It was sometime in the second quarter of 2008 when I heard the news that the new regulations for efficient management of energy for intensive energy users will be gazetted by the end of that year. Then sometime in June I was instructed by my management to prepare the implementation plan to implementation the regulations but in the same time I did not received any detailed information about the new law yet.
It was only in July 2008 I was given the copy of the draft of the regulations for the purpose of me to prepare the implementation plan.
The new regulations was name as Efficient Management of Electrical Energy Regulations(EMEER) and targeted to be gazetted by December 2008.
It took me sometime initially to understand and digest the provisions in the draft for me to be able to throw out from my mind on how should I implement it. Did I do it alone? I would say it yes indeed since at the time, it was only me a clerk in my unit. Even the name of the unit was not confirmed yet although it was regularly called EE unit. My attempts to get more detailed explanation to understand the true meaning of all provisions replied with very general answers and I made a conclusion that it was up to me to propose on what need to be done to implement the new law. My experiences in the legal department for almost three years while performing enforcement and some court related tasks did helped a little bit in looking at how and what could be done.
There were two key provisions in the draft that really bring me back into energy management related subjects. They were Regulation 6 with information on what need to be submitted by affected installations to Energy Commission upon received the notice to comply to the regulations as stated below.
(a) to
appoint or designate a registered electrical energy manager to carry out the
functions and duties under regulation 16 at the installation;
(b) to
submit a written confirmation of such appointment or designation under
paragraph (a) to the Commission containing the name and particulars of
the registered electrical energy manager as well as the date of expiry of his
registration as an electrical energy manager;
(c) to
submit information regarding -
(i) the
statement of policy for efficient electrical energy management of the
installation;
(ii) the
objectives of efficient electrical energy management; and
(iii) the
accounts and documents pertaining to efficient electrical energy management;
(d) to submit the report in Form A of the
Second Schedule that has been duly signed; and
(e) to submit any other information which the
Commission may require.
Then. I had a close look at another provision in Regulation 16 below with regard to the roles of energy manager in the regulations.
Functions and duties of a registered electrical energy
manager
16. The registered electrical energy manager
shall have the following functions and duties:
(a)
he shall be responsible –
(i)
to audit and
analyse the total electrical energy consumption or total net electrical energy
generation at the installation, including the significant end use of
electricity;
(ii)
to advise the private installation licensee or
consumer in developing and implementing measures to ensure efficient management
of electrical energy at the installation; and
(iii) to
monitor effective implementation of the measures referred to in subparagraph
(ii);
(b) he
shall supervise the keeping of records on efficient management of electrical
energy at the installation and verify its accuracy; and
(c) he
shall ensure that the private installation licensee or consumer submits the
information and report under paragraphs 6(1)(c), (d) and (e)
within the periods as specified in regulation 7.
Lastly, I tried to understand the requirements stated in Form A and Form B which need to be filled by the owner of the installation and the energy manager respectively.
When I finally understood (according to my own interpretation) the meaning of the above provisions, that was the time when I felt that I had some materials and example to look at based on EE training programs that I have attended in Japan especially and in India in the same year.With some more references that I have gone through when I prepared the materials for my first ever energy management training previously, I started to feel a little bit better and had clearer idea on what I need to do to draft the plan.
I concluded that the regulations is all about to ensure all affected installations to manage their energy efficiently through the submission of information, records and documents to the regulator as prescribed. To assist each installation to be energy efficient, the appointment of a Registered Electrical Energy Manager(REEM) is a mandatory requirement and the regulator need to qualify REEMs to ensure they will have certain competency and experiences in energy management.
All what it takes to comply is by adopting energy management system and all mandatory requirements in the regulations are apart of elements in management system itself such as reporting, having an energy policy and objectives and also the appointment of energy manager for the organization.
Preparing the implementation plan for EMEER 2008 was a real test to me to extract all my experiences as an EE consultant before I joined Energy Commission, knowledge, exposure and some direct and indirect consultations with some people whom I knew from the industry, within my organization and others. Below are folders that I created in my computer to document the progress on EMEER implementation and for me to refer on every single element of it at anytime from the beginning. It slowly become to close to and finally I almost work , sleep and eat with it for me to ensure the implementation would be smooth as I planned it to be.
Among the easiest ways for me to keep myself into the whole process is making it visualized into flow charts and later I came up with details of each stage in the flow.
Preparing the implementation plan for EMEER 2008 was a real test to me to extract all my experiences as an EE consultant before I joined Energy Commission, knowledge, exposure and some direct and indirect consultations with some people whom I knew from the industry, within my organization and others. Below are folders that I created in my computer to document the progress on EMEER implementation and for me to refer on every single element of it at anytime from the beginning. It slowly become to close to and finally I almost work , sleep and eat with it for me to ensure the implementation would be smooth as I planned it to be.
