Energy Bill [HL]

Written evidence submitted by Vilnis Vesma MA(Oxon) Ceng MIE, Director, VESMA.COM (EB02)

Evidence to Public Bill Committee concerning the Energy Bill 2022-23

Sirs,

I am writing with specific reference to Section 10 of the Energy Bill, dealing with the Energy Savings Opportunity Scheme (ESOS). I am registered as a Lead Assessor under the ESOS Regulations 2014, and have numerous contacts in the field of energy management, in which I have worked since 1985.

The ESOS Regulations require participants to audit at least 90% of their energy uses, but following a consultation two years ago the Government has been backing the idea of increasing this to 95%. The merits or otherwise of such a change are not for debate here but the Environment Agency, as Scheme Administrators in England, have been advising ESOS participants and assessors to assume that this 95% figure will apply for the current compliance period. This is causing concern and confusion because many participants have commissioned the required energy audits, and in some cases achieved compliance, based on the law as it currently stands (i.e., with 90% coverage required). Their fear now is that an amendment to the Regulations will force them to revisit their ESOS assessments. In some cases the additional 5% coverage could be costly to achieve: it will not be unusual for example for a participant to have to commission an audit of a transport fleet which currently they were able to omit.

I understand that the Energy Bill is intended not to amend the ESOS Regulations directly but to empower the Secretary of State to do so. I would strongly urge that protections are built in which would prevent changes to the scheme’s rules having the sort of retroactive effect that ESOS participants and assessors currently fear.

Vilnis Vesma MA(Oxon) Ceng MIE

Director

May 2023

 

Prepared 23rd May 2023