Tuesday, April 15, 2014

Part 2 : EnMS and I - The influence of Efficient Management of Electrical Energy Regulations 2008

In this second part of EnMS experiences sharing, I will share on how I managed to get more platforms to share more of my thoughts and ideas on energy management by  working together with industry players and organizations such as the assocation of ESCOs in Malaysia and  and Federation of Malaysian Manufacturers. This is mainly due to my responsibilities to implement the newly gazetted law which was the first ever energy efficiency regulations  introduced in Malaysia in the end of 2008.

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.



Notification by the Commission

6.         (1)       The Commission may, at any time by written notice, direct any private installation licensee or consumer whose total net electrical energy generation or total electrical energy consumption, as the case may be, equals to or exceeds 3,000,000kWh-

(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.





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.

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=141

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.






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