Among the easiest ways for me to keep myself into the whole process is making it visualized into flow charts and later I came up with details of each stage in the flow.
Next I prepared the checklist for all actions that I believed need to be taken.
Then I came up with the overall implementation plan to enforce EMEER 2008
and....in the same time I prepared the process and criteria to apply to become REEM, evaluate and to register based on requirements in EMEER 2008.
I also designed and prepared the format and content of the application form to apply to become a REEM.
My deep involvement from the beginning in the implementation of EMEER 2008 has made me very clear in the spirit of the law itself. Key provisions in EMEER 2008 actually covering some key elements from energy management system or EMS as what being taught to me in Japan. Among them are the need to have energy policy, setting up objectives and targets for energy management and the need to have an energy manager for factories and building facilities which are intensive energy users.
The common understanding at that moment on EMS in Malaysian market out there is EMS is a technology solution that being installed in industrial or building facilities. EMS known for its common feature to monitor and acquire energy data such as electricity and other operating parameters of system equipment such as for air conditioning system.
It was some time in 2009(if I am not mistaken) when I was informed that ISO was in the midst of developing a standard on energy management which the introduced EnMS instead of EMS for not to be mistakenly understood for Environmental Management System Standard introduced by ISO years earlier.
The need for me to ensure the effectiveness in enforcing EMEER 2008 made me became more keen to learn more about EnMS and I was very fortune that I was sent to attend training programs in Japan and India earlier.
In the learning and information seeking period, training materials and all notes from ECCJ of Japan and TERI of India were my best friends the basis for me to seek more information and details on each element in EnMS.
EMEER 2008 is a very simple and short law in term of its definitions and contents although it is a regulation which normally has more details in the form of appendices and specific instructions.
I was aware at that period that I need to prepare myself as a resource person who would be able to explain clearly about all provisions and how affected installations to comply once EMEER 2008 gazetted and later enforced.
There are not much detailed definitions in EMEER 2008 anyway and the common words in energy management such as energy audit, energy policy, objective and targets are also not clearly defined.
http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=142
http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=143
http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=145
Finally I managed to complete the plan and I forwarded my detailed plan to my superior sometime in in September 2008 and later to be presented. I was told that the ministry wanted to make sure that Energy Commission really know and ready for the law to be gazetted in the year end.
It was a little bit unfortunate that I was not able to be at the
ministry during the presentation of the plan which as done by my
director due to a directive for me to attend other meeting but it was
approved.
On my return, I was instructed to prepare a paper to my board members to propose and obtain approval for budget and activities for the implementation.
Generally my key strategies to implement started from the awareness, drives to register REEMs as soon and as many as possible, on going consultations with stakeholders, industry players and affected organizations, monitor the effectiveness of the enforcement and finally to impose legal enforcement as outlined below.
My understanding and belief is energy efficiency laws have the spirit to educate and assist to comply rather than to jump into punishing whoever committing any offense. That is what I can see on how EE laws being enforced in Japan where making offenders to be punished or or to pay hefty penalties is the thing should be done.
Next...the communication plan and the time were MAESCO and FMM become my strategic partner to reach the target groups to create awareness on the implementation of EMEER 2008 and energy management system as the fundamental to comply the its provisions.
My deep involvement from the beginning in the implementation of EMEER 2008 has made me very clear in the spirit of the law itself. Key provisions in EMEER 2008 actually covering some key elements from energy management system or EMS as what being taught to me in Japan. Among them are the need to have energy policy, setting up objectives and targets for energy management and the need to have an energy manager for factories and building facilities which are intensive energy users.
The common understanding at that moment on EMS in Malaysian market out there is EMS is a technology solution that being installed in industrial or building facilities. EMS known for its common feature to monitor and acquire energy data such as electricity and other operating parameters of system equipment such as for air conditioning system.
It was some time in 2009(if I am not mistaken) when I was informed that ISO was in the midst of developing a standard on energy management which the introduced EnMS instead of EMS for not to be mistakenly understood for Environmental Management System Standard introduced by ISO years earlier.
The need for me to ensure the effectiveness in enforcing EMEER 2008 made me became more keen to learn more about EnMS and I was very fortune that I was sent to attend training programs in Japan and India earlier.
In the learning and information seeking period, training materials and all notes from ECCJ of Japan and TERI of India were my best friends the basis for me to seek more information and details on each element in EnMS.
EMEER 2008 is a very simple and short law in term of its definitions and contents although it is a regulation which normally has more details in the form of appendices and specific instructions.
I was aware at that period that I need to prepare myself as a resource person who would be able to explain clearly about all provisions and how affected installations to comply once EMEER 2008 gazetted and later enforced.
There are not much detailed definitions in EMEER 2008 anyway and the common words in energy management such as energy audit, energy policy, objective and targets are also not clearly defined.
