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COLUMN Energy efficiency as a fuel to compete with electricity generators All EU-28 countries are legally obliged to achieve a certain amount of final energy savings by 2020 Energy efficiency which is regarded as a “fuel” by many countries has not been openly embraced by utilities. While ensuring energy supply security is imperative and discussions for nuclear is underway within the different stakeholders, the author wishes to present an alternative which could be as financially attractive. Utilities have the potential to engage with their customers to drive energy efficiency. Whilst information campaigns, the provision of free energy audits, or similar have often been undertaken by the government of Malaysia, such “soft” activities have had negligible impact on overall energy consumption. While the utilities have taken steps to engage with the public to encourage energy efficient behaviour, utilities have only been shown to be capable of either delivering or fostering large scale energy conservation in the case of capacity constraints (such as in Japan post-Fukushima) or where there is strong regulation and incentive to do so. A Utility Energy Efficiency Obligation (UEEO), also known as a white certificate scheme, is a regulatory method of financing energy efficiency upgrades and driving large investment in energy efficiency that utilities can, if they so choose, use to decouple their income from the sale of energy. This is an emerging form of policy, used in Australia, the US, Europe and Brazil. This is an ideal regulatory intervention which does not require the creation of a new act. Enabling such a scheme would likely require an amendment to the Electricity Supply Act, or alternatively a new Act. UEEOs are used by several European countries (eg Italy, France, Demark, the UK, Poland), roughly half of the states in the United States, in four Australian states, in China and in Brazil. The European Union Energy Efficiency Directive (2012) mandates that all EU-28 countries are legally obliged to achieve a certain amount of final energy savings by 2020. A range of mechanisms By Kevin Hor (Project Manager and Component 3 Consultant) kevin.hor@jkr. gov.my Figure 1: Deeming savings brings forward actual savings, Figure 2 - Example of on-bill financing applied to purchase of a high efficiency air conditioner are required, one of which is the obligation to use energy efficiency obligation schemes or other targeted policy measure.1 UEEO places an obligation on energy utilities to save energy, with a fixed amount of “negawatts” or negative watts to be generated each year. This obligation is placed on the utility to purchase the “negawatts” from a purpose created “Energy Efficiency Generator (EEG)” as has been done in the USA state of Vermont. UEEOs are operationalized through deemed forward savings method where essentially the benefits are paid for before they are realised. This creates an adverse initial cash flow, with a high upfront initial investment required to realise the savings. For example if across all measures implemented in a UEEO scheme the average deeming period is 10 years, an amount equal to the cumulative savings over ten years has to be paid for up front as shown in Figure 1. A long term guarantee purchase contract has to be provided to the EEG to allow the EEG the security to raise funds required to generate annual target for energy savings, effectively generating “negawatts.” This competes 38 november-december, green+.2014
COLUMN with the conventional generation business model where instead of paying for generation it is possible to be cheaper to produce “negawatts” and removes the split incentive for a utility that also wants to maximise its sales of generated electricity. Since no tariff charge will be required to fund the obligation, there will likely be a loss of revenue scenario to the utility. To offset the loss in revenue, utilities can recoup through embracing a new business model of on-bill financing of energy efficiency. This then shifts the obligation partially to the beneficiaries. UEEOs have arisen because essentially most energy users are unwilling to invest in EE. UEEOs essentially subsidise the cost of EE, reducing paybacks down to a level where ordinary energy users are willing to invest some of their own money in a more efficient product or improving the efficiency of their existing buildings. Similar to building generation capacity, achieving large energy savings requires large investment, which the private sector is generally unwilling to make unless substantial incentives exist. A UEEO is an effective way of financing and creating these incentives. UEEOs are a relatively complex instrument and