Name: Let’s talk BICS: How the UK Energy landscape Is evolving and what it means for you
Uploaded: 2026-04-23T11:16:06.994Z
Duration: 1 h 1 min 52 s
Description: Let’s talk BICS: How the UK Energy landscape Is evolving and what it means for you

Transcript for "Let’s talk BICS: How the UK Energy landscape Is evolving and what it means for you": Morning, everybody. Anybody is is on. We'll we'll give it a couple of minutes to to let people join, and then we will kick off. Morning, everybody. And welcome to to our our webinar, how The UK energy landscape is evolving, what it means for you. It's all a conversation about BICS, which is bit of a hot topic in the energy world or in the energy exemption world at the moment. So, thanks for everybody who's attending. I'm I'm here today with Dean, who's our UK energy lead. My name's Zach. I'm I'm the head of energy here at at Leighton, so I've been heavily involved in in understanding BICS, getting to the bottom of it, getting an understanding as to what it is and and how it how it all affect businesses across The UK. So we're gonna have a bit of a conversation today about it and and and hopefully give you a bit of an insight into what BIX is and and how it might impact you. I suppose to kick us off, introductions. As I said, my name is Zach. I'm I'm head of energy here at Leighton. So I've been at Leighton for about three years, and I've been in the energy industry ten, fifteen years. So, predominantly on energy supplier side, energy consultancy side, and I kind of specialize in in energy, exemptions and carbon reduction, net zero strategies for businesses. So I've, I've been speaking or I work very closely with the Department of Business and Trade, DBT, so I've been speaking to them a lot recently around how BICS, is likely to impact the energy market and how we can make sure it effectively has as many people or any businesses can be involved in it as possible. Dean, do you wanna maybe give yourself a bit of an introduction? Yes. Hi, everyone. I'm Dan, the The UK energy lead here. So I I focus primarily on supporting our clients to sort of assess their eligibility for all of the different incentives that we we help businesses with. And Bex is is something that everybody's talking about. It seems to be the thing that's been publicized the most out of any sort of business measure that the government are currently implementing. So, had a lot of conversations on it already, and I hope to have a good chat about it today. It it certainly seems to be the thing that's been mentioned most in the last week or so. So at the end of end of last week's, consultation response. Well, may maybe that's the the best place to start is maybe to be just to set seen us handy bit, and give you a bit of an understanding as to why we're having this webinar in the first place. So, BICS, for those who don't know, is a scheme that was, literally announced in November 2025 by the government as a way of supporting, large, generally large energy users, although it is still available to the SME market, but energy intensive organizations, with the rising cost of energy. The cost of energy has has been a huge topic for a number of years for businesses. I I was selling energy in 2015, 2016, 2017, and, actually, the journey was always for businesses was energy markets would go up and down, but but not hugely drastically. Since 2021, that hasn't been the case. The market has been really volatile. Climate politics, world politics has all impacted it. I think energy has become a a huge impact for businesses across The UK, and I see it on a regular basis in a way they didn't used to be, previously. BICS was was formed as a a scheme to help businesses with the cost of energy, ultimately. First announced in November 2025, the consultation run from January, through to last week, and the response to the consultation came out last week. Hence, we are here today. And what it is is a scheme that the government is suggesting will will support up to 14,000 businesses in The UK. Overall, a reduction in energy bill that's estimating at 25%. Whether that will be the case or not remains to be seen. The consultation response, as often when you get consultation responses from government bodies, answered a lot of questions, but actually raised a lot of questions and also didn't answer other questions. So there there's still a bit of detail around bits that hasn't been, confirmed. But, actually, the bits that really have been, and and some of that is certainly around eligibility. There's certainly some interesting points there around how it will be funded and the benefits that will come from BICS. And the other thing that I think was really interesting is there's definitely desire to to start the ball rolling. So where the government are keen is businesses start thinking about this now as there is likely to be a a fairly quick turnaround in terms of this going through parliament and from there, being able to start making claims, the business is trying to get some benefit. One thing that we were clear about in the consultation at Leighton was was we're absolutely for any scheme like this that supports business with energy bills, but the support is needed now. Waiting a long time for the support is not gonna benefit businesses because it's it's something that's required, very quickly. And interestingly, since consultation, obviously, we've also seen challenges, in Iran has made a a huge impact on energy prices generally. So I think even there, this is even more important than ever it was. So this that's what the consultation was. That's why we're here today, is maybe talk to you a tiny bit about what the scheme is, give you a bit of an overview, but also maybe give you our opinion on it, let you know what we think the challenges might be, and how you might be able to overcome those challenges and make sure that kind of you take advantage of it as much as possible. So from our point of view so for the agenda, we'll we'll we'll talk about why we're talking about it, what it is and who can qualify. We'll talk about the challenges, and we'll probably even do a good tiny bit about how it can fit into your broader energy strategy to make sure that actually from an energy point of view, you have a strategy. Because as I said, all of those outside, factors are really, really challenging. Having an energy strategy can really support you in terms of just making sure you don't have to suffer too much with, the weird and wonderful things that go on, in the in the current world, economic climate. So who are we? We're Leighton. So Leighton, we we are a business consultancy. We're gonna talk today about energy, but, actually, as an organization, we we help businesses