For easier reference to any party or queries that forwarded and asked to Energy Commission or myself, I prepared some write up on key definitions related to the law which later uploaded in the website as outlined below.
GUIDELINES
ON INFORMATION TO BE SUBMITTED TO ENERGY COMMISSION UNDER REGULATION 6, EFFICIENT
MANAGEMENT OF ELECTRICAL ENERGY REGULATIONS 2008
A. INFORMATION TO BE SUBMITTED UNDER SUBREGULATION 6(1)(C)
(I) The statement of policy for efficient electrical energy
management of the installation
- The specific policy statement on efficient management of electrical energy or apart of other policies that has been developed and introduced for implementation at the installation
- The item need to be included in the policy statement of efficient management of electrical energy are:-
i) The commitment in efficient
management of electrical energy to improve energy efficiency usage continually.
ii) The commitment to address and act towards processes and
activities that will give impact on the performance of electrical energy usage
at the installation; and/or
iii) The commitment to ensure compliance towards
the Act and regulations on efficient management of electrical energy.
(II) The objectives of efficient electrical energy
management
- The target or objective of energy savings from the implementation of efficient energy management policy introduced by the owner of installation;
- the item need to be stated:
i) achievable electrical energy saving target for the
installation for short, medium and long terms.
ii) the methodology to measure
electrical energy saving target based on performance indicator established by the owner of the installation.
(III) The accounts
and documents pertaining to efficient electrical energy management
- Organizational structure for efficient management of electrical energy at the installation.
- Comprehensive energy audit report or apart of the report consisting the following information:-
i) availability
of efficient management of electrical energy practices at the installation.
ii) electrical
energy supplied to the installation:-
types of supply : from the
licensee or own generation or both.
iii) electrical
energy consumption:-
Daily/weekly/monthly load
profile in kW.
Load distribution of
electrical energy consumption according to equipment in energy unit(kWh) and
percentage(%) of each load.
operating hours of the
installation and major electrical energy using equipment.
- list of energy saving measures and estimated energy saving value in energy unit (kWh) for each measure identified at the installation:-
i) with the
description of each saving measure and how to implement it such as methodology,
applications and technologies to be used that will save energy.
ii) estimated energy saving value for each saving measure according to:-
-
no
or low cost required to be implemented; and/or
-
high
cost required to be implemented.
iii) method of
measurement/calculation to determine and verify the energy saving achieved for
each measure (with meters or estimation with calculation or both).
iv) estimated return of
investment/financial analysis used by the owner of the installation for
economic evaluation of each saving measure.
v) Implementation plan and
estimated time required to implement each energy saving measure.
(Note: The information in
(III)(b) can be submitted to Energy Commission in stages)
B. INFORMATION TO BE ATTACHED WITH FORM A UNDER THE SUBREGULATION
6(1)(D).
(I) Total consumption of electrical energy/ total net generation of electrical energy for six consecutive months in the period reported in kWh.
(II) Total consumption of electrical energy/ total net generation of electrical energy for six consecutive months in the previous period reported in kWh.
- to attach with supporting documents such as copy of electricity bills in the same period, summarized electricity consumption or data from meter readings/data collected verified by Registered Electrical Energy Manager.
(III) Efficient
management of electrical energy improvement measures implemented in the period
reported
- list of implemented improvements and energy saving measures for efficient management of electrical energy.
(V) Efficient management of
electrical energy improvement measures proposed but not implemented together
with reasons for not implementing them.
- list of measures and detailed description on reasons for each measure.
(VI) Estimated savings in
total consumption of electrical energy/ total net generation of electrical
energy* achieved as a result of efficient management of electrical energy
improvement measures implemented in the period reported in kWh.
- total energy savings achieved from improvement improvement measures implemented in the period reported; and
- measurement and calculation methods used to determine the value of energy saving achieved for each improvement measure.
The links below are some more write-ups for EMEER 2008 that I prepared that I developed and prepared which still being used by the regulator until today with some changes and addition after I left the regulator in early 2011.
http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=141http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=142
http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=143
http://www.st.gov.my/index.php/applications/energy-efficiency/registered-electrical-energy-managers.html?id=145
Finally I managed to complete the plan and I forwarded my detailed plan to my superior sometime in in September 2008 and later to be presented. I was told that the ministry wanted to make sure that Energy Commission really know and ready for the law to be gazetted in the year end.
On my return, I was instructed to prepare a paper to my board members to propose and obtain approval for budget and activities for the implementation.
Generally my key strategies to implement started from the awareness, drives to register REEMs as soon and as many as possible, on going consultations with stakeholders, industry players and affected organizations, monitor the effectiveness of the enforcement and finally to impose legal enforcement as outlined below.
Next...the communication plan and the time were MAESCO and FMM become my strategic partner to reach the target groups to create awareness on the implementation of EMEER 2008 and energy management system as the fundamental to comply the its provisions.
