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Legislation and Compliance


have the skills and understanding to achieve this, but won’t always have the remit to implement estate-wide carbon reduction programmes (the ultimate aim of the scheme), which of course then falls to the facilities manager. In theory, all three roles have an


important and valuable part to play, but in reality few organisations have progressed to a point where they have created a CRC strategy with a dedicated team, each with clear roles and responsibilities. With the first allowance


purchasing date of April 2011 looming, it is becoming increasingly important to turn theory to reality and get a strategy in place to manage participation. For those who fail to do this, there are potentially significant financial and reputational implications. The financial penalties will fall


on those who missed the 30th September registration deadline and those who fail to manage carbon emission allowance purchasing adequately. For example, late registrants will


face a fixed fine of £5,000, plus an additional £500 per working day past the deadline for each subsequent HHM, up to a maximum of 80 days. Non-compliance will also be published. And this does not even take


into consideration the corporate reputation impact of a low position in the CRC’s league table, which will rank participants in part on how successful they’ve been in reducing


their CO2 emissions. For some sectors, such as retail,


which is firmly in the public eye,


league table position could be more important than the financial implications of the scheme. With many still unclear on their


obligations, and lacking a strategy and in-house expertise, we believe it is likely that businesses will call on specialists such as npower for advice. At npower we’re increasingly


working with a number of our customers in this way under our new ‘CRC Assist’ service, which supports organisations in managing their CRC obligations. The service is designed to help businesses understand the CRC scheme; assist them with the development of an energy management strategy; and manage their participation in the scheme including preparation of registration information, compilation of the year end ‘footprint reports’, plus forecasting and guidance on the purchasing of emissions allowances. There are very good reasons


for working in this way. Quite aside from the peace of


mind it provides, using services like ‘CRC Assist’ should prove to be time and cost effective, helping to make clear the role in-house specialists like FMs and energy managers will play, while negating the need to recruit and train extra staff. It also avoids the need to establish


a suite of processes and procedures for compliance with CRC. This arrangement could also prove


to be more productive in the long term as the CRC strategy would be based not only on compliance, but also on long term goals to deliver energy savings and carbon reductions - focused on performing well under the scheme, financially


and reputationally - that are linked to an organisation’s broader business objectives. The importance of this ongoing


strategy cannot be underestimated – while all eyes might be on registration at the moment, we cannot escape the fact that the real focus of the CRC is delivering emissions reduction through energy efficiency. For many establishments this will require a change in how they manage current and future energy consumption and the implementation of new tools. For example, organisations will need to have detailed plans in place to record and report on their emissions, and then reduce them. The ability to forecast allowance requirements, understand risk exposure and control cash flow related to allowance purchases will also be crucial. Smart meters should feature as a


priority in these plans. These will capture data on energy


use which can then be analysed to make informed decisions on energy efficiency. Armed with this data, participants


can take a longer term view on where energy efficiency measures can be implemented; the capital investment required to deliver these actions; and the expected outcome in terms of energy, and therefore carbon and allowance savings. Scheme participants who can


do this will stand to succeed under the CRC, also enjoying significant cost savings from reduced energy consumption as well as potentially unlocking financial rewards through lower emission allowances purchasing. As former Energy and Climate


Change Secretary, Ed Miliband, put it when the scheme was launched: “The rewards for those who act to cut their carbon emissions are really starting to pay off. It's no longer simply about doing the right thing for the environment; it's now a sure- fire financial investment.” Organisations who want to


share these rewards, need to start work now and working with a specialist partner could be the best solution for those looking for long term success.


18 Facilities UK - Handbook 2010 - 11


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