healthcare update - issue eight
Getting your (green) house in order
With the Copenhagen Summit dominating the recent news agenda,
climate change prevention measures are hot topics at the moment.
However, the quest to agree new targets may detract from the
existing commitments put in place.
1 April 2010 is the start date for the UK’s offering – the
Carbon Reduction Commitment Energy Efficiency Scheme (CRC). The
British government is committed to reducing carbon emissions within
the UK by 60% by 2050, in comparison to 1990 levels. As part of
this commitment, the government will be targeting energy intensive
organisations in 2010 to reduce their level of carbon
emissions.
If you are a trust board member or an estate manager in the NHS,
this will affect you!
Over the coming months we will examine different aspects of the
CRC, together with the penalties and ways in which liability is
correctly apportioned. In the first of these articles, we take a
look below at the key issues you need to be thinking about now.
The CRC applies to organisations which fulfil both of the
following:
- Have at least one half hourly meter (HHM) settled on the half
hourly electricity market
- Consumes over 6,000 MWh of half hourly electricity through all
of its HHMs during a ‘qualification period’ - usually the financial
year before the start of a phase but for this initial phase it is
expected to be the 2008 calendar year. (For those not familiar with
their MWh usage, this is equivalent to approximately £500,000
annual spend)
It is less well known, however, that every organisation with one
or more HHM must still register with the Environment Agency by
August 2010, even if it is simply to confirm that they do not
consume the requisite electricity.
Three key points to consider now are:
Has your qualification pack arrived from the Environment
Agency (EA)?
EA is the administrator of CRC in
England and Wales. A pack should have been sent to all affected
organisations within the last couple of months. If you are unsure
whether your pack has arrived then a request should be made to
EA.
Are your 2008 electricity records easily
available?
These will be needed to determine your ‘qualification year’
consumption. You should also ensure your systems for both data
collection and measurement are sufficient to enable ongoing
compliance.
Have you appointed your CRC champion?
A
trust member, preferably at board level, needs to take on this role
to ensure full compliance with the regulations.
There are serious sanctions for a breach of the regulations,
both financial and criminal. Furthermore, the ‘Crown’ exemption on
the criminal penalties will not extend to NHS trusts or their board
members!
With the final legislation still awaited, despite previously
being promised by “the end of the year”, many trusts may have
delayed taking forward compliance in any detail. However, 1 April
2010 will soon be upon us and so we will take a closer look at the
steps trusts need to take from that date in our next edition of the
healthcare update.
In the meantime, if you have any queries on CRC we would be
delighted to hear from you.
talk to us
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The content of this update is provided for the purposes of general
interest and information. It contains only brief summaries of
aspects of the subject matter and does not provide comprehensive
statements of the law. It does not constitute legal advice and does
not provide a substitute for it.