CCA Policy Update: TP6 Actions, the Government response to the consultation on New Scheme

Please some updates on the Climate Change Agreement for data centres: 

Target Period 6

An “Energy Efficiency Declaration” will need to be made in support of your target period 6 data returns.  While we don't know what this will look like yet, SLR Consulting, who administers the CCA on behalf of techUK for the sector, advise that it may be that if this isn’t provided by a facility then a penalty will be brought against the company concerned.  They will provide more information when they receive it from DESNZ and the Environment Agency (EA).

The Department for Energy Security and Net Zero (DESNZ) has published a government response to the Climate Change Agreements: consultation on a new scheme.

New Scheme Summary – Highlights

• Start date pushed back a year (1st Jan 2026): 
  • The first Target Period of the new scheme will start on 1 January 2026 and be for 12 months, the remaining two target periods will each be for 24 months.

• 2022 Base year, with targets out to 2030

• Sector eligibility criteria unchanged: Eligibility remains unchanged but existing participating facilities will not automatically be transferred to the new scheme; all facilities will be asked to confirm that they meet the existing eligibility criteria before the start of the new scheme.

• No automatic transfer for existing participants

• New entrants:
  • There will be a new entrants window which will run from 1 May – 31 August 2025, for new entrants from all currently eligible sectors to apply before the start of the new scheme.
  • Additionally new entrants in eligible sectors will be able to apply to join the scheme between 1 January and 31 August of each year within a Target Period.

• Reporting of UK ETS data (not assessed in target)

• No ‘bubbles’ - Facility level reporting and targets only

• Reporting of energy efficiency actions

• Annual reporting

• Mandatory CHP SRM (if eligible)

• New data requirements (fixed vs variable energy)

• All Novem style targets (single product or multi-product)

 Target Period dates:

• Targer Period 1: 1 January 2026 to 31 December 2026

• Targer Period 2: 1 January 2027 to 31 December 2028

• Targer Period 3: 1 January 2029 to 31 December 2030

 Certification Period dates:

• Certification Period 1: 1 July 2027 to 30 June 2029

• Certification Period 2: 1 July 2029 to 30 June 2031

• Certification Period 3: 1 July 2031 to 31 March 2033

Some areas of concern:

• Facility level data will be gathered to inform target setting process.   DESNZ have stated that the representative sample should reflect a minimum of 70% of energy in the sector CCA.

• Data collection window for target setting is 1st January 2025 to 31st March 2025.   Data for informing targets would be collected from the operators using an excel template, operators would be required to provide detail of planned abatement measures along with expected savings in terms of either fixed or variable energy, as percentage and cost.

• We have concerns about the confidentiality of this process and whether operators would be willing to divulge potentially confidential information.   We are also worried about the complexity of the proposed spreadsheet, meaning facilities will not engage in the process.

• Targets will be set using the Novem style methodology

• The proportions of fixed energy consumption (FEC) and variable energy consumption (VEC) in each facility will need to be determined. 

• The primary electricity factor for self-generated electricity PV, wind or hydro will be updated to 1.0, and the carbon emissions factor will be 0 tCO2e/kWh.

• Bubbles: Participants will be required to report energy and throughput data and to report actions taken during Target Periods to improve energy efficiency (and where appropriate, decarbonisation), as part of the interim and end of TP reporting. Information on energy efficiency and decarbonisation potential should also be collected through the target setting process. Bubbles are no longer allowed so reporting is at facility level and will need to be reported to the EA annually. This will have a significant impact for some sectors with increased administrative burden for operators of large bubbles consisting of small sites and an inability to transfer any carbon surplus between facilities.

Please find attached here a detailed briefing by SLR consulting who administer the scheme on behalf of techUK and data centre members. In the meantime, should any of the above be a concern, please do reach out to Luisa Cardani.

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 Meet the team 

Luisa C. Cardani

Head of Data Centres Programme, techUK

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Luisa C. Cardani

Head of Data Centres Programme, techUK

Luisa C. Cardani is the Head of the Data Centres Programme at techUK, aiming to provide a collective voice for UK operators and working with government to improve business environment for the data centres sector.

Prior to joining techUK, Luisa worked in the Department for Digital, Culture, Media and Sport as the Head of International Data Protection, where she led on the development of elements of the UK's data protection and privacy policy. In her role, she was also the UK official representative for the EOCD Privacy Guidelines Informal Advisory Group.

She has held a number of position in government, including leading on cross-cutting data provisions in the EU-UK Trade and Cooperation Agreement, and in high priority cross-departmental projects when working in the Department of Business, Energy and Industrial Strategy.

She holds an M.Sc. from University College London's Department of Political Sciences.

Email:

[email protected]

Phone:

07587 210 799

Website:

www.techUK.org

LinkedIn:

https://www.linkedin.com/in/luisacardani

Weronika Dorociak

Programme Manager, Sustainability , techUK

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Weronika Dorociak

Programme Manager, Sustainability , techUK

Weronika joined techUK as a Programme Manager for Sustainability in October 2023.

Her role involves advocating for the tech sector in front of key policymakers and stakeholders. Weronika also leads the environmental and sustainability efforts within the Data Centres Group.

Prior to joining techUK, Weronika worked in public affairs and government relations in the legal sector, focusing on innovation and ESG within financial services. She also spent 2 years working as a Caseworker at Parliament. She holds a BA in Politics & International Relations from Queen Mary University of London.

Outside of work, Weronika can be found on a tennis court, at the gym, practicing yoga, or indulging in her love for Taylor Swift's music as a dedicated Swiftie.

Email:

[email protected]

LinkedIn:

https://www.linkedin.com/in/weronikaedorociak/

Lucas Banach

Programme Assistant, Data Centres, Climate, Environment and Sustainability, Market Access, techUK

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Lucas Banach

Programme Assistant, Data Centres, Climate, Environment and Sustainability, Market Access, techUK

Lucas Banach is Programme Assistant at techUK, he works on a range of programmes including Data Centres; Climate, Environment & Sustainability; Market Access and Smart Infrastructure and Systems.

Before that Lucas who joined in 2008, held various roles in our organisation, which included his role as Office Executive, Groups and Concept Viability Administrator, and most recently he worked as Programme Executive for Public Sector. He has a postgraduate degree in International Relations from the Andrzej Frycz-Modrzewski Cracow University.

Email:

[email protected]

Phone:

020 7331 2006

Twitter:

@techUK

Website:

www.techuk.org

LinkedIn:

https://www.linkedin.com/in/lucas-banach-50139650