across variety of different areas, r and d tax credits, capital allowance, business rates. We work across The UK and Ireland, but also we've got bases, across a number of different countries, 17 countries in total. So we're a significant organization. And because we're we talk to businesses all the time around a lot of different things, one of the reasons we're talking to you today is is the question of energy comes up now more than ever. How do we reduce energy prices? What can we do about energy costs? And how can how can a business support them? So that's who we are. Largest independently owned tax incentive consultancy in The UK, and I think that's where it allows us to be really well placed to be able to give you kind of some advice on on these things that are happening. But we're in stock by BIC, so let's let's talk about it. That gives me an idea then of of what it is. Energy costs remain high. We're still in a very volatile market. The support's great, so we're seeing more, support from government. But as I said before, the support can be complex. It can be quite difficult. Being able to qualify can be can be difficult for businesses. Understanding whether you're eligible can be different for businesses. The guidance often isn't clear. So there's lots of challenges for businesses, and and we kind of remain positive that there are more schemes. We're delighted that Pix is coming out, but there's still some work to do to try and get people involved in it. So, maybe to kick us off, Dean is a bit of an expert in this area. I do actually, I do a bit of a disservice. He's more than a bit of an expert in this area. He's he's he's a real expert in this area. So maybe actually, Dean, it's a good place for you to start and to kick us off in terms of, give us a high level overview of what exactly is Bix. Well, BECCS is essentially an exemption scheme, and it exempts businesses from three of the sort of taxes or levies that's imposed on their electricity supply. And it it's come about because the government has what they call their industrial strategy. And what they're trying to do there is they're trying to support UK manufacturing, primarily advanced manufacturers. So what they've come up with is an incentive where these advanced manufacturers, if deemed eligible, can remove these taxes from their electricity supply. And, they've also then thought about it, hopefully, thought about it a bit more and said, right. Well, how do we support advanced manufacturers? Well, it's actually all of the supply chain that's underneath them as well. So what we have is two areas they're calling frontier sectors, which is the advanced guys, and foundational sectors, which is the people that support them. So they've they've got a a essentially a a list of sort of sick codes and and sectors that they've deemed as being eligible, and then they've pinpointed specific manufacturing activity or products as such within each of those that is due to get this this exemption. So seeing that, you know, sort of advanced manufacturers think about cars, planes, defense, etcetera, and then all of the supply chain under them. So think about, metals, chemicals, you know, glass, etcetera, etcetera as well. So, what what we are yet to get is just a absolute certainty on all of the guidance, but what we have so far on the outcome is essentially, very much the the what we believe will be the absolute core. This is the sectors that will be included. This is likely how it'll go, and I suppose we'll we'll get into that in a little bit. So to me then, then part of that would be that that seems like there is a crossover to some of the other government schemes. So if you think about EII exemption particularly, it feels like some of those sectors or some of those areas already have EII exemption that is is focused on that area. What's is is there a big difference between this and, say, EII exemption? The EI exemption EII exemption is is, already in place. What it does is it actually exempts you from several taxes, not just these three that we're talking about. So the three for BECCS is renewable obligation, feed and tariff, and capacity market charges. If we add those three taxes together, that's about 4p per unit reduction. So if you get a 100% exemption, you'll drop your unit rate by about 4p, which can be a pretty hefty percentage discount overall. The EII exemption we're talking about isn't open to as many sectors. It's more the sort of heavier industry, I suppose. And what it does is it it has some more taxes involved, things like the contracts for deference, nuclear, one of the new ones. And it also has a build on to that called the network charges compensation scheme or NCC. So I get confused to all these, acronyms flying about. So that in can be worth the tax side of that EII scheme's worth about 5 and a half pence per unit. So it's a wee bit more lucrative if you can get on to it, but it has a very high barrier to entry. It would be much it's much harder to get on to that, and that's all to do with intensity. The intensity or your electricity intensity, again, some of your financial metrics. So, to frame it, I suppose, a little, the EII scheme has about 550 companies at the moment, and Bex, they're saying, is going to be, you know, 10,000, 14,000, whatever it may be. So this should be open to a lot more more businesses individually. So okay. Well, that's interesting because if you think about fundamentally why this is set up, this is set up to help more businesses with the cost of energy. I think my view has always been the EII exemption scheme. Although, in theory, it's a great scheme because it's being set up for for the right purposes. Actually, a lot of businesses aren't eligible for it, and that's probably the biggest challenge for businesses. It feels then like maybe this is the little brother of that scheme whereby, actually, a bit easier to get into. Benefit's not quite as good, but, actually, as you say, 4p a unit off your energy bill is is still a fairly significant amount. So that's that's that's really, really positive. And then the sectors winding out allow just another section of businesses to maybe get that kind of benefit. Okay. I I get that. That that makes sense. So who would you say fundamentally this this scheme is designed to support then? If it's, you know, ultimately, what what kind of organizations do the government wants or who are they trying to help? Which sectors in in in in detail? Yeah. Well, they've got, you know, automotive, aerospace, defense. They also have, you know, all of the sort of subcategories underneath them as well. And it it's really you know, if if if we want to keep maintaining, you know, building vehicles in The UK, then