Guest Blog: Mervyn Bowden – The lessons from ESOS

As large businesses enter the final straights of ESOS compliance, it’s worth reflecting on the lessons which may be learnt from what has, for many, been a fraught and unnecessarily […]

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As large businesses enter the final straights of ESOS compliance, it’s worth reflecting on the lessons which may be learnt from what has, for many, been a fraught and unnecessarily painful experience. How could it have been done better?

The people

The number of suitably qualified personnel in the Lead Assessor and Auditor roles has been woefully inadequate despite the inclusion of seemingly “non-professional” bodies in the mix. Often, from observation, some have lacked the business acumen to understand either the regulations themselves or the organisations as some have enormously complex structures, struggling to produce the requisite information.

Lack of the right people will inevitably mean many assessments are below the required standard and may have to be done again to achieve the results which participating organisations expected.

There is a screeching need for more qualified and experienced people in the energy sector who are able to interpret such complex pieces of regulation – mandatory or otherwise.

The regulations

They palpably duplicate many of their forerunners, such as the CRC, without adding any particular value. Again the idea they will gain traction solely by bringing opportunities to the attention of boards of directors is seriously flawed if there is no interest in the first place.

More enlightened organisations have shown a high level of enthusiasm to determine how they can take recommendations forward. But naivety is general when talking of others who’ve never had any intention of following suit.

Worst of all, for me, is the imposition of needless expense for many entities that have already made genuine and successful efforts to improve their efficiency regardless of imposed regulation.

It is surely contrary to common sense to expect organisations to implement opportunities purely because they exist and without any mandatory direction.

The results

These will be patchy and reflect the appetite of organisations over time to implement the opportunities presented.

Many organisations who qualified for the scheme have focused on doing the absolute minimum to gain compliance. This is a major lost opportunity considering the significant time, resource and cost demanded by this regulation.

By extending the penalty period, the EA has shown some common sense but the timing of announcements around this has been far too late, given the available resource to do anything about it.

Finally, the EU’s part

This, as with many other EU driven initiatives, demonstrates that a “one size fits all” approach is horribly flawed and would be better resolved at a local level.

Various governments within the EU member states have, as always, progressed at majorly different rates and produced variations on a theme. Driven by completely idiotic timescales the whole energy sector has been preoccupied with squashing a four-year compliance period into weeks and months with resulting pinch points on all resources.

Only the EU could possibly leave an open-ended arrangement where there is no mandatory fix to the serious energy efficiency problems.

For our part in the UK, we appear to have taken this very seriously as always but completely lost sight of the cost and availability of resource necessary to provide a commercially value-add solution to a highly complex piece of regulation. As a result UK plc will fail to achieve the possible benefits from opportunities which a more considered scheme would have achieved.

Perhaps the review of taxes and incentives will pick this up but no one is holding their breath…

Mervyn Bowden is the Managing Director of Intuitive Energy Solutions Ltd.

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