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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How Mid-South Metallurgical cut Energy Use by 22%

Mid-South in Murfreesboro, Tennessee operates a high-energy plant providing precision heat treatments for high-speed tools – and also metal annealing and straightening services. This was a great business to be in before the energy crisis struck. That was about the same time the 2009 recession arrived. In no time at all the market was down 30%.

Investors had a pile of capital sunk into Mid-South?s three facilities spread across 21,000 square feet (2,000 square meters) of enclosed space. Within them, a number of twenty-five horsepower compressors plus a variety of electric, vacuum and atmospheric furnaces pumped out heat 27/7, 52 weeks a year. After the company called in the U.S. Department of Energy for assistance, several possibilities presented.

Insulate the Barium Chloride Salt Baths

The barium chloride salt baths used in the heat treatment process and operating at 1600?F (870?C) were a natural choice, since they could not be cooled below 1200?F (650?C) when out of use without hardening the barium chloride and clogging up the system. The amount of energy taken to prevent this came down considerably after they covered and insulated them. The recurring annual electricity saving was $53,000.

Manage Electrical Demand & Power

The utility delivers 480 volts of power to the three plants that between them consume between 825- and 875-kilowatt hours depending on the season. Prior to the energy crisis Mid-South Metallurgical regarded this level of consumption as a given. Following on the Department of Energy survey the company replaced the laminar flow burner tips with cyclonic burner ones, and implemented a number of other modifications to enhance thermal efficiency further. The overall natural gas reduction was 20%.

Implement Large Scale Site Lighting Upgrade

The 24/7 nature of the business makes lighting costs a significant factor. Prior to the energy upgrade this came from 44 older-type 400-watt metal halide fixtures. By replacing these with 88 x 8-foot (2.5 meter) fluorescent fittings Mid-South lowered maintenance and operating costs by 52%

The Mid-South Metallurgical Trophy Cabinet

These three improvements cut energy use by 22%, reduced peak electrical demand by 21% and brought total energy costs down 18%. Mid-South continues to monitor energy consumption at each strategic point, as it continues to seek out even greater energy efficiency in conjunction with its people.

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Transformation to a process based organisation

Today’s global marketplace rewards nimble organisations that learn and reinvent themselves faster than their competition. Employees at all levels of these organisations see themselves as members of teams responsible for specific business processes, with performance measures tied to the success of the enterprise. As team members, they are “owners” of the process (or processes) to which they are assigned. They are responsible for both the day to day functioning of their process(s), and also for continuously seeking sustainable process improvements.

Transforming a traditionally designed “top down control” enterprise to a process-based organisation built around empowered teams actively engaged in business process re-engineering (BPR) has proven more difficult than many corporate leaders have expected. Poorly planned transformation efforts have resulted in both serious impacts to the bottom line, and even more serious damage to the organisation’s fabric of trust and confidence in leadership.

Tomislav Hernaus, in a publication titled “Generic Process Transformation Model: Transition to Process-based Organisation” has presented an overview of existing approaches to organisational transformation. From the sources reviewed, Heraus has synthesised a set of steps that collectively represent a framework for planning a successful organisational change effort. Key elements identified by Hernaus include:

Strategic Analysis:

The essential first step in any transformation effort must be development of a clear and practical vision of a future organisation that will be able to profitably compete under anticipated market conditions. That vision must be expected to flex and adjust as understanding of future market conditions change, but it must always be stated in terms that all organisational members can understand.

Identifying Core Business Processes:

With the strategic vision for the organisation in mind, the next step is to define the core business processes necessary for the future organisation to function. These processes may exist across the legacy organisation’s organisational structures.

Designing around Core Processes:

The next step is development of a schematic representation of the “end state” company, organised around the Core Business Processes defined in the previous step.

Transitional Organisational Forms/ Developing Support Systems:

In his transformation model, Hernaus recognises that information management systems designed for the legacy organisation may not be able to meet the needs of the process management teams in the new organisation. Interim management structures (that can function with currently available IT system outputs) may be required to allow IT professionals time to redesign the organisation’s information management system to be flexible enough to meet changing team needs.

Creating Awareness, Understanding, and Acceptance of the Process-based Organisation:

Starting immediately after the completion of the Strategic Analysis process described above, management must devote sufficient resources to assure that all organisation members, especially key managers, have a full understanding of how a process-based organisation functions. In addition, data based process management skills need to be provided to future process team members. It is not enough to schedule communication and training activities, and check them off the list as they are completed. It is critical that management set behavioural criteria for communication and training efforts that allow objective evaluation of the results of these efforts. Management must commit to continuing essential communication and training efforts until success criteria are achieved. During this effort, it may be determined that some members of the organisation are unlikely to ever accept the new roles they will be required to assume in a process-based organization. Replacement of these individuals should be seen as both an organisational necessity and a kindness to the employees affected.

Implementation of Process Teams:

After the completion of required training AND the completion of required IT system changes, process teams can be formally rolled out in a planned sequence. Providing new teams with part time support by qualified facilitators during the firsts weeks after start-up can pay valuable long term dividends.

Team Skill Development and Continuous Process Improvement:

Providing resources for on-going skill development and for providing timely and meaningful recognition of process team successes are two keys for success in a process-based organisation. Qualified individuals with responsibility for providing training and recognition must be clearly identified and provided with sufficient budgetary resources.

