By now you would have thought that CRC participants would be well-versed in their compliance activity for CRC.
After five years’ experience of gathering data for each annual submission to the Environment Agency (EA), things should be ticking along like clockwork; invoice data and half-hourly data all safely gathered in, annual CRC Statement requests out of the door on time, CRC Statements in your inbox on time, bish, bash, bosh, job done. Get the CFO to sign off the bill. What could be more straightforward...?
“Oh, that’s a lot more than last year, how did that happen?” “Err...” “Not to worry, CRC is dead and buried in 2019.”
True. CRC was originally designed to focus attention on an organisation’s portfolio of energy supplies in its entirety; to make CRC participants truly aware of what they had and how much it was costing them. It was supposed to bring everything into the light, because what you don’t know about and don’t measure, you can’t control. That was the hope. It was supposed to lead the horse to water.
But then complying with CRC has more often than not been seen as an irritation, rather than anything else up there with the sexier elements of energy management. The whole CRC compliance process is still often seen as a “niche” activity, sometimes delegated (or perhaps relegated?) to the lower echelons of an organisation’s finance department, slightly below ordering stationery.
How will organisations feel about the sudden and significant rise in the Climate Change Levy (CCL) planned by Her Majesty’s government to replace the revenue not being gathered by CRC after 2018-19? Rather than the sharp sting of the bill and the bitter anguish of consigning a very large amount of cash to the dark recesses of HM Treasury, CCL will be the mosquito bite that goes unnoticed, the anaesthetic extraction of the same amount of cash, but slowly and painlessly.
SMS are still offering CRC services. It’s not too late to get a thorough audit of your submissions to the EA – it could reveal a surprise overpayment and the prospect of a healthy refund, especially if your submissions spent too long in the dark before being hastily shoved into the lap of the Regulator, hoping against hope that the EA wouldn’t audit you.
Even after CRC has passed away, organisations will still have to declare what energy they’re consuming. You’ll still need to know what’s going to burst out in the annual Directors’ Report, when emissions of greenhouse gases continue to rise out of your organisation like a bad smell. The Climate Change Act 2008 and the Companies Act 2006 (Strategic and Directors’ Reports) Regulations 2013 require it, remember? Oh, dear...
SMS will continue to provide first-class guidance and support for our existing CRC client base, and ensure that the end of CRC will be marked by a smooth, effective transition to energy management strategies focused on tackling increased rates of CCL.
SMS will continue to offer compliance services connected with ESOS, EPCs, DECs and ISOs 14001 and 50001. Any other changes to the energy legislation and policy landscape will also be covered by our experts.