Review of Energy Audit Standard

Department of Resources, Energy and

Tourism

Revision of AS/NZS3598 Energy

Audits

Consultation Report

REVISION OF AS/NZS3598 ENERGY AUDITS - CONSULTATION REPORT

Project Details

RET Contact Energetics Contact UNSW Contact Rare Consulting

Contact

Professor Deo Prasad Mark McKenzie Belinda Fraser Gordon Weiss

Description

Version 1

Prepared By

Gordon Weiss

Reviewed By

Phil Shorten,

Paul Osmond

Approved By

Anne Pellegrino

Approval Date

14/06/2011

Version 2 Gordon Weiss Anne Pellegrino 13/07/2011

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. ii


Executive Summary

The current edition of AS/NZS3598 was prepared by the Joint Standards Australia / Standards New

Zealand Committee EN1 and formally issued in 2000. In the decade following the release of

AS/NZS3598:2000, the energy efficiency agenda has undergone significant development in both

Australia and New Zealand.

In 2010 the governments of Australia and New Zealand sought a review of the standard for energy audits - AS/NZS3598. A Steering Group, made up of relevant government and industry representatives, was formed to oversee the review of the standard, and an Expert Group of consultants engaged to run a public consultation process.

Recognising that many of the key issues relating to the conduct of energy audits are subject to some degree of debate among stakeholders, a discussion paper 1 and associated background paper 2 were prepared to canvass stakeholder views.

These core issues included the

 adequacy of the current standard in supporting the contemporary energy efficiency agenda and business needs of companies in Australia and New Zealand;

 likely future relevance of the standard given recent developments in energy efficiency legislation and related international standards;





 principal objectives that should be addressed by AS/NZS3598:2000; proposed scope and structure of any revised standard; and intended target audience for the standard.

As well as providing stakeholders the option of a written response to the discussion and background papers, a series of stakeholder forums were run in Australia and New Zealand. The objective of the forums was to present the discussion paper, seek input from users of the standard, and receive suggestions for changes to AS/NZS3598 that will subsequently inform the project teams’ recommendations.

This report documents that consultation process. Fourteen written submissions were received and six public stakeholder forums were held in Australia and New Zealand. See Appendix 1 for a list of written submissions received and workshop attendees. In addition, a separate consultation was held with representatives from energy users in the two countries to validate consultation findings.

1 "Towards a revision of AS/NZS3598:2000 Energy Audits. A discussion paper", Published by the Department of Resources,

Energy and Tourism, April 2011. Available from http://www.ret.gov.au/energy/Documents/energyefficiency/DiscussionPaperFINAL.pdf

(Accessed June, 2011)

2 "Towards a revision of AS/NZS3598:2000 Energy Audits. Background paper", Published by the Department of Resources,

Energy and Tourism, April 2011. Available from http://www.ret.gov.au/energy/Documents/energyefficiency/Background_PaperFINAL.pdf

(Accessed June, 2011) iii


Stakeholder consultation

Stakeholders were invited to respond to one or more of 24 questions posed in the discussion paper.

The following table summarises the outcomes of the consultation process for each question, as interpreted by the Expert Group (Energetics/UNSW/RARE).

Question Question text

1

Outcome

Rationale for the review

What are the key gaps/deficiencies that have emerged in relation to AS/NZS3598:2000 over the past decade?

There is a range of shortcomings with the current version of the standard.

The main issues stakeholders expressed were:

 a strong desire to make the results more practical for implementation;

 redefining the levels of the standard to fit with the most common situations in which the standard is used;

 wanting to ensure the standard suits all types and sizes of business (it currently has a commercial building focus);

 several submissions spoke of the need for consistency among auditors, and the need for better training, qualifications and professional development.

2

3

To what extent (if any) do, or should, the elements of the current standard complement other standards, guidelines and programs?

The revised standard must complement other relevant standards, government programs and guidelines.

Objective

What do you believe should be the principal objective (or set of objectives) of the standard?

A range of areas were highlighted:

•

Support scoping and expectation of quality audit outcomes (energy user).

•

Provide guidance to auditors to deliver effective audits.

•

Identify and support implementation of energy efficiency opportunities. iv


Question Question text

4

5

Outcome

To what extent should the standard focus on improving the skills and practice of energy auditors?

The standard should not focus exclusively on auditors.

To what extent should the standard outline requirements of auditor training and address accreditation programs?

The revised standard should be sympathetic to training and accreditation but not provide definitive guidance

6 Are there any weaknesses in the current standard that are hindering the effective identification and evaluation of opportunities to improve energy performance?

Different stakeholder experiences led to different views of the standard's strengths and weaknesses. Some examples provided included



Inconsistent application of the standard,



Poor measurement and verification after audits, and



Poorly trained auditors failing to provide accurate or practical results.

Scope

7

8

9

10

11

12

What areas of the energy audit process should the standard specifically address?

A range of areas were highlighted including:



How to perform an audit.



Scope of works and key deliverables.



Requirements for data analysis.



More robust guidelines for business cases and how costs and savings estimated.

How should the standard link with other relevant standards and/or frameworks?

The standard should link to ISO50001, take guidance from M&V standards and align with

EEO.

Should the standard address energy used in transport applications and materials movement (e.g. in mining, in port facilities, etc.)?

Approximately three quarters of respondents agreed the standard should address transport and material movement applications.

Should the standard incorporate guidance on measurement and verification? Why?

The standard should address measurement and verification in a manner consistent with international M&V protocols to increase energy users’ confidence in outcomes.

Should the standard incorporate guidance on performance contracting? Why?

The standard should not address energy performance contracting.

Should the standard incorporate guidance on energy efficient design? Why?

The standard should not address energy efficiency at the design stage. v


Question

13

Question text Outcome

Target audience

What group or groups (i.e. energy users, energy managers, energy audit providers, training bodies, and government agencies) should comprise the target audience for any future revision of the current standard?

The standard should primarily address energy auditors and energy users. and include a bias towards energy auditors.

14

15

16

17

18

Please explain what part/s of the target audience that you represent. What are your specific information requirements on energy auditing?

A wide range of stakeholders participated in the consultation including end using companies, energy service providers, the training sector, industry associations and government agencies.

Do you believe that it is necessary to make a distinction between the needs of large energy users, medium energy users, and small energy users? Why?

The audit standard can accommodate both large and small users.

Can the needs of different sized energy users be accommodated by a single standard or is it necessary to find a mechanism for meeting the different needs of small and large businesses. Do you think modifying the level system provides a potential solution?

Stakeholders generally agreed that the use of levels provides a means of addressing the range of energy users. There was no clear guidance however as to the ideal number of levels..

What do you consider to be the most appropriate basis for differentiating between the size of different energy users (i.e. employee numbers, annual turnover, annual energy use)?

Users should be differentiated on the basis of energy consumption.

What is your opinion on the need for ensuring that any revision of the standard takes due account of energy users with a partial or fully implemented EnMS?

Structure

The revised standard should account for the existence of an EnMS.

19

20

21

Do you see value in retaining a generic audit standard – as opposed to developing a suite of standards comprising an umbrella standard and sector specific standards?

Nearly three quarters of responses favoured retaining a generic audit standard. It was felt this would ensure the standard would be applicable across industries, avoid being too prescriptive and stifling innovation.

What is your opinion on the development of an outcomes driven standard versus a process driven standard? Some of the options presented in Appendix B adopt both process and outcomes elements. What are your opinions of those options?

Develop an outcomes driven standard but include detail on elements of good audit practice (i.e. data measurement, analysis, cost and saving estimation)..

What are the benefits of adopting an industry sector focus to guidance on energy audits

– as opposed to the adoption of a technology focus? Can you nominate any existing standards/guidelines that could potentially be used to provide sector/technology specific guidance?

The revised standard should include guidelines, and these should focus on technologies vi


Question

22

23


Other considerations

Should the standard refer to energy audits, energy assessments or energy reviews?

Why?

Mix of opinions with most support for retaining

‘energy audit’, although many felt not reflective of outcomes. Strive for common terminology and definitions. Note that this outcome was modified though discussions with the user reference group.

It is not the role of the standard to provide guidance on training and accreditation.

24

What are the specific requirements of the energy efficiency community in respect of guidance on training content and accreditation?

What do you believe should be the priority areas for the standard?

Clear guidance was not provided.

User reference group consultation

In addition to the stakeholder consultation, a select group of representatives from energy users (both large and small) were invited to comment on the outcomes of the stakeholder consultation. This was designed to validate feedback received from consultation sessions and highlight any potential benefits or hurdles raised from outcomes and solutions proposed at those workshops. See Appendix 2 for a list of User Reference Group participants.

The following table lists the outcomes that were revised as a result of discussions during the user reference group consultation.

Question

16

22


Target audience

Can the needs of different sized energy users be accommodated by a single standard or is it necessary to find a mechanism for meeting the different needs of small and large businesses. Do you think modifying the level system provides a potential solution?

Users of different sizes can be accommodated by appropriately designed levels. In particular, an actual audit can be constructed from a collection of elements, each offering a different level of analysis and complexity.

Should the standard refer to energy audits, energy assessments or energy reviews?

Why?

