Energy Savings Scheme (ESS) Stakeholder Update - 11 November 2019 - - PowerPoint PPT Presentation

Energy Savings Scheme (ESS)

Stakeholder Update - 11 November 2019

Disclaimer: These slides do not constitute legal advice. They should not be relied upon when addressing particular issues in the ESS, for which you may need to seek independent legal advice.

Introductory items

Housekeeping

• Mobile phones on silent, please
• Foyer - public hotspot
• Emergency exits & procedure
• This session is being webcast

Upcoming event

• Module 1: Introduction to the ESS (12

December 2019)

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AGENDA

8:30am – 9:00am Registration & introductions 9:00am – 9:20am Meet the ESS Committee & Message from the Chair 9:20am – 10.00am ESS Update 10:00am – 10:30am Questions and answers 10:30am – 11:00am Networking break 11:00am – 12:30pm Project Impact Assessment with Measurement and Verification (PIAM&V) Guidance Consultation 12:30pm – 12:40pm Close

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Welcome

Philippa Fague General Manager, ESS

ESS Stakeholder Update 11 November 2019

Meet the ESS Committee & CEO

Liz Livingstone, CEO, IPART Pamela Soon, Executive Director & ESS Committee Member Brian Spalding, ESS Committee Member Ed Willett, Chair, ESS Committee Chair

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Message from the Chair

Ed Willett Chair, ESS Committee

ESS Stakeholder Update 11 November 2019

ESS Update

Philippa Fague General Manager, ESS

ESS Stakeholder Update 11 November 2019

IPART’s role

Meet the objectives of the ESS by building a compliance culture, ensuring Scheme integrity through compliance

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Industry DPIE IPART

Administration, regulation, guidance ESS Objectives Capacity building, legislation, policy Feed learnings to policy maker

A Culture of Compliance – success factors

1.

High rates of compliance & low rates of enforcement

2.

High level of understanding of the legislative framework

3.

High levels of ACP capacity and capability to apply all methods

4.

Modern systems and robust processes to prevent non-compliance, rather than react to it

5.

Understanding trends and setting priorities to shape behaviours

6.

Improved relationships – respectful and open

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What are we doing now?

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RISK BASED AUDITING

▼ Auditors – act on

behalf of IPART not independent of IPART COLLATING INFORMATION FROM A VARIETY OF SOURCES USING OUR ‘REGULATORY TOOLKIT’

What is the risk to scheme integrity?

ESS Team work program

• Applications, audits, amendments, queries
• Investigations, enforcement actions
• Scheme Participants compliance process
• Reporting, liaising with policy makers

Business as usual

• Process improvements
• Documentation improvements
• Bespoke IT systems
• Responses to ESS Rule changes

Projects

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BAU Improvements

Team structure & capacity Administration Communication

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What do we have planned?

Compliance priorities Review of communication and engagement with stakeholders

• Accessible and clear guidance documents
• Timely provision of Notices and responses to questions

Reviews of processes and supporting documentation

• Review of guidance documents
• Review of evidentiary requirements
• Review of applications process

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Projects

Audit Scope submission form reduced processing times

• Sampling guidance added consistency

Audit recommendation tracking in Portal Audit report template project

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Supporting auditors

Support our auditors

• Help them perform their statutory

function

Ensure consistent outcomes Provide regular feedback

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What if I have a question?

Why do we ask for questions in writing? How are they prioritised? How soon can I expect a response? What if I don’t like the response?

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Complaints/Reviewing a decision

What if I have a complaint/grievance with IPART? Review of decision Other Complaint

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Complaints

Varies by situation

1.

Make submissions for consideration

2.

We will acknowledge your issue and attempt to address it.

3.

If you are not happy with the response, there is an escalation process.

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ESS GM IPART CEO

Scheme Administrator

Review of decisions

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Merits Review

• Asks “was the decision

the best one?”

• Review by NCAT
• Reviewer “stands in the

shoes” of the original decision-maker

• Reviewer can vary or

replace a decision

• Available only for

specific types of decisions Judicial Review

• Asks “was the decision

made lawfully?”

• Review by a court
• Generally available for

all IPART’s ESS decisions

Merits review

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Examples of ESS decisions subject to merits review:

• A decision to refuse accreditation
• A decision to cancel or suspend an accreditation
• A decision to refuse registration of ESCs
• A decision to impose or vary a condition of accreditation

Right to seek review

You have the right to make an application for internal review of this decision within 28 days after the date of this statement. The application must be in writing, lodged at IPART's offices and specify an address to which a notice of the result of the review can be sent.

