by Kit Oung
There are roughly three months to go before ESOS compliance date – 5th December 2015. By this date all large undertakings in the UK should have notified the Environment Agency of their compliance. One of the key questions that I get on an increasing frequency is, “I haven’t started my compliance process, can I still make it?” or “Is the Environment Agency going to penalise me if I start now but complete process a little late?”
Several weeks back, I had a discussion with one company. They were in panic as they have not started the ESOS compliance process and thought it is more complicated and difficult than it really is. It also transpires that their scope of compliance is down on one building and a small fleet of cars. I have told them if they start immediately, there should be no problem finishing the whole process in a month!
Suffice to say, there really is no excuse for large undertakings to comply by 5th December 2015. Here is how to do so in 3 months … along with some good news.
- Appoint an ESOS Lead assessor. One frequent myth: only external consultants can act as ESOS lead assessor. Having trained many ESOS lead assessors, internal people are best to act as lead assessors because he/she knows the company best. Anyone in your organisation with a minimum of two years’ experience in managing energy or finding opportunities to save energy can become your lead assessor. He/she simply need to apply to one of the approved ESOS registers. Not all registers have lengthy application process.
Good news 1: You do not need to have an ESOS lead assessor to start the compliance process. The primary role of the lead assessor is to review and approve the energy audit for your company. He/she does not have to be part of the energy audit activity. At a minimum, you need a lead assessor before you start the energy audit. As long as you have complied with the simple rules laid out in ESOS, the lead assessor need only review and confirm that the work done so far is compliant.
- Sum up your total energy consumption. This should be the energy consumption from all of your buildings, manufacturing processes (if applicable) plus all the transport fuel that your company pays for. It should be calculated from a consecutive 12-months’ worth of data covering the 31 December 2014 e.g. 5 January 2014 to 5 January 2015. The purpose of this exercise is to determine which 90% (minimum) of the energy consumption needs an energy audit.
Good news 2: If your company have an environmental permit or participates in CRC, Climate Change Agreements (CCA), European emissions trading scheme (EU ETS) or utilises any non-financial reporting frameworks such as GRI or CDP, you already have the data. What is missing would be the transport fuel, which is available from the finance department as mileage expenses.
Good news 3: The calculation for total energy consumption can be in monetary units or in energy units. This gives you the maximum flexibility to pull information from available reports. Do note though, calculations in CO2 units are not acceptable for ESOS compliance.
- Carry out an ISO 50002 Type 1 energy audit. ISO 50002 Type 1 energy audit is a high level energy audit that identifies major areas for energy savings in a systematic, traceable and verifiable manner. The energy audit needs to use consecutive 12-months’ data from 24 months prior to the start of the energy audit activity. At a minimum, the energy audit must have a breakdown of how and where you use energy and a list of cost effective opportunities based on calculation. If energy auditing is not your thing, commission an external consultant to do one. Make sure you extract the calculations for your record.
Good news 4: Most companies already carry out energy audits, implement the recommendations and save money. This previous work can count towards ESOS compliance as long as it meets the same specifications. Check all your previous energy audit work, display energy certificates or green deal assessments. If they are valid, remove them from the scope of your energy audit.
Good news 5: You can also use the energy audit as part of your ISO 50001 in the New Year. The energy audit sits comfortably in ISO 50001’s energy review. To complete the energy review, all you need is (or ask the consultant) to develop your company’s energy baselines and energy performance indicators, use the energy baselines to forecast future energy consumption, and identify the key personnel that affects energy consumption in your company. Upon confirmation that all parts of ISO 50001 requirements are met, you’ll be able to say your company is ISO 50001-compliant.
- Review, sign off, notify and keep records. Once the points 1 to 3 are completed, have your company board of directors review the findings and enrol them to invest in saving energy. At a minimum, 1 board director (2 if you use an in-house lead assessor) needs to testify that the organisation has reviewed the opportunities to save the company money and that the company have complied with the ESOS assessment processes. After this, go to the ESOS notification website (https://www.gov.uk/energy-savings-opportunity-scheme-esos#submit-your-esos-notification-of-compliance) to inform the Environment Agency. All records of your compliance should be kept.
After reading this article, check out the official and in plain English Guide to ESOS compliance. The Guide gives a description of the whole ESOS compliance process and additional information in a simple-to-follow and chronological manner.
If you need more time than until 5th December 2015, contact the Environment Agency at [email protected], describe your situation, efforts and concrete plans to finish. Many people think of the Environment Agency as a “big hairy monster” that dishes out penalties for fun. You may find the Agency more understanding than you think!
Kit Oung is an experienced energy manager at Energy Efficien:ology, board member of Energy Managers’ Association, and Advisory member of 2degrees Network. He is a qualified ESOS Lead assessor and ISO 50001 lead auditor. Kit also trains ESOS lead assessors at the Energy Managers’ Association and IChemE. He is the author of Energy Management in Business: The Manager’s Guide to Maximising and Sustaining Energy Reduction (Gower) and Energy Audits: The Key to Delivering Real Energy Reduction (BSI).
If you wish to become an approved and registered ESOS lead assessor, please contact Jana Skodlova at [email protected] or on +44 (0) 203 176 2834.