Meeting the energy audit requirement
of the Energy Efficiency Directive
& introducing other headline elements of the implementing legislation including CHP provisions
Enda Gallagher and Errol Close, Department of Communications, Energy and Natural Resources
The Energy Efficiency Directive
Its intent is sensible
Energy efficiency is
the energy game-changer
Why?
The Energy Efficiency Directive
Its intent is sensible
Energy efficiency is
the energy game-changer
Why?
Because it’s available to all
As the saying goes, the Stone Age did not end because we ran out of stones;
we transitioned to better solutions. The same opportunity lies before us
with energy efficiency and clean energy – Stephen Chu
The Energy Efficiency Directive (EED)
and EU Energy Targets
The EED establishes
• a common framework of policy measures
• for the promotion of energy efficiency
• to ensure the achievement of the 20%
energy efficiency target
The EED and Ireland’s Targets
Ireland’s national E.E. target is 31,925 GWh
or 20% saving by 2020
and €2.4bn
Non compliance (re Article 7,
1.5% target – see slide on
Obligation Scheme)
=
EU fines
NEEAP – the action pillars
• Public Sector
• Business
• Buildings
• Transport
• Energy Supply
• Cross-
sectional
The Public Sector
Target - 33%
• Fulfil exemplar role
• Minister to publish EE
guidelines to sector
• Publish EE actions &
assessment of savings
• Detailed data to SEAI
• SEAI – public sector
annual report
• Buy/lease - minimum
A3 BER
The Public Sector – OPW & OGP
• Energy inventory heated/cooled central
gov’t public buildings 250m sq – July ‘15
• Central gov’t to only buy high energy
performance products
• Public service contract tenders –
assessment of long term energy savings
• Public body 500m sq or 35k energy
spend must comply with audits regs
Energy Supply
• CER to complete a national
assessment of energy efficiency
potential of electricity and gas
trans and dist systems-30/6/2015
• + the EE improvement measures
in assessment to be timetabled
• CER to have regard to EE when
making decisions on operation
of electricity and gas systems
• CER to provide incentives in
electricity systems for EE
improvement
Energy Supply
• CER to amend licence
conditions so as to reduce
volume of distributed energy
• CER to ensure that tariffs
reflect EE savings
• CER to ensure tariff incentives
detrimental to EE are removed
• CER may approve schemes and
tariff structures with a social
aim
• CER to promote demand side
resources
• CER to make system / grid
services available for e.g. co-
gen etc.
Energy Demand Management Metering and Billing
• CER - mandated - smart metering systems and to
“licence condition” time of use tariffs.
• Must ensure DSO provides final customers -
electricity and gas – smart metering system (actual
and time of use)
• ensure new / re-build, final customers, electricity
and gas – individual meter
• CER - ensure accurate billing
• And free billing
Energy Efficiency Obligation Scheme
• Obligation – Savings of 1.5% of annual energy
sales to final consumers
• 1,469GWh….1,102GWh negotiated
• Options – impose full 1.5% via an EEOS or
impose part via EEOS + alt measures
• Sales higher than 600GWh
• 550GWh = EEOS target (7 years 3,850GWh)
• 75% Non Res, 20% Res, 5% Poverty
• Voluntary Agreement programme transitions…
• Trading of energy credits – buyout (max 30%, 6c,
20.4c and 88c per KWh) and penalty price (1.25
times the buyout price)
CHP & District Heating
Two aspects to be covered
• Regulations 23 to 25
• Promotion of efficiency in heating and cooling
• Comprehensive national assessment
• Installation level assessment
• Regulation 26
• Guarantees of Origin for high efficiency CHP
Promotion of efficiency in heating and
cooling
Comprehensive assessment (Reg 23(1) to (9))
• To be undertaken by SEAI in accordance with Annex VIII of the
Directive
• Assessing national potential for High Efficiency CHP and
District heating
• Includes a cost benefit analysis in accordance with Annex IX of
the Directive
• Include appropriate recommendations to encourage
consideration and accommodate development
• Report to be completed by 30 June 2015
Promotion of efficiency in heating and
cooling
Installation level cost benefit analysis to be undertaken by
the economic operator when the following criteria are
met:
- when planning to carry out particular activities in
relation to electricity generation, refurbishment of
industrial installations or district heating;