Other considerations

Adopt the term ‘energy review’ to be consistent with ISO50001. vii


Next Steps

Outcomes from the consultation process will be used to define a series of recommendations for the update of the audit standard. These will be incorporated into an Implementation Plan which is being developed by the Expert Group to inform Standards Australia of the consultation process conducted and the outcomes industry have put forward for consideration. This will be completed September

2011. viii


Table of Contents

Executive Summary ............................................................................................................................. iii

Next Steps ........................................................................................................................................... viii

Introduction ............................................................................................................................................ 1

1.

Background ............................................................................................................................ 1

2.

3.

The consultation process ....................................................................................................... 1

About this report ..................................................................................................................... 2

Summary of the consultation forums .................................................................................................. 3

4.

Situational context .................................................................................................................. 3

5.

6.

7.

8.

Purpose of the standard ......................................................................................................... 5

Scope of consideration ......................................................................................................... 10

Target audience ................................................................................................................... 15

Structure ............................................................................................................................... 20

9.

Other considerations ............................................................................................................ 24

User reference group review .............................................................................................................. 27

10.

Review of the stakeholder consultation outcomes ............................................................... 27

10.1.

Context ............................................................................................................................. 27

10.2.

Purpose ............................................................................................................................ 28

10.3.

Scope ............................................................................................................................... 29

10.4.

Target audience ............................................................................................................... 31

10.5.

Structure .......................................................................................................................... 33

10.6.

Other considerations ........................................................................................................ 35

Next Steps ............................................................................................................................................ 36

Appendix 1 ........................................................................................................................................... 37

Written Submissions....................................................................................................................... 37

Consultation Workshop Attendees ................................................................................................. 37

Participants of the Energy User Reference Group ......................................................................... 41

ix


Introduction

1.

Background

The current edition of AS/NZS3598 was prepared by the Joint Standards Australia / Standards New

Zealand Committee EN1 and formally issued in 2000. In the decade following the release of

AS/NZS3598:2000, the energy efficiency agenda has undergone significant development in both

Australia and New Zealand. The scale of this development is perhaps best demonstrated by the numerous government programs, legislation, rating tools and related standards that have emerged in recent years which focus on different elements of the energy management process. These include initiatives focused on improving Energy Management Systems such as ISO50001; reporting and rating schemes focused on baseline energy use; energy audit programs supporting the identification and evaluation of opportunities (for example EECA Energy Audit Grants (NZ), NSW Energy Saving Action

Plans, Victorian Energy and Resource Efficiency Plans); and assessment frameworks which combine management system and audit elements to identify, evaluate and make decisions on the implementation of opportunities, i.e. Energy Efficiency Opportunities (EEO) program.

In October 2008, the Council of Australian Governments (COAG) agreed to develop a National

Strategy on Energy Efficiency (NSEE) to accelerate national energy efficiency efforts and streamline roles and responsibilities across all levels of government. Specific elements of the strategy designed to address this issue included a review of AS/NZS3598:2000. The New Zealand Government also saw the need to update the standard, and commissioned a preliminary review of AS/NZS3598:2000 which was completed in June 2010.

In reviewing the standard, consideration needs to be given to the role of the Audit Standard in today’s business context and how it can assist energy users and auditors in the audit process to improve energy performance, address key business needs, clarify roles and responsibilities and improve identified skills deficiencies.

A Steering Group made up of relevant government and industry representatives was formed to advise on how the project will be managed and the key issues which the review should consider. The

Steering Group was assisted by the Experts Group. It was the Experts Group who facilitated the consultation with the energy efficiency community (i.e. energy users, legislators and energy auditors) in Australia and New Zealand to canvass stakeholder views on the need for a revision of the current standard and on the key issues that should be accommodated in any future revision.

This report summarises the outcomes of the stakeholder consultation.

2.

The consultation process

Recognising that many of the key issues relating to the conduct of energy audits are subject to some degree of debate among stakeholders, a discussion paper 3 and associated background paper 4 were

3 "Towards a revision of AS/NZS3598:2000 Energy Audits. A discussion paper", Published by the Department of Resources,

Energy and Tourism, April 2011. Available from http://www.ret.gov.au/energy/Documents/energyefficiency/DiscussionPaperFINAL.pdf


4 "Towards a revision of AS/NZS3598:2000 Energy Audits. Background paper", Published by the Department of Resources,

Energy and Tourism, April 2011. Available from http://www.ret.gov.au/energy/Documents/energyefficiency/Background_PaperFINAL.pdf


1

REVISION OF AS/NZS3598 ENERGY AUDITS - CONSULTATION REPORT prepared to canvass stakeholder views in relation to a number of core considerations. These core issues included the

 adequacy of the current standard in supporting the contemporary energy efficiency agenda and business needs of companies in Australia and New Zealand;

 likely future relevance of the standard given recent developments in energy efficiency legislation and related international standards;





 principal objectives that should be addressed by AS/NZS3598:2000; proposed scope and structure of any revised standard; and intended target audience for the standard.

As well as providing stakeholders the option of a written response to the discussion and background papers, a series of stakeholder forums were run in Australia and New Zealand. The objective of the forums was to present the discussion paper, seek input from users of the standard, and receive suggestions for changes to AS/NZS3598 that will subsequently inform the project teams’ recommendations. The structure of the forums is outlined in Section Ошибка! Источник ссылки не найден.

below.

The information obtained from the stakeholder forums and the written submissions was then tested by a user reference group, to yield a set of solutions that will form the basis of the implementation plan for the revision of the standard.

3.

About this report

This consultation report provides a summary of the outcomes of the consultation.

The next section provides a summary of the questions posed during the consultation process. Each question from the discussion paper is addressed in turn, with a summary of the stakeholder comments and a collection of representative comments.

The following section of the report provides an overview of the user reference group consultation, in terms of the questions asked and feedback on possible solutions.

2


Summary of the consultation forums

4.

Situational context

Q1: What are the key deficiencies of AS/NZS3598:2000 that have emerged over the past decade?

Outcome: There is a range of shortcomings with the current version of the standard.

This question received a lot of feedback, highlighting a range of issues. The stakeholders expressed a strong desire to make the results more practical for implementation - which could include tying it to programs like EEO. There were also many responses in relation to redefining the levels of the standard to fit with the most common situations in which the standard is used, and across all businesses from small to large. AS/NZS3598:2000 was also seen to be too biased towards commercial buildings. Several submissions spoke of the need for consistency among auditors, and the need for better training, qualifications and professional development.

Some indicative responses follow:

 Too vague generally. Need higher level of detail as to scope, required elements of an audit, data analysis, measurement and verification but remaining outcomes focussed.

 More levels of audit are required. A scoping study often is a level 1.5. A detailed feasibility study is >level 3 on targeted systems but level 1 elsewhere. More flexibility is needed also on level of accuracy. 10% is unachievable e.g. on HVAC.





Energy users expect to receive a report which they can use to implement energy measures.

But often more detailed work/analysis is required. The standard needs to focus on ‘customer friendly’/’business friendly’ outcomes to improve the implementation rate of measures.

Focus should be on quickly identifying the best opportunities and the conduct of detailed analysis for those opportunities. Reports should be presented in a fashion that enables them to be easily transferred to the organisations business case processes. [There is] too much emphasis on providing info that won’t lead to useful outcomes.







The key deficiencies that have emerged for AS/NZS3598:2000 relate to the lack of review of the energy auditor themselves and the need for the standard to apply to a broad range of applications (retail, industrial, commercial buildings) but for which it currently does not provide sufficient guidance.

…there is the potential for future regulatory energy programs to explicitly reference the energy audit standard. If this were to occur compliance with standard requirements would be mandatory for program participants, and it is therefore important that the standard is written such that compliance with requirements will achieve the desired outcomes while avoiding unintended consequences.

The current Audit Standard AS/NZS 3598:2000 does not provide clear guidance to energy users about the kind of audit they need. As a result, companies tend to over-specify or underspecify audits and tend to ‘pick-and-mix’ between the current levels.

3


 There is insufficient guidance on measuring methodology, quality and level of data gathered.

Some indicative accuracy requirements could simply be added to the data sheets in

Appendix D to address much of this issue.

Q2. To what extent (if any) do, or should, the elements of the current standard complement other standards, guidelines and programs?

Outcome: The revised standard must complement other relevant standards, government programs and guidelines.

The stakeholders clearly favoured a standard that complemented others; with over 90% of responses favouring this outcome versus a stand-alone standard. The results are illustrated in the figure below.

Some respondents noted that the document should be consistent with other standards, referencing and relating to them, but not relying on them.

<= "Stand alone"

Q2 Responses by Quartile

"Complement other standards" =>

65%

27%

2%

7%


 Standard should have to recognise existence of technology specific standards produced and maintained by ISO, ASME etc. It therefore has a role to complement those technology specific standards and minimise overlap. This also limits the scope of 3598.





Strive for common terminology and definitions

The standard should be consistent with related standards BUT also stand alone and be effective without reliance on them

 AS/NZS3598 should align as closely as possible to ISO and international standards, to ensure Australia maintains a competitive advantage with other countries while keeping a high standard of auditing process. It also allows investors, researchers and NGOs to accredit companies to an ISO.

 AS/NZS3598 should complement the technology or end-use energy audit/assessment standards, such as the steam systems and fan systems assessment standards produced by the ASME and the compressed air systems energy assessment standard in draft with ISO.

