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ESOS and Independent schools

May 31, 2017

You may not have heard about ESOS – the Energy saving opportunity scheme.  This was the UK’s way of meeting the EU Directive on Energy-efficiency.  Phase 1 finished December 2015, phase 2 is due by December 2019.

The primary purpose of the legislation was to encourage energy-savings, which in turn reduces CO2 emissions and often provide knock-on benefits such as reduced down-time, consumable items (such as food, paper or water), and emissions to land, water or air.



UK organisations were obliged to participate in ESOS if they qualified as a “large undertaking”, i.e.:

  • employed 250 or more people , and/or
  • had an annual turnover > 50 M Euro and balance sheet > 43 M Euro (at the time = £38.9 M and £33.5 M respectively)

There were two main routes whereby organisations could meet ESOS:

(1)    conduct a series of energy-audits that covered > 90% of their energy consumption; both stationary and transport related fuels.  For multi-site organisations, this could include site sampling.

(2)    Have ISO50001 (Energy management systems) certification that covered > 90% of the Estate’s energy.

Unfortunately, given the tight time-table for ESOS phase 1, combined with the potential threat of legal penalties, most organisations opted for the cheapest option to tick a box – i.e. minimum number of (sometimes poor) audits.  This was a pity because, properly embraced, an audit can often identify savings worth 5 - 50 times more than the cost of the audit, through:

  • Simple, no/low cost energy saving actions,
  • Attention to staff awareness and behaviour, and
  • Identifying larger investments that offered decent return on investment.

Most of the ESOS assessments and audits that we worked on identified excellent savings, typically 10-20% no/low cost saving opportunities plus up to 30% additional savings through investment - both efficiency and renewable.

Schools and Academies that are primarily funded by public monies and are bound by Public Contracts Regulations 2006 are exempt from ESOS.  However, any school or academy not funded by public money, that operates as a business or trade (even if charitable or not-for-profit) is not exempt. 

Many large, independent schools were captured under ESOS, so carried out energy-audits.  Several of these identified information “gaps” that are being addressed, others identified energy-saving opportunities that are now being progressed.  Some schools even used the process as a vehicle for including pupils as part of the solution, especially awareness and behaviour opportunities.

Some schools that perhaps should have been included in the ESOS legislation may have “slipped through the net”.  Although a problem, it is not necessarily catastrophic.  If the school had not been notified by the Environment Agency (EA), then clearly EA were unaware of their eligibility, nor had they given warning.  So, if this school were to retro-alert EA about the oversight plus demonstrate they are now making all efforts to comply as quickly as possible, then it is likely that the EA would accept this as a genuine oversight that was being resolved.  

If you are unsure, please feel free to contact us. We recognize that money is tight, but as commented, often the quick savings from an energy-audit >> the cost of the audit, and these savings are repeated every year.  It also helps get a proverbial “monkey off the back” in that you meet current legislation.  Finally, there are extra sweeteners for Academies, who can apply for zero-interest Salix loans for energy-saving investment opportunities, using the savings to repay the investment– thus eliminating a major barrier to taking ideas forward. 


Paul Stevenson and Chris Prentice are independent energy/ carbon consultants who regularly work together on energy-related issues; Paul focusing on legislation, accounting and energy-management, Chris on the myriad of energy-saving and renewable opportunities.  For further information, please contact either or

Category: Minerva blogs

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