Requirements of EED Article 8 and implementation experiences and challenges from different countries

Transcription

1 Requirements of EED Article 8 and implementation experiences and challenges from different countries Marco Matteini, Laura Barbier UNIDO Department of Energy Old Tbilisi Hotel, 5-6 June 2018 Tbilisi, Georgia

2 Content 1. Article 8 Energy audits and energy management systems : Requirements and options 2. Article 8: Implementation issues 3. Examples of context and instruments from Member States Acronyms: EED Energy Efficiency Directive EAs Energy Audits EnMS Energy Management Systems 2

3 Article 8 Energy audits and energy management systems : Requirements and options 3

4 Article 8 - Energy audits and energy management systems. Source: [1] 4

5 Definitions Article 8 Energy Audits and EnMS energy audit means a systematic procedure with the purpose of obtaining adequate knowledge of the energy consumption profile of a building or group of buildings, an industrial or commercial operation or installation or a private or public service, identifying and quantifying cost-effective energy saving opportunities, and reporting the findings; energy management system means a set of interrelated or interacting elements of a plan which sets an energy efficiency objective and a strategy to achieve that objective; Source: [1] 5

6 Article 8 What are the obligations? Member States shall Promote availability of high quality and cost-effective energy audits (a) carried out in an independent manner by qualified and/or accredited experts according to qualification criteria; or (b) implemented and supervised by independent authorities under national legislation. Establish transparent and non-discriminatory minimum criteria for energy audits (Annex VI) (for the purpose of guaranteeing high quality of the energy audits and energy management systems) Develop programmes to encourage SMEs to undergo energy audits and subsequent implementation of the recommendations from these audits Bring to the attention of SMEs, including through their respective representative intermediary organisations, concrete examples of how EnMS could help their businesses Source: [1] 6

7 Article 8 What are the obligations? Member States shall Develop programmes to raise awareness among households about the benefits of such audits through appropriate advice services. Encourage training programmes for the qualification of energy auditors in order to facilitate sufficient availability of experts. Ensure that enterprises that are not SMEs are subject to an energy audit carried out in an independent and cost-effective manner by qualified and/or accredited experts or implemented and supervised by independent authorities under national legislation by 5 December 2015 and at least every four years from the date of the previous energy audit. ensure that the management system concerned (energy or environment) includes an energy audit on the basis of the minimum criteria based on Annex VI. Source: [1] 7

8 Member States may Article 8 What is optional? Set up support schemes for SMEs, including if they have concluded voluntary agreements, to cover costs of an energy audit and of the implementation of highly cost-effective recommendations from the energy audits, if the proposed measures are implemented (without prejudice to Union State aid law) Implement incentive and support schemes for the implementation of recommendations from energy audits and similar measures (without prejudice to Union State aid law) Source: [1] 8

9 Article 8 What are obligations & options? Energy Audits May be carried out by in-house experts or energy auditors provided that the Member State concerned has put in place a scheme to assure and check their quality, including, if appropriate, an annual random selection of at least a statistically significant percentage of all the energy audits they carry out. Shall not include clauses preventing the findings of the audit from being transferred to any qualified/accredited energy service provider, on condition that the customer does not object. Shall be considered as fulfilling the requirements of paragraph 4 (i.e. mandatory energy audit for non-smes) when they are carried out in an independent manner, on the basis of minimum criteria based on Annex VI, and implemented under voluntary agreements concluded between organisations of stakeholders and an appointed body and supervised by the Member State concerned, or other bodies to which the competent authorities have delegated the responsibility concerned, or by the Commission. Source: [1] 9

10 Article 8 What are obligations & options? Enterprises That are not SMEs and that are implementing an energy or environmental management system - certified by an independent body according to the relevant European or International Standards - shall be exempted from the requirements of paragraph 4, provided that Member States ensure that the management system concerned includes an energy audit on the basis of the minimum criteria based on Annex VI. Source: [1] 10

