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Any questions about ESOS?

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The Consultus International Group can answer any more questions that you may have about ESOS (Energy Savings Opportunity Scheme).

To that end, we have put further queries received to Steve Atkins, our principal consultant, and taken his responses for this Q & A session.

Steve Atkins, Principal Consultant
Steve Atkins, Principal Consultant

ESOS is changing. Those looking to complete Phase 3 are now subject to a host of additional reporting requests, along with setting a four-year action plan (for Phase 4).

Others who have yet to engage with ESOS could be facing fines, for being non-compliant, with penalties handed out last year totalling a whopping £1.487million.

Producing an annual report for ESOS can be tricky, but Consultus have the confidence of a 100 per cent record of carrying out site audits and subsequent reporting successfully.

Steve went through a lot of what’s new with ESOS in the recent episode of Consultus Chat, which you can access above, but will now respond to other scenario-based situations.

Question: A part of my management role has been to ensure ESOS compliance, which will again be the case for Phase 3. What are the most major changes to the report?

The company that I work have multiple locations, all over the UK, so how they can be best represented under the ESOS guidelines?

Answer: “The implications of what fundamental changes have been made, for reporting, has seen the scheme go into a lot more depth. There are additional requirements around that.

“Under previous phases, around 40 per cent of non-compliance notices have been around the organisational structure, which has to be properly represented under ESOS.

“Those companies failed to clearly define all of the large and group undertakings in their portfolio. To address that, more information has been asked for.

“Moving on to consumption data, you have to be more representative of the different types of energy and their use, regardless of whether the subject matter is offices or factories.

“It’s not been mandated which sites that can be selected, for an ESOS audit, but you do have to state why they are representative of their portfolio.

“The main fuel types that would be relevant are electricity, gas, fuel oil, diesel etc and you have to report what’s used to keep buildings going (lighting, heating, ventilation etc) and transport.

“If you’ve got a production line, in that building, you are expected to provide a breakdown of what’s being used to carry out that industrial process. That’s a brand-new requirement.”

Question: My organisation is a current Consultus client and your team has completed ESOS reports for me so far, how is that service being affected?

We don’t have facilities for metering, in relation to our energy use, so I’m also wondering how accurate reporting of consumption is likely to be?

Answer: “Those that don’t have sub-metering have to provide estimates. Most customers will fall into the three categories of buildings, transport and industrial processes.

“You have to consider that collecting data, along with completing the audits and analysis, is a multi-week engagement. If a customer decides to wait for much longer, they would be pushing it fine.

“For any customers that we have already visited, we have now got to re-dissect their data into those categories. We can’t just work it out by fuel type, it has to be by category as well.

“All of the energy intensity metrics are additional information that we have got to gather, which wasn’t required before. Previous site audits should have the building size anyway.

“Further additional data includes the energy savings and what are they identified by. A short-term investment is three years or less, everything else is long-term.

“ESOS is not just about rolling from phase to phase, it’s about identifying and categorising what is happening during each of the phases and achievements made.

“By having to prove this, with more evidence, ESOS has been given more teeth and has become a more complex beast. Everyone has to play their part in energy saving measures.

Question: My business owns multiple forms of transport, which are stored at a car park on-site. How will this affect my ESOS report, now that there have been a number of changes?

Also, how will the de minimis level going up impact on my consumption? Most of our vehicles are petrol, but we still run a few diesel motors.

I’m also wondering how similar ESOS is to SECR (Streamlined Energy and Carbon Reporting) now? Hopefully, this will help us with our Net Zero ambitions.

Answer: “If a company owns a fleet of lorries and a fleet of cars, both metrics have to be reported. Issues with car park lighting might come up, even if it’s not attached to the building.

“The de minimis level used to be 90 per cent, so that’s also increased to a five per cent difference of the overall energy used, which means that will be more detail in the report.

“For example, a fuel that’s used occasionally might be a relatively small part, compared to mains gas and electricity, but if it’s over five per cent, it will have to be included.

“All information about ESOS is and will be in the public domain, so you can find reports and who decides to take no action, along with the reputational risk that the latter presents.

“To be honest, if my company was placing at the top end of energy efficiency, as defined by an ESOS report, I’d be looking at my peers to see if that was high on their agenda.

“There’s a huge cross-over now between ESOS and SECR, because they are asking for a lot of the same information, but neither is a Net Zero plan, they are energy saving schemes.

“ESOS expects you to identify energy saving measures, but their audit wouldn’t expect you to identify options such as renewables, which our Net Zero Pathway would.

“The government has suggested that ESOS Phase 4, going forward, may introduce some sort of Net Zero commitment, but no details have been released as yet.”

There are thousands of businesses and organisations, in the UK, that will be eligible for ESOS commitments, due to their standing.

To qualify for ESOS, a company must employ 250 or more people, or have posted an annual turnover in excess of £44million and a yearly balance sheet of more than £38million.

Corporate groups could also meet the ESOS definition, if any of their UK interests fall under the basic criteria. All are subject to this additional reporting.

Whether a client is looking to complete Phase 3, plan ahead or has never undertaken ESOS at all, Consultus’ experts, which include an in-house lead assessor, can ensure compliance.

This is a busy time for ESOS audits, though, so any prospective new clients are advised to act now and avoid disappointment. To contact us, with an enquiry, click here.

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