are significantly more complex to administer than the Feed in Tariff as already exists in Malaysia. Without effective administration, measurement, verification, evaluation and enforcement a UEEO is unlikely to be effective. Strong commitment across all political divides is required to develop a sustained, long term UEEO. What sort of activities are undertaken to generate savings from UEEOs? Savings can be generated from either “standard measures” where the savings are deemed (i.e. estimated) or “project measures” which require measurement and verification of the savings achieved. Some examples of activities include: + Efficient Water heating + Efficient Heating and cooling + Weather proofing and insulation + Efficient Lighting Figure 3 - The electricity market with an EEG-on-bill. + Standby power controllers + Efficient appliances, such as televisions, refrigerators, clothes dryers + Efficient Pool pumps + Efficient refrigerated display cabinets + Efficiency refrigerator fans + Efficient motors + Metered baseline for commercial and industrial (any activity can be implemented, providing savings can be measured) With on-bill financing each beneficiary of the reduced upfront cost of an EE measure pays for the financing provided through an additional charge on their electricity bills. There is no need for tradeable certificates or a marketplace. Example in Figure 2 shows how this would work for the purchase of a 5 star air conditioner. Such a scheme: + Has a set of regulator approved standard measures for EE fixtures. For example an air-conditioner, insulation installed in a roof cavity, installed light fitting are all fixtures. A domestic refrigerator is not a fixture. + Has regulator approved standard calculations for determining the amount of financing that can be provided and the payback period. + Attaches the on-bill payment to the electricity meter number. So that is, irrespective of whether a property is sold or changes tenants, a payment is still made, for a fixed number of payment periods. + The payment could normally be expected to be less than the savings arising from EE. As shown in Figure 3 below, the utility company is not required to pay the EE generator any more than what it collects form the on-bill payments and potentially generate income to supplement the revenue loss from the on bill financing business model. Whilst it may lose some revenue due to decreased sales of electricity, its electricity purchases from generators will also drop. Enabling Legislation Possible ways of creating the enabling legislation are: + Incorporate it into the Electricity Supply Act (as has been done in NSW, Australia) + Create a separate Act (as has been done in Victoria, Australia) + Links to both these pieces of legislation are included at the end of this document. If changes were to be made in the Electricity Supply Act a new part VB could be incorporated into the Act. Alternatively it could be incorporated in Part VA – Efficient use of electricity – although a UEEO is substantially different to Part VA, and for the purposes of clarity it would be better to have it has an entirely new part. Synergy with other policies, regulations and thrusts A UEEO has substantial synergy with other proposed measures mentioned in the National Energy Efficiency Action Plan. It complements MEPS, and the expansion of MEPS. It can be used to incentivise improved whole of building performance. It can be used to drive electricity savings in both the building and industrial sector, and create significant employment opportunities in energy efficiency. A UEEO has synergies with a range of other policies and regulations: + Labelling and MEPS. A UEEO can use MEPS to allow certificates for the purchase of 5 star appliances. This leverages the labelling system + An energy efficiency rating tool for buildings. Improvements in performance based on the rating tool could be used to award certificates. + A national EE energy consumption database. This adds value to a UEEO by facilitating measurement and verification of savings. For example, if a lighting upgrade was undertaken and certificates claimed under a UEEO for the upgrade, the actual drop in electricity consumption at the site where the upgrade was undertaken could be identified from a national energy consumption date based. With appropriate database design, this could be used to tune the methods used to calculate savings. + Building energy performance standards. Certificates could be used to incentivise performance that was measured to be better than the standard. + Energy savings at large facilities (i.e. those facilities subject to the Efficient Manager of Electrical Energy regulations) – based on reductions in energy use certificates could be generated. + Promotion of ESCOs. ESCOs could create certificates from a range of activities + Enabling of mortgages for EE in housing. The deeming methodologies used under the scheme could be used as the basis by which financial institutions can calculate the amount they can lend for different EE features (such as high efficiency air conditioning). + Need to allocate resources to analysing the data and fine tuning policies. green+.2014, november-december 39