we need to support not just, you know, the JLRs of the world, but everybody who support who supports them on the way, you know, up to that sort of car being made. So it's it's quite broad in that sense. Defense, obviously, is something that's become maybe a bit more prevalent very recently, but it has been, you know, something that's been on the agenda since, say, Ukraine, for example. So it's the defense sector, which typically hadn't ever received anything on any of the incentives. And, you know, there's some outliers in there of eligibility. You know, for example, the manufacturer of sugar has been included. So, you know, that might have been, you know, something that was, I don't know, heavily lobbied for. I don't know. Or it could have been could have been a case that, you know you know, we don't have that many many sugar refiners in The UK. Maybe we want to keep some. So there's various different sectors that this went after. But if you think about it, it's all manufacturing entities, and that's, you know, that's the core things. At the minute, it just feels like we're watching in the news manufacturers closing all the time. So the the scheme needs to hasn't, needs to deliver on what it's open for. I remember, when the consultation came out, I I did a fair bit of work with a number of, federations and associations. And I think the thing that came up a lot was, will it support the the supply chain? Predominantly, I think that was the biggest challenge I found from from certainly large manufacturers. Because as you say, there's a lot of these areas. There are schemes available for large energy users or, intensive energy users, but it seems to be very much focused on those organizations who are are a natural fit. And, actually, there's a massive supply chain. I know I always remember JLR. When the issue JLR hit last year, I remember talking to a lot of businesses around how they could support themselves because they were part of the supply chain. Does this scheme do you think it's it's maybe done the work that those associations wanted in terms of supporting a fuller supply chain, or do we think there's maybe still gaps in the list of available eligible sectors? would I would definitely say there's still gaps. You know, what the so the most prevalent one was when the consultation was first announced and the the list of potential sort of industries were there, they had included all chemicals. So that wasn't just, you know, so your basic chemical manufacturing. That was people who made, you know, pigments and dyes, people who made soaps and detergents and, you know, various different things. And that that was on there, it said all chemicals. And now that we've actually got the outcome of that, they've they've pretty much removed the the majority of that. And this is the sector. These were the the categories within chemicals that weren't able to get EII. We thought, great. These these sectors will be able to get the BECS scheme. And now when the outcomes have finally been launched, it's they've been removed, so they're back to square one. And, unfortunately, won't won't be getting anything. But, again, there's, you know, like, what we've done in for other businesses looked at, you know, their their their manufacturing process to determine, you know, is the part is the first part of their process eligible or something like that. So there's always still an angle or a potential angle to to review. But, yeah, there's been a lot of initial factors we thought were being included have all been pulled out, unfortunately. It's HJ, I I take your point in what you say there, interestingly enough, around, around some sectors not being agile that you thought it would be, but also around there being an angle to try and get eligibility. My my opinion on these kind of things is, and having worked with the on the other schemes, the guidance is never absolutely clear even when the full guidance comes out. There's always areas that I think certain businesses, are able to maybe get eligibility or look at a way of being eligible, because the guidance isn't totally clear. It's one of one of key things I'll probably jump ahead and what probably one of my bits of advice right at the end would be would be, I think, for all organizations, it's around your specific situation. And don't assume you're not going to be eligible, or don't assume you are going to be eligible just based on some really, really high level SIP codes. Certainly, government or or DBC in particular tend to do quite a lot in their scheme. So have they'll just try and bracket a lot of people into one area. And if you're in the area, it's wonderful. If you're not, you fall outside of it. You don't get that benefit. But, actually, some businesses do lots of different things and impact different areas. So, my advice certainly to any business would be just look at your own particular, situation because the you may find you're eligible and you you don't believe you are. I mean, that's that's all around sectors and products and and, processes and eligibility from that side. Is there any other eligibility other than because, again, I'm and I I don't wanna talk too much about the EIA exemption scheme, but, again, there is there are all the tests other than just with SIC code. What is is that the case for BICS, or is is that not the case for BICS? So Beck's has been a little different in that, and they've articulated that not an individual business does not need to pass an intensity test as such. What the department for business and trade have essentially done is they have looked at a a sector as a whole using, I believe, ONS data or something along those lines and run a test themselves. And that's what that new list that's came out alongside the outcome of of eligible sectors is are articulating, basically. We've done a test at the sector level. We have deemed these these sectors to be intensive enough. However, when it comes to then actually achieving and receiving the exemption, there has been a few, I suppose, gates to to entry. And the first gate is that a a business now needs to be able to to demonstrate that 25% or more of their electricity is consumed in eligible manufacturing. Because if you're below 25%, unfortunately, you will not receive any benefit. So they they almost have included an intensity test just in a roundabout way. And because at the moment, if you were, you know, an EII business and you made several products and one of them was eligible and it was only 10% of your energy, Well, as long as you pass the the initial intensity test, you would be able to claim on that 10% and get a 10% exemption. At this point, it's sort of like a gated process. If you're below 25%, you get