REVISION OF AS/NZS3598 ENERGY AUDITS: IMPLEMENTATION PLAN
12 October 2011| REF: J/N 109680Department of Resources, Energy and Tourism
Energy and Environment Division
Revision of AS/NZS3598 Energy Audits
Implementation Plan
Project Details
RET Contact / Energetics Contact / UNSW Contact / Rare Consulting Contact /Belinda Fraser / Gordon Weiss / Professor Deo Prasad / Mark McKenzie
Description / Prepared By / Reviewed By / Approved By / Approval Date /
Version 2 / Mark McKenzie / Gordon Weiss / Gordon Weiss / 7 August 2011
Version 3 / Energetics/RET / Energetics / Gordon Weiss / 12 October 2011
About Energetics
Energetics is a specialist management consultancy in the business of climate change. In partnership with our clients, we help them transition to a carbon-constrained environment by managing risks, achieving cost reductions and identifying new opportunities. For over 25 years, Energetics has been providing clients with competitive advantage from the top to the bottom line.
About UNSW
The University of New South Wales (UNSW) is one of Australia's leading research intensive universities and has the largest concentration of climate change and renewable energy expertise of any Australian university. The UNSW Global is a wholly owned enterprise of UNSW with over 230 full-time staff and an annual turnover in excess of $90 million. UNSW Global offers a single point of entry to intellectual resources within UNSW for international donor agencies, regional government agencies and private companies. As such it is one of Australia’s leading consultancy providers, managing over 1,600 consulting and contracted research projects each year.
About Rare Consulting
Rare Consulting is a national consultancy specialising in the provision of services in the area of transport and the environment with a major focus on transport technologies, transport energy use, and greenhouse strategy. Originally founded as Abbott Consulting Group (a wholly owned subsidiary of Abbott Tout Lawyers) the firm was reconstituted as Rare Consulting in August 2005 and has since grown to become as one of the leading providers of environmental and energy strategy services to the Australian transport sector.
Disclaimer
Where conclusions have been drawn based upon information provided to Energetics by the recipient of this report, Energetics has relied upon the accuracy of the information provided.
To the extent that this report contains prospective financial information, that information has been based on current expectations about future events and is subject to risks, uncertainties and assumptions that could cause actual results to differ materially from the expectations described in such prospective financial information.
Table of Contents
1. Executive summary 1
2. Strategic Context 3
2.1. Substantial evolution of the energy efficiency agenda since 2000 3
2.2. Expansion of the energy efficiency agenda beyond traditional focus areas 4
2.3. Differences in sector motivations for energy efficiency improvements 4
2.5 Link between energy efficiency and GHG emissions reporting 5
3. Nature of the review 6
3.1. Objectives of the review 6
3.2. Scope of the review 6
3.3. Methodology 7
3.4. Steering Group 9
4. Suggested improvements – architecture of the revised standard 10
4.1. Objectives of the standard 10
4.2. Target audience 12
4.3. Scope 13
5. Content of the revised standard 16
5.1. Outcomes-driven generic approach with specific sectoral focus 16
5.2. Inclusion of technology specific guidelines 20
5.3. Modification of audit levels to improve energy user guidance 21
5.4. Inclusion of greater guidance on auditor competencies 24
5.5. Energy audit, energy assessment or energy review? 25
6. Net benefits of a revised Energy Audit Standard 27
7. The Standards development process 29
7.1. Complete a project proposal form (Step 1) 29
7.2. Development of a project plan and negotiate approval of the project with Standards Australia (Step 2) 30
7.3. Reconstitute the Technical Committee and revise the standard (Step 3) 30
Appendix A Steering Group 32
Appendix B Possible models for the structure of the revised standard 33
Figures
Figure 1: An ISO50001 Energy Management System. 14
Figure 2: Recommended structure of AS/NZS3598 17
Figure 3: Summary of the development process for the revised Energy Audit Standard 31
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REVISION OF AS/NZS3598 ENERGY AUDITS: IMPLEMENTATION PLAN
1. Executive summary
In October 2008, the Council of Australian Governments (COAG) agreed to develop a National Strategy on Energy Efficiency (NSEE) with the stated aim of accelerating Australia’s energy efficiency efforts and streamlining the activities of Australian and New Zealand governments in this area. The strategy identified the development of enhanced knowledge and skills in energy auditing and energy assessments as a priority – with specific mention made of the need for the conduct of a review into the adequacy or otherwise of current Australian / New Zealand Standards on energy auditing.
