EEO Desktop Verification

Implementation & Outcomes

Presented by: Ben Roberts, EEO Verification ManagerAustralian Sugar Milling Council, Brisbane14 February 2011

PRESENTATION CONTENT

• Objectives

• Scope

• Process

• Outcomes

• What does risk look like

• Assess the RISK of NON COMPLIANCE in order to identify companies for full verification

• Identify potential compliance related weaknesses and develop / deliver capacity building activities to assist compliance

• Provide data relating to program compliance

• Provide re-assurance to companies

OBJECTIVES

• Undertaken by the Department

• Involves approx. 100-120 companies annually

• Representative across sectors and energy users

SCOPE

PROCESS (1)

• Department makes initial contact- Phone/email/letter

• Company completes and submits

‘Verification Checklist and Information Request’ Smartform

- Available on DRET website

• Department reviews submitted Smartform

• Makes preliminary assessment (risk score)

& may request sample documents

PROCESS (2)

• Company submits requested documentation

• Department revises risk assessment (score)

- Takes account of documentation contents

(Does it add to or confirm the story?)

• All Companies compiled and ranked

- Highest to lowest risk scores/ratings

• Company is notified of outcome

- Telephone/letter

OUTCOMES

• Risk Score & Rating

- High

(prioritised for full verification)

- Medium

(may be fully verified - priority/random)

- Low

(may be fully verified – random selection)

• Sectoral trends for capacity building

• Individual needs for capacity building

WHAT DOES RISK LOOK LIKE (Smartform Examples)

• Low risk- Detailed descriptions of Key Requirement processes &

systems that align with Assessment Framework- A clear picture can be gained by the verifier- Timeliness and accuracy of reports

• High risk- Descriptions of Key Requirements lack detail- Ambiguous – do not align with Assessment Framework- Poor timeliness and inaccuracy of reports- NIL RETURN

QUESTIONS / QUERIES / QUANDARIES

FURTHER INFORMATION

• EEO Verification Manual

• EEO website: www.energyefficiencyopportunities.gov.au

• EEO email: energyefficiencyopportunities@ret.gov.au

• EEO Hotline: 1300 799 186

• Contact: Your Sectoral CLO (Emma Punyer) Manager – Verification

Manager – EEO Compliance & Reporting

HAVE A STRETCH

REST YOUR MIND

EEO Full Verification

Implementation & Outcomes

Presented by: Ben Roberts, EEO Verification ManagerAustralian Sugar Milling Council, Brisbane14 February 2011

PRESENTATION CONTENT

• Objectives

• Scope

• Process

• Outcomes

PURPOSE

Validate companies compliance with EEO legislation in conducting energy assessments, identifying opportunities and reporting outcomes

OBJECTIVES (1)

• Confirm whether companies comply with EEO legislation, specifically the Assessment F’work (Schedule 7 of EEO Regulations 2006)

• Confirm that information within reports is true, accurate and reliable

• Monitor whether a company has carried out scheduled assessments as per ARS

• Identify potential compliance related weaknesses and provide recommendations to achieve compliance

• Provide data relating to program compliance

• Establish a pathway (action plan) to compliance

• Provide re-assurance to companies

OBJECTIVES (2)

SCOPE

• Sample to be selected from preceding period

desktop verification results

• Approx. 75% risk based / 25% random selection

• Aim for representation across sectors & energy use

• 1 – 2 day on site (may vary)

• Undertaken by Departmental lead verification team

(lead & support verifier, external energy expert)

OVER TIME, ALL COMPANIES WILL BE FULLY VERIFIED

PROCESS: PRE-VERIFICATION

• Department makes initial contact to set date

- Phone/email/letter

• Company revises/prepares/updates ‘Verification

Checklist’

• Logistics planned/organised (company & VTL)

• Pre-verification teleconference (about 2 weeks out)

PROCESS – DURING VERIFICATION

• Full verification undertaken

- Occurs on-site

- Involves key staff involved in energy mgmt

- Review docs to demonstrate compliance

- Discussion and explanation

- Site tour (wherever possible)

PROCESS: POST VERIFICATION (1)

• Department analyses information & prepares draft report

• Follow up consultation/clarification with company (if required)

• Provide draft to company for comment/correction

• Company commences Action Plan development

• Company provides corporation comment

PROCESS: POST VERIFICATION (2)

• Department prepares final draft for comment (where corrections have been made)

• Department gains internal approval of report

• Departmental delegate sends report to CEO/MD

• Acknowledgement of receipt from CEO/MD

• Company implements Action Plan

(may include assistance from/monitoring by CLO)

• Department re-verifies non compliant elements (subject to Action Plan but usually within 12mths)

EXAMPLES OF APPLICATION

• For example in verifying KR 3.2: “A data collection

process is identified, documented and implemented …”

- Will listen to explanations of the process

- Will look at documentation of the process

- Will look at the systems that implement the process

- Will look at examples of the data that is collected, and the data

that is output

• To verify that a compliant data collection process

has been identified, documented and

implemented

COMPLIANCE RATINGS

• Leading Practice

• Complies in all material aspects

• Complies but observed risk of future non-compliance

• Non-compliance – minor discrepancies

• Non-compliance – significant discrepancies or failure to meet key requirements

• Insufficient information

VERIFICATION OF MULTIPLE SITES

• Multiple site companies include those having: - Multiple business groups and/or activities - Complex company structures - In excess of 5 sites registered for assessment as per

ARS

• Sites will be selected by the Department in consultation with the corporation to take account of OH&S etc.

• Company preferred sites - considered BUT not guaranteed

• An intensive whole of business corporate verification will precede site verifications

HOW CAN YOU ASSIST THE VERIFICATION PROCESS?