11 Article 8 Main obligations 1. Member states must promote the availability to all final costumers of high quality energy audits which are cost effective and: a) carried out in an independent manner by qualified and/or accredited experts according to qualification criteria or b) implemented and supervised by independent authorities under national legislation. 2. Member states must ensure that enterprises that are not SMEs carry out regular energy audits at least every 4 year. Exemption of energy audit applies to not-smes if: Enterprise is implementing an energy or environmental management system - certified by an independent body according to the relevant European or International Standards and Member State ensures that the management system includes an energy audit that meet minimum criteria of Annex VI of the EED. 11

12 Article 8 Implementation issues 12

13 Article 8 What are the implementation issues? 1. Definition of non-sme (i.e. large enterprises) 2. Exemptions from and inclusions for mandatory energy audits 3. Minimum criteria of energy audits 4. Coverage of energy audits and penalties for non-compliance 5. Administrative processes for monitoring compliance 6. Administrative processes for measuring impact of resulting energy efficiency improvements 7. Cost of energy audits 8. Qualification of Energy Auditors 9. Context of/for Energy Audits 13

14 An estimation of complying companies Issue 1 - Definition of large enterprises Country Employees Link employees to financial criteria Annual turnover Link between financial criteria Annual balance sheet total 500 Denmark 250 AND EUR 50m AND EUR 43m 5,000 Finland 250 OR > EUR 50m AND > EUR 43m 50,000 Germany 250 OR > EUR 50m AND > EUR 43m 4,000 Italy 250 OR > EUR 50m AND > EUR 43m 400 Bulgaria 250 OR > EUR 50m AND > EUR 43m 144 Croatia 250 OR > HRK 260m AND > HRK 130m >200 FYRO Macedonia 250 OR > EUR 10m AND > EUR 11m The OR in the EU definition is considered as a non-exclusive OR, i.e. it may also be read as AND/OR Reference: European Union (2016, April) ** Current proposal under discussion Source: [2] 14

15 Issue 1 - Definition of large enterprises Source: [2] 15

16 Issue 2 - Exemptions & inclusions from regular EAs Country Exemption Additional inclusion Reason/ aspects Denmark Finland Germany Companies with an energy consumption below 100,000 kwh/year Large companies participating in a voluntary EE agreement that include energy audits and was signed with government agency ( E.G. the national tool ETJ+) Municipalities and institutions with mainly statutory activities ( e.g. security, judiciary, police, public water supply & government funded educational institutions) Energy-related Art. 8 provision Statutory Italy Public administration offices Energy intensive companies that are registered in the annual list set up by CCSE Ireland Energy use that is covered by the Greenhouse Gas Emission Permit (under the EU Emission trading scheme) Public Service organisations that either: 1. Meet the definition of a large enterprise, or 2. Have an individual building of more then 500m², or 3. Annual energy cost of more than EUR Statutory Energy related Energy related Financial Source: [2] 16

17 Issue 2 - Exemptions & inclusions from regular EAs Country Exemption Additional inclusion Reason/ aspects Bulgaria Croatia In addition, any enterprise operating industrial processes with more than 3,000 MWh annual consumption must also comply with the large enterprise requirements Companies with EUR 34 m < annual turnover < EUR 50 m EUR 17 m < annual balance sheet < EUR 43 m Energy-related Financial Source: [2] 17

18 Issue 2 - Exemptions & inclusions from regular EAs Non-SMEs that are implementing an energy or environmental management system - certified by an independent body according to the relevant European or International Standards - shall be exempted from the requirements of an energy audit. Consider prolonged timeframe for fully implementing alternative systems Source: [2] Remember need for third-party certification by an independent body according to the relevant European or International Standards Ensure quality of EnMS implementation and related advisory/ consultancy services Source: UNIDO 18

19 Issue 3 - Minimum criteria of Energy Audits Energy audits shall be based on the following guidelines: a) be based on up to date, measured, traceable, operational data on energy consumption and (for electricity) load profiles b) comprise a detailed review of the energy consumption profile of buildings or groups of buildings, industrial operations or installations, including transportation; c) build, whenever possible, on life-cycle cost analysis (LCCA) instead of Simple Payback Periods (SPP) in order to take account of long-term savings, residual values of long-term investments and discount rates; d) be proportionate, and sufficiently representative to permit the drawing of a reliable picture of overall energy performance and the reliable identification of the most significant opportunities for improvement. Energy audits shall allow detailed and validated calculations for the proposed measures so as to provide clear information on potential savings. The data used in energy audits shall be storable for historical analysis and tracking performance. Source: [1] 19

