Helping the NHS with EU-ETS compliance

The Challenge

Barking, Havering and Redbridge University Hospitals NHS Trust operates across two main sites at Queen’s and King George hospitals serving a population of around 700,000 making it one of the largest acute hospital trusts in England. The trust has two combined heat and power plants, large boilers and thus qualifies for the European Emissions Trading System (EU ETS).

In 2009, the person responsible for EU ETS within the Trust retired, and it was decided to hire a consultant to provide assistance and direction for fulfilling EU ETS responsibilities.

What we did

As an experienced EU ETS Lead Auditor and Technical Reviewer, Carbon Architecture’s Peter Simmonds was able to help make the necessary compliance demonstrations for the EU ETS auditor, as well as advising on issues that crossed over with the CRC Energy Efficiency Scheme.

Following the first verification under his guidance, Peter re-wrote the Monitoring and Reporting Plans, and had them approved, so that the method of calculating and reporting emissions has been more easily achieved going forward.

He also completed the application for obtaining free allowances in phase 3 of the scheme, and ensured that the submission resulted in a successful audit outcome. This has secured an initial earmarked allocation which will offset a considerable proportion of the forecasted emissions post 2012.


In 2010, Peter identified that for Queens Hospital, Romford, it would be possible to make an application to the New Entrant Reserve for free CO2 allowances in phase 2 of the scheme. The Trust accepted the proposal for the necessary application work at the end of September 2010, and by mid November 2010 nearly 25,000 allowances had been determined in the Trusts favour, having an approximate current total value of £ 140,000.

Peter continues to be retained and is currently helping the Trust consider options in phase 3 of the scheme, taking into account the availability of the EU allowances described above

Jandi Pearman, Sustainability Manager at Barking Havering and Redbridge University Hospitals NHS Trust:

In view of the risks and opportunities associated with the EU ETS legislation, we believe that it makes good financial sense to retain Peter’s services. Bringing one of our own managers up to speed to cope with the ever changing EU ETS requirements would be time consuming and would detract from other responsibilities. We are also aware that our own people might not be able to provide the same level of information for making properly informed decisions in this specialised area, and that this could result in either a financial penalty or a missed opportunity.

Peter’s professionalism, quality of service, technical ability, organisation skills and willingness to help have been particularly welcome in the current challenging climate within the NHS. We would recommend his services to others in a similar position to ourselves.

Carbon Architecture has extensive experience of providing consultancy support on emissions schemes.  With an UKAS approved EUETS Lead Auditor in our team, experienced administrators of Climate Change Agreements, and providing EUETS support services to 15 operators, we are well placed to help you reduce compliance costs.

About Dan Jackson

Dan Jackson is a process and sustainability consultant. He has experience in helping clients reduce energy and cost in the NHS and across the hospitality supply chain, from breweries to pubs.