ESOS Myth Busters!
There are common misconceptions, even amongst some energy professionals, about what is required under the Government’s Energy Savings Opportunity Scheme.
Posted on 16 October 2014.
Jes Rutter, Managing Director of energy efficiency specialists JRP Solutions, has scrutinised the regulations and checked out the facts to eradicate these myths:
Myth 1: It is necessary to submit an Energy Report including energy data and improvement projects.
The facts: An Energy Report does NOT need to be submitted. A short document stating that a senior company Director has reviewed the Energy Report and that compliance has been agreed by the Lead Assessor (each with a signature) is all that is required.
Myth 2: It won’t matter if we are late to submit the required documentation.
The facts: DECC and the Environment Agency (EA) know all of the organisations that are required to be part of ESOS (a letter will be going to all organisations in November 2014) such that on 6th December 2015 they will do a match using this list against those that have submitted compliance. The financial penalties for noncompliance are clearly outlined in the ESOS Guidance notes and can be substantial.
Myth 3: The Environment Agency will not audit the submissions.
The facts: The EA have stated clearly that they will carry out compliance checks and quality assurance audits. Compliance checks will look at basic compliance requirements and ask for evidence that these have been met (e.g. production of audit reports, energy saving opportunities identified etc), and quality assurance audits will go into further detail on the exact nature of the audits. The EA aim to compliance check at least 5% over this phase.
Myth 4: 90% of all sites in a group organisation need to be surveyed.
The facts: Whilst it is true that 90% of the group energy consumption needs to be considered, if, for example, facilities are similar, then only an appropriate sample needs to be considered. Organisations with multiple sites or assets that are identical or very similar can take a proportionate approach and apply (scale up) the energy saving opportunities identified in their site visits to their wider portfolio. The lead assessor and participant organisation should determine a suitable site visit sampling approach to reflect the energy consumption patterns of their assets and activities. This is not prescribed in legislation or guidance so it is up to your organisation and Lead Assessor to agree this and explain in your evidence pack how the approach taken reflects the energy consumption patterns and saving opportunities for your portfolio of assets and activities. In a compliance audit the regulators will look for well-reasoned and documented justification for the approach taken.
Myth 5: Survey evidence from sites outside of the UK cannot be used as part of ESOS compliance within the UK.
The facts: As long as the opportunities were representative of the asset in the UK then there is no reason why the site visit to the foreign asset couldn’t be used to ascertain the energy saving opportunities at a UK asset. The EA would expect justification for why it was suitable to use the foreign site visit as indicative of the UK energy saving opportunities in the evidence pack.
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