20 Issue 4 - Coverage of EAs and Penalties Member states are required to lay down rules on penalties applicable in case of non-compliance. These penalties must be effective, proportionate and dissuasive. Country Denmark Finland Germany Italy Minimum coverage of energy consumption by mandatory audit Up to 10% of the total energy consumption in the company in Denmark can be exempted Minimum of 95% of energy consumption of a company Sampling approach allowed in which: 15 sites = 1 site audit must be completed sites= 10 % must be completed sites = square root of target sites Over 400 sites = 5 % total sites Minimum share of 90% of the energy consumption of a company. Sampling approach allowed Energy audit need to be proportionate and sufficiently representative. Sampling approach allowed Maximum penalties for noncompliance Not specified, case by case decision (Danish court) Case by case, but greater than the cost of undertaking audits Up to EUR Up to EUR Source: [2] 20

21 Issue 4 - Coverage of EAs and Penalties Country Bulgaria Croatia Minimum coverage of energy consumption by mandatory audit All energy purchased by the end user must be covered by audits, i.e. 100%, no exclusion allowed. Sampling of sites is not allowed and all activities of qualifying companies must be audited. No information available (secondary legislation under preparation at the time of the study 2015) Maximum penalties for noncompliance Non-compliance can be penalised through financial measures, or seizure of assets (usually financial). The size of the penalty depends on the severity of the noncompliance, and ranges from EUR 5,000 to EUR 50,000, or facing a property sanction of up to EUR 100,000. Fines for companies between HRK 20,000 (about EUR 2,650) and HRK 500,000 (about EUR 66,225). For a person in charge (e.g. director of the company) an additional fine of HRK 2,000 (approximately EUR 260) to HRK 15,000 (approximately 2,000 EUR) has to be paid. Both penalties may potentially have to be paid at the same time. Source: [2] 21

22 Issue 4 - Coverage of EAs and Penalties Source: [2] 22

23 Issue 5 Admin. process for monitor compliance As of mid-2015 many countries were still in the process of defining how to organize their monitoring processes Country Monitoring of company compliance Denmark Every large company must provide a report of the energy audit to the Danish Energy Agency no later than 1 March 2016 Finland Audit assessments are uploaded to a national database in which Finnish Energy Authority is responsible for quality assessments and completion checks Germany Energy audits are currently not recorded (2015). The Federal Office of Economics and Export Control (BAFA ) carries out spot checks of large companies Italy Bulgaria Croatia Audit assessments are uploaded to a national database in which the ENEA is responsible for checking at least 3% of the audits each year. SEDA collates summary findings from all audits undertaken to monitor compliance and track progress of each company s implementation of the recommended measures. The Ministry of Economy to set up a register for monitoring energy audits. Details regarding the collection of data are not available. Source: [2] 23

24 Issue 6 Admin. process for measuring impact As of mid-2015 most countries still in the process of defining which data to collect and how to monitor the impact of the audits. Some countries expect an active input from the companies Others intend to verify implementation by checking a random sample of companies. Source: [2] 24

25 Issue 7 Cost of Energy Audits The cost of energy audits is highly variable depending on the i. sector ii. size of the facility iii. qualifications of the energy auditor and/or auditing firm iv. type of audit (buildings, processes or transport or a combination) v. accuracy and completeness of information provided by the client vi. level of competitiveness in the auditor market vii. detail provided by the expert viii. Other aspects (tax laws, cost of living, etc.) Source: [4] 25

26 Issue 7 Cost of Energy Audits Manufacturing Source: [4] 26

27 Issue 7 Cost of Energy Audits Manufacturing vs Offices The audit costs depend on the occupied floor area (m²) and on the energy intensity of the organization. These two parameters regularly go hand in hand: Source: [3] 27

28 QUESTIONS! Issue 7 Cost of Energy Audits How would you measure the cost-benefit of an energy audit? How would you measure the cost-benefit of an energy audit programme? 28

