ESOS: It's not all about ISO 50001
15/10/2014« Back

When it comes to complying with the UK's Energy Savings Opportunity Scheme there are many cases where ISO 50001 may be the best fit.

But it is not the right answer for all argues Richard Hipkiss

A recent article published on the 2degrees community website may have given the impression that DECC had made a mistake in allowing DECs and Green Deal Assessments to be used for ESOS, and that only ISO50001 was really suitable. While some may take this view, there was, and still is, a very strong industry view, from the property and retail sectors in particular, that DECs and GDAs should be allowed as alternative compliance routes.
   


 So what are the benefits that Display Energy Certificates and Advisory reports can provide?

·         DEC's/GDA only apply to buildings. But for buildings they provide energy use data and the Advisory Report (AR) should provide cost effective improvement advice, as required by ESOS. That is surely a benefit, not a drawback? However they do need to be used with caution. The DEC methodology is helpful in identifying total energy use and providing a hierarchy of performance to inform a sampling strategy, and is also a useful tool in monitoring performance trends during the 4 year ESOS cycle.

·         The advisory report that accompanies a DEC is valid for 7 years, but that does not stop a new one being prepared if there is a significant change to the building or its occupancy. The DEC/AR can even be part of an energy management system. The DEC itself is only valid for one year and would be required for the reporting year.

·         Within the DEC/AR approach there is the option, and some might argue professional obligation, for the assessor to add their own recommendations on cost effective improvements to the building.

·         The fact that a DEC/AR is software driven is irrelevant – DEC assessors are required to demonstrate that they have minimum competencies. Software has been used to automate and standardise the process and improve consistency. All the software packages are approved by government after testing.

·         Software has pre-programmed assumptions, but engineers also have pre-programmed assumptions. A well prepared, Advisory Report, with a competent assessor’s input, and not just the software input, can have a role in meeting ESOS requirements. The ESOS Guidance and ISO 16247 both recommend the use of whole life costing where appropriate, whilst the DEC software works on simple payback, so the ESOS assessor will need to consider this.


 Why multiple routes to compliance?

So why did DECC allow multiple routes to compliance? Because there are a plethora of initiatives out there asking business to measure energy use, or carbon emissions, or greenhouse gas emissions, and then submit reports. Business suggested to government that rather than create yet another unique compliance route for ESOS, it should look at the existing methods and identify which of those could assist with ESOS compliance, and the specifically allow those routes. ISO50001 was never going to be the only route, as it is mentioned in the Energy Efficiency Directive as ONE way to comply, not the only way. If DECC had tried to lead everyone down the ISO50001 route not only would the Treasury and Better Regulations Committee have sent them packing in short order, they would have been wide open to the Parliamentary committee that monitors EU legislation for over implementing(or “gold plating”) on Article 8 of the Energy Efficiency Directive. We need to be clear, ISO50001 was never going to be the only route to compliance in the UK.

There are many cases where ISO50001 may be the best fit for an organisation to approach ESOS but the cost, timescale and/or internal resource requirement may be a barrier to achieving this in time for the first round of ESOS. But it is not the right answer for all. There will be other cases where a DEC/AR may be the most appropriate tool, maybe where all buildings are of a standard format that brings value to a benchmarking exercise, and let’s not forget a DEC is an excellent tool for stakeholder engagement if used correctly.

And we also need to be aware that DECs alone do not meet the ESOS requirements. What they do is to contribute data and advice to the ESOS process.


The first core competency of an ESOS Assessor as described in PAS 51215 is:

“Understanding the operational context of an organization being assessed”.

A competent assessor will use the information in a DEC and an Advisory Report within that operational context, to deliver a compliant ESOS report in a cost effective manner, making good use of existing information to provide advice that the client will want to implement. If all that ESOS achieves is the creation of a few thousand reports, and nobody acts on them, it will be an opportunity well and truly squandered, whatever compliance route was used.

For some of the large organisations who have to undertake an ESOS audit, a bespoke energy audit may well be most appropriate. The beauty of the ESOS Regulations is that businesses and lead assessors have been left with that choice and professional discretion to choose the route that meets the clients need, in their “operational context” as the Publically Available Specification (PAS) describes it, rather than following a one size fits all approach, which inevitably leads to perverse outcomes.

Instead of the energy assessor community being drawn into a pointless argument about regulations that are made and in force and are not going to change this side of an election, we ought to be focussed on raising awareness of the ESOS requirements, promoting the benefits of ESOS assessments that are acted upon to deliver real energy savings, and not just reports to the Environment Agency, and supporting DECC in trying not to reinvent wheels for ESOS, but using existing tools.

Finally, we should be well aware that some in government would dearly love to do away with DECs – Michael Gove tried it in schools, along with BREEAM - and that the concerted efforts that have appeared recently to undermine DECs will only serve to strengthen those Ministers, and their Special Advisers, who view all form of energy assessment and audit as “a burden on hard working businesses” and not the means for those hard working businesses to save themselves some serious money on their energy bills. Those of us who understand the benefits of energy saving ought to be working together to promote the benefits of sound energy management, not disagreeing openly amongst ourselves over the legislation before anyone has even tried to implement it seriously.



Richard is Director of digitalenergy Ltd and an active campaigner for wider action and improved legislation for demand side energy efficiency. He is also chair of the Energy Services and Technology Association (ESTA), a body that represents a diverse range of experts and technologies across the UK.

This piece follows up on Richard’s original response to the article ESOS: The pros and cons of four routes to compliance.

 

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