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* 1. What are your views on the Government proposal to follow the current CCA scheme with a new, revised scheme; are you in favour of a follow-on scheme?

The current scheme is due to end on 31 March 2025 which means from 1 April 2025 members would pay full rate CCL on energy bills (12.5 times the discounted rate for electricity) unless a phase 3 is introduced.

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* 2. What is your view on the appropriate length of a new scheme?

Arrangements are mostly fixed for the entire length of the scheme. The current scheme started in April 2013 and was due end in March 2023 until the Government extended it to March 2025.

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* 3. What would be the appropriate length for Target Periods?

The first scheme used one year target periods, but the current, second, scheme uses a two-year period, to lessen the effects of weather and long production cycles.

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* 4. Do you agree with the proposal to review sector and facility eligibility for any future CCA scheme?

There are currently over 50 sectors in the scheme with tightly defined eligibility criteria. BEIS are prepared to consider removing some or adding others where there is a case for doing so.

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* 5. Do you agree that targets should remain primarily focused on energy efficiency?

The current scheme measures the energy used per amount of product produced during a base year to compare that with what is achieved in a target period.

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* 6. Should the scheme continue to have a surplus mechanism to allow overperformance to offset underperformance in future Target Periods?

Currently the scheme allows members who more than meet their reduction target to bank the surplus saving for use in future periods where they may not meet targets.

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* 7. Do you have any specific views on potential changes required regarding throughput measures used within any CCA?

Each sector will have different throughput/production metrics which best suit the evaluation of energy efficiencies. The current scheme uses broad categories, like weight of product, production area, etc., since it is difficult to establish baselines if more than one measure is used on a site.

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* 8. What would you change to any future CCA scheme’s process?

Every two-year target period members’ data is collected and their performance is compared with the base year performance to see if has met the target for that period. If it has, members can claim CCL discount for a further two years. If it has not, members may either elect to pay a buy-out, related to the excess carbon emitted, or leave the scheme.

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* 9. Are there any other criteria that should be considered?

Members views on the CCA scheme and hurdles you have faced.

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* 10. What reforms should be considered for the buyout mechanism?

The buy-out fee increased from an initial £12 per tonne of CO₂ equivalent to £14 per tonne for 2017-18 and finally to £18 per tonne for 2021-22, due to the significant increase in the value of the CCL discount.

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* 11. Which sector are you in?

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* 12. Please note, this question needs to be answered by Horticulture scheme participants only:

What are your thoughts on the current fee structure for the NFU Horticulture CCL Scheme?

Our fee structure remains the same and only RPI (the metric the Government uses as a basis for an annual CCL rate increase) is used when fees are increased. The fee was last increased in 2019. The fee depends on the amount of delivered energy p.a. last reported, for NFU members adjusted by RPI for 2022 would be about  0.0143p/kWh p.a. subject to a minimum of £275 p.a. and a maximum of £3,475 p.a. For members who use largely renewable energy this may mean much of their CCL saving goes in meeting the fee.

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* 13. Please note, this question needs to be answered by Horticulture scheme participants only: 

Are you in favour of a change in fee structure for the NFU Horticulture CCL Scheme which is based on CCL savings made?

We are considering a fee structure based on the usage of fuels which attract CCL, last reported in a target period, with the fee being about 3.5% of annual CCL saved on that quantity at the current rates of CCL in the membership year subject to a minimum for NFU members of a slightly lower figure of £230 p.a. and a higher maximum of £4,000 p.a. For the scheme as a whole, the fees change would be cost neutral in that both the current structure and the structure being considered would raise the same amount in the year starting 01 April 2022.

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