Administrative review process

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IPART’s ESS Decisions Merits Reviewable Decisions Internal Merits Review NCAT Merits Review Judicial Review

Questions and answers

www.ess.nsw.gov.au 11 November 2019

Networking Break

10:30am – 11:00am

Please return promptly to your seats at the time indicated above 11 November 2019

PIAM&V Guidance Consultation

Ed Willett Chair, ESS Committee

ESS Stakeholder Update 11 November 2019

• 1. Required records
• Existing record keeping requirements include an M&V Plan,

M&V Report and M&V Professional Report.

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Question 1: What types of supporting evidence and explanatory reasoning should be included in the Preliminary M&V Professional Report?

• 2. Measurement period where energy

consumption is subject to seasonal variation

• The Measurement Period used for the baseline and operating energy

models must cover at least one full operating cycle of the End User Equipment (EUE).

• Where energy consumption is affected by weather, a full operating

cycle is typically described by 12 months of data.

• Measurement Periods for the Baseline and Operating Energy Models

should be selected to reduce statistical bias such that they

• are the same length (eg 12 months)
• Integer multiples of the operating cycle, not fractions of the operating cycle.

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Question 2: What types of evidence and justification can be provided to demonstrate that a proposed Measurement Period covers the full operating cycle for implementations where energy consumption is affected by weather?

• 3. Normal operating conditions
• The definition of normal operating conditions must include:
• That the EUE is properly installed, maintained and used in

accordance with the original equipment manufacturer’s instructions

• The normal hours of operation of the EUE
• Weather conditions (if applicable) and
• Normal production.

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Question 3: What other factors should be considered when defining normal operating conditions?

Question 4: What should be addressed by the explanatory reasoning in the Preliminary M&V Professional Report to demonstrate the appropriateness of factors related to the baseline Measurement Period?

• 4. Measurement and Verification

Professional (M&VP) engagement

• The proposed Rule change to clause 7A.5(h) will mean that

ACPs will need to demonstrate that an M&VP has been engaged and provided feedback on the measurement procedures before the project is implemented.

• We propose to require a Preliminary M&VP Report be used to

meet this requirement.

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• 5. Measurement Boundary
• M&V Plan must document all EUE included in the Implementation

within the measurement boundary

• Energy savings calculated using data from a utility meter must occur

due to the Implementation

• If Energy savings cannot be isolated from utility meter data as
• ccurring as a result of the Implementation an ACP must:
• use Sub metering
• Change the RESA definition to include all activities at the Site.

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Question 5: What options (other than sub-metering), that can be supported by acceptable evidence, are available to ACPs to define the measurement boundary?

• 6. Independent variables
• Selected Independent Variables must affect the energy consumption of

the EUE that is upgraded.

• We have proposed key statistical tests of good fit to assess

Independent Variables

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Modelling criteria Threshold t-statistic of Independent Variable Absolute value >2 Adjusted R2 (coefficient of determination) >0.75

Question 6: What other modelling criteria and corresponding thresholds should be considered? Question 7: Is there supporting evidence that can justify different thresholds than those provided in Table 1 and, if yes, what is that evidence?

• 7. Accuracy factor
• All material sources of error associated with the development of the

model must be taken into consideration when calculating the relative precision of the Energy Savings. These sources of error could include:

• Data uncertainty
• Measurement uncertainty, and
• Modelling uncertainty

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Question 8: What additional guidance or tools may provide support for the calculation of data uncertainty?

• 8. Estimate of the Mean model
• When considering the use of an Estimate of the Mean model, ACPs

must assess if there are Independent Variables that significantly affect energy consumption

• ACPs must measure likely Independent Variables to determine that

they do not have a significant effect on the energy consumption before deciding that an Estimate of the Mean model is appropriate

• M&V Plan must document all potential variables and reasons for

exclusion

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Question 9: What other evidence can be provided to support the identification and selection of relevant Independent Variables?

Next steps

IPART to consider workshop feedback Written submissions due 22 November 2019 Final requirements expected to be published December 2019

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Meeting Close

ESS@ipart.nsw.gov.au – general queries

(02) 9290 8452

ESS_compliance@ipart.nsw.gov.au – compliance & audits ESSlighting@ipart.nsw.gov.au – lighting queries ESSregulator@ipart.nsw.gov.au – annual compliance targets & Scheme Participants ESS_applications@ipart.nsw.gov.au – applications & amendments

ESS Stakeholder Update 11 November 2019