 Despite the overlap that is probably inevitable with those technology-specific standards, the new AS/NZS3598 should be positioned as an umbrella-type standard covering the general disciplines of good generic auditing practices.

4


 The standard should at least line up very closely with National Programs such as EEO,

EREP and ESAP etc. For example opportunities identified under the standard for a level 2 audit must have a payback period of <3 years or >3 years yet for EEO it is 4 years.

5.

Purpose of the standard

Q3. What do you believe should be the principal objective (or set of objectives) of the standard?

Outcome: A range of areas were highlighted:



Support scoping and expectation of quality audit outcomes (energy user).



Provide guidance to auditors to deliver effective audits.



Identify and support implementation of energy efficiency opportunities.

The participants highlighted the importance of four of the seven objectives. There was a clear desire for the standard to complement other standards, which mirror the sentiment in response to question 2 above. The stakeholders did not see that the standard needed to provide guidance to training organisations; nor support voluntary use and regulatory/incentive programs. Respondents did not want the standard to be too prescriptive, to allow organisations to pursue goals by the most effective means for their organisation.

Q3 Responses by Objective

Be suitable f or voluntary use and support regulatory programs

2%

Be consistent with relevant international standards 35%

Provide guidance to training organisations

Increase the rate of implementation of energy saving opportunities.

Support the integration of energy management into core business

Provide guidance regarding responsibilities and roles.

Strengthen the capability and quality of energy auditing

0%

8%

16%

20%

18%






It should provide clarity to business around the process for assessing energy use and the confidence that the outcomes meet a minimum standard of quality.

We believe the standard should “Strengthen the capability and quality of energy auditing and assessment services ”.





Increase the effectiveness of converting energy audit outcomes into energy efficiency improvements.

Rather than either of the two on offer, the proposed objective for the new AS/NZS3598 is:

5


“To set the expectations relating to the outcomes from, and minimum audit process and reporting requirements for, energy audits conducted by professional energy auditors.”





We believe that guidance around training and accreditation should not be part of the standard because each audit can be radically different and training can’t cover all possibilities.

Outcomes – The main aim of the audit(s) should be towards practical implementation of measures to improve energy efficiency.





No, it should not set minimum standards for training, however it should refer to the use of accredited energy auditors and recognised VET and Tertiary training of energy auditors.

Provide a baseline standard for the conducting of a quality assured Energy Use study and identify realizable, cost effective business relevant improvement opportunities. The audit is a tool to identify real opportunities and should naturally lead on to a Business Case for financing and project Management of implementation.

 Principal objectives of the standard should be:





To define minimum levels of accuracy and duration of data gathering.

To maintain a structure and methodology that aligns with the requirements for accreditation of ISO 50001.

 To introduce a platform on which various government program requirements can be based upon or leveraged off. This will assist in reducing overlap or slightly divergent requirements that are a common characteristic at present, particularly between state and federal schemes in Australia.

 In my view the proposed objective for the standard is too narrow. The existing standard has led some organisations to believe that an “audit” is sufficient in its own right to identify all cost effective energy efficiency opportunities. One approach may be to change the objective from “the conduct of an energy audit” to “processes to identify projects that will lead to energy efficiency improvement”.

Q4. To what extent should the standard focus on improving the skills and practice of energy auditors?

Outcome: The standard should not focus exclusively on auditors.

The consultation process provided a range of responses to this question. There was a slight bias towards focusing on all potential users equally, not exclusively auditors. This is illustrated in the figure below. A few respondents noted that the standards should be tailored to specific users with regards to terminology, and allow the skilled auditors to transfer ideas for businesses to implement. One comment highlighted that training and accreditation programs will ensure auditors have necessary skills, so the standard doesn’t need to.

6



<= "Exclusively auditors" "All users equally" =>

34%

26%

21%

19%

Some indicative responses are as follows:

 I think the focus for guidelines should be on individual users with regard to terminology, that it should have separate versions for auditors & business owners, because the information is so technical and extensive. It would help each stakeholder (auditors, business owners, and financiers) from getting lost in each other’s goals and specific needs of the guidelines.

 Should focus on auditors so that auditors are better (valid reliable) to service other stakeholders.





Focus on users so that users can deliver the results and make it easier for users to self audit

– helps ownership and commitment.

Should be focused on ‘practices’ and not ‘skills’. Complimented by skills and accredited programs.





The standard should include training and accreditation as part of its text, to ensure there is a common level of skills required to be an energy auditor. This standardised level of training will allow companies to internally train to a set criteria and provide an “AS standard” compliant set of outcomes.

The standard should focus on the ‘product’ and supported by a complementary industry

(energy services industry) accreditations system that addresses the training and accreditations gap so that the skills needs of industry can be met in more adaptable, and responsive ways that effectively polices the quality of the standard.

 The standard should set minimum requirements for an energy auditor, outlining expectations of training and an accreditation process. Care should be taken to ensure that the fees for attending this training and for gaining certification are not excessive and due consideration given as to which individuals/bodies are best placed to provide accreditation.

 Ensuring that energy auditor have a required level of skills in order that their work is delivering qualified Energy Saving and improvement is a must.

 The standard should define qualifications of auditors based on the system being audited.

Industrial sites should be audited by personnel with specific industry experience due to the complexity of the energy profiles and management systems involved and the unique constraints that may apply.

7


Q5. To what extent should the standard outline requirements of auditor training and address accreditation programs?

Outcome: The revised standard should be sympathetic to training and accreditation but not provide definitive guidance.

The charted responses to this question were evenly divided. However, the written responses tended to favour the revised standard either defining minimum standards or omitting training and accreditation entirely.

<= "Referred to"


"Separate consideration" =>

43%

24% 24%

9%


 Training and Accreditation is a separate consideration. Can be addressed by Education

Providers and industry associations.





Audit standards should be one of the tools to assist improvement of auditor skills along with training and accreditation. However auditors should be trained and accredited to specific technology areas and therefore 3598 might NOT add much value in that regard.

It shouldn’t. Separate training and accreditation schemes should be in place to ensure auditor skills and compliance. This has worked very well in NZ.





Should be an integral consideration, but handled in another form (program or otherwise) to address this key issue of ensuring the standard is applied properly

Auditors should be accredited and registered for the audit levels of 0-4 similar to the DCCEE registered auditors to ensure they have the experience and qualifications to conduct the audits. The standards should address the accreditations requirements.

 At most, the new AS/NZS3598 could refer to the existence of such accreditation schemes as a one of the consideration when planning the resources to be used for an audit.

 The standard should set minimum requirements for an energy auditor, outlining expectations of training and an accreditation process. Care should be taken to ensure that the fees for attending this training and for gaining certification are not excessive and due consideration given as to which individuals/bodies are best placed to provide accreditation.

 The standard should define minimum levels of training and skills so that an auditor is sufficiently knowledgeable of the system being audited and can apply the appropriate techniques to conduct the audit correctly.

8


Q6. Are there any weaknesses in the current standard that are hindering the effective identification and evaluation of opportunities to improve energy performance?

Outcome: Different stakeholder experiences led to different views of the strengths and weakness, and these views helped frame other outcomes.

Approximately four out of five stakeholders believe there are weaknesses in the current standard that are hindering outcomes. Some of the examples listed are inconsistent application of the standard, poor measurement and verification after audits, and poorly trained auditors failing to provide accurate or practical results.

Q6 Responses

No,

23%

Yes,

77%


 The standard needs to include a section on M&V to ensure that the original assessment is delivering its intended benefits.





More levels required so that the audit scope can be better defined.

The standard favours broad/all organisation studies rather than specific technologies or processes. Limited funding dictates that audit outcomes must quickly lead to actions or opportunities and their implementation. Failure to do this results in audits being ‘left on the shelf’.

 We recommend that maximum demand be included in the standard (kW) .Currently only energy is addressed (kWh).This is of interest to users and utilities (infrastructure cost).





A potential weakness of the current AS/NZS 3598 in identifying opportunities is that it is not technology/end-use/application specific enough to result in comprehensive systematic auditing of the key opportunities.

The current standard tends to emphasis individual projects to the detriment of whole projects.

 The current standard is focussed at a relatively high level and therefore does not define requirements for data analysis sufficiently to identify all possible opportunities.

9


6.

Scope of consideration

Q7. What areas of the energy audit process should the standard specifically address?

Outcome: A range of areas were highlighted:



How to perform an audit.



Scope of works and key deliverables.



Requirements for data analysis.



More robust guidelines for business cases and how costs and savings estimated.

There were a number of well thought-out responses to this question. Some emphasis was placed on the inclusion of examples or explanatory text, and better definition of business cases. The respondents wished to see more transparency in how auditors obtain cost estimates and make calculations, as well as for verification purposes. They would like the standard to include examples to improve consistency and standardisation as well as empowering clients to check for compliance.


 We need to have a greater emphasis on how auditors calculate and/or estimate cost of new equipment and /or predicted energy savings.

 Need more meaningful business cases e.g. incorporating future energy pricing in cash flow model, linking closely to specific requirements of the business in terms of hurdle rate of return, etc.

 Scope: should provide guidance on skill set required (as well as need for specific process expertise) so that real benefits can be identified once “low hanging fruit” picked.