zero. If you're eligible manufacturing consumes 25 to 50% of your electricity, then you get a 50% exemption from those three taxes. And if it's over 50%, then you get a 100%. So it's essentially three gates. It feels like then yeah. Like you say, that feels like there is an intensity test, although not necessarily in the same way as other schemes. It feels like there's still a way of doing it. How how is how are they gonna, are they gonna review that? That that seems fairly Yeah. difficult or challenging to be able to absolutely guarantee the percentage of your energy that is intensive or not. I I'm not quite sure how you'd go about that. Do have they have they given any detail on how they'll go about that? No. They've they've not really given any methodology, to to calculate that apportionment. You know, in all the other schemes that do, you know, similar things, we need to split out where energy is being consumed in a business. Is it eligible? Is it not? Etcetera. And the the go to phrase from department for business is typically a fair and reasonable apportionment. And we've sort of honed in on the the methodology that they're you know, will accept and works for everything. However, they have launched a second consultation straight after the outcome of this, and it articulates that, this is some of the stuff that they're gonna launch later down the line as the outcome of the second second consultation. They love a consultation. There's one thing that, Yes. that every government body loves is a consultation. So, yeah, so you say there's been a second consultation, Lewis. These so the second consultation is essentially more about my or correct me if I'm wrong. My understanding is the second consultation is is more around how it's going to be delivered. So less around so the first consultation is this is this is what's included. This is how it's gonna work. But the second consultation is a bit more around the detail of, okay, how does it work? Is it is that right? Yeah. I think it's it's more about, you know, what data are we gonna ask a a business to provide as supporting evidence? How do we want them to, you know, structure that data? And what is the actual, application process? They've given us an indication of the sort of timelines, etcetera, of when things will happen. So that that consultation but the I would say the majority of our consultation is actually geared towards the suppliers and getting them up to speed and getting their thoughts on how they will, you know, be able to forecast renewable obligations going forward if there's gonna be you know, 10,000 businesses exempt from it to some proportion, etcetera, etcetera. So there's a lot of questions in the second one. Really, I think, is geared more towards the suppliers. Yeah. That makes sense. I mean, as as an ex blind myself, I know there's there's there's difficulties in doing this, and I've never been want to necessarily, I'm not gonna sit here and necessarily defend all suppliers, but, I think I mean to deal with them on the other side. But the reality is there is a fair bit of complexity in them easily getting the billing right. I I was aware that I think I think I read some of the responses to the first consultation from suppliers where we need more time for this. And I think this interest for me, the the biggest challenge around this whole thing is timing. I think businesses need support today. I think suppliers are pushing back and saying, well, we can't do it until later. I think there has to be a middle ground. And, actually, one part just get on to that. I think one part that really interested me in the consultation is essentially the the backdate opportunity, which I know hasn't we haven't had much detail around it, have we? Is that right? I mean, I. I read about it, and it was interesting that they responded to say, look. We're gonna look at these some backdating, but there's not much detail around it. What what's your understanding of the of the backdating claim that they've made in the country? much what you said, they they've said and articulated we're gonna backdate until April 26, but they've not actually give us any indication of the mechanism. You know, is it just a is it everybody who applies in the first cohort of of, you know, of applications, first 10,000? Is it limited to certain sectors that they believe need additional relief. You know, they've really not articulated that. I think it was very much something, you know, it's re Rachel Reeves essentially in announced it. There was maybe one line in the whole of the the consultation outcome that alluded to the the back date, and that was it. And so, obviously, it's good that there's a back date. Still, it's, you know, making people wait until they get the benefit. But, again, there's not enough detail for me to be able to say, you'll get it, you won't, or anything like that. Okay. I know I know it was it was the thing. And we'd just be clear, at later, we we also responded to consultation back in January. And the thing we one of our key points in it was we felt the timing, was too long. So just I don't think we've covered it or not. The the current plan is that this scheme will start in April 2027, but that will be the start of the exemption. So your your exemption will start in April 2027. The application process, so the process to get the exemption, we expect to start a lot sooner than that. I having worked with the partner business trade for a long time, the thought of 10 to 14,000 businesses all making a claim at the same time, fills me with more than bit of horror. So, and if if that date is March, April 2027, and then all of those have to go to a supplier to get exemption, that does not sound like a process that will work for me. So, my expectation is that the window will probably open before then, but, who knows? It hasn't gone through parliament yet, and, there's still some detailed unknowns. So it's interesting you kinda say and then if we have a backdate, it add in to that. So there's unknowns. I think I suppose from my point of view, I would be saying to any business out there, there's unknowns. But, look, if you're if you're in that list of activities or sick codes that's come out, you know, there's a high level of chance you're going to be eligible or at least there's an opportunity for you to be eligible. Certainly start thinking now around, your intensity and how you can measure that intensity intensity. It's like anything else. The stronger the claim, the more opportunity you've got generating this this, this value, and it is significant. 