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ESOS: Five key steps to successful compliance

Open-access content Tuesday 30th June 2015 — updated 1.53pm, Tuesday 5th May 2020

The ESOS compliance programme presents FMs with a chance to find cost-cutting routes to help their businesses save money and even generate revenue, says Stuart Campbell .


18 June 2015 | By Stuart Campbell


At first glance, the ESOS (Energy Savings Opportunity Scheme) compliance scheme may seem like an exercise in red tape. 


But it is being implemented to help the government to meet Article 8 of the European Union Energy Efficiency Directive (2012/27/EU). 


Set to affect up to 15,000 businesses, the ESOS audit process will help companies to identify areas where energy use can be reduced across company buildings, transport and industrial activities. Companies are required to complete ESOS audits every four years. 


The 15,000 businesses that must comply either employ 250 people or more, and/or have an annual turnover above £38.9 million, and/or an annual balance sheet above £33.5 million. Firms are required to complete and submit the audit by 5 December 2015 at the risk of ongoing fines of £500 each working day and a fixed penalty of up to £50,000. 


What's in it for FMs? They get to raise their profiles within their businesses with an increased capacity to lobby for energy improvements and cost savings. It's also a chance to incorporate energy efficiency into your company's financial planning.


1. Who carries out the audit? 

Decide who is going to complete the ESOS audit before work begins. Are you going to complete it yourself? Or would you rather outsource it? If you are outsourcing the process, ensure that you engage the services of a company that employs lead assessors directly in-house. Otherwise, you run the risk of non-compliance, as the company you've hired may not have the resources to get the work done before the deadline. 


Choosing the right lead assessor for the role is crucial. Hiring an experienced and qualified assessor to complete your audit is important - find one who knows your sector. You have to select an assessor who is professionally vouched for by one of 12 registers, including the Association of Energy Engineers (AEE) or the Energy Institute or CIBSE (Chartered Institution of Building Services Engineers). 


2. Data collection

The next step is gathering the data you need to declare your firm's building, process and transport energy use, which will need to be translated into common units of kilowatts per hour when it comes to completing the audit. 


If you've undertaken the compliance process yourself - and some FMs have chosen to take control of the full compliance process and become trained as lead assessors in their own right - this is where the complexity begins. These FMs need to be especially cautious when it comes to calculating their data use as they may not be fully aware of the scope of what they need to report. 


Transport, for example, is especially challenging as it lies far outside the traditional FM role and requires a detailed breakdown of your company's fleet to identify where a higher level of consumption needs to be declared. If you are taking this route, factor in time and cost for consultancy with an external lead assessor to help you identify all available savings. 


3. Establish survey demands

Bear in mind that there are a number of ways data can be accumulated, especially on the property side of the audit. Only a representative portion sample of your portfolio will need to be sampled. If most of your company's buildings perform the same role - if you manage, say, a string of fast-food chains a site visit won't be required for each property. You can justify this approach when completing your compliance pack. Providing your lead assessor feels the sample you've picked reflects your portfolio, you will be considered compliant. 


4. Seal of approval 

Although the energy surveys you're required to provide can be completed by anyone, remember that the full ESOS compliance pack needs to be signed off by a lead assessor before you can present it internally. This has to be factored into both timings and costs. 


5. Prepare a successful presentation

Your completed ESOS audit report will need to be signed off by a director or board-level member within your business - two directors if you undertake the work in-house. Bear in mind that they will not need to act on the energy improvements that you've highlighted, but they do need to confirm that they've read and understood the information in the report. 


If you've decided to outsource the presentation process to your lead assessor, remember that you'll need to pay for this service. Make sure also that you've got a date booked in the diaries of both assessor and director early on. The festive season is a hectic period - and no one wants to be offering the risk of fines as an early Christmas present to their company if the process isn't complete by the 5th of December. 

 

Once the report has been signed off, you will need to notify the Environment Agency of your compliance.  


Stuart Campbell is a director at Savills Energy


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