Environmental Audit CommitteeWritten evidence submitted by Energy Efficiency Verification Specialists

EEVS “HIGH-RESOLUTION REPORTING”: BRINGING CARBON SAVINGS INTO FOCUS

IPMVP-COMPLIANT MEASUREMENT AND VERIFICATION OF ENERGY AND CARBON SAVINGS WITHIN THE CIVIL ESTATE

Executive Summary

In May 2010, the Government set a target of achieving a 10% reduction in carbon emissions across Government headquarter buildings within one year. The Government has since set itself a more demanding target, to deliver 25% carbon emissions reduction across the entire Government estate, some 7,000 buildings,1 by 2015.

The operational integrity and depth of the current performance reporting system has come under review2 and in the context of the above can expect to be placed under increasing scrutiny. The cost and resource required to upscale this system for all buildings within civil estate is likely to be prohibitive.

The current reporting system may not sufficiently take account of the dynamics generated by the government’s asset management improvement programmes (such as the Workspace Efficiency Standards and Office Estate Rationalisation initiatives). For example, the effects of these and other initiatives are likely to result in an apparent increase in building-level carbon emissions within the current system.

EEVS proposes that the Government supplements the current volume-based system for reporting annual carbon savings with a complementary high-quality measurement and reporting system. The proposed High Resolution Reporting model (detailed below) would provide a greater depth and quality of reporting by delivering more detailed and analytical outputs for a smaller, but strongly representative, sample of Government buildings. Overall, we consider that this “twin-track” approach would provide the Government with a more robust account of emissions savings achieved than those presented in July 2011.

The proposed High Resolution Reporting system would be built on the good practice principles of the International Performance Measurement and Verification Protocol (IPMVP).

High Resolution Summary Reports would be presented at building, departmental and estate levels. As well as a providing a robust reporting platform, this information could be used to support the development of efficient and effective carbon saving strategies across the civil estate by identifying the most effective ways of reducing carbon emissions.

By utilising existing Governmental data collection and reporting infrastructure wherever possible High Resolution Reporting will have minimal cost and resource implications.

Introduction

1. This paper:

sets out why the Government should consider supplementing the current carbon savings measurement system with a more in-depth but complementary model;

discusses what this system would comprise and the benefits it would bring; and

outlines the cost and resource required to deliver the proposed system.

Context

2. In May 2010 the Government set itself a target of achieving a 10% reduction in carbon emissions across Government headquarter buildings within one year. In July 2011 the Government reported carbon emissions savings of 13.8% across these 80 buildings. The Government has since committed to saving 25% of carbon emissions by 2015 across the entire Government estate. With around 7,000 buildings across almost 50 departments, the UK Government faces a major challenge in ensuring that it has the right mechanisms in place for reporting energy and carbon performance, not least against mandated performance targets.

3. The current system for reporting energy and carbon performance across the civil estate—utilising the ePIMS platform—provides a practical and appropriate solution to the significant reporting challenge. Given the scale of this challenge, the generation of annual and estate wide carbon emission metrics is a very major achievement.

Carbon Reporting 2012: Fit for Purpose?

4. The carbon emission reduction targets the Government has committed to achieve by 2015 are very stretching and it is right that the Environmental Audit Committee and leading interest groups should take an increasing interest in climate change reporting. The measurement system and the individual performance claims that underpin the Government’s reductions are therefore expected to come under increasing scrutiny.

5. Government must consider whether the current system is still “fit for purpose” and, in particular, whether it gives policy-makers certainty and confidence in the accuracy of performance statements, and whether it is capable of withstanding the range of scrutiny that could be directed at it.

6. A detailed analysis of potential criticisms of robustness and reliability is outside the scope of this paper, although the recent National Audit Office briefing paper3 released July 2011 highlighted concerns around data quality and, in particular, the use of estimates. Other aspects which may not be able to withstand greater scrutiny include the use of low frequency and low resolution data and the lack of an independent verification process.

7. This paper presents a framework for a complementary “high quality” reporting system that would mitigate these risks with limited resource and cost implications.

The Proposed Service: Balancing Quantity with Quality

8. The current E-PIMS platform assembles data annually from all buildings within the Government estate. This system focuses on a wide breadth of reporting and necessarily aims to achieve a minimum standard—at a realistic level of cost and resource—across every building within the civil estate.

