The most common ESOS compliance mistakes and how to avoid them
The Environment Agency’s (EA) latest newsletter for participants of the Energy Savings Opportunity Scheme (ESOS) contains some interesting pointers on how firms have been going wrong. What’s the lowdown on where you might improve your compliance efforts?
Top ESOS pitfalls
The EA’s findings were part of an annual audit to help identify new and repeated non-compliance issues.
First off, many ESOS Energy Audits did not meet the minimum criteria stated in the Regulations/Guidance. In further cases Lead Assessor and or Board Director signoff was missing.
In yet more examples the sampling approach was not representative of Significant Energy Consumption (SEC), and in others organisations moved premises between qualification and compliance date so they thought there was no need for energy audits.
Other common errors included process energy consumption omitted, and omitted transport consumption when it was a significant part of Total Energy Consumption (TEC).
In total, the number of compliant participants increased to 21% against the previous year’s total of 16%. The number of firms that were ‘compliant with remedial actions’ was 55%, down from the previous year’s figure of 75%.
Solving ESOS woes
Here at the Hub we spoke with industry experts to get advice on how firms can avoid non-compliance. Here’s what they had to say…
The sense among our experts is very much that the right Lead Assessor is key. “My view is that a lot of these mistakes can be avoided by appointing an appropriately qualified and experienced Lead Assessor,” said one.
“There are multiple routes to Lead Assessor status, some of which are more robust at assessing suitability than others.”
“Companies should be interrogating potential Lead Assessors on experience and track record. Ask how many ESOS assessments they have undertaken and how many were compliant. And have they got experience in your sector?”
Other useful feedback from our experts argues that firms should decide what they want out of ESOS. Is it simply complying or tailoring the process to identify key areas of savings, or to showcase investment opportunities that you may know already exist?
“Think about what your business would like to achieve, engage with the relevant directors and use the ESOS process as a vehicle to help you get there,” advises another expert.
You should work closely with your Lead Assessor to agree the scope of the total energy consumption audit, the sample audits (sites, transport, fuel ) and obtain assurances that they will meet compliance standards, and ensure they capture areas you know your business may be interested in.
Taking compliance a step further
Additionally, our feedback suggests there is real value in looking past a ‘compliance-only’ mentality:
“If you know there is a realistic chance of projects being completed; why not go a step further and get an investment grade audit carried out? Working with your auditors and potential suppliers will give you tangible figures to work with. Most audits will only supply indicative cost and ROI calculations, you would then still need to obtain quotations from suppliers to move any potential project to the next stage.”
And there were some more final tips. “Be prepared, know your business. Omitting areas such as transport fuel and process energy will be a fast track to non-compliance.
“A decent Lead Assessor will be able to guide you, ask the relevant questions and start requesting the various streams of data. However, they are only as good as the information they are provided; you will need to know where to get this data which may involve the cooperation of various people and departments.”
Best of all: get organised. There are a limited number of Lead Assessors and a large number of businesses. One expert advised: “I’d anticipate limitations on availability of Lead Assessors and maybe a last minute rush of orders for compliance work. Unless there’s any significant change to the guidance, I doubt the EA will extend beyond the December 2019 deadline this time.”
