QUALITATIVE REQUIREMENTS

The CCLA includes Qualitative Requirements that describe a number of basic activities that are considered by NAMB/SAMB and DEFRA to be an essential element of any well structured energy efficiency programme.

The Qualitative Requirements are fully described below in an extract from a DEFRA document. Basically they require that Participants have in place a formalised and structured energy management system. This must address certain commitments and procedures under the following headings:

• Policy

• Planning and Organisation

• Monitoring and Control

• Reporting

• Review

From the perspective of meeting the quantitative energy efficiency targets in each Underlying Agreement, the Qualitative Requirements can be considered as purely voluntary guidelines – if a site meets each quantitative milestone target DEFRA will not review whether the Qualitative Requirements have been met.

However, compliance with the Qualitative Requirements has three possible advantages for Participants and is strongly recommended:

• The Qualitative Requirements are "common sense" activities that will help ensure both the success and the cost effectiveness of an energy efficiency programme. They emphasise the activities that often provide zero cost or low cost savings.

• The Qualitative Requirements are a prerequisite of the Risk Management system (See Information Sheet 8). Under risk management a site may be able to be re-certified after a "near miss" at a milestone. However, DEFRA will not consider this possibility if the site cannot show it has implemented the Qualitative Requirements.

• For sites that are large enough to require an IPPC authorisation, there will be a mandatory requirement to undertake certain "base-line" energy efficiency activities. It is believed these include implementation of the Qualitative Requirements.

Extract From DEFRA Document NA(00)26, Qualitative Requirements

Participants must show that they have in place a formalised and structured energy management system. This should address certain commitments and procedures under the following headings: Policy, Planning and Organisation, Monitoring and Control, Reporting, Review.

Under each heading therefore, this document explains the clear intention of each part of the energy management system, and the components that it should include. However, the degree of detail required to be demonstrated in each component of the system, and the exact approach, will depend on the size of the company/site and its energy use.

It is also essential for participants to go beyond having policies, plans, and procedures. There must be evidence that these are acted upon, and that there is consequent and related improvement to equipment and its operation.

Policy

Each participating company should have in place a formal energy policy that demonstrates the company’s commitment to continuous improvement in the use of energy, and to meeting the CCLA quantitative targets. It should explain the key approaches that the company will take to achieve these combined objectives.

The Policy will:

• Set out the aims for energy management. These should include the aim to meet or exceed the quantitative milestone targets in CCLA;

• Demonstrate the Company’s commitment to managing energy in a way that both supports good business performance and takes due regard for environmental effects;

• Commit the company to having a continuous improvement programme for its energy use. This will include regular surveys of the main energy consuming parts of the company, which will identify means of reducing energy consumption by:

• improved ‘house-keeping’ measures

• improved management and control of processes

• installation of better processes, either by retrofits or new build

• increased use of Combined Heat and Power where appropriate;

• Commit the company, when capital investments are planned, to giving energy efficiency due regard in the selection and configuration of plant, and adopting the most energy efficient equipment available when the marginal cost is justifiable;

• Recognise the need for adequate resourcing and reporting throughout the company of energy management, and the need for measurable objectives;

• Identify the Director or Senior Manager with overall responsibility for the energy policy and its implementation;

• Commit the company to a regular review of the Policy.

Planning and Organising

To achieve the aims and objectives of the energy policy, there should be clear and formalised responsibilities and plans in place that are linked to the CCLA targets, and appropriate procedures for plant procurement and operation.

There will be:

• Documented roles and responsibilities, including identification of who is responsible for energy use in each major energy using facility;

• Plans which set targets for energy savings, and supporting action plans;

• Appropriate methods for communication, to ensure that policies and procedures are understood and that management commitment to them is visible;

• Training plans, both for energy managers and the workforce as appropriate;

• Procedures for appropriate planned and emergency maintenance of equipment, and for its replacement;

• Procedures for assessing the cost-effectiveness of an energy saving measure. These should take a view of savings over the lifetime of the measure.

Monitoring and Control

A system for monitoring and controlling performance should be set up. This should provide the information necessary for monitoring progress against the plans, and enable improvement actions to be identified.

Monitoring and control activity, appropriate to the size of site and level of energy use, should:

• measure the principal energy flows on each site that is covered by the CCLA;

• report energy use in appropriate units to operating managers at a frequency appropriate to the quantity of energy consumed;

• provide standards of performance that managers are charged with achieving;

• allow the review of achievements against standards in order to identify where action needs to be taken;

• allow the review of standards periodically so that they may be tightened as performance improves.

Reporting

Companies should provide management reports on energy use and management (progress against plans, conclusions from regular reviews, etc) in a way appropriate to the size and complexity of the company.

Reporting should include:

• progress reports as necessary or as required by the appropriate senior management body (e.g. Board) in order to ensure adequate control and review of objectives;

• frequent reports for operational management control;

• reports on energy use and related data to the relevant sector association at the frequency that it requires or is necessary to ensure reporting to DEFRA.

Review

Regular reviews close the management system loop. They give the opportunity to stand back, consider whether the energy management system which is being employed remains appropriate, and to decide whether modifications are needed. Companies should conduct such reviews regularly.

Reviews should include:

• consideration of the policy (its aims and objectives, scope, adequacy);

• comparison of quantitative performance against targets;

• comparison with benchmark data (where available);

• A review of the barriers to the implementation of energy efficiency improvements, and proposals for addressing these as far as is possible.