EU Energy Efficiency Directive (EED) Article 8

Transcription

1 EU Energy Efficiency Directive (EED) Article 8 Insert then choose Picture select your picture. Right click your picture and Send to back. May 2015

2 Agenda Introduction Overview of EED and European Implementation Pan-European Compliance Options Challenges and Benefits Any Questions?

3 Introduction to ERM ERM is a leading global provider of environmental, health, safety, risk, and social consulting services Operating for over 40 years, now in over 40 countries in the fields of: performance improvement, including enhanced compliance with EHS regulations, due diligence in the context of transactions management of safety risks associated with workplaces and hazardous installations impact assessment and planning support to major capital projects management of contaminated sites Strong track record and expertise on energy, carbon & climate policy issues

4 What is EED? EED stands for the European Union Energy Efficiency Directive EU target of a 20% improvement in energy efficiency by Directive 2012/27/EU (EU Energy Efficiency Directive) established common framework of measures, to be transposed into national legislation in all member states. Article 8 of the EED requires Member States to ensure that large enterprises carry out energy efficiency audits by 5 th December 2015 and at least every four years thereafter.

5 Overview of implementation status in EU Final Regulations implemented Austria, Bulgaria, Denmark, France, Germany, Ireland, Italy, Slovakia*, Sweden and UK Draft Regulations under review Belgium, Czech Republic, Hungary, Netherlands, Portugal, Poland, Romania, and Spain No Regulations or timeline confirmed Greece * Alternative scheme already in place

6 Overview of EED implementation Name of scheme Energy Savings Opportunity Scheme (ESOS) Qualification criteria Scope of energy supplies included Scope of audits Total energy consumption across all UK registered undertakings over 12 month period 90% of consumption, within which a sampling approach is allowed Decree , 24 Nov 2014 All large undertakings defined as: 250 employees; OR Balance sheet > 43m EUR and Turnover > 50m EUR Total energy consumption across all French operations over 12 month period 65% of consumption (Year 1) with no sampling allowed Law on energy services and other energy efficiency measures Total energy consumption across all German operations over 12 month period A sampling approach is allowed Relevance of existing schemes Only ISO enables full exemption ISO or 2009/1221/EU (EMAS) enable exemption Aggregation rules UK registered companies, aggregated at highest UK parent level Company is identified by the SIREN code Germany registered companies

7 UK: ESOS Compliance Requirements Energy Assessment based on EN over a 12 month reference period to establish total energy consumption reference period must include 31 st December 2014 includes all UK energy consumption all fuels, all buildings, all company operated transport (including employee business mileage in own vehicles) Aggregated at the highest UK parent level Energy Efficiency Audit overseen by registered Lead Assessor, who also signs off the Energy Assessment covers 90% of total energy consumption, on a sampling basis identifies cost-effective energy efficiency measures, and rank these based on the ROI ISO is an alternative route to compliance Reporting and Sign Off must be signed off by at least one board member of the company Full compliance must be notified through the Environment Agency portal before 5th December 2015 no obligation to act on findings under ESOS purely business decision Submit ESOS notification of compliance online to the Environment Agency

8 France: Decree 1393 Energy Assessment Energy Efficiency Audit Reporting, Sign Off & Penalties based on EN over a 12 month reference period to establish total energy consumption includes all France energy consumption all fuels, all buildings, all company operated transport (including employee business mileage in own vehicles) aggregated at the legal entity level (code SIREN) overseen by qualified assessor, who also signs off the Energy Assessment (if external assessor, and no ISO14001 certification exists) covers 65% of total energy consumption identifies cost-effective energy efficiency measures, and rank these based on the ROI Does not need to complete these audits if company has current ISO in place must include a description of the entity submit report to local authorities (prefecture) before 5th December 2015 no obligation to act on findings purely business decision the potential penalty is defined by local authorities, subject to a maximum of 2% of the company s revenue, exc. taxes 8

9 Germany Energy Assessment Federal Agency for Energy Efficiency (DENA) has finalised the Law of Energy Services and Other Energy Efficiency Measures Qualification is based on the whole corporate group which includes Affiliated and Partner companies Scope of included energy consumption is yet to be confirmed Energy Efficiency Audit Energy audit must be conducted independently and overseen by qualified assessor. A representative sample is required to cover all operations identifies cost-effective energy efficiency measures Exempt from energy audits if ISO certification has formally begun or if EMAS is in place Reporting and Sign Off Full compliance must be completed before 5 th December 2015 Compliance reporting mechanism is yet to be confirmed

10 Typical Steps to Pan-EU Compliance Stage 1 Stage 2 Stage 3 Country assessment Data collection and compliance plans Audits and compliance reports What are the rules in my countries? Do I need to comply? What have I already done? What audits are needed? What are the next steps? How do I confirm compliance? 1. Identify and review country level Article 8 legislation 2. Undertake qualification assessment to determine which entities meet the qualification thresholds 1. Review of corporate energy dataset and information on previous audits 2. Develop compliance strategies 1. Complete audits and reporting 2. Submit evidence packs to the local/national authority

11 ISO option EED compliance can be achieved by demonstrating a valid ISO Energy Management System (EnMS) certification If you already have a mature EnMS, it is still possible to achieve ISO50001 certification by Dec 2015 OR: the EED energy assessment in 2015 can form part of building an EnMS in time for the next compliance period. Why follow this route? ISO 50001: Requires that you have improved energy performance An internationally recognised good practice Similar to ISO 14001, likely to become desired/required in procurement More expensive initially but maintaining certificate ESOS assessments EED compliant audits: Can be compliant by simply shelving assessment findings: may not deliver performance improvements doesn t demonstrate value to customers/ stakeholders Different requirements for different countries = bureaucracy

12 Challenges to manage Different systems across Europe, different levels of complexity and current understanding Timing: compliance date of 5th December 2015 for all Energy Assessment and full program of Energy Audits Significant additional administrative burden for some organisations Registered Lead Assessors and qualified energy auditors are likely to be in high demand, particularly in H2 of 2015 Allocating responsibility between central corporate functions (EHS, legal) or national entities

13 Benefits Energy savings In ERM s experience, energy efficiency programmes, especially for operations who haven t actively undertaken such actions, have the potential to save 10-15% of energy costs from low-cost or no-cost interventions, year after year. Identifying priorities for investment and efficiency A program of audits will help to map out and prioritise energy cost saving opportunities across an organization s Improving energy management across European operations and helping achieve a consistent approach. A four yearly rolling program of audits will be required by EED. Engagement with senior management will help to raise the profile of energy efficiency programs.

14 Any Questions? To recap: EED Article 8 requires large enterprises carry out energy efficiency audits by 5 th December 2015 and at least every four years thereafter. Article 8 is implemented by national laws in each Member State. To date, at least 10 Member States have fully implemented their national laws. At least 8 are in the process of doing so. Approaches vary subtly between Member States, e.g.: The scope of the energy audit and allowance of sampling Rules on aggregation of corporate entities Exemptions for ISO50001, EMAS, and in some countries, ISO14001 with energy audits Audits should identify significant opportunities for cost savings through energy efficiency and raise profile with senior management

15 About ERM ERM is one of the leading sustainability consultants worldwide, providing environmental, health, safety, risk and social consulting services 5000 employees globally in 40 countries Over the past five years we have worked for approximately 50% of the Global Fortune 500 Who to contact UK Charles Allison Partner ERM France Stefano Bonelli Principal Consultant ERM +33 (0) Germany Sasa Fistric Senior Consultant ERM +49(151)