• Pre-verification- Update the ‘Verification Checklist and Information Request’

Smartform if required- Contribute to planning the verification – agenda, people, docs,

sites- Seek & gain necessary approvals for consensual participation

• During verification and site visit- Have documents and people ready & available- Logical & sequential for each of 6 Key Elements- Three levels of explanation / inquiry

: Company (strategic and general) - CONTEXT: Procedural (process, system, procedure) - HOW: Implementation (proof by example, detail) - WHAT

• Post site visit (preparing & finalising the report)

- Expect follow up queries and/or evidence requests

- Provide comment/feedback when requested

- Prepare an Action Plan to address non compliances

- Brief your senior management – they will get the report

- Acknowledge receipt of report

HOW CAN YOU ASSIST THE VERIFICATION PROCESS?

QUESTIONS / QUERIES / QUANDARIES

FURTHER INFORMATION

• EEO Verification Manual

• EEO website: www.energyefficiencyopportunities.gov.au

• EEO email: energyefficiencyopportunities@ret.gov.au

• EEO Hotline: 1300 799 186

• Contact: Your sectoral CLO (Emma Punyer) Manager – Verification

Manager – EEO Compliance & Reporting

Thank you

EEO VerificationBackground and context

Presented by: Ben Roberts, EEO Verification ManagerAustralian Sugar Milling Council, Brisbane14 February 2011

PRESENTATION CONTENT

• Verification – what, why & legalities • Desktop verification – general background• Full verification – general background• Initial findings from completed verifications

VERIFICATION – WHAT IS IT?

Validation & monitoring of company compliance with

EEO legislation

• Aims to confirm that:- Companies comply with EEO legislation,

specifically the Assessment Framework (Sched 7 of EEO Regs 2006)

- Information within reports is true and accurate

- A company has carried out scheduled assessments

MORE SPECIFICALLY……..

• That corporations have undertaken rigorous and comprehensive assessments to identify energy efficiency opportunities with up to a four year payback

• That the company has complied with Part 6 of the EEO Regulations 2006 and that results have been reported accurately

LEGAL REQUIREMENTS – OBJECT OF EEO ACT

• Pg 1 – Energy Efficiency Opportunities Act 2006- “…improve the identification & evaluation of energy efficient opportunities by large energy using businesses and…encourage implementation of cost effective eeo’s”

- “…the Act requires…a) undertake an assessment of eeo’s to a minimum standard …in order to improve the way in which eeo’s are identified and evaluated; andb) report publicly on the outcomes of the assessment to demonstrate…that businesses are effectively managing their energy.”

LEGAL REQUIREMENTS - VERIFICATION

• Verification of company compliance is covered by:

Energy Efficiency Opportunities Act 2006- Part 8 – Powers of Inspection- Part 8 (Division 3) – Powers of authorised officer – Subdivision A – Monitoring Powers – Section 27“Authorised officer may enter premises by consent or under monitoring warrant”

Energy Efficiency Opportunities Regulations 2006- Part 9 – Miscellaneous – Division 1 – Verification of compliance with the EEO program“A controlling corporation must:a) Make and keep records of its compliance with these Regs and the Act for at least 7 years; andb) Make its records available for inspection in accordance with Part 8 of the Act”

• Assess the RISK of NON COMPLIANCE in order to identify companies for full verification

• Identify potential compliance related weaknesses and develop / deliver capacity building activities to assist compliance

• Provide data relating to program compliance

• Provide re-assurance to companies

DESKTOP VERIFICATION

INITIAL RESULTS – DESKTOP VERIFICATION

• Undertaken October – December 2010• 79/80 companies submitted responses• All sectors (except Sugar)• Approximately half registered energy use• High Risk: 15• Medium Risk: 33• Low Risk: 32

FULL VERIFICATION & SITE VISITS

• A full and detailed analysis of a corporations

systems and processes to determine whether

compliance with EEO legislation has been

achieved.

• Combines explanation with documentary proof

• Combines evidence at strategic, procedural and

implementation levels

VERIFICATION – INITIAL OBSERVATIONS

• Key Element 1: Leadership - Visibility of commitment of leadership is variable- Lack of clearly communicated energy use improvement objectives - Specific EEO resources are variable – usually incorporated

• Key Element 2: People - Support provided by engineers & other technical staff- Broad cross section of people/expertise used – interconnection variable

• Key Element 3: Data collection & Analysis

- Few specific procedures documented – compliance risk (and also risks for succession/consistency)- Variable data collection methods with varying reliability- Variable methods in use of data – EMB’s, energy-material flows- Flow charts of procedures, background papers often lacking

VERIFICATION – INITIAL OBSERVATIONS

• Key Element 4: Opportunity ID & evaluation- Often lack documentation of process- Some confusion of opportunities vs ideas & how to differentiate- Reasons for not pursuing opportunities not formally documented

• Key Element 5: Decision making- Major decisions through CAPEX process – documentation variable- Energy projects compete with other priorities/projects - Not a specific budget item – usually must have ancillary benefits- Decisions made at varying mgt levels, including Board- Systematised/ process based feedback often lacking

• Key Element 6: Communicating outcomes

- Board involvement & context in which energy is presented is variable- Can be operational / productivity based or energy specific- Clear messages variable in what is presented - assessment outcomes - Engagement: very inclusive (culture change) / compliance / informal

QUESTIONS / QUERIES / QUANDARIES

FURTHER INFORMATION

• EEO Verification Manual

• EEO website: www.energyefficiencyopportunities.gov.au

• EEO email: energyefficiencyopportunities@ret.gov.au

• EEO Hotline: 1300 799 186

• Contact: Your Sectoral CLO (Emma Punyer) Manager – Verification

Manager – EEO Compliance & Reporting

HAVE A STRETCH

REST YOUR MIND