 It should include guidance on developing cost assumptions so quotes/business cases can be evaluated.

 Scope: should include guidance/requirements for measurement and verification so that actual improvements can be verified or need for further review identified.

 The standard should clearly outline how to actually perform an energy audit irrespective of sector and assess each type of energy use so that auditors are confident they are correctly performing an audit and companies have clear expectations as to what this involves and what the outcome will be.

 The standard should contain (in appendices) a scope of works and key deliverables for each of the standard levels so that clients are better tooled to check the product for compliance with the standard

 There should be a responsible person identified with some sort of responsibility to follow through and evaluate audit outcomes. Audit standard should address reporting requirements including non-technical aspects i.e. responsible people, documentation, accuracy

 Areas of the Energy Audit process that should be addressed by the standard include:

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 Identification of specific audit techniques for different equipment and systems. E.g. industrial energy systems, offices, commercial, etc

 Definition of system and equipment based competencies and certifications for auditors.

 Defining roles and responsibilities to ensure auditors and energy users are clear on what is required of them.

Q8. How should the standard link with other relevant standards and/or frameworks?

Outcome: Should link to ISO50001, take guidance from M&V standards and align with EEO.

The respondents wanted the standard to complement other standards to increase the applicability and consistency, and to ensure best practice. Specific standards mentioned included IMPVP (M&V) and

ISO50001.


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

Standard should make use of existing standards/codes of practice from other regulatory agencies to lower the cost of implementation and shorten lead time in development and adoption of the standard.

The standard shouldn’t link to other relevant standards directly. Rather, it should attempt to provide a link between other relevant frameworks and aim to be the basis of future energy efficiency frameworks and standards.

 EEO legislation and regulations are already prescriptive in how energy assessments need to be carried out, and as such establish the framework that EEO participants currently need to comply with in undertaking energy audits. This pre-existing arrangement needs to be recognised in the review of the audit standard, as any inconsistencies between energy program requirements will increase the already significant administrative burden energy efficiency programs represent to large energy users to the detriment of identifying and achieving actual energy savings.

 It is essential that the revised standard be aligned with the ISO50001 standard. The standard could also utilise established sector based standards to ensure a high quality of auditing.

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Q9. Should the standard address energy used in transport applications and materials movement (e.g. in mining, in port facilities, etc.)?

Outcome: The standard should address transport.

Approximately three quarters of respondents agreed the standard should address transport and material movement applications. However some of the comments were qualified suggesting the standard shouldn’t be technology focused, but maintain a level of generality with some specific sector focus.

Q9 Responses

No,

29%

Yes,

71%


 Inclusion of transport should be dependent on the nature of the business being audited by clearly defining the audit boundaries.

 We should limit the scope to aspects that are not specific to a sector of technology. Separate standards exist or should exist for separate areas





There should be a suite of standards for different sectors so that more meaningful provisions apply.

Yes. The basic approach to analysing and addressing energy used in transport is the same as stationary energy use.

 The standard should include an assessment of the transport application and materials movement where they are considered to fall within the boundary of the audit. These activities are an integral part of most mining and manufacturing activities in Australia and can contribute significant energy demands where long distances are involved.

 The standard should include the transport sector because of its significant energy consumption and most sectors have or utilise transport systems to some degree. If practical the revised standard should provide guidance for audits on all significant consumers of energy however particular sectors, e.g. industry, may require guidance that can be adapted to various activities due to the unique nature of many industrial sites.

Q10. Should the standard incorporate guidance on measurement and verification? Why?

Outcome: The standard should address measurement and verification (M&V) in a manner consistent with international M&V protocols to increase energy users’ confidence in outcomes.

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A large majority answered yes to this question, although the comments were less definitive. Many strongly believed separate standards should be adopted for M&V, or that M&V comes after the audit is complete, during the implementation phase. While others felt that M&V was fundamental to an audit, and required to validate the results and ensure energy efficiency is enduring and initiatives are maintained.

Q10 Responses

No,

18%

Yes,

82%


 M&V should be referred to in an “Audit’ in order to increase the end users confidence in the outcomes EMO’s. Can be verified: Measurement is a critical part of the audit process.





M&V Baselines could be part of the audits, but M&V normally follows implementation, which is usually after the audit. And there is an M&V, de facto standard, the IPMVP.

If the purpose of the audit is to deliver an outcome the NZ’s commitment on combating climate change then the ability to measure this change is fundamental. Measurement also ensures changes remain and are enduring.

 M&V should be excluded from energy reviews standard as it complicates and costs are increased. The standard is for finding energy opportunities.

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Only to the extent that, as an umbrella standard, it will specify general reference to the measurement expectations and methods of the applications or technologies being audited, in the context of scope and depth (accuracy requirement) of the audit requested.

It could make reference to M&V for awareness only purposes.

Measurement and verification processes should be considered in the standard to ensure that appropriate levels of data quality of a sufficient duration, are obtained to provide a statistically representative analysis of the system being audited.

 The standard should reference established standards/legislation with regard to measurement and verification. There is sufficient guidance available on this topic and rather than add to this, referencing the National Measurement Act 1960, National Greenhouse and Energy

Reporting (Measurement) Determination, 2008 and any measurement standard established in legislation regarding a carbon price would be appropriate.

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Q11. Should the standard incorporate guidance on performance contracting? Why?

Outcome: The standard should not address energy performance contracting.

Two thirds of respondents believed the standard should not incorporate guidance on performance contracting. Some of the comments mentioned other standards already in place, or to be developed to manage this, or ESCOs performing their own due diligence audit.

Q11 Responses

Yes,

35%

No,

65%


 EPC should be a solution adopted after the audit. Most ESCO’s do their own due diligence audit.

 No this should be a separate standard that can refer to AS3598

 No. There is already an energy performance contracting body (EEC) and a well defined set of processes incorporating EPCs into standard would be repetitive.





As a procurement framework, the standard should be compatible with the Energy

Performance Contract (EPC) process.

Yes as optional to ensure implementation of proposal

Q12. Should the standard incorporate guidance on energy efficient design? Why?

Outcome: The standard should not address energy efficiency at the design stage.

The majority of respondents believed the standard should not incorporate guidance on energy efficiency design. They believed this was best left to other programs and regulations, as it’s too broad a category to tackle in this standard. Stakeholders noted that design reviews for energy efficiency are detailed and expensive. However, some stakeholders saw the current standard as being capable of supporting design audits.

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Q12 Responses

No,

61%

Yes,

39%


 Many energy audit recommendations will require further feasibility studies prior to implementation because the fee being paid for an energy audit will not cover the cost of a detailed project study.

 Most energy audits relate to existing facilities (i.e. Post design and post built). Design reviews for energy efficiency is a separate exercise to an energy audit.

 Current standard allows for audits of designs. If required may be included as case studies/training modules.

 EE design should be incorporated into other standards and regulatory processes. EE should transcend all processes => design does not need to be prescribed in 3598.

 Yes. Good design and build should be the key to energy efficiency rather than trying to retrofit. If well done initially the requirements for auditing and inspection will be less onerous and more cost efficient.

 No, energy efficient design is too broad a topic to incorporate into this standard. It should be referenced as a separate document. Additionally adding this type of technical expertise will increase the difficulty of getting sufficient auditors accredited.

7.

Target audience

Q13.What group or groups (i.e. energy users, energy managers, energy audit providers, training bodies, and government agencies) should comprise the target audience for the standard?

Outcome: The standard should primarily address energy auditors and energy users.

Approximately half the submissions felt that all listed stakeholders should comprise the target audience as they are all relevant for energy management. However most of the remainder believed the emphasis should be on energy managers and auditors, with users as the main beneficiaries.


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 Standard should address the needs of all stakeholders so that implementation of energy audit and subsequent EE implementation becomes easier.

 Audit providers should be the main target but energy users as main beneficiaries





Energy Managers and Energy Providers/Auditors should be the primary target for this standard and will require in depth knowledge. Users need to be aware the standard exists but it is important that the standard is created by experts to give the best results for users.

Standard to focus on energy “assessors” to set minimum performance levels and then on energy users to set expectations and increase uptake.

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

We should target the audit providers as a target audience as the ISO 500001 standard will provide the necessary requirements for all other groups.

The primary audience is existing or prospective energy auditors. The secondary audience is the client base of those auditors – to encourage their use of auditors with the skills and tools to provide valuable analysis and recommendations.

Q14. Please explain what part/s of the target audience that you represent. What are your specific information requirements on energy auditing?

Outcome: A wide range of stakeholders participated in the consultation.


 We are all Energy Auditors based in Christchurch. We require a guideline to assist auditors to deliver a best practice result.

 We represent the energy audit provider. Our specific information requirements on energy auditing are a basic procurement framework and, of course, client energy usage and requirements.

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



We provide energy audit consultancy services (Level 1 and Level 2 in accordance with the

Standard). Our specific requirements relate to the minimum requirements for the conduct of an audit and to ensuring the client understands what it is they are commissioning and what they can expect at the end of the process.

NGO looking at energy efficiency. Background as a building surveyor.

We are a manufacturing company utilising major industrial facilities that are very significant consumers of energy.

