High fidelity record keeping

10th June 2013


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IEMA

Lucie Ponting discovers how CRC league table champion BAM ensures its energy records are top notch

Construction firm BAM Group topped the latest and final carbon reduction commitment (CRC) energy efficiency scheme performance league table (PLT), published in February. Under the CRC, organisations must keep adequate and up-to-date records in an “evidence pack” to support the energy data and other information they have provided to the regulator.

As well as becoming “league champion”, BAM was one of the first CRC participants to receive an agency audit of its records. “We got audited almost straight away,” explains Jesse Putzel, sustainability manager at BAM Construct UK, “which was good because we went through the process and had to have everything ready.”

The audit involves an initial desk-based investigation, after which – if this identifies anything worrying or there are gaps in the information – auditors will visit the site. “We provided a CD with the entire evidence pack on it,” says Putzel. “That was enough; they found just one tiny mistake in the data – amounting to an error of about 0.0024% in the overall return.”

Essential housekeeping

Although the government has now scrapped the CRC PLT, good record keeping by participants remains essential. Following the publication of the final PLT, IEMA policy director, Martin Baxter, pointed out that accurate data not only underpins the CRC as an environmental tax and affects how much money companies will pay for allowances, but it is also critical for the scheme’s reputation.

The four-month delay in publishing the 2012 PLT suggests that some CRC participants were not as well prepared as BAM, and may need to review their data collection and record keeping to ensure it is consistent, accurate and based on a strong methodology.

Be smart

BAM Construct UK – one of the two main BAM Group companies in the UK; the other being its civil engineering arm BAM Nuttall – manages the CRC on behalf of the whole group. “We took responsibility in 2008,” explains Putzel. “We were the larger company and had the most developed systems, though both firms already had mature environment management systems, which are key to how we deal with the record keeping requirements of the CRC.”

In practice, BAM Construct manages the evidence requirements of the scheme and some of the audit processes at a high level; then responsibility is spread around the wider organisational structure. “We were well underway with record keeping in its most basic sense when CRC came along,” says Putzel. “We were calculating our carbon footprint, so we were already grabbing hold of the necessary data – speaking more with energy and fuel suppliers.”

The next step was to start working with the commercial teams to set out the implications for buying energy and for setting up project contracts – creating the partnerships necessary for good CRC reporting. This, and subsequent work to define who was responsible for what – for example in more complex private finance initiative projects – helped to build the structural records required under the CRC, which describe the organisation, how energy is purchased and who deals with it.

As well as structural information, CRC participants must keep a raft of data records in the evidence pack. For this, the cornerstone of the group’s approach is its online BAM sustainability measurement and reporting tool (BAM SMaRT), a bespoke system launched in 2010 and based on the Building Research Establishment’s SMARTwaste system.

“We started collecting energy data at project level in 2004/05 using Excel spreadsheets,” says Charlie Law, head of environment management at BAM Construct. “But, by 2008, the pressure for better data and reporting was increasing, not just with the CRC but elsewhere for waste, water and timber.” The spreadsheets were also getting far more complicated because of the amount of data captured on different fuel types and meters.

BAM SMaRT lists every project for each construction region and uses a simple traffic light system to show whether the required information is up to date. “We wanted good data, and to know people were reporting on a regular basis,” says Law. “If it’s not regular, things get missed, so the traffic lights allow the environment advisers in the regions to see at a glance if any sites or projects are lagging.”

The tool’s design means it is quick and easy to enter data. Each project manager is ultimately responsible for their project’s energy use and emissions, but they generally nominate someone onsite, most often the site manager, and it is frequently the site administrator who physically enters the data.

Projects set up their meters in SMaRT, and populate the record with data, such as the supply company, MPAN number, and who is paying for the energy supply – whether it is BAM, the client or a contractor. “We also monitor our client-provided supplies even though they not part of our CRC, so we get a full picture of each site’s energy use,” says Law.

“The important thing is having the data at the most granular source we can get,” adds Putzel. “Each meter is monitored, and we also attach a use type. If we can confirm that energy supply is used for accommodation or for the permanent building, it gives us a much clearer picture.”

When BAM introduced this level of granularity, staff were not necessarily used to picking out four different meters and identifying individual subcontractors and their fuel use, although they were already used to collecting data. “It was more about changing how we brought the information together and how they reported it; the culture was in place and it was a very good base to start from,” says Putzel.

Human error

In December 2012, the agency noted that its CRC audits had identified “human error” as the key source of reporting errors “on numerous occasions”. In light of this, it advised all organisations manually typing in supply figures or meter numbers to ensure they had a “robust quality assurance process” to double-check figures. “We can get the odd mistake with data,” admits Law. “But we get fewer now with automated meter reading [AMR]; it’s made life a lot easier.”

