Managing the 30 June 2020 deadline to register 2019 ESCs (including information on COVID-19)

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By 30 June of every year, all energy savings certificates (ESCs) representing energy savings that occurred in the previous calendar year must be registered in the ESS Registry. This means that ESCs for energy saving activities in 2019 (2019 ESCs) must be registered by Tuesday 30 June 2020. This is a statutory deadline under section 131(3) of the Electricity Supply Act 1995 and the Scheme Administrator has no discretion to extend or waive this deadline.

This ESS Update sets out the actions that you should be doing now to manage your 2019 ESC registration before the 30 June 2020 deadline.  It also provides information on audits.  This follows our ESS Update email sent on 19 February 2020.

Information on special arrangements due to COVID-19

In line with the advice from the Commonwealth and NSW Chief Medical Officers, IPART has moved to remote working wherever possible to reduce the risks of infection and help slow the spread of COVID-19. While we have had no confirmed cases of COVID-19 Coronavirus, we have decided it's in our staff's and the community's best interests that we stay away from our office. More information on IPART’s response to COVID-19 can be found here.

It is our intention to keep the processes running that you need to do your business. Our staff have access to systems that allow for the effective administration of the ESS. As with any transition of this kind, there may be some technical challenges that we will need to resolve along the way, so please let us know if you are having difficulties using our systems, submitting a request or getting in contact with us.

The best way to get in contact with us at this time is to email ess@ipart.nsw.gov.au

We understand that the COVID-19 pandemic may present additional challenges to ACPs

We understand that there may be additional challenges meeting the statutory deadline for ESC registration this year. While our general expectation is that ACPs meet our established standards and processes for audit and registration of ESCs, we will work with ACPs and auditors to explore options where special challenges arise such as restricted access to physical sites.

We are closely monitoring ESC creation and audits so that we can be agile in responding to any practical challenges that may arise due to the COVID-19 situation. We will continue to provide advice to ACPs and auditors as the situation develops.

You should be implementing your plan

You should already have:

  1. Reviewed your 2019 energy saving activities to determine if you need to register 2019 ESCs.
  2. Reviewed your ESC registration limits and audit requirements to determine if you need to arrange audits and/or request an amendment to your conditions of accreditation (see next section). 
  3. Reviewed the other conditions in your Accreditation Notice and the requirements of the calculation method to determine any other actions that may be needed (eg, making applications for acceptance of lighting products).
  4. Prepared your plan for audits and registration of 2019 ESCs, allowing ample time for these to be completed (see sections below) and also allow additional time to account for unexpected delays such as disruptions caused by COVID-19.  Remember, if you are conducting pre-registration audits, the audits need to be completed before you can register ESCs.  Likewise, amendment requests must be approved before you can register additional ESCs. 

What you need to be doing now

You should now be:

  1. Conducting your audits of 2019 ESCs, or arranging for them to be started now or as soon as possible.  This may be a pre-registration audit or a volumetric audit – or both.
  2. If relevant, submitting any applications for amendment to your conditions of accreditation to increase your volumetric audit limit. For information and guidance about our typical approach for increasing volumetric audit limits, see Section 4.2.1 and Figure 4.1 of the ACP Compliance Guide.  

Timeframes for audits and amendments

It typically takes around two months for audits to be completed – from the submission of the Detailed Scope of Works to the audit completion – assuming there are no complex issues to be resolved.  This is a busy time of year for auditors due to the high demand for audits – so it may take longer for audits to be completed as 30 June approaches.  The key message is to initiate your audits as early as possible.

We understand that auditors may face special challenges due to COVID-19 such as not being able to access sites where energy savings activities have occurred. We will work with auditors to indentify flexible approaches to establishing reasonable assurance where thes challenges arise. 

Please allow additional time to account for unexpected delays such as disruptions caused by COVID-19.

It typically takes us around five weeks to process an application for amendment to increase volumetric audit limits – as with audits this may take longer if we identify unexpected issues. Approval of applications is not guaranteed and you may need to arrange for a pre-registration audit of your ESCs if your request is not granted.  As with audits, submit your application as early as possible.   

Information on audits

We have received a number of inquiries from auditors about how to manage Tier 3 audits given the evolving COVID-19 situation. The below information is intended to provide additional guidance to assist auditors in navigating challenges that may arise.

Tier 3 evidence and impact of COVID-19 on ESS activity

In general Tier 3 checks have involved site visits. We are aware that auditors may be currently facing restrictions on entering some sites. In other instances it may not be safe to do so. No auditor is required to enter a site where it is not safe to do so and we encourage auditors to follow public health advisories.

The reasonable assurance standard still applies

Reasonable assurance still applies. That is, audit opinions are not altered as a consequence of constraints in presenting evidence. You may find alternatives to site visits such as having an authorised person stream video or customer interviews by phone or video links.  IPART does not intend to prescribe procedures for how auditors may arrive at assurance but will be open to considering flexible approaches to achieving assurance.  We ask that auditors document the way in which they have arrived at a reasonable assurance opinion in their audit report.

Where assurance cannot be given

As per usual, ACPs will have the opportunity to make submissions to the Scheme Administrator, after audit close out, as to whether they should forfeit ESCs over which assurance is not provided. 

Other information

Our website provides information about:

The ESS Registry provides information about your ESC registrations and the number of certificates available for registration before you reach your limit. 

To find out how many ESCs you can register before you reach your limit:

  1. Select “Current Holdings”
  1. Select “My Holdings: Summary of ESS Certificates I have created”
  2. Select “Date range”
  3. Select “View Accreditation or Select View project and then View project again”

The remaining number of certificates that you can register before you reach your limit will be shown as “Certificates Allowable for Registration”. 

If you have any questions, please contact us at ess@ipart.nsw.gov.au