EEO Desktop Verification Implementation & Outcomes

1. EEO Desktop Verification Implementation & Outcomes Presented by: Ben Roberts, EEO Verification Manager Australian Sugar Milling Council, Brisbane 14 February 2011

2. PRESENTATION CONTENT • Objectives • Scope • Process • Outcomes • What does risk look like

3. OBJECTIVES • 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

4. SCOPE • Undertaken by the Department • Involves approx. 100-120 companies annually • Representative across sectors and energy users

5. 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 preliminaryassessment (risk score) & may request sample documents

6. 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

7. 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

8. 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

9. QUESTIONS / QUERIES / QUANDARIES

10. 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

11. HAVE A STRETCH REST YOUR MIND

12. EEO Full Verification Implementation & Outcomes Presented by: Ben Roberts, EEO Verification Manager Australian Sugar Milling Council, Brisbane 14 February 2011

13. PRESENTATION CONTENT Objectives Scope Process Outcomes

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

15. 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 OBJECTIVES (1)

16. OBJECTIVES (2) • 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

17. 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

18. 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)

19. 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)

20. 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

21. 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)

22. 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

23. 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

24. 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

25. 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

26. HOW CAN YOU ASSIST THE VERIFICATION PROCESS? • 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

27. QUESTIONS / QUERIES / QUANDARIES

28. 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

29. Thank you

30. EEO Verification Background and context Presented by: Ben Roberts, EEO Verification Manager Australian Sugar Milling Council, Brisbane 14 February 2011

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

32. VERIFICATION – WHAT IS IT? Validation & monitoring of company compliance with EEO legislation

33. 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

34. 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

35. 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; and b) report publicly on the outcomes of the assessment to demonstrate…that businesses are effectively managing their energy.”

36. 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; and b) Make its records available for inspection in accordance with Part 8 of the Act”

37. DESKTOP VERIFICATION • 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

38. 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

39. 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

40. 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

41. 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

42. QUESTIONS / QUERIES / QUANDARIES

43. 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

44. HAVE A STRETCH REST YOUR MIND