4p off your energy bill is a significance chunk. So I think what you're looking to do here is, is be prepared and and be ready whatever the outcome of the consultation. And that backdate was quite interesting. The other thing I'd I'd like your thoughts to do would be, the other thing I felt was very different to other things was is my understanding is this is all gonna be on sites level rather than company level. So do you think that will lead to any challenges for businesses if it's a site claim? But, yeah, you know, business will now need to track their consumption on a site by site basis rather than as a, you know, a a total legal entity. And they'll need to to understand, you know, is that site doing more than 25% of eligible manufacturing? Yes. Then is it over 50 to get a 100% relief or 50% relief? You know, and they'll need to articulate that for every site. So the more sites a business has, the more complex their application process is going to be. And I and I actually just wanted to to touch on, the timeline, Zach, on the previous with the within the second consultation that they launched, it did allude to a proposed timeline. That proposed timeline is that applications would open in October. Mhmm. And. What's quite seen there? so what that would mean is applications open in October. They've then said they want to have all 10,000 plus applications processed by something like the January 8, so three and a half or three and a bit months. And then they want to give, the certificates either to back to the, you know, the the claimers or maybe straight on to the suppliers so that the suppliers have time from the January 8 right through to the April 1 to make sure that, basically, they have everything in place so that from the April 1, if you're due an exemption, you're actually getting it. You know, and you alluded to it earlier, Zach. The the fact that this went you know, the biggest the other biggest scheme here is the EII, and I said there's only 550 or so businesses claiming that. The fact that this is gonna be, what, twenty twenty times that is, you know, quite a scary thing because we've watched how they, sometimes fumble with 550 applications on EII. So I don't know how they're gonna fare when it's, you know, 10,000. Yeah. I I think that could be an interesting end to next year if those timelines work, which I hope they do because I think I think having getting that that in and being able to get started sooner rather is good. I mean, my my my view with this is in when Bix was first announced in November, right, the high level conversation has been great, and the first announcement from government is really really great. We've got a lot of businesses struggling with energy bills. We're putting this scheme in place for some significant energy users, you know, 10 to 14,000 businesses to be able to benefit from this. That's great. I think my probably a bit of my disappointment has been that on the back of the first consultation, which, you know, often consultation documents are actually really policy documents. So I expect it to be broadly how it runs. My biggest disappointment will probably be it is a bit more complex than maybe I I thought initially it would be. I thought it would be a fairly easy process. I think if I look at it now, there's definite complexity around whether you're eligible. Definitely. It's not clear, and it and I don't think it will be because I think some businesses will fall between the gaps. I think then the the amount of eligibility, so the intensity test that doesn't exist but clearly does exist, I think that's a lot of work as well. You know, you are going to be after evidence, really clearly evidence how much, your your energy usage, and I think that will be a real difficult thing for a lot of businesses to do clearly. And then I think you've got, outside of that, I think that you've got the challenge with your supplier and making sure a, the supplier, does what they should be doing. It's making sure there's exam exemptions in place. If you add on top of that maybe the backdating piece, I I think there's probably it's a much harder process than I I would say I thought it would be. I think it's probably a much harder process than maybe potentially it needs to be. I don't know why I'm surprised by that. I've I've seen these things before. However, I do think when it first came out, the, the response last week, my first instinct was, okay. That just feels a bit more complex than it should be, and I think it will be. Now whether that changes over time, what I often find with these schemes is what happens is the launch, the initial iteration can be fairly, fairly complex. But I think over time, we will wait and see. Okay. It's it's interesting. So, is there anything from a blocker point of view? So also from another point of view, I'll probably say, Dean, if you were a business, what what other things could maybe stop them being eligible? Well, they've set a very low or they're they've proposed a very low minimum consumption. It is very low, though, so I don't expect it to affect many manufacturing businesses, something like three and a half thousand kilowatts, which is, you know, pretty pretty darn low. But the the main blocker I see is the how do we collect the evidence that the department for business trade wants to determine eligibility on a site by site basis? What methodology are they willing to accept? We don't know that yet, and we can't expect every business to have, you know, meters and every bit of plant, you know, that that that we have. So it'll it'll be down to, you know, what I sort of mentioned is what is the gonna be their fair and reasonable apportionment process for the scheme and figuring figuring that out. And, hopefully, the consultation, the second one, when that finally comes out, will come along with, you know, maybe actually guidance and the, you know, the the full thing where we can work from there. But I think that'll be the the the main blocker. And there's also things like if I have a landlord supply, you know, how are we gonna have that treated? Because we've seen that being a blocker to quite a few businesses actually that are should be getting EII exemption. But because of the relationship with the landlord, well, it's actually the landlord supply that would achieve the benefit. So is there gonna be some sort of policy put in that, you know, make sure that the actual claimer person consuming the energy and the eligible manufacturing activity achieves the benefit of of going ahead and getting this put in place for them. So it's various things like that. The the landlord bit, I'd probably get asked more than anything else. That probably is the blocker that comes up more than anything else from some of the schemes. I don't think it's ever really been addressed properly. And I think sometimes there's there's maybe