 We are a large energy user with obligations under the Energy Efficiency Opportunities Act

Q15. Do you believe that it is necessary to make a distinction between the needs of large energy users, medium energy users, and small energy users? Why?

Outcome: The audit standard can accommodate both large and small users.

When responding to the simple yes/no question, a majority believed that a distinction should be made between large and small energy users. However, the written guidelines were less clear, and in fact,

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REVISION OF AS/NZS3598 ENERGY AUDITS - CONSULTATION REPORT most suggested that whilst the application of the standard across the range of energy users may be different, the standard itself need not be.

Q15 Responses

No,

37%

Yes,

63%






 The level structure in the standard should be used to differentiate. Application by other regulations e.g. EEO could stipulate level required based on an organisation size or other criteria.

 Not needed because the size of the business will dictate whether an audit is justified or not, or will limit the audit scope to match what is economic.

Yes, provided there is a detailed reference/scope for level of audit.

We should have a uniform definition of energy audit regardless of size and industry so that the process is easier to manage and regulate.

 We should set thresholds and materiality guidelines on extent and level of detail. So that different size organisations are catered for.

 We believe there is no need to make a distinction between different sized energy users. The standard should be flexible and able to cover a wide range of different sized energy users.

By being outcomes focused, the standard can cover different sized energy users and still detail a procurement process for end users to achieve real energy reductions.

 It is necessary to make a distinction between the needs of the different sized users. The complexity of an energy audit and the scope of the savings identified will be determined based on the materiality of the energy savings calculated in the recommendations made which is directly related to the amount of energy used. Energy audits can provide meaningful recommendations to all sized businesses but the scope of work involved is very different.

 Yes, larger energy users tend to have more complex systems that require more detailed and technical analysis. This would require specialised auditor training and equipment to produce an audit of the required level.

 The principles should be the same. It is the design of the assessment process that may differ for size of company. Also – differentiation is not so much about size – more importantly it is about level of interest, past experience progressing energy efficiency, business drivers, appetite and potential for significant innovation vs incremental change etc.

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Q16. Can the needs of different sized energy users be accommodated by a single standard or is it necessary to find a mechanism for meeting the different needs of small and large businesses. Do you think modifying the level system provides a potential solution?

Outcome: Clear guidance was not provided by the stakeholder consultation. An outcome emerged from the user reference group consultation.

The stakeholders generally agreed that the use of levels provides a means of addressing the range of energy users. There was no clear guidance though as to the ideal number of levels.





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






Yes because level of detail and complexity required needs to match decision processes of users.

Level 4 audits and being able to produce energy saving options to ±10% is a good idea in theory but may require considerable cost/time to achieve – Need to have confidence that the auditor’s financial calculations are good.

Level 0?? Maybe “walk through” or assessment. Agree.

Level 1a No Just level 2 Audit…could only change level 1 price

Level 2a No confusing call it a design audit

We should keep to 3 levels as it is easier to market and service users. However we should broaden the application in each level to include more flexibility so that more level 1 and level

2 audits are done.

 There is a need to accommodate both large and small energy users as energy auditing is a valuable tool for both. However more guidance is needed for small users and we are very supportive of option level 1a.

 A single standard can accommodate the needs of different sized users because the principles are the same and the size of the user will determine the level of investigation

 We should have a mechanism within a single standard that can scale so that effort and rigour is applied depending on the complexity and risk and value of the work / project / use

 The level system must be very simple in order that end user are not lost in 10's of level and which one to implement, 4 level are considered enough to cover all needs as listed below:

 The variation in scale and complexity of energy users in Australia is quite significant. A single energy auditing standard would not be sufficient to encapsulate the transport, industry and commercial sectors. A mechanism is required that identifies the needs of not only varying scales of use but also the different types of energy used. It may prove more practical to address the needs of industrial energy users with a separate standard.

 The kind of audit that an energy user needs should be determined by the outcomes that they want from the audit. The Council recommends three levels for audits:

 Benchmarking and making the case for an audit: The first level of audit would identify the possible scale of savings on a site using benchmarking and/or a basic audit. For example, in a commercial building, this stage could involve a NABERS assessment and broad identification of the scale of energy saving opportunities on a site.

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 Scoping out opportunities: A scoping audit would identify energy saving opportunities and determine their feasibility, costs and benefits to a reasonable level of accuracy.

The level of accuracy would depend on the energy spend on the site (see below).

 Investment-grade audit: An investment-grade audit would build on the scoping exercise and undertake detailed modelling, feasibility studies and costings of some or all of the energy saving measures identified for a site.

 We are generally supportive of the identification of the different levels for an energy audit and do agree that these go some way to distinguishing the requirements of the different customers. It is recommended that the single standard address, as different sections, the minimum requirements expected for each size of energy user.

Q17. What do you consider to be the most appropriate basis for differentiating between the size of different energy users (i.e. employee numbers, annual turnover, annual energy use)?

Outcome: Users should be differentiated on the basis of energy consumption.

Few respondents commented on this question, however of those that did, most favoured a combination of energy usage and revenue to ensure large energy users and large companies alike were captured at the appropriate level. An alternative approach is to consider the size of the potential savings.


 Suggest an energy audit ranking be linked to energy usage and revenue. This is to ensure that bigger companies put a higher level of auditing in place. For example:











Level 1: $1m - $100m, 0-200GJ.

Level 2: $100m - $500m, 200-500GJ

Level 3: $500m+, 500GJ+

Relevant thresholds should use a % of annual spent or a minimum GJ/MJ value based on the audit level (0-4). This would capture uses of a minimum value as well as those of a minimum $ value for all energy users.

N/A. The differentiating of different sized energy users should not be an issue. The focus should be upon savings potential and as above, the standard should be able to encapsulate all sizes of energy user.

Q18. What is your opinion on the need for ensuring that the standard takes due account of energy users with a partial or fully implemented EnMS?

Outcome: The revised standard should account for the existence of an EnMS.

The majority of responses agreed the standard should consider a partial or fully implemented EnMS.

Many noted the need for process linkages between energy audit standards (EEO and SESP were two examples given) and EnMS.


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 The standard should not need to be tailored to accommodate whether an EMS is in place.

This should be irrelevant. A company with an EMS may use the standard as a significant component of that system however if an EMS is not in place it can be used as stand alone.

 Due to the potential synergies involved, the standard should take account of energy users with an EnMS. Likewise, it should account for users undertaking EEO auditing etc.

 The standard should provide clear linkages to other standards and mandatory reporting as appropriate. This clearly includes the EnMS but should also include EEO and State programs such as the Queensland Government’s Smart Energy Savings Program (SESP).

 The audit process should be structured in such a manner that it can be fully integrated into a companies’ energy management system certified to ISO50001 (and if appropriate

ISO14001) to avoid duplication of effort.

8.

Structure

Q19. Do you see value in retaining a generic audit standard –as opposed to developing a suite of standards comprising an umbrella standard and sector specific standards?

Outcome: Retain the generic standard.

Nearly three quarters of responses favoured retaining a generic audit standard. It was felt this would ensure the standard would be applicable across industries, avoid being too prescriptive and stifling innovation, and simplify the audit process reducing the effects of skill shortages among auditors.

However many respondents wished to see sector case studies, sub-standards, or technology guidelines still focused on processes.

Q19 Responses

No,

29%

Yes,

71%


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

Perhaps a generic standard with sub sectors for industry specific / property groups.

The standards should be kept general so as to : a) be more applicable across various industries and b) does not become too prescriptive (and possibly discourage innovation)

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 Better to retain economy wide approach to standard and develop specific case studies and examples of how standard can be applied to different sectors. Also via training modules.

 Each audit process should identify the site/process/activity under its ANZIC code. Processes for each category could have a range of standard industry “P” codes and for the opportunities provide a range of standard “O” codes -> potential national database.

 Technology rather than sector, as any sector should be able to be broken into technology components e.g. motors and driver and across most sectors.

 We suggest a set of sector, outcome based standards so that standards accommodate different emphasis and metrics required by each, AND a set of end use “technology” guidelines, prescriptive but not binding, describing the PROCESSES of measurement and identifying savings, so that people know a method to achieve results without stifling innovation.

 We should have a generic standard so that clients can know what they can expect as outputs and energy auditors know what they have to work towards.

 Generic standard with specific guidance and examples/exceptions for the large energy users such as electricity generators – provide consistency and guidance.

 A generic audit for base principles is fine but it must then separately identify the vertical markets as they are different. A house is different to a shopping centre, which is different to a transport business.

 There should be a suite with an umbrella standard covering common areas and child standards focussing on different technologies. This will provide guidelines to introduce consistency in different situations.

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

We should have a generic one standard that is applicable across sectors so that the audit process is simple, transferable and to reduce skill shortage in energy auditing

Propose there to be one standard for auditing, but different subsets, so that there are set requirements in auditors accreditation and methods of reporting – but subsets be pertinent to industry e.g. Agriculture, Transport, Mining = AS3598.1, AS3598.2, etc.

 There is value in the generic standard albeit with increased guidance on the minimum requirements for each level of audit and tailored to each type of energy user. That said there is also a lot to be gained in clarifying expectations of both parties by using an umbrella standard with sector specific sections.

 The Council recommends a suite of three standards (commercial buildings, industrial sites and transport). The industrial site standard should consist of a core standard for auditing along with technology-specific guidelines.

