OPINION: REGULATIONS


OPPORTUNITY KNOCKS


The government is consulting on the Energy Saving Opportunity Scheme. Hywel Davies explores what it could mean for building owners, operators, and energy professionals


officials emphasised the pre-existing schemes, and section 6.2 of the


impact assessment identifies some 16 of them across the buildings, industrial and transport sectors. As a result, the consultation proposes that organisations already within the CRC, or with Display Energy Certificates, or a Green Deal Assessment, may use these in their energy audit. The consultation also proposes that organisations which have implemented ISO 50001, the international energy management standard, and in some cases ISO 14001, the environmental management standard, may use these for partial or full compliance with Article 8. Those organisations will already


Who will audit Britain’s building stock?


Last month I described the Energy Saving Opportunity


Scheme (ESOS), which has been proposed by the government to implement the requirement for energy audits contained in Article 8 of the Energy Efficiency Directive. This sparked a lively debate on


both the CIBSE and the Energy Performance Groups’ LinkedIn pages about who is going to undertake these audits. There are also some interesting estimates buried in the impact assessment from the Department of Energy and Climate Change (DECC), which merit some further debate. These are about how much energy these audits are expected to save. The directive itself requires energy


audits to be based on up-to-date, measured, traceable operational data on energy consumption and electricity load profiles. They must comprise


16 CIBSE Journal September 2013


a detailed review of the energy consumption profile of buildings or groups of buildings, industrial operations or installations, including transportation, and be proportionate, representative and identify significant energy savings opportunities. They should take a long-term, life cycle view rather than being simple payback calculations. These are all sensible activities, although the Directive stops short of requiring anyone to implement any of the savings opportunities. However, there are already schemes in place that do similar things, although none of them fully matches the requirements of Article 8. This means that the UK cannot just point to an existing scheme


as meeting its obligations under Article 8, but has to introduce a new scheme for that purpose. Early discussions with DECC


During


discussions, CIBSE and others suggested that DECC should try to employ those already accredited


have accredited assessors in place to carry out those assessments. But what about those activities not covered by one of these schemes, or those organisations brought into ESOS that do not complete a CRC return or have DECs or greenhouse gas returns? Who will audit them? Chapter five of the consultation document considers this. It notes that there are already a number of schemes in place that recognise competence in this field, including the CIBSE Low Carbon Consultants scheme, the Low Carbon Energy Assessors Scheme and the Register of Professional Energy Consultants operated by the Energy Institute. There are also a good number of chartered engineers who already provide investment-grade energy audits for leading property businesses. Indeed, the consultation suggests that ‘there are a large number of individuals who already have the expertise to conduct energy audits’. During discussions between DECC


and various stakeholders, CIBSE and others suggested that DECC should try to employ those already accredited, without imposing significant additional accreditation requirements on them. The consultation proposes two


options for recognition of appropriate www.cibsejournal.com


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