a lack of understanding of how the actual practical energy world works, when these schemes are written up. And I I think BICS will probably be the same as maybe sometimes a lack of real world experience. It's probably why I go back and say that just remember with all of these things, it's how your particular business works. You know, there there will be things here that are very specific to you as an individual business. So I think it's, I think it's really important that that you kind of do either look at it from your view specifically or get advice on it because I think that's really important. The other thing you say that interesting or did was was around actually how you split across, different sites, the energy use across different sites. And I think that kind of that leads me into kind of thinking about how UK BICS can fit into just a broader energy strategy. Because I I think so anyone who's had we speak before around some of these things will know that I've I've always been, of the opinion that a lot of this stuff is all linked together, and, actually, just having a really, really clear energy strategy helps you a million times being able to manage your data on a weekly, daily, monthly basis. And when you've got these schemes come in, actually, it's really dead easy for you because you've already got your data in one place. And having that, like, data led energy strategy, I think, makes a big, big difference. I think you could even link it into, phase four of ESOS, which goes live, very January next year, which I think a lot of businesses here will probably also have to be doing ESOS next year. And, actually, when you break it down, the data required for things like ESOS, and the data required for things like, SCCR, actually will be very similar to the data required for this scheme. So there's an opportunity here from a business to actually just bring your data into probably a more managed area and say, actually, do we really understand our energy usage across site, across, every area of your organization? It's gonna help you, in reality, not only make this claim, but, actually, if you're gonna have to do that piece of work anyway for this claim, why don't you tie it into all the other stuff you're gonna do? Because, otherwise, you're repeating the same work four or five times. And I I find a lot of businesses, one of their biggest frustrations is it'll be different departments doing different bits, but they're all running the same data for completely different purposes, whether it be a carbon report, whether it be an ESG report, whether it be a a SECRA or an ESOS, or whether it be the data for an EII exemption or the data for, BICS. So my other piece strong piece of advice for business would be bring this into a more broader energy strategy. And for me, it's the non commodity cost side is make sure you're looking at every opportunity there. So, yeah, it's it's it's an interesting point around the data and splitting it by sight. I think that could be quite challenging for businesses, and I think it could be something that we we probably see businesses struggle with more than anything else, which makes sense. Okay. I think I think from from my point of view, from a bit, because I think we we've covered quite a lot. I is there anything, Dean, that maybe would not cover because there was a lot in the consultation that you think that it'd be worth people knowing about? Okay. I think I'll just reiterate that they haven't really give us all the answers at this point. So whilst we, you know, whilst me and Zach have been down this road before with other incentives and stuff, and we we see what they've now put in, and we're pretty confident that that's the way it'll be, you never know. There could be some outlier that happens and and changes everything when it finally comes to the guidance being launched. So, you know, we we've sort of articulated what we're confident of today. I think we've also said what we're maybe not as so confident on. But, yeah, I guess it's just sort of watch this space. We'll be watching it keenly just to see, right, what is the actual outcome, what is the actual mechanism, how you can clients benefit from this. And, you know, likelihood is, with the volume of applications they're expecting, you know, it'll it'll be like they do with all the other installs, first come, first served. So we need to be, you know, quick off the mark whenever we do get the absolute clarity and are able to start putting together applications. Yeah. But it's an interesting point. I see links into a question we've had, from from Andrew. So around, is there an appeal processing? So the question is, is there an appeal process in the second consultation for manufacturing businesses with being excluded? E g, SIP codes for casting of iron and steel are allowed, but those for casting of aluminum and nonferrous metals have been excluded. I'll I'll maybe I'll take the first and then maybe d u chipping because you might have an opinion on that. Yes. There is in the second consultation. There is an area where you you can respond to the second consultation. So, yes, in in the pure purest sense, and we're happy to share, a link to that consultation if you want to make a response. What I think I would say is it's a challenge because I I do it feels to me as if DBT are fairly set on the SIC codes. But the example you've given is probably what we've been saying a fair bit of whereby there are really are and it's not alone. There are specific examples here of, things that just don't quite add up for that specific business. And, again, I think it's because the scheme is looking at at everything rather than real world examples. Sometimes you tend to find, not everything's covered. So in answer to the question, yes. You absolutely there is an appeal process. There is a second consultation. We can send you the link, and you can definitely put your thoughts in there. It will be challenging as to whether or not there is any viewers whether or not DBC are gonna be willing to look at any of those schemes. Any thoughts on that, Dean? Well, yeah. So it's a it's an odd it's an odd way that they've articulated the sectors that are included and and then the products within those sectors that are deemed eligible. So for a for a business that's casting, for example, let's say, aluminum, Once the SIC code hasn't been articulated, a lot of the the potential cast product, so the product that you're casting so I'll just use an example off the top of my head. You know, somebody casting a part for a car. So if we look at the SEC codes that have been included, we've got all of the SEC codes for cars. We've got all of the parts for cars, etcetera, etcetera, but we don't