CRC countdown blog: your time is running out
There is officially one month left to register for the government’s Carbon Reduction Commitment Energy Efficiency scheme. Here, Knight Frank head of sustainability David Goatman gives his view on what you should be doing now:
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I’ve got good news and bad news.
The good news is that for those of us who have been labouring with CRC registration over the last few months, the agony is nearly over.
The bad news is that for those of you who haven’t registered, you are running out of time.
The Environment Agency is taking two to three weeks to process registrations, so the real deadline is this Friday, or next Friday at the latest, not 30 September.
Fines start with an immediate £5,000 for missing the deadline and £500 for each day after that. Tedious and confusing as it may be, burying your head in the sand is a sure fire way to start racking up penalties.
Registration is simply submitting a range of information.
This is essentially layered, starting with corporate structure, from highest overseas parent company downwards; then mapping properties to the correct corporate entity; and finally mapping the half hourly meters you are responsible for to the correct property.
Once this is complete you have to state what electricity was consumed through your half hourly meters in 2008.
It’s not rocket science. All of this information is somewhere. The challenge is pulling it together in a coherent fashion within the imposed time frame.
From our experience the trickiest and most sensitive registration task is the corporate structure. For perfectly sensible business reasons an organisation may have properties held in a multitude of subsidiary companies, many or all of which may be based off-shore.
The most important issue to resolve is the responsible organisation for CRC purposes. This should involve a conversation with your lawyers. This is so important because we have found in a number of cases that the presumed parent company may not be the responsible organisation for CRC purposes. This could be the difference between you being on the hook for substantial allowance purchase costs next April or not.
So talk to your advisers, get clarity on the corporate structure you need to register and gather your property and meter data together.
And do it quickly. Time is running out.
- CRC countdown blog: don’t count on leniency
- CRC countdown blog: property causes headaches for offshore fund
- Auditor slates running of £12bn Welsh estate
- Carbon Reduction Commitment legislation
- Blog: Quit playing politics with planning, Pickles
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It will be more than embarrassing if any public sector organisations incur a fine – will there be a public black list ?
Information from the Environment Agency who are administering the scheme suggests they are anticipating around 5,000 companies will have to register fully and about 20,000 firms will be required to participate in some way. By the middle of August only 1398 organisations had signed up !
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