9. EEVS Insight proposes supplementing this high-volume and universal reporting system with a complementary high-quality reporting system in order to make overall reporting more robust. The “high-quality” system would provide a greater depth of reporting by collating more detailed and analytical outcomes from a smaller but highly representative sample of Government buildings.

10. This enhanced “twin track” approach—which acknowledges the need to balance core “baseline” quantitative reporting with more detailed and analytical outputs— is likely to deliver a system that is significantly better equipped in terms of robustness and reliability by delivering the following key benefits:

High quality reporting—highly robust and reliable analysis of building-level performance.

Representative sample audit—to provide a high level of confidence in, and corroboration of, achieved savings across the civil estate.

Good practice leadership—the system to be founded on IPMVP, the leading global standard for measuring and verifying energy saving performance.

Operational management tool—outputs can be actively used by operational executives to drive performance improvements (eg by providing evidence on which energy-saving measures have delivered the best results and value for money, and in which order measures should be installed).

Downstream financial gains—the new system may facilitate substantial downstream financial savings through better and more informed procurement decision-making.

Low cost/resource solution—focused on a discrete sample of buildings, say 10% of the total estate (but with scope for extension over the medium and longer terms).

EEVS “High Resolution Reporting”: focused on quality and best practice

11. This section details what this high quality High Resolution Reporting might comprise and how it would operate.

Founded on best practice

12. For maximum credibility it is essential that the operation of High Resolution Reporting is founded on an accepted and widely-used good practice standard. The good practice principles of the International Performance Measurement and Verification Protocol (IPMVP) provide a well proven structure on which to base High Resolution Reporting.

13. IPMVP was developed in the mid-1990s by the US Department of Energy to drive best practice in the measurement and verification of energy/carbon savings. By harnessing the protocol the Government can expect to receive the highest level of quality assurance. Methodologies that adhere to IPMVP are objective, accurate and transparent and seek to bring complete confidence to the process for reporting savings. It should be noted that IPMVP specifically allows for the use of sample reporting. For more information about IPMVP see Appendix 1.

Reporting outputs

14. Using the IPMVP approach, High Resolution Reporting will aim to deliver “IPMVP adherent” carbon savings evaluation at a building level. Each building manager within the sample will be presented with the two following core outputs:

Measurement & Verification Plan (M&V Plan). This document defines the detailed operational approach to evaluating performance. Core to this is the Baseline Model of building energy (and carbon emissions) performance; future energy saving performance is measured and compared to this benchmark measurement.

Carbon Savings Verification Reporting. Using the methodology and baseline information set out in the M&V Plan a series of periodic “Savings Reports” are delivered. Each report sets out a range of building-level key performance metrics set against the Baseline and a projected level of savings detailed in the M&V Plan. As well as providing high quality and detailed performance information, these metrics will equip building managers with valuable information about which measures have delivered the best savings and value for money. Annual reporting is likely to be the minimum acceptable standard. This information can then be used to drive change across the wider non-sample population of buildings.

Scope of reporting—how many buildings?

15. Cost and resource concerns mean that delivering High Resolution Reporting across all 7,000 buildings within the civil estate is not a feasible option in the short term. A practical solution would be to deliver High Resolution Reporting for a small and ideally representative sample of buildings within the civil estate, say 10% of buildings. Sampling is a method recognised by IPMVP when the resources are too scarce to analyse the full population of sites.4

16. For a form of High Resolution Reporting to be delivered across all buildings within the civil estate in the long term, additional investment for the provision of resource and time saving technologies will be required. The requirements of IPMVP adherence mean that some measure of human input and analytical review will be necessary.

Departmental & sample estate reporting

17. A statistically representative sample set will be used to draft High Resolution Summary Reports at Departmental and Estate levels. These reports would set out high level findings, for example, performance tables for the energy savings measures carried out during the previous reporting period. This evidence-based information may be used by individual departments and building managers (as well as the wider public sector) to help determine which interventions are likely to deliver highest levels of carbon savings as well as value for money.

18. High quality evidence-based market information in relation to the broad range of energy saving products and services is not currently available in a consistent and analytical format.

Knowledge Sharing

19. High quality reporting will help support the development of efficient and effective carbon-saving strategies across Government departments. For example, results from the High Resolution Summary Reports, alongside case study examples and lessons learned, could be presented at knowledge sharing events for departmental managers. These seminars would help disseminate good practice and evidence-based performance analysis across Government.

