Carbon and Energy Reporting Regulations – what your school needs to know

Carbon and Energy Reporting Regulations (CERR) are a new statutory reporting requirement for large companies in the UK.  This article
looks at whether your school is affected, and the action that you may need to take now if you are.

CERR imposes new reporting requirements on large UK companies.  A trust is large if it exceeds any two of the following:

• Total income (from all sources) >£36 million
• Gross assets (i.e. fixed plus current assets, before deducting any liabilities) >£18 million
• Employee numbers (total, not full time equivalent) >250

Whilst the reporting requirements only exist at the trust level, all schools within a trust will need to have systems and process in place to capture the required information.

The requirement to report is as part of the trust’s statutory accounts for accounting periods beginning on or after 1 April 2019 so this will affect trust accounts for 31 August 2020 and subsequent periods.

There are no exemptions available for charities or for public sector bodies.

Trusts which are required to report under the new rules will have to make three qualitative and two quantitative disclosures within the statutory Trustees’ report.  These disclosures are:

• UK energy use, to include as a minimum purchased electricity, gas and transport;
• Associated greenhouse gas emissions measured as tonnes of Carbon Dioxide emissions;
• At least one ‘intensity ratio’ that measures energy usage compared with an appropriate business metric such as income, staff numbers, or student numbers;
• Information about energy efficiency measures undertaken during the year;
• Methodologies used in calculating the disclosures.

Trusts will need to make sure that they have systems in place by 1 September 2019 (being the first date of the August 2020 accounting period) to capture data on electricity, gas and transport.

Electricity and gas consumption should be fairly easy to capture provided that meter readings or utility invoices are available.  Where utility suppliers are changed during an accounting period, trusts will need to make sure that usage figures from all providers are captured and collated.

Capturing transport costs might be more complicated.  The fuel consumption that needs to be captured includes:

• Fuel used in company cars on business use;
• Fuel used in any fleet vehicles on business use – this will include minibuses, and any coach transport where the trust is the coach operator;
• Fuel used in personal cars for which the trust reimburses its staff members;
• Other onsite transport or power generation.  This is likely to be rare, although some trusts have diesel generators, and agricultural colleges may have diesel-powered farm equipment.

Train travel is not included, nor are coaches, ferries, aircraft etc. where the trust does not perate the vehicle.  For example, where a trust’s own minibus is used to transport an exchange group to an airport, the minibus fuel is included but the plane’s fuel is not.  If purchase ledger and staff expense claim procedures are not currently capturing all of the required information there is still time to get system and protocol changes in place before 1 September.

Once the fuel usage is known, the Government has provided an online tool to convert energy usage into standard figures for Carbon Dioxide emissions.

At first glance this may seem like just another reporting burden, but the first set of reports from the academies sector will be interesting to read.  The requirement to disclose an efficiency measure will give some insight into how similar schools are using energy differently, and will provide potentially valuable benchmarking in terms of maximising efficiency and cost effectiveness.  In time, will these figures provide quantitative data on the efficiency of different building types & use of space?  With a student body that’s ever more conscious and activist as regards environmental matters, will we even see students engaging with these figures and leading the drive towards efficiency and sustainability?

Thank you to Mike Bath for his contribution to this blog post.