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Discover the Sustainable Footprints' musings and responses to legislation, news and events.

According to the Energy Savings trust, the energy bill of a typical office based company could cost over 65% more than that of an equivalent energy efficient office. Below we have listed a few of our energy saving tips and advice for easy no cost ways to save energy, lower your bills and reduce your carbon footprint within your business. Keep an eye on our social media for more energy saving tips coming out in the next few weeks!

For heating, check your systems operating hours match the times when heating, ventilation and cooling are required as needs vary throughout the day and in different seasons. You should also observe your working patterns and ensure you make the relevant adjustments to your controls.

For heating and cooling you should set a dead band (a wide gap between the temperatures at which heating and cooling cut in) to avoid heating and cooling operations at the same time. In an office environment, the heating should switch off when a temperature of 19ºC has been reached and cooling should not come on until the temperature exceeds 24ºC. This sets a dead band of 5 degrees Celsius and offers 10% savings.

For your equipment, minimise cooling load by placing heat emitting equipment in a naturally ventilated area with good airflow. You should also switch off all equipment when not in use and enable power down modes. As well as clearly reducing the energy consumption, it also reduces the heat produced by equipment which in turn, lowers cooling costs. Equipment lifespan will also be extended and maintenance costs and risk of breakdown should be reduced.

To maximise lighting savings ensure you utilise natural daylight and have a switch off policy for staff to increase awareness. You could also consider using transparent shades or fittings, as a dark lampshade can absorb some of the light a bulb emits. Finally, wash your hands using the cold tap – by the time the hot tap has got hot water, you’ve finished washing your hands anyway, but you’ve emptied some hot water from the hot tank, with cold water going in to replace it – thus you trigger the boiler to warm it up. All you’ve done is warmed up the pipes in your house!

What’s New with ESOS Phase 3

The Energy Savings and Opportunities Scheme (ESOS) is a mandatory energy assessment scheme for UK organisations who meet the qualification criteria regulated by the Environment Agency (EA).

Assessments must be conducted every 4 years with the corresponding compliance period also known as a ‘phase’.  Phase 3 is approaching quickly with the qualification date being 31st December 2022. This means that the 12-months data used for your ESOS compliance must include this date.  The deadline for Phase 3 compliance is 5th December 2023.

Please see:  https://sustainablefootprints.co.uk/esos for more details about qualification and complying with ESOS.

Phase 3 Changes:

Following a lengthy consultation, the UK Government have recently announced changes to the ESOS requirements for Phase 3.  These include:

  • Turnover and balance qualification criteria now in GBP:  Following Brexit, the legislation for ESOS has been moved from EU to UK law.  This means that, due to no longer needing to convert between Euros and GBP, there is a slight change to the qualification criteria for turnover and balance.  This is now set at a turnover in excess of £44m and a balance sheet total of more than £38m.  The number of FTEs remains unchanged (250+).
  • De-minimis reduced to 5%:  The previous de-minimis for ESOS of 10% has been reduced to just 5% (the de-minimis is a percentage of the total energy consumption (TEC) that can be excluded from the assessment).  This means that energy sources that you may have previously excluded from your ESOS compliance may now need to be included.
  • Inclusion of an energy intensity metric:  This is already a requirement under Streamlined Energy and Carbon Reporting (SECR) which is a sign of the Government aligning the two compliances.  The intensity metrics, such as  kWh/m2 for buildings, kWh/unit output for industries and kWh/miles travelled for transport, will allow wider context to energy usage and will more adequately demonstrate energy consumption reduction than comparing the total quantity with previous years.
  • Sharing ESOS report with subsidiaries:  If your ESOS is managed at parent company level for all your subsidiaries, there will now be a requirement for the ESOS report to be shared with your subsidiaries so they are all aware of the findings and recommendations made.
  • Inclusion of a standardised compliance template within the ESOS report:  To make reporting more standardised, a template for including compliance information has been set out for Phase 3 and includes details such as reason for qualification; route(s) to compliance used; total energy consumption (TEC) and significant energy consumption (SEC); de-minimis exclusions; estimates and energy profiling; number of sites, how sites have been sampled and rationale for this; total savings identified and actions taken since previous audit; and confirmation that the Board Member signing off the report is an Executive Director for highest UK parent.  The full template will be provided by the Government in sufficient time so necessary changes to reporting can be made.
  • More detail on next steps:  This will provide additional information on implementing your recommendations.
  • Requirement to set energy efficiency targets and implement a energy reduction action plan:  Whilst this is not required for ESOS Phase 3, there is an expectation that they will be adopted once your ESOS Phase 3 compliance has been completed.  It is worth noting that you will be required to report against this for ESOS Phase 4 so it is important that you undertake this process once your Phase 3 compliance is complete.