Accordingly, the Australian Department of Resources Energy and Tourism (RET) was tasked to conduct a review of AS/NZS3598 Energy Audits (2000). Technical and consultative components of this task were outsourced to a consortium led by Energetics and comprising the University of New South Wales and Rare Consulting. A Steering Group comprising relevant government and industry representatives was formed to provide oversight and ensure that key issues were considered. See Appendix A for a list of Steering Group members.
This paper discusses the findings of the review. It is intended to provide RET and key stakeholders in the NSEE with specific guidance in respect of the:
· need for revision of the current standard based incorporating feedback from a comprehensive consultation with key stakeholders in Australia and New Zealand;
· key areas of potential improvement of the existing standard;
· degree to which the identified improvements are (a) likely to strengthen Australian and New Zealand capability in energy auditing and energy assessments, and (b) accommodate the evolving needs of business and industry in respect of securing energy efficiency improvements;
· likely key areas of contestability, complexity, and continuing uncertainty; and
· key implementation considerations and suggested future actions.
At the centre of the review was a consultation with key industry stakeholders. The consultation addressed a range of questions posed in a discussion paper (see Appendix B), and the outcomes were distilled into a set of solutions which inform the next stage of the review of AS/NZS3598 - this Implementation Plan. The objectives of the Implementation Plan are to explain the requirement for a new version of AS/NZS3598; to outline the proposed scope and structure for the revised Standard, based on industry feedback; and to propose the next steps required to make it happen.
Analysis of the strategic context, business needs and stakeholder feedback revealed that there is a need for a comprehensive overhaul of the existing standard. The potential improvements can be summarised in two principal areas, namely:
§ Architecture of the revised standard – improvements relating to the overall purpose of the standard in terms of the desired objectives, the scope of the standard, and the nature of the target audience, and
§ Content of the revised standard – improvements required to address specific aspects of energy auditing processes.
The stakeholder consultation proposed that the overarching objective of the Standard is to set the expectations relating to the outcomes from, and minimum audit process and reporting requirements for, energy audits conducted by competent energy auditors. (See Section 4.1)
The Standard should complement existing systems standards. In particular, the Standard should be consistent with the provisions of the ISO 50001 Energy Management Systems standard and the International Measurement and Verification Standards. It should also align with the Energy Efficiency Opportunities (EEO) Assessment Framework (See Section 4.3).
The Standard is proposed as an outcomes-driven standard which defines a “generic” audit, intended to suit all sectors and large, medium and small organisations, excluding residential housing. Underneath the umbrella ‘generic’ standard will be three instances of the generic standard that address the specific data measurement and analysis needs of the industrial sector, the commercial buildings sector and the transport sector (See Section 5.1).
To increase the flexibility, relevance and responsiveness of the revised Standard to the needs of business, revision of the current audit level model is recommended. Comments from stakeholders and the views of the Expert Group favoured a structure built around the key audit stages of data definition, data analysis, opportunities identification, opportunities evaluation and business case development. A range of audit levels are required, as is the case with the current standard. Some stakeholders favoured retaining the current three levels, and including recognition that the recommended depth of analysis at each level should depend upon the size of the business undertaking the review. There was general agreement that energy users should be free to select from elements at different levels across the five stages of the audit to customise the level of audit suited to their business needs (see Section 5.3). This area of the Implementation Plan was one where a consensus or even a majority view did not emerge from the consultation process, and it is recommended that the drafters of the new standard undertake another round of consultation to further refine the audit level structure of the revised standard.
To address some of the specific needs of business, the revised Standard should provide guidance on the development of business cases and on the required competencies of energy auditors (see Section 5.4).
And in keeping with the view to align with ISO50001, it is proposed here that the term audit be changed to review (see Section 5.5).
It is envisaged that, subject to formal consideration of the recommendations contained in this paper, that the Energy Efficiency Working Group (on behalf of NFEE) commence formal discussions with Standards Australia to initiate a formal revision of AS/NZS3598 Energy Audits (2000) (see Section 7).