have the sick code for casting of aluminum. So in Andrew's case, there may be an angle where depending on what the casts are used for, they might be included under a different sort of remit as such because we've got sick codes, but then we've got something called HS codes, which are essentially import export codes that you need to align your product to. So it's here's the sick codes of sectors we've deemed eligible, but here's all the products that they must manufacture. So, again, in when the guidance comes out, we should have clarity of, do we need to be on the sick code as well as the the sort of commodity code, or is it okay to just do the commodity code? So, again, this is just it's a a gray area at the moment, I'm afraid. Yeah. Interesting. And and, my views on whether there'll be any benefit from I I certainly think you should be responding to the second consultation. Absolutely. I also think from a, it may be worth speaking to sector associations who I know have had more joy in in pushing these things as well be my advice. Another question is the low minimum consumption is extremely low. Is that correct? My understanding is a yes. That is that is. correct. So not sure why. number almost. You know, it's almost sort of comical, like, the the low barrier to entry. Yeah. It's a proposed you know, that's the first question, I think, on the second consultation of, you know, do you agree with, being a minimum requirement of I think it's three and a half megawatts. So three and a half thousand units, which is extremely low. So, yeah, that that is correct, I believe. I've mentioned and I think you can probably tell from our reaction. Yeah. It it is extremely clear. I mean, I'm not quite sure of the reasoning behind it, but but you're not wrong. And then, actually, there's details on on on how much the scheme costs. And you you mentioned 600,000,000. 600,000,000 is, the number that's been given. Yes. That is the estimated number that's come out is £600,000,000 a year. How has it been paid for? Great question. Interesting question because I was on a number of webinars at this before the first consultation came out where that question was asked quite detailed question was asked of DBT, and I think, Dean, maybe you were on one or two of those as well. Yeah. We never really got a clear answer. Well, the maths didn't add up to the clear answer, so it's a great question. It's something I'm massively interested in. Essentially, they're saying it's not coming from taxation. Okay. That is that is the answer that's given. And my understanding, is there will be an increase across some other so it's interesting. They say it's not gonna come from general taxation. My understanding is it's gonna come from taxation within energy bills, and, actually, the cost is gonna be essentially spread across everybody else who's not involved. That is my understanding of it if we gave it really high level. I'll be really honest. The conversations I had of the, the webinars I was involved, which were DBC leading them, people people pushed them on it, and there was never really a clear understanding. It it didn't quite land with me. But that if I'm telling you what what if you if you ask the question, the answer we'll be giving is £600,000,000 a year estimate, and the cost is not coming from general taxation, and therefore, it is gonna come across all other, other energy nonpromoterity costs. But I I don't know the detail of who or where or how that will work. I don't know. Is is that your thinking as well, Dean? Yeah. It's it seemed for me whenever the the questions were asked of the the team at DBT that were, you know, talking to us about it in those webinars, it felt like they didn't know. It almost feels like they, you know, they're pigeonholed into their box of we are figuring out how to implement this incentive. This is what the we're trying to do. This is who gets it, etcetera. And there wasn't really just didn't seem like anybody knew where where or how it was gonna be paid for. But I I agree with Zach. It'll rather than general taxation, it'll be more than likely energy tax levy, etcetera, imposed on everyone else. I I actually think it I I think the the chalets they had is is I there was an element of just trying not politically speaking, trying not to say we're increasing tax was was actually where it came from. And I think the reality is if you are not one of the businesses involved, it will be spread across all the other businesses. So that 600,000,000 will be spread across all the other businesses. And what I think they they want they were avoiding saying is that there will be an increase across everybody else because the the line was definitely, there will be no increase in tax. I think the reality is that's that's kind of is semantics, isn't it? So so, yeah, that's why we'd go on. Another question. Does eligible product process require sub metering or an agreed monitoring verification process? Experience of IETF scheme, if a monitoring verification approach can create admin that could cost more than the scheme benefits, some claimants, for for some claimants, be careful. I don't know. Let let me have a think. Do you have any thoughts on that, Dee? We did a few IETF last year. I don't think it so so, Yes. actually, let me let me give actually, maybe quickly my view. I I I don't think it will be I don't think it will require it is my gut instinct, but I think it would definitely be a huge benefit to you. Submetering will give you the information you need for the verification process. So I think if you've got if you've got submetering, and you have that data standard, it's gonna give you a really good opportunity to make the claim. I don't think it will be required, though. I don't know what your thoughts are doing. I I agree. So submetering would essentially automate the the task a a good bit. However, what we what we're what we need to understand is what is the, you know, what are they going to bring out as the fair and reasonable apportionment method that goes alongside this. You know, you know, that could be things like looking at the tonnage of your products and deciphering which is eligible or, you know, just estimating based off running hours, for example, how much energy is consumed in eligible manufacturing. So there's various different ways that it could go, and we what we're waiting on is basically that that answer. But, yeah, if you if you have it already, submetering would probably be a a way of automating some of that task. Yeah. I certainly wouldn't be getting it necessarily for this, but then I'm a I'm a huge fan of submitting a gift done properly because I think having access to your data and then view of your data and understanding