If you are utilising a registered ESOS Lead Assessor for your ESOS compliance, they will take care of all the above changes for you but if you comply via the ISO 50001 or the DEC route, you will need to be aware of this yourself.

It’s important to acknowledge that these may not be the only changes that the UK Government bring in for ESOS Phase 3 so it is important to watch this space for more up-to-date details and to ensure that your registered Lead ESOS Assessor is aware of the new changes that have been announced.

Phase 4 Expected Changes:

There are many changes expected for Phase 4 which have not yet been announced.  The only one that has been confirmed is the requirement to report against your energy reduction targets and action plan that you should adopt following Phase 3 compliance.  However, the Government have stated that there will be more inclusion of net-zero requirements which may include the additional reporting of greenhouse gas emissions alongside energy consumption (Sustainable Footprints already include this as standard).   There are also considerations being made as to whether implementing the identified recommendations should be made mandatory, as well as potentially making is a requirement for some elements of the report to be made public.  It is also likely that the qualification thresholds will reduce to require medium-sized organisations to be required to comply with ESOS Phase 4.

More details of the consultation and the Government’s response to it can be found at:  Strengthening the Energy Savings Opportunity Scheme (ESOS): consultation on options (publishing.service.gov.uk)

Need ESOS Support?

Sustainable Footprints are registered ESOS Lead Assessors and specialise in all areas of ESOS including buildings, process and fleet.  If you would like to discuss your ESOS Phase 3 requirements or would like any further information on ESOS, please don’t hesitate to contact us at info@sustainablefootprints.co.uk or call 01444 350021.

The CEDREC Roadshow

The Sustainable Footprints Team attended the recent CEDREC Roadshows in London and Sheffield, which are great annual events covering legislation updates for both the environment and health and safety. We are regular attenders at these events, as we find them invaluable. For information about CEDREC, see www.cedrec.com.

The 2020’s are being lauded as the decade of significant change for UK environmental legislation. With the government setting the net-zero target of 2050, there is an urgent need for businesses and other institutions to implement more sustainable practices and embrace net-zero for themselves. It has therefore been disappointing to see how little progress there has been in bringing forward a lot of the required legislation, with much of it still in the consultation phase.

Energy Savings Opportunities Scheme (ESOS)

We are currently within the compliance period for ESOS Phase 3 but there is still ongoing consultation about potentially strengthening the ESOS requirements for this phase. The proposed changes include the requirement to report greenhouse gas emissions (GHG); the potential public disclosure of ESOS reporting, to allow more transparency and implementation; and the introduction of further ESOS auditor qualifications. 

In addition to this, there is also consultation on further increasing requirements for ESOS Phase 4 (deadline 5th December 2027) by lowering the threshold to medium-sized enterprises (MSE) in order to increase the number of participants. The new eligibility criteria would involve organisations to have 50 or more employees, or a turnover of greater than £10.2m and a balance sheet total greater than £5.1m. We are not yet sure, if this will apply to all MSEs, or only to those that are industrial in nature or have a high energy usage but hopefully this will be confirmed soon. It is also proposed that implementing ESOS recommendations with a payback period of between 3 and 7 years becoming mandatory.

