Today’s energy legislation does not have ‘teeth’ to make a difference, I am a ESOS (Energy Saving Opportunity Scheme)*1 Lead Assessor based in the UK and though I can only comment on the UK Government, I am sure if we were to delve into other countries we will see legalisation that also needs a review.
In the UK we are now ‘plodding’ our way through ESOS Phase 3 and I know that we will not see any movement from organisations prior to the last 12 months because in phase 3 its just the same as phases 1 and 2 and to complete an assessment and present ‘opportunities’ to a Board director (not the whole Board) is just a repeat from before. Opportunities are great but without implementation all they can be are ‘opportunities’.
In Phase 1, I completed possibly 43 Assessments and though during the presentations the uptake looked promising, nothing actually happened. In Phase 2, I actually supported 2 assessments and the same followed. There was positivity during our presentation but no action taken.
I personally believe that ESOS is a well thought out, structured process but I wish it had ‘teeth’ as a Lead Assessor (I think I answer for many) we have to complete some significant work load and it does become very stressful towards the deadline. We have to understand the company structures, develop plans, collect data, provide reporting and then carry out assessment just to see all of these reports get placed on a shelf to gather dust. Very similar to what we see with the ‘Carbon Trust Reports’
The implications to all of this is that the overall goal and objective of the legislation just gets diluted with each phase and sadly we are now in Phase 3 and there has been no changes made to the legislation. There is no reasons that I can see why there is no changes made to the process. There is significant dilution of the legislation and no incentives into what needs to be done.
This legislation is a European wide legislation which each country has their own levels of deployment and interpretation. It has been created to implement the to implement Article 8 (4 to 6) of the EU Energy Efficiency Directive (2012/27/EU). My personal believe is that we should be focusing on the implementation element of the legislation in Phase 4 and taking what we have identified in the last 12 years which is a considerable amount of time. I believe also that incentives would be worthy here as well.
The UK Government last week announced their 10 point green plan as a country it is aiming to bring all greenhouse gas emissions to net zero by 2050.
What can we be doing differently in Phase 4, I think just simply the whole process of Phase 4 could be for the phase to actually absorb the data in Phases 1, 2 and 3 and provide comparisons. We should then take the ‘Total Energy Consumption’ (TEC) for Phase 1, 2 and 3 and review the new profiles (obviously compensating for business growth and changes) can you imagine the report that could provided.
The regulations around ESOS does not require you to review previous phases. This will provide a very interesting overview to the business. It would provide a trend of what the organisation has done over rhe last 12 years.
In addition introduce a regulatory instruction on ESOS Phase 4 that possibly 50% of the measures and opportunities are reviewed and implemented in the last year of the phase prior to the deadline.
Now for me that provides an exciting element to ESOS Phase 4 and organisations now have 6 years to start to consider this, given them significant time to understand there Total Energy Consumptions and the ‘Life Cycle Cost Analysis to deliver such projects.
If the UK organisations were to embrace the legislation in this way there will be a significant impact made on kWh savings and carbon which will provide further savings financially.
There are probably now over a 1000 ESOS Lead Assessors now in the U.K. and I’m sure all of these Assessors would like to see some changes made in Phase 4 so that they could really get their teeth into making a difference to the scheme. Another initiative here to consider would be to report the kWh figures not to name and shame organisations but to encourage them. I once worked with an organisation where we made significant savings by focusing on ‘Best Practice’ (newly being identified as Energy Consciousness ECON) and technologies their kWh savings year on year was significant, they were very proud of their achievements and I’m sure they would not have minded a ‘UK League Table’
I would personally like to see some ‘Teeth’ introduced to legislation and some initiatives regarding ‘Tax Breaks’ and benefits. Now could you imagine what would happen to the UK Carbon Emission trend if this was introduced.
*1ESOS is a mandatory energy assessment scheme for organisations in the UK that meet the qualification criteria. The Environment Agency is the UK scheme administrator.