Five Myths about ESOS: Part 2
More ESOS Myth Busting facts from Jes Rutter, Managing Director of energy efficiency specialists JRP Solutions.
Posted on 11 November 2014.
This is the second in a series of articles referring to common misconceptions, even amongst some energy professionals, about what is required under the Government’s Energy Savings Opportunity Scheme. Jes Rutter has scrutinised the regulations and checked out the facts to eradicate these myths (part 1 is here):
Myth 1: It is expected that the compliance date of 5th December 2015 will be delayed due to unavailability of Lead assessors.
The facts: This is not the case as the compliance date is set in law both in the UK and the rest of the EU. Whilst the number of certified Lead Assessors currently stands at 112 it is expected to reach the projected number of 1,500 in the coming months, though it is not clear how many of these will have expert manufacturing experience.
Myth 2: As long as our organisation doesn’t have 250 employees on the qualification date of 31st December 2014 it will not be required to comply with ESOS.
The facts: Unlike most criteria under ESOS where the status of the organisation on the qualification date will determine its requirements under ESOS this is not the same when referring to the number of employees. When assessing the employee criteria the participant should take the average number of employees, on a month by month basis, they have had during the period they existed and there is not distinction between full and pat time employees. To work out your average number of employees, the participant needs to:-
Find the number of persons employed under contracts of service by the company for each month of the financial year (whether for the whole month or part of it)
Add together the monthly totals
Divide by the number of months in the financial year
Myth 3: There will be fees levied by the Environment Agency when registering and submitting the ESOS compliance documentation.
The facts: There is no need to register with EA as they are aware of all organisations that need to comply with ESOS. The EA have stated clearly that no fees or subsistence will be charged either to comply or for any follow up audit work that they may undertake.
Myth 4: ‘Investment grade’ energy audits covering at least 90% of the organisation need to be surveyed.
The facts: Investment grade energy audits are required but not usually covering 90% of the sites/facilities. 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 method to be used 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.
Myth 5: Test fuels (e.g. energy consumption for testing/R&D purposes) do not have to be included in the ESOS assessments.
The facts: If test fuels are being used as energy then they are in ESOS regardless of whether they are for testing or not. They will be therefore be treated just as any other energy source.