Q20. What is your opinion on the need for an outcomes driven standard versus a process driven standard? Some of the options presented in Appendix B adopt both process and outcomes elements. What are your opinions of those options?

Outcome: Develop an outcomes driven standard, but need detail on elements of good audit practice (i.e. data measurement, analysis, cost and saving estimation).

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The majority of respondents believed an outcomes focus was best, most often for the reason that a process-driven standard would be fraught with difficulty capturing all the complexities of diverse industries. Most responded that an outcome driven standard is more flexible and all-encompassing.

Some respondents opted for process-driven elements, such as a small business checklist in an appendix, or a high level process for ensuring coverage of generic issues.


 A small business would value a checklist or prescriptive standard which may be accommodated in an appendix of a standard.

 Focus on outcomes (possibly sector/technologies guidelines). To attempt process/ prescriptive will force a need to capture all complexities. Particularly in complex industrial energy systems the need is for well qualified people.

 You should use an outcomes driven standard to account for diversity of industries and to assure quality there should be a process around transparency of an audit and its outcomes so that there is a map the end user can follow to understand the audit outcomes.

 Outcomes v process is too black and white. Largely outcome focussed but requires some level of high level process to ensure coverage of fundamental generic issues.

 Outcomes driven more important for generic standard, process driven more appropriate for sector/technology specific guidelines.

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



We should have an outcomes driven standard so that non-energy professionals + users can know what an energy audit is supposed to deliver.

I think the outcomes driven standard is more preferable than process driven, due to the variance in approaches within sectors. Within gold mining alone, a number of mining and processing techniques are used, making a prescriptive standardised approach difficult.

We should have a technology focus, as appendices, so that there is consistency across auditors and industries.

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

An outcome delivered standard is a must. It must detail that a key outcome is implementation and deliverable energy efficiency.

In carrying out audit processes it is important to have a process driven approach to ensure consistency of information provided to energy users and to provide for a cost efficient process in simple and straight forward examples. In order to provide for flexibility and innovation, the use of an outcomes approach is also recommended

 A technology based energy auditing system would be relevant to a greater number of sectors, as most sectors have common systems, e.g. compressed air, steam, HVAC, pump, etc. However sector specific technologies not covered by a generic technology based process driven auditing system will be numerous. A sectoral approach to the standard may partially alleviate this issue. There will always be some specialised energy consumption, particularly on industrial sites, that is going to be difficult to audit no matter which approach is taken to the audit methodology.

 To be effective, the approach taken by the auditor needs to be pragmatic, recognising the magnitude of energy use/costs and focusing on priority areas as identified through the

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REVISION OF AS/NZS3598 ENERGY AUDITS - CONSULTATION REPORT energy mass balance (or equivalent). An outcomes-driven energy audit standard is likely to be more flexible and able to be appropriately applied across a broader range of sectors than a prescriptive, process-driven approach.

 We should adopt a process driven standard so that companies new to energy auditing can understand their obligations.

 We should have a combination of outcomes and process driven so that flexibility is retained in the standard. This model would suit a suite of standards with the overall one in outcomes and specific sectors perhaps process.

Q21. What are the benefits of adopting an industry sector focus to guidance on energy audits – as opposed to the adoption of a technology focus? Can you nominate any existing standards/guidelines that could potentially be used to provide sector/technology specific guidance?

Outcome: The revised standard should include guidelines, and these should focus on technologies.

Nearly all the comments were in favour of a technology focus for guidance. Their reasons included facilitation of more structured audits, allowing project engineers to apply standards in design, increased flexibility, and that programs like EEO already existed for sector focus. There were however some responses that favoured sector based guidelines.

 The focus of standards should be on the items of equipment – heat exchangers etc etc so that project engineers can apply these standards in process / plant design leading to big wins.

 A technology driven focus would be more appropriate as this is the better way to focus discussion during energy audits. It is a better fit than industry focus.

 The standard should have a technology focus. This should allow business to select sub-sets of the standard applicable to them, and account for diversity of energy end use within a business. This will be flexibility within the standard meeting the diversity of industry and take into account practiced differences between different energy end uses.



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Industry groups/associations can develop supporting guidelines specific to their sector/technology.

My suggestion is that a ‘sector’ based approach will provide a catalyst for technology laggards to improve their technology offering and improve energy efficiency. A technology focused approach will encourage complacency.

Assuming the objective of the standard is to deliver outcomes against NZ’s commitment to combat climate change, then target reductions by sector are then very important. This then translates into benchmarks by sector that companies or organisations can measure themselves against.

 Adopting an industry sector focus does aid energy auditors in targeting the audit to the particular arrangements of an industry.

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 The s tandard will need to take a mixed approach. There should be a single ‘sector’ standard for commercial buildings (as the technology is highly homogenous), but the ‘sector’ standard for industrial sites would need to be complemented by technology-specific guidelines.

9.

Other considerations

Q22. Should the standard refer to energy audits, energy assessments or energy reviews?

Why?

Outcome: Mix of opinions with most support for retaining ‘energy audit’, although many felt not reflective of outcomes. Strive for common terminology and definitions. Note that this

outcome was modified though discussions with the user reference group (see Section 10)

The respondents’ views were split between ‘audit’, ‘assessment’ and some combination of names. The term ‘audit’ was preferred to remain consistent with the current standard and to give weight to the process. Using the term assessment was suggested because it doesn’t carry the negative connotations of the word ‘audit’, and because this standard is so dissimilar to other audits. The combination of terms was preferred to signal varying levels of detail, or aspects of the path towards the end goal. One suggestion was to have an assessment before an audit, and a review afterwards.

Another was to refer to the entire exercise as the assessment with an audit as one component.

Q22 Responses

'Assessment'

'Audit'

'Review'

Other or

Combination

Some indicative responses include:

 The term “Audit” carries weight. Consider that only professionally qualified Energy Auditors can provide “audits” others “Assessments” and maybe this replaces the Level 1-3 in current standard.

 As an auditor I actually think that “assessment” is a more accurate term it is a more accurate description however the term audit holds more weight.

 The standard should refer to an assessment, so that it can be more outcomes driven. An audit is to be prescriptive and process based.

24


 Energy audit should remain as the assessment and review once the next steps. Similar to verification procedures. Level dependent.

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

“Audit” can have a negative impact on certain end users so “assessment” is a better term.

Will drive outcomes, rather than just report.

It doesn’t matter what the standard refers to, but the entire industry must use the same terms. As such, it makes sense to retain Energy Audits as the incumbent.

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Name should reflect level of accuracy of the audit/assessment i.e. L1 = assessment, L2 = audit.

An assessment is the process .An audit is the function – An auditor undertakes and energy efficiency audit at an agreed level e.g. level 1 residential and retail. Level 2 Commercial.

Level 3 Industrial. A “review’ is to re visit a function or a process.

The standard should refer to “review”. This would be consistent with IEC, the coming international standard. Also the word audit is not correct for identifying energy opportunities.*

We should call it an assessment so that it doesn’t confuse people as it doesn’t align with other audit processes

 I would suggest that Level 1 = Assessment, Level 2 = Audit, Level 3 = Review (as nominally this would follow on from level 2 Energy Audit of the site).

 Generally an audit is too much a check list, so Energy Assessments or Energy Reviews seem more adapted.

Q23. What are the specific requirements of the energy efficiency community in respect of guidance on training content and accreditation?

Outcome: It is not the role of the standard to provide guidance on training and accreditation.

Most respondents felt that the standard should not give guidance on training and accreditation as this was a separate, albeit related, issue.

 The standard should be separate from guidance on training as the document should focus on standards (separate document for training).

 Guidance is not required. The standard sets what needs to be delivered, then nationwide, government (or similar) bodies set what they consider is required for accreditation. The NZ system is working very well and provides a largely consistent product across providers.

 Specific requirements can be helped by accreditation standards and competency training for auditors and end users.

 Standards for audits need to be set. Training needs to be developed based on these standards. Training needs to be accredited and incorporated in National Training Packages relevant to industry skill sectors eg. Electro technology ISC. Auditors are trained to these

NTP and AQTF standard and should be accredited also with peak industry bodies e.g.

Energy management Industry. **

 Training content and accreditation should be industry driven and not covered in a standard.

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 There needs to be clear and measurable criteria for training courses and accreditation. In the same way that the level of audit is supported then the level of accreditation should provide for different levels of auditors to carry out the audits. The more complex the audit the higher level of skills.

Q24. What do you believe should be the priority areas for the standard?

Outcome: Clear guidance was not provided.

Opinions varied on this topic, as people prioritised buildings, transport, requirements of reporting, sector specific guidelines, and focusing on outcomes.

Some of the more illustrative comments follow.

 The priority of the standard should be to outline what requirements are needed in the energy audit report. These requirements then determine what is reviewed onsite, the level of calculations required, etc.

 Buildings new and retrofitted, as investment in this area have a long term benefit.





Transport, due to the high energy use and impact on import costs.

We believe it should stay as an open performance based tool that focuses on outcomes, not the process. The skill of the auditor is the process. This way there is an ability to cover broad areas e.g. Electricity, Gas, water, fuel, etc **

 Providing an overarching framework that provides clear guidance to the company undertaking the audit of what is involved and the results that they can expect while providing energy auditors with clearer guidance as to what an audit at each level should consider and address as a minimum requirement.