your data is key, like, to everything you do. So I'm a big fan of it done properly. I've also seen it not done quite well. And and often, if it's not done well, you're you're paying for a product that quite frankly doesn't give you that benefit. If done well, meeting is really good. And it would definitely help you if you have decent data that you can split easily. It's gonna help you in this game. Don't think it will be required. I think we did get a question as well. Sorry. While I go around, does the BICS replace or work with e EII, ETS, CTS? It it, does it does it replace it? No. The one piece that I think would be interesting on that to say is if you have an EII certificate, the advice at the moment is that actually you wouldn't so you can't have both just because it doesn't replace you. You cannot have EII exemption and BICS, is is the current guidance. But, again, it goes back to these ones a bit about being unclear. It isn't really specified yet. The reality is and there's a if you think about the logic, they're covering a lot of the same things. In EII, there's a better benefit. So I don't think there's necessarily guidance that, you know, you you at this stage, the guidance hasn't been clear as you can't have both, but certainly, there's an element of saying, well, why would you if you've got an EII certificate? The benefit is gonna outweigh the benefit of BICS. So don't have BICS, have EII. But, again, there's a case by case basis because there's an argument to say if you're, you know, if if your savings are quite low on EII, but to have an EIS to give you access to the network charges conversation scheme. And there might be the odd client who gets a real benefit from NCC, very little benefit from EII, they need EII to get NCC, but may go for BICS. Look. There's lots of different different things, but, no, it does not replace. EII exemption and the ETS scheme will continue to run. BICS is an additional scheme, so there will be an additional scheme on top of those. They are not replaced. There's still some lack of clarity as to which is the better one to have for you as an individual businesses. I would guess for vast vast majority of businesses, if you have an EII exemption certificate, that will outweigh having BICS. So there's no there's no benefit to having BICS if you've got an EII certificate already for the vast majority. Always worth checking, though. There will be, I have no doubt, that odd situation whereby a business might go, hang on a minute. It might be smarter to do things in a different direction. Get your own. I would get individual advice on some of this stuff just to make sure you're doing things properly would be my my my thoughts. But if anything to add on that, Dean? Yeah. It it it will it will be down to a bit of a, I suppose, an ROI of at the minute, you know, we and I have clients that at the minute, they get a EII exemption on the network charges compensation on, say, 20% of their consumption because that's what's deemed eligible for the EII. However, there may be an opportunity for the other 80% to be eligible for BECCS. So there's we're currently in a bit of a limbo where we don't know how would be best to to plan that. You know? Does that 20% of consumption with the additional taxes on the network charges outweigh the getting 80% with Bex? Are are we gonna be able to do that? And so I think, you know, the the way that DBT have looked at it, if they've looked at it, well, you don't you you can't be exempted from the same taxes twice. So you can't have BECCS and EII at the same time. But I think we've maybe not got into the gray area of if I'm only getting it on half of my consumption, should I not be able to exempt the other half through a different mechanism? So, again, hopefully, we'll get some sort of clarity on that, but that that might be a gray area that's that's left gray, just based on, you know, the the they'll not want to articulate every single possible scenario ever. So that's maybe one for me and Zach to talk with the team at DBT and say, right. This is what we have. What's the process? And see what they come back with. how it works on EII and ETS, in the early days and still, actually, still for both of those schemes, we still regularly come up with scenarios or find scenarios that that just aren't aren't really clear in the guidance. And we we have that conversation with with DBT, and you end up having a an agreement as to, okay. Fine. That is now the policy. And there's an element we've we've had a number of situations where we've we've essentially, made up policy for DBT by having customers, customers, and say, hey. This this situation actually was not really covered in the guidance. We'll we'll we'll speak to DBT and find out what the guidance should be. So, good. Well, let let's wrap things up. I don't know if you've got any final thoughts, Dean, or anything you wanna just just leave us with, before we, go. no. I I guess it would be, you know, with the the volume of applications expected, if you are able to review this, I would be looking to review it as soon as possible. And and what I mean by that is once the guidance is out, get the application ready to go and try and hit send on that on the October 1 if that's the go live date, because you wanna be one of the first in the pile rather than one one of the last. So that that really be what I'm saying. I'd I'd probably repeat that, and I'd I'd also add, you know, each each individual organization you'll have at your have your own circumstances. If you're not there and you think you should be, and certainly, I would be thinking of ways of raising it, and feel free to raise it with us as well. I know that the question around is of an appeal process, those kind of situations, there will be plenty of those whereby you actually look at it and go, well, actually, the the theory behind this means my organization should be eligible for something because that's what it's saying to do. But for whatever reason, it doesn't. Absolutely a vase that and and be get get advice on it because, you know, we're more than happy with help with those conversations. Again, I hope that's been useful today. I know it's a a a tricky situation. We will probably do another of these post second consultation, so watch out for that. But in the meantime, feel free to pick up the phone to us if you want any conversation around Bix or anything else that, we're more than happy to help with. We will, we will leave you with that. And and, hopefully, when BICS comes out, it answers all the questions. As many as you as possible can actually get the benefit, which is definitely the goal at the end of the day. So thank you for your time. Thanks, Dean. Thanks, guys.