On fuels (which are no longer included in the CRC under the revised framework), mistakes are more common. “There might be the extra zero – 10,000 instead of 1,000 litres – but these show up quite easily.”

To control for errors, once the data is inserted, each regional environment adviser spot checks the figures. If they see anomalies, they flag it and investigate, and Putzel also looks at the high-level figures to identify exceptions. BAM is currently developing its exception reporting further to obtain even finer detail. “We now see exceptions at a higher level,” says Law. “But we want to drill down deeper and, if something is outside certain parameters, to identify the reason.”

“Audit checks are an important aspect,” adds Putzel. “But you need people on the ground to take responsibility and ownership of the data and records. Then you have to do far less checking.” To reduce mistakes further, BAM now records who enters the information. “If the data is entered incorrectly, we can identify who did it and train them further so they better understand the process,” says Law.

Such a bottom-up approach not only reinforces the importance of inputting accurate information but also gets people to act on what the data tells them. “They see the energy they’re using and where,” says Law. “It’s a lot more visual and accessible.”

The firm’s central energy management service, for example, models costs for a wide range of plant. In one case, this identified the inefficiency of site drying rooms, which were using lots of energy but not drying workers’ wet clothing effectively. Introducing dehumidifiers not only used one-quarter of the energy of traditional drying rooms, but also dried the clothing properly.

“The spin off from gathering the figures, keeping and comparing records, is that benefits come through,” says Putzel. “Then you get more buy-in from project and site management teams.” Buy-in is also crucial in getting tools adopted. “Metering was a bit of a sales job at the beginning – with remote metering, we had to get people to take it up on projects. They had to pay for it, so they needed to see benefits too.”

Back-up evidence

In addition to being a CRC participant, BAM is also participates in the certified emissions measurement and reduction scheme (CEMARS). “We are audited in multiple areas,” says Putzel. “They look at every detail, so it’s very important that we have evidence against each piece of information; the auditor needs to see immediately where every bit came from and how it’s backed up, which often isn’t easy because the data comes from lots sources.”

BAM keeps the CRC evidence pack on its network in its environment management system folders. The pack’s structural records show at a high level where emissions come from and which emissions qualify for what scheme – CEMARS or CRC, for example – as well as the different checks made on sources of data. BAM SMaRT identifies all the firm’s projects across the regions, the AMR meters and supplier reports on a quarterly and annual basis, both for energy (from EDF) and the firm’s seven core fuel suppliers.

BAM also uses its financial systems to double-check that sites are recording all their paid-for energy. “We have a SAP financial system and an online document management system [Livelink],” explains Putzel.

Monitoring at source is obviously crucial, he adds. “I don’t think relying on bills at a corporate level is anywhere near enough; you need to drill down.” But the next stage is then having the right checks through the finance system or through some other system. “Having two or three checks is really important,” he emphasises, “because you can seriously over or under report, which has compliance and cost implications beyond carbon.”

Both BAM Construct and BAM Nuttall also do a specific internal CRC audit of the evidence pack, which is signed off by a director before submission to the agency.

Do it yourself

Beyond the CRC, the broader issue of how best to ensure records satisfy the changing array of internal and external reporting requirements remains a challenge. Putzel acknowledges that for some firms there may be issues with reporting different things to different people. “We probably do three different reports: the CRC is different to CEMARS, which is different to what we report to our parent for its Carbon Disclosure Project return. But, to be honest, because we’re reporting from the bottom-up, we can record whatever we want and filter it off for whatever we need; then it’s about putting it into a different format.”

Law adds: “Depending on who we’re reporting to, we can then take out certain sources.” With CRC, for example, fuels are no longer included, but when BAM in the UK reports to its parent company, fuels will be back in. “Our best advice to people who are not so far down the line in record keeping and reporting is to get that granularity of data,” says Law.

“The important thing is how many litres, how many kWh, and what these are used for, rather than starting by thinking, ‘we spend £1 million on energy’, and then making assumptions,” says Putzel.

For the CRC, the evidence pack is the basic compliance element. There is no set way to store or bring this together, although the agency produces extensive guidance on what it should contain. “Some [organisations] just buy a piece of software that does it all for them,” says Putzel. “But we chose to do it ourselves; we were collecting data in our own way anyway.” Because BAM SMaRT is not there just to deal with CRC, however, the firm still keeps specific spreadsheets to summarise the information into the right format for CRC.

Overall, BAM’s main tip is to keep core data and associated records flexible and robust so they can be adapted to whatever comes along. “When things change or new requirements come in, you need flexibility and control; try to do it yourself because you know your systems and your business,” advises Putzel.


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