 Developing consistency in audit processes and accreditation of auditors and accreditation bodies.

26


User reference group review

10.

Review of the stakeholder consultation outcomes

This section of the report presents the outcomes of a consultation workshop that involved a select group of representatives from energy users (both large and small). As the value that a revised standard delivers to energy users forms the basis of the business case to revise the standard, the

Steering Group felt that representatives of large and small energy users should provide an assessment of the impact of the recommended changes to the standard that emerged from the stakeholder consultation.

The workshop presented the 24 questions in the six broad themes and sought input on the outcome of the consultation phase for each question and any potential benefits or hurdles.

Item

Question

Outcome

Hurdles

Benefits

Description

This was the text of the question posed in the discussion paper.

The representative responses to the question as interpreted by the expert group.

Hurdles that may emerge if this outcome was adopted, as identified by members of the user reference group.

Benefits stemming from the implementation of the outcome, as identified by members of the user reference group.

10.1.

Context

Question 2

Item

Question

Outcome

Hurdles

Description

To what extent (if any) do, or should, the elements of the current standard complement other standards, guidelines and programs?

The revised standard must complement other relevant standards, government programs and guidelines.

Agree, but shouldn’t just complement standards, must also complement government standards and frameworks.

Nil Benefits

Additional feedback received on context:

 How should the standard refer to business case development to support implementation given the diversity of approaches in business?

27


 3598 should refer to accuracy levels pertinent to the level of investment so that money is not wasted on unnecessary assessments.





[The standards] should recognise existing legislated programs (i.e. EEO) so that outcomes are broadly aligned (or at the very least not contradictory)

“Professional” may infer must use external auditors.

10.2.

Purpose

Question 3

Item

Question

Outcome

Hurdles

Benefits

Question 4

Description

What do you believe should be the principal objective (or set of objectives) of the standard?

A range of areas were highlighted:



Support scoping and expectation of quality audit outcomes (energy user).



Provide guidance to auditors to deliver effective audits.



Identify and support implementation of energy efficiency opportunities.

Nil

Guidance to get a useful comparison which can drive changes.

Item

Question

Outcome

Hurdles

Benefits

Description

To what extent should the standard focus on improving the skills and practice of energy auditors?

The standard should not focus exclusively on auditors.

Nil

Standard should provide guidance for energy specialists/energy managers and all involved in delivery of a service.

Question 5

Item

Question

Outcome

Description

To what extent should the standard outline requirements of auditor training and address accreditation programs?

The revised standard should be sympathetic to training and accreditation but not provide definitive guidance.

28


Item

Hurdles

Benefits

Description

Nil

[Provides] guidance for energy specialists/energy managers and all involved in delivery of a service.

Question 6

Item

Question

Outcome

Description

Are there any weaknesses in the current standard that are hindering the effective identification and evaluation of opportunities to improve energy performance?

Different stakeholder experiences led to different views of the strengths and weaknesses of the current standard.

Nil

Nil

Hurdles

Benefits

Additional feedback received on the objectives:

 The standard should provide some “indicators” around the skills of an auditor.

10.3.

Scope

Question 7

Item

Question

Outcome

Hurdles

Benefits

Description

What areas of the energy audit process should the standard specifically address?

A range of areas highlighted:



How to perform an audit.



Scope of works and key deliverables.



Requirements for data analysis.



More robust guidelines for business cases and how costs and savings estimated.

Need to recognise existing internal evaluation and tracking processes. Being too prescriptive could make this difficult.

Identify energy savings. It is then up to the company to develop a business case including other benefits e.g. production increase.

3598 should advocate custodians of best-practice standards on-line.

Don’t tie to ISO 50001 too tightly but guide towards ‘EnMS’ development.

29


Question 8

Item

Question

Outcome

Hurdles

Benefits

Description

How should the standard link with other relevant standards and/or frameworks?

The standard should link to ISO50001, take guidance from M&V standards and align with EEO.

“Link” – consistent with; doubling up; recognises; terminology aligned.

Encourage 3598 towards all types of energy and associated utilities i.e. water pumping in tall buildings.

Question 9

Item

Question

Outcome

Hurdles

Benefits

Question 10

Description

Should the standard address energy used in transport applications and materials movement

(e.g. in mining, in port facilities, etc.)?

The standard should address transport.

Nil

Nil

Item

Question

Outcome

Hurdles

Benefits

Description

Should the standard incorporate guidance on measurement and verification? Why?

The standard should address measurement and verification in a manner consistent with international M&V protocols to increase energy users’ confidence in outcomes.

Audit delivers potential savings but may require further measurement before a business case can be made.

M&V standardisation helps deepen trust in advice as best practice.

M&V is crucial to prove the financial value of the CAPEX spend on energy efficiency.

Question 11

Item

Question

Outcome

Hurdles

Description

Should the standard incorporate guidance on performance contracting? Why?

The standard should not address energy performance contracting.

Nil

30


Item

Benefits

Question 12

Description

EPCs should be dealt with specifically outside of 3598.

Item

Question

Outcome

Hurdles

Benefits

Description

Should the standard incorporate guidance on energy efficient design? Why?

The standard should not address energy efficiency at the design stage.

Nil

Design should be covered by EnMS.

Additional feedback received on scope:

 The revision should ensure the standard emphasises the importance of involving local expertise in the audit process... So that relevant and business owned outcomes are produced.

 The standard should give guidance on producing the scope... So that the Energy User can define if business cases will be an outcome of the audit or just recommendations.

 The revision should ensure that the standard is supportive & not contradictory to ISO 50001 and government programs ... So that duplication of effort is not an outcome for business.

10.4.

Target audience

Question 13

Item

Question

Outcome

Hurdles

Benefits

Description

What group or groups (i.e. energy users, energy managers, energy audit providers, training bodies, and government agencies) should comprise the target audience of the standard?

The standard should primarily address energy auditors and energy users and include a bias towards energy auditors.

Address all stakeholders but no bias to auditors.

Nil

31


Question 14

Item

Question

Outcome

Hurdles

Benefits

Question 15

Description

Please explain what part/s of the target audience that you represent. What are your specific information requirements on energy auditing?

A wide range of stakeholders participated in the consultation.

Nil.

Nil

Item

Question

Outcome

Hurdles

Benefits

Description

Do you believe that it is necessary to make a distinction between the needs of large energy users, medium energy users, and small energy users? Why?

The audit standard can accommodate both large and small users.

Nil

Differentiate on size so that resistance to con ducting an ‘audit’ can be overcome.

Allow choice, less prescriptive.

Question 16

Item

Question

Outcome

Hurdles

Benefits

Description

Can the needs of different sized energy users be accommodated by a single standard or is it necessary to find a mechanism for meeting the different needs of small and large businesses?

Do you think modifying the level system provides a potential solution?

Users of different sizes can be accommodated by appropriately designed levels. In particular, an actual audit can be constructed from a collection of elements, each offering a different level of analysis and complexity.

Nil

Range of options. Similar to NABERS Small to Huge. L1, L2, L3, L4.

32


Question 17

Item

Question

Outcome

Hurdles

Benefits

Question 18

Description

What do you consider to be the most appropriate basis for differentiating between the size of different energy users (i.e. employee numbers, annual turnover, annual energy use)?

Users should be differentiated on the basis of energy consumption.

And [also] complexity of energy use.

Nil.

Item

Question

Outcome

Hurdles

Benefits

Description

What is your opinion on the need for ensuring that the standard takes due account of energy users with a partial or fully implemented EnMS?

The revised standard should account for the existence of an EnMS.

Nil

3598 should encourage development of an EnMS.

Additional feedback received on target audience:

 Should provide standard modules that are used to assemble an actual audit so that audits can be tailored to every user.

10.5.

Structure

Question 19

Item

Question

Outcome

Hurdles

Benefits

Question 20

Description

Do you see the value in retaining a generic audit standard – as opposed to developing a suite of standards comprising an umbrella standard and sector specific standards?

Retain a generic standard.

A generic standard may tick the ‘Audit’ box, but does it really deliver true EE savings.

Nil

Item Description

33


Item

Question

Outcome

Hurdles

Benefits

Description

What is your opinion on the need for an outcomes driven standard versus a process driven standard? Some of the options presented in Appendix B adopt both process and outcomes elements? What are your opinions of those options?

Develop an outcomes driven standard, but need detail on elements of good audit practice (i.e. data measurement, analysis, cost and saving estimation).

Nil

[Desired] outcomes.



Understand where/how energy is used.





What does optimum look like?

Business cases evidence based?

Question 21

Item

Question

Outcome

Hurdles

Benefits

Description

What are the benefits of adopting an industry sector focus to guidance on energy audits – as opposed to the adoption of a technology focus? Can you nominate any existing standards/guidelines that could potentially be used to provide sector/technology specific guidance?

The revised standard should include guidelines, and these should focus on technologies ahead of sectors.

Technology based and system based.

How to integrate energy management into business as usual

Outcomes good

Technology based rather than sectors. Sectors can be too generic.

Strongly agree with majority of responses. Keep standard outcome based with process identified in technology based guidelines.

