One of the new requirements for ESOS compliance in Phase 3 is an action plan. The deadline to submit your ESOS action plan for Phase 3 is 5 December 2024, but it pays to think about it now rather than leaving it until after you’ve submitted your reporting. Here’s how to put together a good quality plan.
Consider all the recommendations
Your initial ESOS audit will identify a number of opportunities for your organisation to save energy. The official guidance says that the measures recommended should be “practical and cost-effective”. This doesn’t mean you have to implement every recommendation, but it does mean that they are all worth consideration. For the recommendations you’re choosing to reject, it’s worth recording your reasons. This is mainly for your organisation’s own records, so that if someone wants to revisit the decision in the future the information will be to hand. But you can include a short summary of rejected measures in your action plan to show that your organisation is taking its ESOS obligations seriously.
Be clear on timescales
Once your organisation has chosen the measures to implement in the current ESOS phase, you need to work out when you will be carrying them out. Some measures would not be appropriate to implement immediately – for example, if an equipment lease is up for renewal then it makes sense to wait for a new lease. Your ESOS audit should suggest timescales for each of the recommended measures, taking into account issues such as equipment obsolescence, lease renewal dates, tenancy agreements and so on.
You do not have to accept the audit’s suggested timings, but the information should help you make decisions on what to do when. Then your ESOS action plan should include not just the list of actions your organisation intends to take, but intended timescales. For each measure, state the month and year you intend to begin.
Be realistic
The ESOS rules require you to submit a progress update in the 12 months following the action plan deadline, then another one in the 12 months after that. All this information is made public, so it could affect your organisation’s credibility if you make an over-ambitious ESOS plan but then only achieve a small fraction of it. If your planning is thorough and realistic, you should be able to chart a course of action that is achievable but still results in significant energy savings.
State the energy savings
Your ESOS action plan must include an estimate of the energy savings you expect to achieve through each action over the course of the action plan period. For Phase 3, that means up to 5 December 2027. The information that you need to calculate this should be in your original audit report. If you took an alternative route to ESOS compliance, such as ISO 50001, you will need to find another way to calculate estimated savings. Whatever way you come up with the numbers, you will need to state the source of the data for your estimate.
Add it up and break it down
The rules also require:
- a combined estimate of all the energy savings you will achieve by the end of Phase 3 if you carry out everything in your action plan;
- a breakdown of these energy savings according to the area of energy consumption (e.g. transport, industrial processes).
State your sources
Your ESOS audit doesn’t have to be the only source of recommendations for energy-saving measures. Your organisation may get advice from elsewhere, may be using an alternative route to ESOS compliance, or simply decide to carry out actions that are not suggested in the audit. It’s fine to include measures that are not mentioned in your ESOS audit, but you do need to clearly state the source of the recommendation. As with any other measure, you also need to include the month and year you intend to carry it out, and the projected energy savings in Phase 3.
Compiling a credible ESOS action plan is a challenge, but your initial audit will be packed with information and suggestions to inform your decision-making. Your action plan is effectively a strategy for saving your organisation significant sums of money and perhaps operating more effectively too. So don’t rush these discussions and don’t be afraid to seek expert advice.