Data Requirements

20. The success of High Resolution Reporting relies on the ability to access robust and reliable performance data, quickly and easily. Fortunately, much of the requisite building-level data as well as the IT systems needed to access it, are already in place. For example:

E-PIMS data –access to the relevant sections of the E-PIMS platform would be required for building level data and any other materially relevant data items (eg energy costs, FTE occupancy data, core hours of operation and so on).

Half-hourly to monthly energy data—half-hourly energy (kWh consumption) data is preferred and will enable the generation of the highest quality analysis. Departmental HQ buildings should be able to supply this resolution of data quickly and easily. Non-HQ buildings would need to make available, as a minimum standard, monthly energy use data. Annual or quarterly consumption data is insufficient.

Energy cost data—depending on availability and resolution of data within the E-PIMS database, there may be a requirement for further and more granular energy cost data (eg £ per kWh energy data).

Baseline period data—to build a robust baseline model for each building’s performance, the above data is required for a 12 month historic period. The best case scenario would be to gather this data for the same year as the Government’s existing baseline. If this is not possible, the most recent 12 months of data is sufficient and a new baseline performance level will be established.

Reporting period data—a complete data set (ideally half-hour resolution) is required for the agreed reporting period to enable High Resolution Savings Reports to be delivered for each building within the sample set.

Additional Data Requirements: An Energy-Saving Measures Survey

21. High Resolution Reporting also requires details of the specific energy savings measures that have been, or will be, implemented within each building. As EEVS Insight understands it, this information is not currently recorded for reporting purposes. This information may be obtained from building managers through the completion of a short annual questionnaire (perhaps as a “bolt on” to E-PIMS submissions). The core data items required include the name and description of the energy saving measures, installation date, costs and expected savings. It is anticipated that this would have minimal cost and resource implications for government departments.

Cost and Resource Implications

22. The cost of delivering High Resolution Reporting may be considered on a per building basis, and IPMVP stipulates that the cost of the building-level evaluation should typically not exceed 10% of the average annual savings being assessed.5 The quantity of savings therefore places a limit on the reporting budget—and this figure may be used to determine the scope and frequency of reporting (key drivers of High Resolution Reporting costs).

23. High Resolution Reporting also requires the resources of departments and facilities management teams. Here the major demand on time and effort is likely to be the completion of the annual Energy Savings Measures Survey outlined above. Much of the other data will already be available and readily accessible.

Next Steps

24. The purpose of this paper was to highlight to the Environmental Audit Committee how the Government could benefit from a supplementary and high quality carbon savings measurement and reporting system, and how this system might work in practice.

25. EEVS would welcome the opportunity to further discuss these proposals with the Environmental Audit Committee and, in particular, the material steps needed to successfully deliver High Resolution Reporting for example, defining the sample of buildings, level of reporting, financial costs, and additional resource implications for the government departments.

Appendix 1

AN INTRODUCTION TO IPMVP

The International Performance Measurement & Verification Protocol (IPMVP) is a guidance document describing good practice in measuring and reporting savings achieved by energy or water efficiency projects. By doing so, it sets a framework for transparently, reliably and consistently reporting a project’s savings.

The development of IPMVP was originally sponsored by the US Department of Energy in the late 1990s having identified that the uncertainty associated with future energy savings was a barrier to energy efficiency investments. This uncertainty arises in part from inconsistency in standards, so IPMVP aimed to establish an international consensus on methods to determine efficiency savings and promote third-party investment in energy efficiency projects.

IPMVP is published by the Efficiency Valuation Organisation (EVO) to increase investment in energy and water efficiency, demand management and renewable energy projects around the world. EVO has included the following as key purposes of good measurement and verification:

Boost energy savings. Accurate determination of energy savings gives all parties valuable feedback on their projects, which helps them adjust the design or operation to improve savings and achieve greater persistence of savings over time

Enhance financing for efficiency projects. Good measurement and verification increases the transparency and credibility of reports on the outcome of efficiency investments. This credibility can increase the confidence that investors and sponsors have in energy efficiency projects, enhancing their chances of being financed.

Improve engineering design and facility operations and maintenance. Good measurement and verification encourages comprehensive project design by including all costs in the project’s economics.

Manage energy budgets. Even where savings are not planned, measurement and verification techniques help managers evaluate and manage energy usage to account for variances from budgets. Measurement and verification techniques are used to adjust for changing facility-operating conditions in order to set proper budgets and account for budget variances.

12 October 2011