INFORMATION SHEET 6

REPORTING REQUIREMENTS

Summary of Reporting Obligations

Under the Umbrella Agreement with DEFRA the MPMA has certain reporting obligations. The most important of these are to supply information that will enable DEFRA to decide whether:

• A site has met its milestone target.

• The whole of a sub-sector has met its milestone target

• The whole of the MPMA has met its milestone target.

At all levels of the Agreement this will require quantitative calculation of energy savings and comparison with the savings target. Both energy and production data are required.

In addition to these major reporting requirements, there are other obligations including:

• Recording information about meeting the Qualitative Requirements (See Information Sheet 7).

• Recording information about emissions trading (See Information Sheet 9).

• Obtaining information to confirm eligibility and to identify compliance with the 90/10 rule (See Information Sheet 2).

Reporting will encompass all fuels, not just those subject to the Levy. Hence oil use, for example, must be fully reported.

For those sites that select an absolute target (See Information Sheet 3 for information on currency options), only energy data is required to assess performance at milestones. However, the site data must be consolidated with other sites to calculate MPMA performance expressed as CO₂ per unit of output. To cater for calculation of a relative target at MPMA level, all sites (including those with absolute targets) will need to report production data.

Reporting Methodology

The data required to meet the reporting obligations will be supplied on application to the MPMA Scheme and on an annual basis there after.

A standard Application Form will be used to gather all initial data. A form must be filled in for EACH SITE applying to the Scheme and returned to the Scheme Administrator. The data in this form will be used as the basis for issuing an Underlying Agreement and to define Base Year performance.

On an annual basis the Scheme Administrator will send customised data gathering forms to each Participant to gather the required data each year. The customisation will ensure that only relevant data is requested.

Levels of Reporting Complexity

The simplest types of site, from a Climate Change Levy perspective are those that purchase all their energy from utility companies and use it all in an eligible process. This type of site will only need to fill in the standard part of the Application Form. The majority of sites in the metal packaging industry are likely to fall into this category.

A number of factors will slightly complicate the data gathering and reporting requirements, including:

• Sites with CHP.

• Sites that import heat or electricity from a neighbouring site.

• Sites that export heat or electricity to a neighbouring site or to the national grid.

• Sites that are not fully eligible because they fail the 90/10 rule.

The Application Form will cater for these more complex situations via an extra section. At the annual data gathering stage the Scheme Administrator will be able to customise your data gathering form to take the site specific circumstances into account.

Participant Obligations

Participants will need to report relevant data within the timescale set down by the Scheme Administrator. Failure to do this could mean you lose your Levy discount.

All data is supplied on a self-assessment basis, but is subject to external audit by Customs & Excise. Hence data must be fully documented and auditable. Utility company invoices provide an important audit trail. Self read meter readings from both utility company meters and your own sub-meters may also form an important part of your data gathering methodology.

Application Form Explanatory Notes

The Application Form has been prepared with comprehensive guidance notes that should help Participants identify the correct data to enter.

Going Beyond the Basic Reporting Requirements

The data that will be collected annually by the Scheme Administrator represents the minimum level of reporting from each Participant.

It is important to point out that going beyond the basic reporting requirements could have benefits. The extra data need not be sent back to the MPMA Scheme Administrator, but it is useful "in-house". There are three especially important opportunities that will be missed if you only meet the minimum requirements:

1. Comprehensive energy reporting is one of the Qualitative Requirements. If these are not fulfilled you cannot apply the Risk Management options (See Information Sheet 8) at milestones.

2. Comprehensive energy reporting can be the basis of an analysis of the influence of product mix and product output level on specific energy consumption. Without such data you cannot use the Risk Management option linked to these parameters.

3. MOST IMPORTANTLY, comprehensive energy reporting can be the basis of an energy M&T (monitoring and targeting) system that can provide a low cost way of meeting your energy efficiency targets during the early years of the CCLA.

What does comprehensive energy reporting mean? There is no simple answer to this question – site specific circumstances must be taken into account. Clearly a site spending £1 million per year on energy will need a more comprehensive system than a site only spending £50,000. The general requirements of a good system are:

• The ability to sub-divide energy usage into appropriate parts to enable efficiency problems to be linked to particular parts of your site. This means that you need sub-meters for electricity, gas, steam, water, compressed air etc. A good rule of thumb is that if a system uses £10,000 of energy a year it is worth sub-metering.

• A system of regular data collection and analysis. Weekly data collection is appropriate for most medium sized sites. Very small sites may find monthly data collection is sufficient. Very large sites may use daily or batch wise data collection. However, data collection is only the starting point – the data must be analysed to identify energy efficiency opportunities.

To support the analysis process it is vital that relevant "production variables" are recorded on the same regular basis. These variables include production volumes, split into product types AND other "influencing variables" such as weather data or production hours.