- when seeking a license or revised license from the
Environmental Protection Agency under Section 83
of the EPA Act of 1992
Activities requiring the installation level
assessment
Activity CBA Assessment – Assess
using CHP or waste heat
recovery to
To install a new thermal electricity generation installation with a total
rated thermal input exceeding 20 MW that is not already a cogeneration
unit; Provide for the operation of the installation
as, or conversion to, a high-efficiency
cogeneration installation; To substantially refurbish an existing thermal electricity generation
installation with a total rated thermal input exceeding 20 MW and the
refurbished unit will not be a cogeneration unit;
To install or substantially refurbish an industrial installation with a total
rated thermal input exceeding 20 MW generating waste heat at a useful
Utilise the waste heat to satisfy economically
justified demand, including through
cogeneration, and of the connection of that
installation to a district heating and cooling
network;
To construct a new district heating and cooling network or to install a
new energy production unit with a total rated thermal input in excess of
20MW in an existing district heating or cooling network or to
substantially refurbish an existing such installation and waste heat is not
being used from nearby industrial installations.
Utilise the waste heat from nearby industrial
installations.
Preparation and assessment of the
installation level CBA
• Installation cost benefit analysis to be prepared in accordance with
Annex IX
• SEAI to prepare guiding principles
• Cost benefit analysis to be submitted to the SEAI who will assess
taking account of:
• Comprehensive assessment
• Annex IX
• Actual activity versus the findings of the CBA
• SEAI shall publish notification of its assessment and invite
submissions
• SEAI shall then issue a notification of the outcome of its
assessment to the economic operator
Exemptions
Exemption from undertaking a CBA • The installation is of a class or at a location identified by the
Comprehensive assessment as not having potential for the
implementation of cost beneficial energy efficiency measures,
• The installation is an electricity generating station which is planned to
operate under 1,500 operating hours per year as a rolling average over
a period of 5 years,
• the installation needs to be located close to a geological storage site
as permitted by the European Communities (Geological Storage of
Carbon Dioxide) Regulations 2011 (S.I. No. 575 of 2011), or
• the installation is below any threshold designated by the Minister for
the amount of available useful waste heat, the demand for heat or the
distances between industrial installations and district heating networks
Exemption from outcome of CBA • The economic operator may make an application to the SEAI for an
exemption from implementing the energy production option preferred
under the cost benefit analysis for imperative reasons of law,
ownership or finance.
CHP & District Heating
Two aspects to be covered
• Regulations 23 to 25
• Promotion of efficiency in heating and cooling
• Comprehensive national assessment
• Installation level assessment
• Regulation 26
• Guarantees of Origin for high efficiency CHP
Guarantees of Origin (GOO’s)
• Guarantees of origin for electricity from High Efficiency CHP
• Similar process to that already in existence for GOO’s for renewable
generators
• Supervisory framework to be established by the CER for
• management of the system for issuance, registration, transfer and
cancellation of GOO’s
• provide for the recognition of GOO’s issued by other Member
States
• To be administered by SEMO in accordance with S.I.426/2014 and the
CER supervisory framework
Guarantees of Origin (GOO’s)
Eligibility
• Only for electricity generated from high efficiency CHP
• Standard size 1MWh
• 1 GOO issued for each unit of electricity from high efficiency
CHP
• Must be used within 12 months of the generation of the
corresponding unit
• Each GOO will be cancelled once used
• Information to be provided to support a request for a GOO
outlined in the statutory instrument
Provisions for revocation included due to:
• the provision of incorrect information,
• fraudulent activity,
• The issuance of an inaccurate GOO
• a GOO issued to the incorrect party
SEMO to publish any fees associated with GOO’s on its website
Energy Audits – Part 3 of SI 426/2014
Mandatory element applies to non-SMEs i.e.
