PUBLIC CONSULTATION ON INTRODUCING ENERGY EFFICIENCY OPPORTUNITIES ASSESSMENT AND ENERGY PERFORMANCE MEASUREMENT REQUIREMENTS FOR NEW VENTURES

Introduction

The National Environment Agency (NEA) of Singapore is seeking feedback on a proposal to introduce energy efficiency opportunities assessment and energy performance measurement requirements for new ventures¹ from 1 October 2018. The consultation exercise will commence on 14 August 2017 and end on 1 September 2017.

 

Current Energy Efficiency Improvement Efforts

3 To improve energy efficiency in the industrial sector, the Government had introduced mandatory energy management practices under the Energy Conservation Act (ECA) in 2013. Energy-intensive users in the industrial sector that consume 54TJ or more of energy annually in at least two out of the three preceding years have to comply with the following requirements:

a) appoint at least one certified energy manager;

b) monitor and report energy use and GHG emissions annually; and

c) develop an energy efficiency improvement plan and update the plan annually.

4 Analysis of data³ submitted by companies regulated under the ECA for the period between 2014 and 2016 revealed that there continues to be a lack of management attention on proper energy management. This is shown from the findings that about 60% of the energy performance of major energy-consuming systems reported under the ECA was not tracked and more than half of the companies measured less than one-third of the important parameters. Many companies were therefore unable to manage their energy use effectively.

5 Based on the energy efficiency improvement plans submitted under the ECA, companies achieved an annual energy efficiency improvement rate of about 0.6% in 2015, a slight improvement over 0.4% in 2014. This is still low, considering that energy-intensive companies in leading developed countries like the Netherlands and Belgium have been achieving 1 to 2% improvements annually.

Enhanced Energy Management Practices for New Ventures

6 To meet Singapore’s 2030 commitments under the Paris Agreement, further energy efficiency improvements are needed. To this end, the ECA was amended⁴ to introduce the following new requirements for new ventures:

a) Energy efficiency opportunities assessment (EEOA)

b) Energy performance measurement

 

7 Many system design synergies are only available early in the design process before system choices are locked in. Facilities, on-site utilities and supply utilities tend to be oversized at the expense of energy efficiency. Designing a facility to be energy and resource efficient can reduce:

a) Capital cost of the systems, due to reduced capacity needs in upstream utility systems;

b) Operating costs, due to lower resource and energy use;

c) Maintenance costs for the systems. For example, reducing thermal loads and stress leads to lower maintenance costs and improved uptime.

It becomes far costlier and less effective to retrofit or improve a facility for energy efficiency after it has been built (refer to Annex 1).

8 To promote energy management discipline from the facility development stage, companies investing in new ventures with potentially large energy consumption will be required to review the facility design for energy efficiency and develop economically feasible energy efficiency opportunities.

9 The design of an industrial facility is developed through a few stages. First, a feasible process to be used within the facility is identified. Thereafter, the types of equipment and systems needed for the process are decided, before the detailed size and capacity of these equipment and systems are developed. These three design stages are commonly known as Concept Engineering, Front-End Engineering Design (FEED), and Detailed Design respectively. The impact of decisions made in each stage on the overall energy efficiency of the facility typically declines across the stages. As the design progresses, it becomes costlier to make changes to decisions made in earlier stages, as it entails redoing many parts of the design, and often less effective in energy efficiency improvement. This necessitates the need to incorporate energy efficiency as a critical criterion for the design as early as possible.

10 The owner of a new venture who applies to the competent authority for planning permission under the Planning Act (Cap 232) on or after 1 October 2018 must carry out an EEOA and submit an EEOA report. The detailed requirements of the EEOA process can be found in Annex 2.

11 The EEOA report must be submitted at the point of application for a Development Control (DC) Clearance Certificate from NEA. To expedite the approval process, companies should ensure that their report has sufficient details, by engaging NEA early for discussion, preferably during the concept engineering and FEED stages.

12 The requirements of the report are listed in Annex 3. The report detailing the process and results of the assessment must be:

a) Submitted through a Qualified Person⁵, via BCA’s Corenet e-submission system;

b) Signed off by the individual and company who were responsible for preparing the report; and

c) Endorsed by the Chief Executive of the new venture.

Any data used for the EEOA must be kept for at least 5 years.

13 To ensure that the scope and quality of the EEOAs are adequate, a Verification Office (VO) comprising independent experts and experienced industry practitioners will review the EEOA reports. After their review, the VO may offer suggestions for improvement and recommendations for voluntary adoption or further study by the company.

14 The VO will follow up with the company to gather information on the energy efficiency opportunities identified in the EEOA report that have been implemented, and their energy performance.

Rationale for Energy Performance Measurement Requirement for New Ventures

15 The findings mentioned in paragraph 4 highlight the lack of proper monitoring and reporting tools to track energy performance of major energy-consuming systems. Measurement is critical to continual energy efficiency improvement as managing energy use is a data-driven activity. Measured data also facilitates benchmarking and hence comparison of energy performance of similar systems across facilities within a sub-sector and across sub-sectors, thereby highlighting the potential for improvement for poorer performers.

16  As it is less disruptive and more cost-effective to install such measurement systems in new ventures, owners of new ventures will be required to plan for and install instruments and meters for energy-consuming systems, and report energy use and energy performance indicators based on measured data in their ECA submissions.

 

a) Total energy consumption of the new venture; and

b) Annual energy consumption, intended output and specific energy consumption figures of energy-consuming systems that make up at least 80% of the calculated total energy consumption of the new venture.

19 This proposal is released for the purpose of consultation. All comments received during the consultation exercise will be reviewed thoroughly and may be incorporated into the final measure. Interested parties can submit their feedback to NEA_EEPC@nea.gov.sg. The consultation exercise will end on 1 September 2017.

20 To ensure that the consultation is productive and focused, respondents are requested to observe these guidelines when providing their feedback:

a) Identify yourself as well as the organisation you represent (if any) so that we may follow up with you to clarify any issues, if necessary

b) Be clear and concise in your comments

c) Focus your comments on the proposal to introduce energy efficiency opportunities assessment and energy performance measurement requirements for new ventures and how it can be improved

d) As far as possible, substantiate your points with illustrations, examples, data or alternative suggestions

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¹ In this paper, a new venture refers to any new business activity or expansion of any existing business activity that is designed to consume 54 TJ or more of energy annually (based on 365 days of operations at 100% of designed production capacity), carried out at a single site and is attributable to one of the following industry sectors:

a) Manufacturing and manufacturing related services
b) Supply of electricity, gas, steam, compressed air and chilled water for air-conditioning
c) Water supply and sewage and waste management

² Emissions intensity refers to greenhouse gas emissions per dollar of GDP, measured in CO2-equivalent per dollar.
³ Energy use reports and energy efficiency improvement plans submitted by companies
⁴ The other initiatives that will be introduced under the Energy Conservation (Amendment) Act 2017 are i) structured energy management system for existing facilities; ii) EEOAs for existing facilities; and iii) minimum energy performance standards for common industrial equipment and systems.
⁵ Appointed under section 8 or 11 of the Building Control Act (Cap. 29) in respect of the building works for the new venture facility
⁶ The energy performance indicators refer to the specific energy consumption (SEC) of energy-consuming systems in the energy use report specified in the ECA.
⁷ A business activity becomes relevant under the ECA if it consumes 54 TJ or more of energy annually for 2 out of the 3 preceding years of operations.