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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User-Friendly RASCI Accountability Matrices

Right now, you’re probably thinking that’s a statement of opposites. Something dreamed up by a consultant to impress, or just to fill a blog page. But wait. What if I taught you to create order in procedural chaos in five minutes flat? ?Would you be interested then?

The first step is to create a story line ?

Let’s imagine five friends decide to row a boat across a river to an island. Mary is in charge and responsible for steering in the right direction. John on the other hand is going to do the rowing, while Sue who once watched a rowing competition will be on hand to give advice. James will sit up front so he can tell Mary when they have arrived. Finally Kevin is going to have a snooze but wants James to wake him up just before they reach the island.

That’s kind of hard to follow, isn’t it ?

Let’s see if we can make some sense of it with a basic RASCI diagram ?

Responsibility Matrix: Rowing to the Island
Activity Responsible Accountable Supportive Consulted Informed
Person John Mary Sue James Kevin
Role Oarsman Captain Consultant Navigator Sleeper

?

Now let’s add a simple timeline ?

Responsibility Matrix: Rowing to the Island
? Sue John Mary James Kevin
Gives Direction ? ? A ? ?
Rows the Boat ? R ? ? ?
Provides Advice S ? ? ? ?
Announces Arrival ? ? A C ?
Surfaces From Sleep ? ? ? C I
Ties Boat to Tree ? ? A ? ?

?

Things are more complicated in reality ?

Quite correct. Although if I had jumped in at the detail end I might have lost you. Here?s a more serious example.

rasci

?

There?s absolutely no necessity for you so examine the diagram in any detail, other to note the method is even more valuable in large, corporate environments. This one is actually a RACI diagram because there are no supportive roles (which is the way the system was originally configured).

Other varieties you may come across include PACSI (perform, accountable, control, suggest, inform), and RACI-VS that adds verifier and signatory to the original mix. There are several more you can look at Wikipedia if you like.

4 Reasons Why You Might be Missing Out on Energy Savings…

?well your company actually, although for many small-to-medium businesses it boils down to the same thing. Governments usually lag behind in terms of innovation but are beating us hands-down when it comes to going green. I have heard that private sector energy savings average less than 1% per year and I for one would not be surprised if that were true. So what is causing this rot, when we started out so enthusiastically? Here are four possibilities for you to mull over.

  1. Your Team is Unevenly Yoked ? A pair of mismatched horses cannot pull a wagon in a straight line any more successfully than a business team can achieve its goals, if there is no agreement on priorities. While your sales team may be all for scoring green points against your competition, your accountant has a budget to balance and your operations department just wants to get on with the job.
  1. Energy?s not in Focus ? The above may in part be due to production goals you set your department heads. Energy is not nearly as greedy as raw materials and human capital. If you tell them to cut 5%, where do you think they are going to look first? You need to put energy savings up there, and agree specific targets as you do with other primary goals.
  1. Your Equipment Could be Over-Spec ? It is a very human thing to put more food on our plates and buy faster cars than we need. Only a few generations ago our ancestors lived through feast and famine, and the shadow of this still influences our thinking. Next time you buy equipment sit around the table and agree the decision criteria together. Then stick to them and repel all attempts at up-selling.
  1. You Are Delegating Too Much ? Delegation is part of company culture, or if you prefer the collective way of doing things. If you delegate something completely it is akin to saying I do not care much about this, make it happen. Energy saving is a financial and moral imperative. The fact the oil price is down does not mean there is no place for sustainability on your desk (and the price is likely to be up again soon).

Governments succeed in saving energy (whereas businesses often do not) because governments have a crowd of stakeholders beating down the door and demanding progress. As business owners we are more likely to do the same when the pressure is upon us, and that pressure surely has to come from us.

Failure Mode and Effects Analysis

 

Any business in the manufacturing industry would know that anything can happen in the development stages of the product. And while you can certainly learn from each of these failures and improve the process the next time around, doing so would entail a lot of time and money.
A widely-used procedure in operations management utilised to identify and analyse potential reliability problems while still in the early stages of production is the Failure Mode and Effects Analysis (FMEA).

FMEAs help us focus on and understand the impact of possible process or product risks.

The FMEA method for quality is based largely on the traditional practice of achieving product reliability through comprehensive testing and using techniques such as probabilistic reliability modelling. To give us a better understanding of the process, let’s break it down to its two basic components ? the failure mode and the effects analysis.

Failure mode is defined as the means by which something may fail. It essentially answers the question “What could go wrong?” Failure modes are the potential flaws in a process or product that could have an impact on the end user – the customer.

Effects analysis, on the other hand, is the process by which the consequences of these failures are studied.

With the two aspects taken together, the FMEA can help:

  • Discover the possible risks that can come with a product or process;
  • Plan out courses of action to counter these risks, particularly, those with the highest potential impact; and
  • Monitor the action plan results, with emphasis on how risk was reduced.

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