more than 250 employees
Or
Turnover > €50m and an annual
balance sheet > €43m
Multi-site organisations must identify their
total energy use in Ireland, and ensure that
90% of this is covered by energy audit
Compliance Requirements
• Buildings, operations, and transport
• Cover at least 90% of total energy use
• Reporting to the SEAI must be completed
by the compliance date (5th December
2015)
• If no audit, may be asked for evidence why
Exemptions: ISO 50,001
• ISO 50,001 certification indicates
compliance, but only if the ISO 50,001
covers at least 90% of the energy use
(measured in kWh or cost)
• If not, then activities, buildings, and
transport outside the scope of the ISO
50,001 certification must be audited also
• In all, at least 90% of the energy
consumption of the organisation must be
covered by an energy audit
Exemptions: ISO14,001
• Environmental management systems such
as ISO14,001 may also be exempt, if an
energy aspect is explicitly included in the
scope and covers at least 90% of energy
use
• These organisations must still report
compliance, identifying the basis of the
exemption
Priority Requirements
• A National Registration
Scheme for Energy
Auditors, independently
run and supervised
• Transparent access to it
• National minimum
standards for energy
audits
• The availability of sufficient
auditors to meet the need
National Registration Scheme
• SEAI to operate
• Can farm out aspects
• Phased development
Registration Process
• Clear qualification requirements, open access
• Application received and evaluated
• Meets requirements – certified
• SEAI website page lists qualified auditors for
classes of audit, starting with large business
Minimum Criteria for Audits
“Minimum criteria for energy audits including those carried out as part
of energy management systems
The energy audits referred to in Article 8 shall be based on the following guidelines:
(a) be based on up-to-date, measured, traceable operational data on energy
consumption and (for electricity) load profiles;
(b) comprise a detailed review of the energy consumption profile of buildings or
groups of buildings, industrial operations or installations, including transportation;
(c) build, whenever possible, on life-cycle cost analysis (LCCA) instead of Simple
Payback Periods (SPP) in order to take account of long-term savings, residual values
of long-term investments and discount rates;
(d) be proportionate, and sufficiently representative to permit the drawing of a
reliable picture of overall energy performance and the reliable identification of the
most significant opportunities for improvement.
Energy audits shall allow detailed and validated calculations for the proposed
measures so as to provide clear information on potential savings.
The data used in energy audits shall be storable for historical analysis and tracking
performance.”
Qualification/Accreditation of Auditors
• Competence shall be evidenced using a
combination of experience and qualifications.
• SEAI are developing list of minimum qualifications
for various activities
• Auditors must register with SEAI’s national
registration system
• SEAI will manage a database of approved auditors
• In house auditors must also be registered and
independent – they must not be working in the area
they audit
• State must train up…Art 16
Overall Principles of S.I. 426/2014
• Aim is high quality energy audits, deep
and effective in line with Annex VI of
Article 8
• Key criteria are quality, transparency,
independence and auditor competence
• Member State (MS) determines what is
sufficiently qualified auditor
• Audit is to be independent i.e. external
or internal auditor independent of entity
or process being audited
• Auditor is to be accredited, qualified and
certified
• MS must ensure sufficient expertise and
capacity of certified auditors (internal or
external)
Overall Principles of S.I. 426/2014
• Scope is all energy across buildings, processes and transport
• MS must put in place means to demonstrate compliance
• MS determines what is reasonable or representative of total
energy use e.g. audit 90% of total
• Where a certified EnMS or EMS is the alternative, the obligated
organisation must include a high quality energy audit that fulfils the
requirements of Annex VI
• Results must be communicable i.e. a closed PDF report would
need to be accompanied by data / spreadsheet
• NB SP - Simple Payback is no longer acceptable, LCCA is the
preferred methodology
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