Additional feedback received on structure:

 [Standards] should include technology specific guides ... So that large energy using disciplines are given the level of special analysis required.

 Should use the update to the standard to emphasize that it is only 1 part of an EnMS ... So that it isn’t used as an isolated process.

34


10.6.

Other considerations

Question 22

Item

Question

Outcome

Hurdles

Benefits

Question 23

Description

Should the standard refer to energy audits, energy assessments or energy reviews? Why?

Energy user group supportive of the term ‘energy review’ to be consistent with ISO50001.

‘Audit’ can scare some people and audit indicates a review of the energy number not energy efficiency.

The term ‘audit’ is threatening to most people, while the word ‘review’ may be a bit light.

‘Audit’ confuses people with compliance activities. It should be assessing energy use.

Nil

Item

Question

Outcome

Hurdles

Benefits

Description

What are the specific requirements of the energy efficiency community in respect of guidance on training content and accreditation?

It is not the role of the standard to provide guidance on training and accreditation.

Nil

3598 should not have training or accreditation role.

Emphasise the importance of the partnership between the auditor and the local expertise.

Question 24

Item

Question

Outcome

Hurdles

Benefits

Description

What do you believe should be the priority areas of the standard?

Clear guidance was not provided.

Nil

Nil

35


Next Steps

An Implementation Plan is being developed by the Expert Group which will be used to inform

Standards Australia of the consultation process conducted and the outcomes industry have put forward for consideration. This will be completed September 2011 at which time Standards Australia will be engaged.

Once formally engaged, Standards Australia will manage the process of revising the Energy Audit

Standard AS/NZS3598. The process for revising and updating the standard is:



Formation of the technical committee



Drafting of the standard



Draft for public comment



Consideration of comment



Draft for postal ballot



The published standard.

For more information on the standards process, please refer to the Standards Australia website at: http://www.standards.org.au/DevelopingStandards/Developmentphases.aspx

Updates regarding the process of revising the standard will be provided on the Department of

Resources, Energy & Tourism website when available.

For more information regarding this consultation process, please email the Department of Resources,

Energy & Tourism at energyauditstandard@ret.gov.au.

36


Appendix 1

Written Submissions

Written submissions were received from the following organisations and individuals:

 Integrated Energy Services Corporation Pty Ltd (EnSight)

 Sustainable Business





















Ecofund

Energy Conservation Systems Pty Ltd

Don Lewis (EECA)

EECA

Clyde Anderson Pty Ltd

The Property Council of Australia

The Energy Efficiency Council

Mildura Development Corporation

Rio Tinto Ltd

Schneider Electric

One confidential submission was also received.

Consultation Workshop Attendees

Name

Kyle Joustra

Rob Clinch

Matt Power

Gilbert McLean

Keith Allilomdy

Christina Larkin

Rod Boyle

Giovanni Barbieri

George Li

Paul Lang

Organisation

Versalux P/L

Arup P/L

St Vincent’s Health Aust

Compair (Gardener Denver) Ltd

Fulton Hogan

National Australia Bank

Smart Power Utilities

Jott Engineering

Jott Engineering

Coles

37


Name

Sue Lacey

Dennis Fantin

Kamaljit Singh

Nitin Joklekar

Brad Magee

John Strozycki

Tony Tefarcar

Ravi Singh

George Charakos

Jack Fanning

Caroline Harris

Dan Coffey

David Cogan

Dean Johnston

Ellen Blake

Frans Plugge

Justin Angell

Mike Janus

Peter Prichard

Rob Bishop

Rod Treder

Daniel Jessop

Daniel Roos

Dave Taylor

Jeff Smit

Jonathan Pooch

Kees Brinkman

Brian Guthrie

Organisation

Rio Tinto

Origin

LaTrobe University

Beca Pty Ltd

UGL services

Enman P/L

Parsons Brinckerhoff

Schneider Electric

Melbourne Water

Net Balance caroline.harris@med.govt.nz

dan.coffey@eeca.govt.nz

dean.johnston@spotless.co.nz

ellen.blake@dia.govt.nz

FRANS@eco.co.nz

justin.angell@dia.govt.nz

mike.janus@meridianenergy.co.nz

peter.prichard@med.govt.nz

rob@energysolutions.co.nz

rod.treder@eeca.govt.nz

Daniel.Jessop@emsol.co.nz

daniel.roos@alpineenergy.co.nz

davidt@enercon.co.nz

JSmit@transfieldworley.co.nz

jonathanp@enercon.co.nz

keesb@enercon.co.nz

brian.guthrie@honeywell.com

38


Name

Chris Hopper

Don Lewis

Edgar Ludwig

Ivan Fraser

Jeremy Allen

Martin Lynch

Noel Mason

Scott Noyes

Siegfried Zoellner

Trevor Murray

Paul Antonelli

Ray Anderson

Noel Munkman

Simon English

Martin White

Stephen Bower

Chris White

Haydee Foster

Kurt Whalan

Greg Chaplin

Clyde Anderson

Glen Eales

Deepa Punnoose

Chris Tiemann

Fiona Hubczenko

Chris Rogerson

John Grasso

Ian Zappala

Organisation chrishopper@technoform-anz.com

Don.Lewis@eeca.govt.nz

e.ludwig@xtra.co.nz ivan.fraser@watchdog.net.nz

martin.lynch@farmside.co.nz

nemason@xtra.co.nz

siegfried.zoellner@eastharbour.co.nz

trevor.murray@0800saveenergy.co.nz

Energy Sales

Ergon Energy

EG

– 02 Training Standards

Honeywell

Arnott’s

Aurecon

Aurecon

JJ Richards and Sons P/L

JJ Richards and Sons P/L

Bradken

Clyde Anderson P/L

Envirolan / JJ Richards and Sons P/L

Origin Energy

Newcrest Mining

Newcrest Mining

Smartcool

Energy rating Consulting

Energy rating Consulting

39

John Quinn

Michael Terry

Mark Rutter

Veronica Mauri

Gabrielle Sartori

Jodi Dean

David Robertson

Clare Ryall

Beatriz Palazzi

Gail Giodensi

Karen Boyce

Tony Lorite

Sean Parker

Russel Slaughter

Gabby Pracilio

Peter Murphy

Brandan HIrniak

Dominic Da Cruz

Dan Gardiner

Eric Hill

Goldfields Ltd

David GOodfield

Scott Talbot

Chiara Pacific

Jeff Waddinston


Name

Peter Hope

Ed Schmidt

Helen McCarthy

Sandra O’Sullivan

Gordon Sidhu

Angela Scezpanski

Organisation

Building Service Authority

BECA Consultants

Ecofund Queensland

Ecofund Queensland

Colliers international

Electrical and Communications

Association

Queensland Government (DERM)

Ergon Energy

EE – 02

Electrical and Communications

Association

Tarong energy Corporation

Yancoal Australia

Greenbase

Greenbase

Worsley Aluminium

Worsley Aluminium

Tiwest Joint Venture

The Laminex Group

Rio Tinto Iron Ore

Preston Consulting

CITIC Pacific Mining

Shelwood Engineering

BGC Australia

Enigin Western Australia

Enigin Western Australia

Murdoch Uni

Xstrata Nickel Australasia

Curtin University

St Barbera Limited

40


Name

Angela Nathan

Gerry Magee

Lorraine Stivey

Timothy Edwards

Julian Fairhall

Andrew Fairs

Greg Bell

Andrew Ormcos

Andre Kriegler

Alex Sejournee

Organisation

Office of Energy

Energy Corporate

Polytechnic West

Metro Power Company

Office of Energy

Office of Energy

Water Corporation

Synergy

Synergy

HFM Asset Management

Participants of the Energy User Reference Group

Name

Karen Boyce

Dean Michele

Sue Lacey

Jonathan Woodbridge Buys

Bruce Precious

Paul Lang

Organisation

Tiwest Joint Venture.

Bosch.

Rio Tinto.

SkyCity Auckland.

The GBT Group

Coles

41

Review of Energy Audit Standard

Department of Resources, Energy and

Tourism

Revision of AS/NZS3598 Energy

Audits

Consultation Report

Project Details

About Energetics

About UNSW

About Rare Consulting

Executive Summary

Stakeholder consultation

User reference group consultation

Next Steps

Table of Contents

Introduction

1.

Background

2.

The consultation process

3.

About this report

Summary of the consultation forums

4.

Situational context

<= "Stand alone"

Q2 Responses by Quartile

"Complement other standards" =>

5.

Purpose of the standard

Q3 Responses by Objective

Q4 Responses by Quartile

<= "Exclusively auditors" "All users equally" =>

<= "Referred to"

Q5 Responses by Quartile

"Separate consideration" =>

Q6 Responses

6.

Scope of consideration

Q9 Responses

Q10 Responses

Q11 Responses

Q12 Responses

7.

Target audience

Q15 Responses

8.

Structure

Q19 Responses

9.

Other considerations

Q22 Responses

User reference group review

10.

Review of the stakeholder consultation outcomes

10.1.

Context

10.2.

Purpose

10.3.

Scope

10.4.

Target audience

10.5.

Structure

10.6.

Other considerations

Next Steps

Appendix 1

Written Submissions

Consultation Workshop Attendees

Participants of the Energy User Reference Group

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