2. Strategic Context
A high level examination of the current national energy efficiency agenda in Australia and New Zealand supports the business case for revising the current energy audit standard (AS/NZS3598:2000). While the study team (comprising Energetics, University of NSW, and Rare Consulting) was careful not to let these insights prejudice the final outcomes of the review, the insights largely informed the design and conduct of the review process.
A brief discussion of these strategic insights is provided below.
2.1. Substantial evolution of the energy efficiency agenda since 2000
Perhaps the single biggest argument for the revision of the current energy audit standard is the fact that the national energy efficiency agenda has grown markedly in sophistication over the decade since this standard was published.
In 2006, the Australian Government introduced national legislation requiring that large energy users (>0.5PJ of energy consumption per year) conduct an assessment of energy use to identify opportunities to improve energy efficiency. This legislation, the national Energy Efficiency Opportunities Act (2006) and associated regulations, places the onus on large energy using businesses to analyse their energy use, identify and evaluate opportunities to improve their energy consumption over time, and report publicly on the outcomes. As part of the program’s implementation, the Government reviewed AS/NZS3598:2000 and concluded that it did not provide a suitable framework for industrial businesses to conduct assessments that would result in the identification and implementation of opportunities. A separate Assessment Framework was developed that took on the key elements of successful business improvement owned by the business and successful data analysis techniques of auditors to achieve more business relevant energy savings. It placed the responsibility on the energy using corporation, not the auditor, and recognised that barriers to improvements in energy efficiency were organisational and behavioural, as well as technical. It was envisaged that the key elements of the Assessment Framework, which reflected the partnership required between the energy auditor and the business, be incorporated in future updates of the audit standard.
The passing of the National Greenhouse and Energy Reporting Scheme (2007) resulted in the introduction of a national framework to report GHG emissions and energy use. While not primarily focussed on energy efficiency, this legislation introduced sliding thresholds on Australian businesses for the reporting of GHG emissions and energy consumption. The thresholds for reporting under NGERS are lower than for EEO and so this legislation effectively increased the number of Australian businesses that were required to undertake some form of annual energy reporting.
The period since 2000 also saw the emergence of several state based schemes that require energy audits, and which refer to AS/NZS 3598. New South Wales required large users of electricity or natural gas to prepare Energy Saving Action Plans (ESAPs). The preparation of an ESAP required a technical assessment to the standard of a level 3 audit so that investment decisions could be made. The Victorian EPA requires large energy and water users to prepare Energy and Resource Efficiency Plans (EREP). A Resource Efficiency Site Assessment (RESA) is required during the preparation of an EREP, and the requirements of these RESAs are based on the AS/NZS3598:2000 approach. Finally, the Queensland Smart Energy Savings Program (SESP) calls for participants to assess energy use in a manner that, at a minimum, complies with a Level 2 energy audit according to AS/NZS3598:2000.
Substantial developments have also occurred in respect of the New Zealand Energy Efficiency agenda since 2000. In 2000, the New Zealand Government passed the Energy Efficiency and Conservation Act which resulted in the establishment of the Energy Efficiency and Conservation Authority which administers key elements of the act.
Within its broad remit to promote energy efficiency and the use of renewable energy, EECA provides a range of services to business. The objectives of the EECA Business program include working with businesses to identify energy management opportunities and develop energy management action plans. Energy audit grants support this objective. The audits funded through the program must comply with AS/NZS 3598:2000 and be performed by an accredited energy auditor. Accreditation of auditors is provided by the Energy Management Association of New Zealand (EMANZ). Demonstrating knowledge of energy auditing, as defined in AS/NZS 3598:2000, is necessary to achieve EMANZ accreditation. EECA has also developed an Energy Audit Manual as a complementary document to AS/NZS 3598:2000 to aid those carrying out energy audits.
National policy developments in Australia and New Zealand have also seen the formulation of national strategies and frameworks that seek to promote improvements in energy efficiency. These agendas include the 2007 New Zealand Energy Efficiency and Conservation Strategy, and the Australian National Strategy on Energy Efficiency which was enacted in 2009.