IEMA backs streamlined energy policy framework
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Companies are concerned by the increasing number of overlapping energy and carbon reduction policies, warns IEMA
In its response to Decc's consultation on introducing mandatory energy audits for large companies, IEMA states that the expanding energy and carbon policy landscape is causing businesses concern.
The Institute argues that the increasing number of overlapping but disconnected policy measures, such as the carbon reduction commitment (CRC) and the proposed energy savings opportunity scheme (ESOS), which will require firms to conduct regular energy audits, is making it difficult for practitioners to explain environment policy and its impacts to directors.
"The new ESOS proposals are being introduced into what is already a very busy policy landscape," said Nick Blyth, policy and practice lead at IEMA.
"We do not wish to see any important policy drivers lost without adequate replacement. However, many practitioners want to see a more streamlined and complimentary policy suite, underpinned by effective long-term fiscal drivers, such as a carbon tax."
IEMA acknowledges that ESOS, which implements the requirements of the EU Energy Efficiency Directive (EED), will help firms improve their energy efficiency, particularly if they are not subject to the CRC or mandatory greenhouse-gas reporting, for example. However, it urges the government to ensure the scheme does not place too great a burden on those enterprises already regulated on energy and carbon.
The Institute's response to the consultation also warns that there may not be enough qualified assessors to undertake the energy audits when the scheme comes into force at the end of 2014.
"Many practitioners consulted by IEMA advise that there is likely to be a shortage in supply of energy assessors, especially in the initial period," it states. "Concerns are around both the quality of assessors and also their availability... examples were provided of earlier schemes with poor quality energy reviews.
"The ESOS is placing a significant reliance on these assessors in terms of their abilities, understanding, discretion and judgment. IEMA believes that a training programme is required to ensure that energy assessors are suitably prepared for ESOS."
The Institute also backs the use of ISO 14001 in ensuring compliance to ESOS. While acknowledging that certification to the environment management standard will not automatically address the EED requirement for an energy audit, it argues that with 9,000 firms in the UK already using 14001, it is logical to use it as a starting point for compliance.
"We see 14001, with accredited certification and energy auditing, as an effective option for supporting ESOS compliance. We believe Decc should prioritise its use as a potentially effective 'lighter touch' response option for thousands of businesses," states IEMA.
To read IEMA's full response click here.
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