It seems our old friends at the EU policy unit have been spending their summers on the beaches dreaming up more ways of loading yet another unnecessary cost onto our industries and commerce.
Only the EU could come up with a requirement, under the improbably named Energy Efficiency Directive, for all businesses (private sector only – the public sector, strangely, gets a mention but is excluded from the debate) with a turnover of c. 50 Euros or more to have an “energy audit”. What’s more an undefined energy audit, cue much debate in the industry as to what exactly they mean.
It will have to be repeated every four years – and failure to do so will incur, as usual, a set of penalties (that’s fines to you and me).
I can already sense some of our EU friends, from Croatia to Ireland to France to Slovakia frantically searching for ways to completely ignore the contents of this strange edict from Brussels.
So there we have it: ESOS, acronym for the Energy Savings Opportunities Scheme, on which the Department of Energy & Climate Change has launched the inevitable consultation (with a picture of solar photovoltaic panels on the front of the document which have nothing whatever to do with energy efficiency).
Are we missing something?
Except… The EU, in its great enthusiasm to potentially create yet another cottage industry, this time for aspiring energy auditors, appears to have missed a small but salient detail.
Whilst there are penalties for not having the “energy audits” completed there is absolutely no requirement on businesses to do anything at all about the findings.
A range of estimated costs for completing these “audits” in various businesses are quoted which seem mysteriously low. There are no estimates for the major businesses for whom costs will be many times those quoted. They also ignore the extra costs of installing Automatic Meter Reading equipment which could far outweigh the costs of the “audits”.
Seeing double? So am I
In fact, with my former corporate hat on, it has to be said that any responsible business will already have audited their buildings to a standard far beyond the requirements of this “EU offspring of CRC”.
In the retail sector alone these savings, of combined investment, behavioural change and improvements to things like Facilities Management, can be counted at least in the range 20-40% over the last five years.
Why on earth would these businesses want to pay out again on another level of auditing which most likely duplicates what’s been done already? That’s not even taking into account the audits they have from standards they already hold (but which are there for totally different reasons) like the Carbon Trust Standard and ISO50001.
Is this inevitable time-wasting?
Could this time not be better spent just managing energy within the businesses concerned? Energy efficiency is on the radar already for the vast majority of organisations and they’re visibly doing something about it – legislation should be encouraging this in lean, green and mean measures which incentivise results, not woolly fluff.
Whilst it may be that compromises are reached, once everyone figures out what the ESOS is all about, it is also apparent there are many aspects of the Directive which are “non-negotiable”.
It looks inevitable that businesses will be dragged into yet more fundamentally needless and expensive bureaucracy by an EU which insists on teaching Granny to suck eggs in perpetuity…