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This blog will be written when I have something to say, so there may be times when it will not have been updated for a while, but at least it won’t end up like some pop star’s Twitterings.
ESOS – A LOST OPPORTUNITY FOR EPB?
15 December 2015
Up to 10,000 companies were required to have got their Energy Savings Opportunity Scheme audits in 10 days ago, and according to figures released yesterday by the Environment Agency a much-better-than-expected 4,000 did, with another 2,500 taking advantage of the Environment Agency’s cobbled-together ‘extension which is not an extension’, and promising to get their figures in by 29 January 2016. This is far better than anyone thought possible, even just a week or two ago.
There is no word on what is happening over the audits of an estimated 3,500 other companies, which have neither lodged their audits nor given ‘late submission’ notifications. And perhaps more importantly, there is no knowing when, if ever, we will have a clear picture of how the scheme has progressed and what the results are in potential energy efficiency terms. Audits must include proposed energy efficiency improvements, though companies are not required to implement them, but it is questionable whether we will ever get to see a breakdown of the sorts of measures proposed for improving energy efficiency anyway.
What seems clear, is that sadly there has been little in the scheme for assessors, which is not just frustrating for those assessors who made the appreciable investment to become ESOS Lead Assessors, but bad for the energy efficiency of commercial buildings. Clearly DECC and the Environment Agency expected assessors to be in demand to assess buildings as part of the scheme, since the official guides to the scheme proposed that Display Energy Certificate assessors, and the handful of commercial assessors who completed the ND Green Deal qualification, could provide assessments of buildings and proposals for improvements.
Despite these expectations however, it seems likely that the energy efficiency of buildings has not formed a significant part, if any part, of most ESOS audits. This may be because most audits have been completed by environmental consultants, for whom EPB does not seem to be a major concern. Most consultancy audits seem likely to have been based on energy costs taken from utility bills, so if, say, manufacturing is the major energy use on a company’s sites, then a consultancy is likely to have looked at energy efficiency improvements in the manufacturing sector only.
As a result, most audits have probably not involved any assessment of the energy efficiency of the buildings large companies are using. This is surely not what DECC intended when the scheme was planned, but given that the Environment Agency has struggled to get audits in, it seems unlikely that those which are submitted will be knocked back for further work. So audits are likely to be nodded through with little more than a check on fuel bills, and a major opportunity to check on the energy efficiency of a great many of our commercial buildings will have been lost.
It is surely too late to do anything about this now, and this phase of the scheme will go through as it is. The next phase is not due for four years, and given the present administration’s attitude to energy efficiency schemes, and the compliance shambles that the present phase has descended into, it’s questionable whether there will actually be another phase of ESOS.
If there is, then the government should certainly add EPB as a separate item, and require companies to obtain EPCs or DECs on their buildings and consider energy efficiency improvements to them, in addition to the audit carried out on other forms of energy use. It is questionable how many companies really have much idea of how energy efficient their buildings are, and it is important that they should be required to look at this area of their operations, not just pass it over if manufacturing is using more energy. Given the sort of fees that most environmental consultancies charge, the additional costs of obtaining EPCs or DECs would add comparatively little to most companies’ costs.
However, it remains to be seen whether the Government will be prepared to continue with ESOS, let alone extend it, even modestly.