Are you ready for ESOS round two?
It seems like only yesterday that we were all working towards getting our first submissions in for ESOS. Back in November/December 2015 every company with more than 250 employees was busy putting together their submission and searching for a Lead Assessor to sign it off.
Even as late as December 2015 I was training people to become Lead Assessors, and we had companies approaching us to help them with compliance well into 2016.
So how should it differ this time?
Lead in time
The first point, without stating the obvious, is that this time we have had a four-year lead in time. This should have enabled companies, particularly those with a high number of sites, to plan when and how to carry out audits and to focus on elements of their activities. So by the time we get to December 2019 there shouldn’t be any last-minute panics. There are, of course, some elements that can’t be done until January 2019, such as the assessment of the qualification year, but this shouldn’t prevent auditing and data reviews from being carried out.
Last time there were a limited number of Lead Assessors available, particularly at the beginning of 2015 where many hadn’t undertaken training. This time, however, each of the professional bodies that have approved status will offer lists of their certified Lead Assessors. The same will apply as last time. You will need to think about your type of business and what type of Assessor you need. You might want to use the same one for consistency or you might want to try a different Assessor who is going to match your business better or indeed challenge you more.
Tying it in with other things
Because there is more time available, businesses have a chance to think about how they can combine ESOS compliance with other regulatory requirements. For example, metering updates and the minimum building standards Not only does this mean that you will achieve compliance in each aspect efficiently but it will also help to lower the administrative burden. For example, selecting buildings that won’t meet the minimum building standard requirements in 2018 and auditing them now for measures means that you will have your ESOS compliant audit and know what investment is required to meet the standard. You can then choose what to do with the building in question.
Legislation hasn’t changed
There is something about being familiar with what is required. Last time there were lots of questions that were asked about how companies were going to achieve compliance in areas where guidance was a little ambiguous. For example, the number of audits that needed to be completed. This time though, apart from a few companies, more will have already been through the process and know what information is required and how to gather it. They will have the evidence pack to hand and simply want to update it, so physically it will be quicker. It will also be less mentally taxing as you will know what to do and feel more relaxed about it. That said, we have seen a few of our 2015 compliance customers go through audits with the Environment Agency and we know what is asked, and it is worthwhile not becoming complacent.
f you were one of the mass of companies that had European operations then you will know that getting through the UK requirements was easy compared to working out what you needed to do on the continent, if only because each country announced its requirements at different times. At the time, we worked with the Commission looking at how countries were implementing the Directive and even at the beginning of this year saw countries still issuing requirements. And this headache will continue into the next cycle. Needless to say at least you will know again what to do.
I should say that, as at the moment the Commission is busy working, supported by Ricardo, on developing guidance for Member States on how to ensure that their transposition is cost-effective, representative and proportionate.
Finally, there is of course BREXIT hanging over us. But it is fair to say that ESOS isn’t going to be the priority in 2019, and perhaps the Great Repeal Act will cover the continuation of the scheme for at least that phase. That said, none of us can predict the future so who knows what will happen. And of course, irrelevant of what happens in the UK, the European factor of the Energy Efficiency Directive will continue to apply.
So what does all that mean or say to you?
Start early to finish with ease or wait till 2019 and get it done in a month? My preference would be to plan ESOS compliance now, and implement over time, in strategic fashion, to get the most value out of it and any other legislation.
For more information on these changes and what they mean for you, contact me at Christine.StJohnCox@ricardo.com