity using the grid average emissions factor. This is consistent with the approach taken under UK Emissions Trading Schemes and Climate Change Agreements, and is consistent with the focus of the CRC on actions taken by the end user organisation.

Moreover, government wishes to ensure that the carbon savings from the CRC are in addition to those that will be achieved by the Renewables Obligation. The CRC is aimed primarily at improving energy efficiency and reducing emissions, and therefore credit will not be given to offsetting schemes.

How does a participant show that its energy use has not been estimated, to avoid a 10 per cent uplift?

With regard to electricity and gas supplies, the participant should retain auditable evidence, which could be the supplier statement, energy bills or internal records of actual meter readings (when the energy supplier reads or the participant reads the meter, for at least a six-month period during a reporting year). 

Please note: For an energy bill to be treated as accurate (not estimated) at least two meter readings for at least a six-month period are required during any compliance year.

Regarding consumption of energy other than gas or electricity supplies, organisations must prove the quantity of fuel they have consumed either via invoices or delivery notes covering at least half of the compliance year.

Government proposes that if a participant is able to provide such evidence, the energy supply will not incur the 10 per cent uplift. Where a participant does not have evidence for at least a six-month period during a compliance year, the 10 per cent uplift will be added as appropriate to the energy consumption for that source. It will apply during that compliance year. Uplift will not be applied on the emissions reported in the footprint report, as in this case this would incentivise estimation.

How should participants account for on-site renewable electricity production?

Depending on whether or not Renewables Obligation Certificates (ROCs) or Feed In Tariffs (FIT) are issued:

The CRC Energy Efficiency Scheme will treat electricity which receives a FIT in the same way as electricity which is issued ROCs.

Electricity which is issued ROCs or FIT and exported to the grid or a third party will not be able to claim electricity generating credit but will not have to be reported as a consumed supply.

Electricity issued with ROC or FIT, which is generated and consumed on site, will be required to apply the ‘renewables adjustment’, for example, reported as consumption of an electricity supply at the grid average emissions factor, to ensure that the incentives to reduce demand from all electricity sources remain.

How should oil consumption be measured and is it acceptable to use delivery quantities in reporting submissions?

Yes. For bulk supplies (such as fuel oil) you need to keep a record of all supplies that have been purchased or delivered, and report emissions on the basis of what has been delivered. Also record the exact types and blends of fuel being used (for example gas oil, medium fuel oil). You must be able to verify these records with supplier's invoices or other primary data.

In those instances where a single bulk fuel purchase has been made and the fuel is in fact consumed in the course of several compliance years, the participant has the option to estimate the quantity of fuel consumed during the relevant compliance year and therefore will need to apply the 10 per cent uplift factor to the estimated consumption.

The Environment Agency will publish guidance approximation techniques that can be used to estimate fuel use.

What is the minimum meter reading frequency required to avoid the 10 per cent estimation uplift, and when must those meter readings be taken?

Gas and electricity

Government proposes that for supplies of electricity and gas, more than six months (50 per cent) of any compliance year must be covered by verifiable meter readings to avoid the 10 per cent estimation uplift. These do not need to be consecutive readings. For example, a reading in early April and another in mid October will suffice as covering 50 per cent of the reporting year. 

They can however be more frequent. Therefore two electricity or gas meter readings spaced over six months apart will be the minimum number of meter readings required during any single compliance year to avoid the 10 per cent estimation uplift.

Other fuels

The uplift will be applied to other fuel use where consumption is estimated and two or more data reference points covering at least half the compliance year are not available. The Environment Agency will publish guidance approximation techniques that can be used to estimate fuel use.

Where a participant can prove the quantity of fuel they have consumed, either via invoices or delivery notes, covering at least half the compliance year, then the 10 per cent uplift is not applied in respect of that fuel supply. For example, if a participant purchased a fuel in April 2010, then again in November of that year, there are two data reference points covering eight months (more than half the compliance year). Therefore, the 10 per cent uplift would not apply. This approach is consistent with how the estimation uplift is applied for supplied electricity and gas.

In those instances where a single bulk fuel purchase has been made and the fuel is in fact consumed in the course of several compliance years, the participant would have the option to estimate the quantity of fuel consumed during the relevant compliance year and therefore will need to apply the 10 per cent uplift factor to the estimated consumption. If the participant has a process to measure and account for the use of such fuels this may be accepted by the administrator where adequate evidence is made available

In summary, the uplift will be applied to fuel use where consumption is estimated and two or more data reference points covering at least half the compliance year are not available. We will publish guidance approximation techniques that can be used to estimate fuel use. Here are some examples of instances when the estimation uplift would or would not be applied:

Single delivery within one year:

  • Treat the full delivery as amount consumed and don’t apply 10 per cent uplift;
  • Estimate the amount consumed during the year and apply the 10 per cent uplift.

Multiple deliveries covering less than six months:

  • Treat the full deliveries as amount consumed and don’t apply 10 per cent uplift;
  • Estimate the amount consumed during the year and apply the 10 per cent uplift.

Multiple deliveries covering more than or equal to six months:

  • Treat the full deliveries as amount consumed and don’t apply 10 per cent uplift;
  • Estimate the amount consumed during the year and don’t apply the 10 per cent uplift.

Is a standard CRC report format available to assist participants in gathering the necessary data?

We have issued guidance on registration on our CRC guidance web page:

At the above link we also list future guidance topics, which include the content and registry reporting requirements for footprint and annual reporting.