The Hernaus model for transformation to a process based organisation is both well thought out and clear. His paper provides an ample resource of references for further study.

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What Is Technical Debt? A Complete Guide

You buy the latest iPhone on credit. Turn to fast car loan services to get yourself those wheels you’ve been eyeing for a while. Take out a mortgage to realise your dream of being a homeowner. Regardless of the motive, the common denominator is going into financial debt to achieve something today, and pay it off in future, with interest. The final cost will be higher than the loan value that you took out in the first place. However, debt is not limited to the financial world.

Technical Debt Definition

Technical debt – which is also referred to as code debt, design debt or tech debt – is the result of the development team taking shortcuts in the code to release a product today, which will need to be fixed later on. The quality of the code takes a backseat to issues like market forces, such as when there’s pressure to get a product out there to beat a deadline, front-run the competition, or even calm jittery consumers. Creating perfect code would take time, so the team opts for a compromised version, which they will come back later to resolve. It’s basically using a speedy temporary fix instead of waiting for a more comprehensive solution whose development would be slower.

How rampant is it? 25% of the development time in large software organisations is actually spent dealing with tech debt, according to a multiple case study of 15 organizations. “Large” here means organizations with over 250 employees. It is estimated that global technical debt will cost companies $4 trillion by 2024.

Is there interest on technical debt?

When you take out a mortgage or service a car loan, the longer that it takes to clear it the higher the interest will be. A similar case applies to technical debt. In the rush to release the software, it comes with problems like bugs in the code, incompatibility with some applications that would need it, absent documentation, and other issues that pop up over time. This will affect the usability of the product, slow down operations – and even grind systems to a halt, costing your business. Here’s the catch: just like the financial loan, the longer that one takes before resolving the issues with rushed software, the greater the problems will pile up, and more it will take to rectify and implement changes. This additional rework that will be required in future is the interest on the technical debt.

Reasons For Getting Into Technical Debt

In the financial world, there are good and bad reasons for getting into debt. Taking a loan to boost your business cashflow or buy that piece of land where you will build your home – these are understandable. Buying an expensive umbrella on credit because ‘it will go with your outfit‘ won’t win you an award for prudent financial management. This also applies to technical debt.

There are situations where product delivery takes precedence over having completely clean code, such as for start-ups that need their operations to keep running for the brand to remain relevant, a fintech app that consumers rely on daily, or situations where user feedback is needed for modifications to be made to the software early. On the other hand, incurring technical debt because the design team chooses to focus on other products that are more interesting, thus neglecting the software and only releasing a “just-usable” version will be a bad reason.

Some of the common reasons for technical debt include:

  • Inadequate project definition at the start – Where failing to accurately define product requirements up-front leads to software development that will need to be reworked later
  • Business pressure – Here the business is under pressure to release a product, such as an app or upgrade quickly before the required changes to the code are completed.
  • Lacking a test suite – Without the environment to exhaustively check for bugs and apply fixes before the public release of a product, more resources will be required later to resolve them as they arise.
  • Poor collaboration – From inadequate communication amongst the different product development teams and across the business hierarchy, to junior developers not being mentored properly, these will contribute to technical debt with the products that are released.
  • Lack of documentation – Have you launched code without its supporting documentation? This is a debt that will need to be fulfilled.
  • Parallel development – This is seen when working on different sections of a product in isolation which will, later on, need to be merged into a single source. The greater the extent of modification on an individual branch – especially when it affects its compatibility with the rest of the code, the higher the technical debt.
  • Skipping industrial standards – If you fail to adhere to industry-standard features and technologies when developing the product, there will be technical debt because you will eventually need to rework the product to align with them for it to continue being relevant.
  • Last-minute product changes – Incorporating changes that hadn’t been planned for just before its release will affect the future development of the product due to the checks, documentation and modifications that will be required later on

Types of Technical Debt

There are various types of technical debt, and this will largely depend on how you look at it.

  • Intentional technical debt – which is the debt that is consciously taken on as a strategy in the business operations.
  • Unintentional technical debt – where the debt is non-strategic, usually the consequences of a poor job being done.

This is further expounded in the Technical Debt Quadrant” put forth by Martin Fowler, which attempts to categorise it based on the context and intent:

Technical Debt Quadrant

Source: MartinFowler.com

Final thoughts

Technical debt is common, and not inherently bad. Just like financial debt, it will depend on the purpose that it has been taken up, and plans to clear it. Start-ups battling with pressure to launch their products and get ahead, software companies that have cut-throat competition to deliver fast – development teams usually find themselves having to take on technical debt instead of waiting to launch the products later. In fact, nearly all of the software products in use today have some sort of technical debt.

But no one likes being in debt. Actually, technical staff often find themselves clashing with business executives as they try to emphasise the implications involved when pushing for product launch before the code is completely ready. From a business perspective, it’s all about weighing the trade-offs, when factoring in aspects such as the aspects market situation, competition and consumer needs. So, is technical debt good or bad? It will depend on the context. Look at it this way: just like financial debt, it is not a problem as long as it is manageable. When you exceed your limits and allow the debt to spiral out of control, it can grind your operations to a halt, with the ripple effects cascading through your business.

 

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