The recent BEIS consultation on strengthening the Energy Savings Opportunity Scheme (ESOS), sought views on proposed measures to strengthen the scheme, improve the uptake of energy efficiency measures, and increase the benefits for participating businesses. Following a workshop with BEIS and IEMA members, IEMA has submitted a detailed response to the consultation here.
The consultation looks to improve the quality of audits through increased standardisation of reporting requirements. IEMA’s response supports improvements and also the principle of reducing the use of de minimis (excluded energy) to 5%. Under the current 10% approach, there can be whole sites excluded or organisations which never audit their transport energy use. Other improvements include proposals to ensure ESOS assessors are all appropriately trained and monitored. These are supported in the IEMA response, along with a further IEMA proposal for considering two categories of auditor (lead assessor with the overview and with technical assessors contributing).
The consultation raises the concept of introducing a net zero element into energy audits and this is supported by IEMA. ESOS is currently seen as particularly supportive of the upper activities within IEMA’s GHG management hierarchy (i.e. eliminating and reducing emissions). Shorter term cost saving actions recommended through current ESOS audits, can sometimes conflict with longer term investments that will be required to get businesses on a trajectory to meet net zero targets (such as investment in zero carbon technologies, electric vehicles and clean heat). By extending into net zero, ESOS will support additional de-carbonisation through GHG management ‘substitution’ approaches. IEMA has not proposed for these developments to extend into offsetting.
A further important proposal is to extend ESOS to cover a larger range of enterprises (either to all Medium-Sized Enterprises, or to a subset of Medium-Sized Enterprises). IEMA’s response supports extending the scheme to cover Medium-Sized Enterprises (MEs) potentially with use of a threshold requirement which would ensure priority focus on larger scale energy use.
A further proposal in the consultation, is for mandating some ESOS audit recommendations. Although mandatory obligations may not be welcome by some businesses, especially during difficult economic times, this development could support businesses in transitioning their operations to a more sustainable footing. As an alternative, IEMA’s response also proposes that an enhanced ESOS scheme could be better aligned with the Government’s mandatory carbon reporting requirement (SECR). In this regard, an alternative option exists for introducing a mandatory carbon (GHG) reduction target. IEMA strongly supports the use of appropriate mandatory requirements and the imperative for a clear and consistently maintained policy direction.
The BEIS consultation has outlined a range of positive scheme improvements. IEMA’s response emphasises how a revised ESOS, aligned to other government policy and IEMA’s GHG management hierarchy, can support businesses in their transition to net-zero. Central to this is the foundation of good energy management, but for this to be enhanced through a revised ‘net-zero’ Energy Savings Opportunity Scheme and with effective but proportionate mandatory requirements.
Posted on 29th September 2021
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