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COLUMN<br />
Energy efficiency as a<br />
fuel to compete with<br />
electricity generators<br />
All EU-28 countries are legally obliged to achieve a certain amount<br />
of final energy savings by 2020<br />
Energy efficiency which<br />
is regarded as a “fuel” by<br />
many countries has not been<br />
openly embraced by utilities.<br />
While ensuring energy<br />
supply security is imperative <strong>and</strong> discussions<br />
for nuclear is underway within<br />
the different stakeholders, the author<br />
wishes to present an alternative which<br />
could be as financially attractive.<br />
Utilities have the potential to<br />
engage with their customers to drive<br />
energy efficiency. Whilst information<br />
campaigns, the provision of free<br />
energy audits, or similar have often<br />
been undertaken by the government<br />
of Malaysia, such “soft” activities have<br />
had negligible impact on overall energy<br />
consumption. While the utilities have<br />
taken steps to engage with the public to<br />
encourage energy efficient behaviour,<br />
utilities have only been shown to be<br />
capable of either delivering or fostering<br />
large scale energy conservation in the<br />
case of capacity constraints (such as in<br />
Japan post-Fukushima) or where there<br />
is strong regulation <strong>and</strong> incentive to do<br />
so.<br />
A Utility Energy Efficiency Obligation<br />
(UEEO), also known as a white certificate<br />
scheme, is a regulatory method of<br />
financing energy efficiency upgrades<br />
<strong>and</strong> driving large investment in<br />
energy efficiency that utilities can, if<br />
they so choose, use to decouple their<br />
income from the sale of energy. This<br />
is an emerging form of policy, used in<br />
Australia, the US, Europe <strong>and</strong> Brazil.<br />
This is an ideal regulatory intervention<br />
which does not require the creation of a<br />
new act. Enabling such a scheme would<br />
likely require an amendment to the<br />
Electricity Supply Act, or alternatively<br />
a new Act.<br />
UEEOs are used by several European<br />
countries (eg Italy, France, Demark, the<br />
UK, Pol<strong>and</strong>), roughly half of the states<br />
in the United States, in four Australian<br />
states, in China <strong>and</strong> in Brazil. The<br />
European Union Energy Efficiency<br />
Directive (2012) m<strong>and</strong>ates that all EU-28<br />
countries are legally obliged to achieve<br />
a certain amount of final energy savings<br />
by 2020. A range of mechanisms<br />
By Kevin<br />
Hor<br />
(Project<br />
Manager <strong>and</strong><br />
Component 3<br />
Consultant)<br />
kevin.hor@jkr.<br />
gov.my<br />
Figure 1: Deeming savings brings forward actual savings,<br />
Figure 2 - Example of on-bill financing applied to purchase<br />
of a high efficiency air conditioner<br />
are required, one of which is the<br />
obligation to use energy efficiency obligation<br />
schemes or other targeted policy<br />
measure.1<br />
UEEO places an obligation on energy<br />
utilities to save energy, with a fixed<br />
amount of “negawatts” or negative<br />
watts to be generated each year. This<br />
obligation is placed on the utility to purchase<br />
the “negawatts” from a purpose<br />
created “Energy Efficiency Generator<br />
(EEG)” as has been done in the USA<br />
state of Vermont.<br />
UEEOs are operationalized through<br />
deemed forward savings method<br />
where essentially the benefits are paid<br />
for before they are realised. This creates<br />
an adverse initial cash flow, with a<br />
high upfront initial investment required<br />
to realise the savings. For example if<br />
across all measures implemented in<br />
a UEEO scheme the average deeming<br />
period is 10 years, an amount equal to<br />
the cumulative savings over ten years<br />
has to be paid for up front as shown in<br />
Figure 1.<br />
A long term guarantee purchase<br />
contract has to be provided to the EEG<br />
to allow the EEG the security to raise<br />
funds required to generate annual<br />
target for energy savings, effectively<br />
generating “negawatts.” This competes<br />
38<br />
november-december, green+.2014