Robust public commitment: Get your ESOS Action Plan ready
Under ESOS Phase 3, organisations captured by ESOS now need to submit an ESOS Action Plan stating what energy savings they intend to make over the next four years. While there is no requirement to make any savings at all, organisations are asked to submit a progress report each year. Both the Action Plan and the Progress Reports are expected to be signed off by senior management and available to the public, so internal alignment and commitment are crucial.
Key time frames and updates
The deadline for submitting ESOS Action Plans is 5 December 2024; organisations are advised to meet this deadline wherever possible. However, in recognition of the delays in delivering the MESOS platform, recently the Environment Agency announced a grace period whereby Action Plans will be accepted up to 5 March 2025.
The broad requirements for the Action Plan are already set out in legislation and ESOS guidance. However, the details, including what needs to be submitted to the online system, are not yet available. These are expected by the beginning of November, and we’ll be in touch with our clients as soon as new information is released.
Key actions to consider
For organisations planning to submit an Action Plan, now is the time to consider the wider implications of publicly committing to energy savings.
Organisations will typically need a data system to track multiple energy-saving interventions from idea through to delivery, so it’s worth factoring these into your budgets for the new year. A process is required to understand which stage each measure is at, and whether it is likely to be implemented. It would be wise to screen ideas for practical feasibility (and alignment with other strategic objectives) before approving targets for publication.
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Organisations will also need to integrate the savings commitment into their wider business processes. This may require revisions to budget and CAPEX decision processes, data management plans, metering arrangements, and operating procedures. In addition, suitable governance arrangements and staff training will be required to ensure that measures are implemented in time, the resulting savings are documented and the action plan remains on track.
Overall, although the compliance requirement itself may be light touch, when viewed as a prompt to establish a robust energy management system it can be a powerful agent of change. Such a system will bring significant benefits to organisations who are aiming to align their operations with corporate net-zero carbon targets or ambitions, and to track progress year-by-year.
If you need advice on incorporating action-planning into your business operations ahead of the compliance date, please get in touch.