2015 ESOS Guidelines Chapter 7, 8 & 9 – Sign-Off, Compliance & Appeals

This is the final chapter in our series of short posts summarising the quite complex ESOS guidelines (click on ?Comply with ESOS? to see the details). This one addresses the legalities to follow to complete your report – and how to appeal if you are not happy with any of the Environment Agency?s decisions.

  1. Director Sign-Off

This is by no means an easy ride. Confirmation of the work at individual or lead assessor level locks the company into the penalty cycle in the event there are significant irregularities. By signing off the assessment, the board level director(s) # agree that they have

  • Reviewed the enterprise?s ESOS recommendations
  • Believe the enterprise is within the scope of the scheme
  • Believe the enterprise is compliant with the scheme
  • Believe the information provided is correct

Having an internal assessor requires a second board-level signature.

  1. Compliance

You report compliance on the internet. This is free and you can do it at any time within the deadline. You can dip in and out of the process as many times as you wish, but must use the link in the receipting email. While this is something a board member must do, there is no reason why the lead assessor should not complete the basics. The online compliance notification addresses the following topics:

  • The ESOS contact person in the enterprise
  • Any aggregation / dis-aggregation during the period
  • The names and contact details of the lead assessor
  • The proportion of energy consumption per compliance route

The Environment Agency will acknowledge receipt. This does not constitute acceptance. You should keep the ESOS evidence pack in a safe place with at least one backup elsewhere.

  1. Compliance & Enforcement Issues

In the event the Environment Agency decides your enterprise has not met ESOS requirements, it may either (a) issue a compliance notice with instructions, or (b) apply one of the following civil penalties:

  • A fine of up to ?5,000 for failure to maintain records
  • A fine of up to ?50,000 for failure to undertake an energy audit
  • A fine of up to ?50,000 for a false or misleading statement

Any enterprise has the right of appeal against government decisions. In the case of ESOS, this is via:

  • The First-Tier Tribunal if your enterprise is England, Wales or off-shore based
  • The Scottish Minister if your enterprise is based in Scotland
  • The Planning Commission if your enterprise is Northern Ireland-based

The notice you appeal against will supply details of the appeal steps to take.

This blog and its companion chapters concerning the ESOS Guidelines as amended 2015 are with compliments of ecoVaro. We are the people who break ESOS data into manageable chunks of information, so that board-level directors have greater confidence in what they sign.

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Is Change Management a Myth or a Possibility

The theory that it is possible to manage organisational change (Change Management) in a particular direction has done the rounds for quite some time, but is it true about Change Management. Was Barrack Obama correct when he said, ?Change will not come if we wait for some other person or some other time. We are the ones we have been waiting for. We are the change that we seek.?
Or, was business coach Kelly A Morgan more on the button when she commented, ?Changes are inevitable and not always controllable. What can be controlled is how you manage, react to, and work through the change process.? Let us consult the evidence and see what statisticians say.

What the Melcrum Report Tells Us

Melcrum are ?internal communication specialists who work alongside leaders and teams around the globe to build skills and best practice in internal communication.? They published a report after researching over 1,000 companies that attempted change management and advised:

? More than 50% report improved customer satisfaction

? 33% report higher productivity

? 28% report improvements in employee advocacy

? 27% improved status as a great place to work

? 27% report increased profitability

? 25% report improved absenteeism

Sounds great until we flip the mirror around and consider what the majority apparently said:

? 50% had no improvement in customer service

? 67% did not report increased productivity

? 72% did not note improvements in employee advocacy

? 73% had no improved status among job seekers

? 73% did not report increased profitability

? 75% did not report any reduction of employee absenteeism

This shows it is still a great idea to hear what all parties have to say before reaching a conclusion. You may be interested to know the Melcrum report gave rise to the legend that 70% of organisation change initiatives fail. This finding has repeated numerous times. Let’s hear what the psychologists have to say next.

There is a certain amount of truth in the old adage that says, ?You can lead a horse to water but you cannot make him drink.? Which of us has not said, ?Another flavour of the week ? better keep heads down until it passes? during a spell in the corporate world. You cannot change an organisation, but you can change an individual.

At the height of the Nazi occupation of 1942, French philosopher-writer Antoine de Saint-Exup?ry said, ?A rock pile ceases to be a rock pile the moment a single man contemplates it, bearing within him the image of a cathedral?. Psychology Today suggests five false assumptions change management rests upon, THAT ARE SIMPLY NOT TRUE.

1. The external world is orderly, stable, predictable and can be managed

2. Change managers are objective, and do not import their personal bias

3. The world is static and orderly and can be changed in linear steps

4. There is a neutral starting point where we can gather all participants

5. Change is worthy in itself, because all change is an improvement

Leo Tolstoy wrote, ?Everyone thinks of changing the world, but no one thinks of changing himself.? A prophet can work no miracles unless the people believe. From the foregoing, it is evident that change management of an organisation is a 70% impossibility, but encouraging an individual to grow is another matter.

A McKinsey Report titled Change Leader, Change Thyself fingers unbelieving managers as the most effective stumbling stones to change management. To change as individuals ? and perhaps collectively change as organisations ? we need to ?come to our own full richness?, and as shepherds lead our flock to their ?promised land?, whatever that may be. Conversely, herding our flock with a pack of sheepdogs extinguishes that most precious thing of all, human inspiration.

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Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

New Focus on Monitoring Soil

There is nothing new about monitoring soil in arid conditions. South Africa and Israel have been doing it for decades. However climate change has increased its urgency as the world comes to terms with pressure on the food chain. Denizon decided to explore trends at the macro first world level and the micro third world one.

In America, the Coordinated National Soil Moisture Network is going ahead with plans to create a database of federal and state monitoring networks and numerical modelling techniques, with an eye on soil-moisture database integration. This is a component of the National Drought Resilience Partnership that slots into Barrack Obama?s Climate Action Plan.

This far-reaching program reaches into every corner of American life to address the twin scourges of droughts and inundation, and the agency director has called it ?probably ?… one of the most innovative inter-agency tools on the planet?. The pilot project involving remote moisture sensing and satellite observation targets Oklahoma, North Texas and surrounding areas.

Africa has similar needs but lacks America?s financial muscle. Princeton University ecohydrologist Kelly Caylor is bridging the gap in Kenya and Zambia by using cell phone technology to transmit ecodata collected by low-cost ?pulsepods?.

He deploys the pods about the size of smoke alarms to measure plants and their environment.?Aspects include soil moisture to estimate how much water they are using, and sunlight to approximate the rate of photosynthesis. Each pod holds seven to eight sensors, can operate on or above the ground, and transmits the data via sms.

While the system is working well at academic level, there is more to do before the information is useful to subsistence rural farmers living from hand to mouth. The raw data stream requires interpretation and the analysis must come through trusted channels most likely to be the government and tribal chiefs. Kelly Caylor cites the example of a sick child. The temperature reading has no use until a trusted source interprets it.

He has a vision of climate-smart agriculture where tradition gives way to global warming. He involves local farmers in his research by enrolling them when he places pods, and asking them to sms weekly weather reports to him that he correlates with the sensor data. As trust builds, he hopes to help them choose more climate-friendly crops and learn how to reallocate labour as seasons change.

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