29 Issue 8 Qualification of Energy Auditors Majority of MS have put in place certification schemes for the providers of energy audits to help identify appropriately qualified auditors Source: [3] 29

30 Issue 8 Qualification of Energy Auditors Some MS have introduced mutual recognition of qualification/ accreditation schemes across MS borders, to lead to a more open European market for energy auditors Source: [3] 30

31 Issue 9 Context of/for Energy Audits and EnMS Art.8 calls MS to.. Develop programmes to encourage SMEs to undergo EAs and subsequent implementation of the recommendations from these audits Bring to the attention of SMEs concrete examples of how EnMS could help their businesses.. consider to.. Set up incentive and support schemes for EAs and implementation of recommendations also in non-smes Past national and international experience with energy auditing programs in industry (and other sectors) show strong evidence that EAs programs, when run in isolation, have limited impact in terms of energy efficiency projects/ recommendations implementation and energy savings. Evidence shows that EAs impact is high when EAs are combined with additional complementary policy measures 31

32 Examples of context & instruments from Member States 32

33 Issue 9 Context of/for Energy Audits and EnMS Overview of instruments in Denmark Instrument Area of application & Focus Type of instrument Mandatory energy audit Large enterprises Energy audits Regulatory Energy saving obligation targeted at energy companies Renewable energy for production processes ( VE til process scheme) Large enterprises SME Energy audits SME Energy audits Financial Financial Energy management light SME Energy management system Voluntary agreement scheme Large enterprises SME Energy management system Information Voluntary agreement Source: [2] 33

34 Issue 9 Context of/for Energy Audits and EnMS Overview of instruments in Ireland Instrument Area of application & focus Instrument Mandatory energy audits & Energy Auditing Scheme (SEAI ) Large enterprises SME Energy Audit Regulatory SEAI Energy Agreement Programme (EAP) Large enterprises Energy management system Voluntary agreement Large Industry Energy Network (LIEN) Large enterprises Exchange Mechanisms Voluntary agreement Source: [2] 34

35 Issue 9 Context of/for Energy Audits and EnMS Overview of instruments in Germany Instrument Area of application Type of instrument Mandatory energy audits - Interpretation guideline published by BAFA Large enterprises Energy audits SME Energy Consulting Programme SME Energy audits Regulatory Financial Eco tax cap for manufacturing industry Large enterprises SME Energy audits Energy management system BAFA support programme for energy management systems BAFA support programme for cross cutting technologies Large enterprises SME Energy management system Large enterprises SME Energy audits Energy efficiency networks Large enterprises SME Energy audits Financial Financial Financial Information Source: [2] 35

36 Issue 9 Context of/for Energy Audits and EnMS Overview of instruments in Bulgaria Instrument Area of application Type of instrument Mandatory energy audits Large enterprises (SME) Energy audits Energy Efficiency and Green Economy SME Energy audits Regulatory Financial Industrial Energy Efficiency Targets (IEET) for industrial energy enterprise owners Large enterprises SME Energy audits (Energy management system) Voluntary agreements Source: [2] 36

37 For consideration and discussion What is the objective of Article 8? Who will pay for the energy audits? When to consider an energy audit cost-effective? How many would be the large enterprises in Georgia? How many in the industrial sector? How many energy auditors would be needed in Georgia? How many for industrial systems/enterprises? 37

38 Sources and References [1] DIRECTIVE 2012/27/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC [2] A Study on Energy Efficiency in Enterprises: Energy Audits and Energy Management Systems - Report on the fulfilment of obligations upon large enterprises, the encouragement of small- and medium-sized companies and on good-practice [3] A Study on Energy Efficiency in Enterprises: Energy Audits and Energy Management Systems - Report on the qualification of energy auditors in all Member States [4] A Study on Energy Efficiency in Enterprises: Energy Audits and Energy Management Systems - Library of typical energy audit recommendations, costs and savings [5] A Study on Energy Efficiency in Enterprises: Energy Audits and Energy Management Systems - Implementation of national minimum criteria for energy audits, in line with Annex VI of the Energy Efficiency Directive [5] 38

39 THANK YOU! For more information: Mr. Marco MATTEINI Industrial Development Officer Energy System and Infrastructure Division UNIDO Department of Energy