These proposed changes, especially those related to phase 3, which is right around the corner, may have a knock-on effect to organisations already preparing data, as the proposed reporting requirements won’t be announced until a later date. This is why Sustainable Footprints Ltd are already preparing for the new requirements when collecting data on site. However, there is a possibility this could change the compliance deadline due to the proposed last-minute change.

Task Force on Climate Related Financial Disclosures (TCFD)

There have been some significant changes to mandatory climate-related disclosure reporting. As of 6th April 2022, Britain’s largest companies and financial institutions must now report on their climate-related risks and opportunities in alignment with the requirements set out by the Task Force on Climate Related Financial Disclosures (TCFD). TCFD are an industry-led group which aim to help provide transparency to investors.

This new legislation will include many of the UK’s largest banks and insurers, as well as private companies with more than 500 employees and a turnover greater than £500 million. Aspects to include in this new reporting disclosure include climate related risks and opportunities; the time period of these risks; actual/potential impact on business activity; a resilience assessment; and targets and KPIs for the management of risk and resilience.

Environment Act

Moving towards the environmental side, the Environmental Act came out last year and it is the most significant piece of legislation in decades due to the resolutions of Brexit issues and a new framework for environmental controls, such as the Office for Environmental Protection (OEP). Currently, the act is only directed at governments; however, it is likely that this will be directed to the general public through regulations and requirements from the government at a later stage.

The OEP are new independent environmental regulators with the aim of holding local authorities and the government to account if they don’t achieve set environmental targets. However, it looks like a long process for this to happen due to the scope lacking clarity. A ‘public authority’ is described as a person carrying out any function of public nature that is not a devolved or parliamentary function. The scope later explains “the term public function is not defined in the act (or in the Human Rights Act 1998), so it will ultimately be for the courts to determine what constitutes a “public function.” We are now awaiting further clarification of the scope.

Plastic Packaging Tax

The plastic packaging tax came into force from 1st April 2022. Businesses are obligated to register and report (even if not taxable). There is a £200 per tonne charge for plastic packaging manufactured in the UK where over 10 tonnes of plastic are manufactured in either the last 12-months or the next 30 days.

This new piece of legislation is very interesting as, if someone in your supply chain is not paying the tax, you can be held accountable for their non-compliance. Furthermore, there is a lot of confusion over the rules of financial modifications – for example, if you print an expiry date onto a water bottle you are classed as a manufacturer; however, if you put a label onto the product then you aren’t.

Plastic in scope includes transport packaging within the UK used for supply chains and single use consumer packaging. Primary functions such as medical equipment or first aid boxes are exempt.

Environmental Changes to Buildings Regulations

From 15th June 2022, anything greater than 25% of a new or major refurb site’s carbon footprint will be required to include electric vehicle charging infrastructure if they plan on having at least 10 parking spaces. This infrastructure must include at least one charging point and at least 1 in 5 spaces having cable ducting to allow future charging point development for electric cars.

Additionally, in the building sector, the Bill for Minimum Energy Performance has proposed amendments of regulations to introduce new rates. Currently, the rating for domestic buildings is B and non-domestic E. By 2030, it is proposed that all non-domestic rented B and B with milestones in 2025 and 2028 for new and all domestic rented to become B and C.

To conclude, a lot of eligibility criteria for new compliance is open to interpretation, very loosely explained and subject to last minute reviews which will undoubtably cause issues for eligible organisations. It’s therefore important to keep an eye out for any future changes to what has been discussed in this blog, especially due to the fact that a large amount of legislation still remains in the consultation stage. Sustainable Footprints will be keeping you up to date via our social media feeds, bi-monthly newsletters and blogs so watch this space!

We want to thank CEDREC for having us and we look forward to attending your roadshow next year!

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