Irish companies are facing a new wave of energy-audit obligations under the recast Energy Efficiency Directive. This is because the threshold for requiring an EAS audit now obligates Irish companies with an annual energy consumption greater than 10 TG (2,778 MWh).
Many companies with licences from the EPA also have a requirement for an energy audit. The question many environmental managers in EPA licensed companies will be asking is ‘will their EPA energy audit satisfy SEAI’.
The short answer is no as the scope of work of EAS and EPA energy audits is different. However, it may be possible for the EAS audit to satisfy the EPA. This post explains why.
The scope of the EPA energy audit is to audit energy use within the boundary of the licensed site. The scope of the EAS audit differs as it is of the whole organisation (strictly at least 85% of the organisations energy use). That is the key distinction: EAS compliance is company-wide energy-audit compliance; EPA compliance is site licence-specific compliance.
For an EAS audit to satisfy the EPA, the EAS report then must clearly identify the energy use within the licensed site boundary and differentiate it from the rest of the organisation. This is important as some sites will be divided into two, one side of the site EPA licenced, the other side not. The EAS audit will then need to clearly audit separate both parts of the site.
In addition to clearly separating out the energy use within the licensed boundary, there will need to be specific recommendations for energy reduction for the licensed site. For a large organisation where the energy use of the licensed site is small, an EAS audit will not necessarily focus on recommendations for the licensed site, perhaps because the licensed site’s energy use is de minimus. This is unlikely to be to the satisfaction of the EPA. Take for example a large company with significant logistics (transport and cold stores) and a small, licensed printing operation accounting for less than 15% of energy use. It would be correct for the EAS audit to focus on the logistics. However, that would not satisfy the EPA’s requirements.
For an EAS audit to satisfy the EPA, then the scope of work for the auditor is to ensure that the licensed site(s) are clearly separated out within the report and a significant number of recommendations made for energy efficiency improvements for the licensed site(s) regardless of the proportion of energy use of those licensed site(s).
When seeking a competent energy audit to undertake EAS audits for organisations that included sites with EPA licensed operation, it is essential that a discussion is had to ensure that the report covers the licensed sites in enough detail to satisfy the EPA.
Environmental Efficiency has over 20 years’ experience in EPA, EAS and ESOS energy audits throughout Ireland and the UK. The author, Bob Sutcliffe, a Chartered Engineer and Certified Energy Manager may be contacted on bobsut@enviro-consult.com.