Recently, the Spanish Ministry for Ecological Transition and Demographic Challenge, MITERD, published Order TED/815/2023, which extends Royal Decree 36/2023 establishing a system of Energy Saving Certificates (Certificados de Ahorro Energético, CAE) and enables that system to be correctly set up and operated.

One aspect of the Ministerial Order is to define the conditions that companies must meet if they wish to be accredited to act as Energy Saving Verifiers. In this regard, MITERD’s General Directorate for Energy Policy and Mines has requested ENAC to develop an accreditation scheme (RDE-33), following its guidelines, that references the UNE-EN ISO/IEC 17029 and UNE-EN ISO 14065 standards.

Susana I. Pérez Baelo, Head of the Sub-Directorate General for Energy Efficiency at the General Directorate for Energy Policy and Mines, explains accreditation's role in achieving the objectives of this policy initiative and how collaborating with ENAC has been.

What are this measure's objectives and what does the national system of energy efficiency obligations mean for obligated subjects?

The European Parliament and Council on Energy Efficiency’s approved on 13 September Directive (EU) 2023/1791, the framework standard for promoting energy efficiency within the European Union. Article 8 sets out cumulative final energy savings targets for two obligation periods: 2014-2020 and 2021-2030, with the current obligation period's objective being particularly ambitious and demanding in relation to the previous one.

Once the 2014-2020 obligation period ended, Spain had to formally report the accumulated final energy use savings achievements to the European Commission. The resulting value was 15,207.50 ktoe, representing 95.2% of the savings target (which was 15,979 ktoe). In view of this result, and taking into account that for the 2021-2030 obligation period the final energy savings target imposed has increased to 53,593 ktoe, there was a clearly identified need to create a new mechanism in addition to the previous ones, and included within the framework of the National System of Energy Efficiency Obligations (Sistema Nacional de Obligaciones de Eficiencia Energética, SNOEE), to achieve the EU's energy saving targets for the period 2021-2030 and beyond in a flexible and effective way. This mechanism is the Energy Saving Certificate System, which came into operation in July 2023, with the publication of the aforementioned order TED/815/2023.

In addition, this system will make it easier for SNOEE obligated bodies (electricity and natural gas marketers and wholesale operators of petroleum products and liquefied petroleum gases) to comply with their annual savings obligations, as it provides them with an alternative to the present mechanism; contributing an economic amount to the National Energy Efficiency Fund (FNEE). Therefore, SNOEE's obligated subjects will be able to decide - depending on which alternative is more economically beneficial to them - between continuing to contribute their obligation total’s economic equivalent to the FNEE or settling a part of their obligation by presenting Energy Saving Certificates (CAE). By doing so, we hope to contribute to improving productivity and business competitiveness, boosting the energy efficiency sector’s employment and having a beneficial impact on end consumers.

What were the fundamental reasons why MITERD decided to require accreditation as a tool to support regulation? What benefits and guarantees does accreditation bring to the CAE system?

The mission of the Energy Savings Verifier within the CAE system is to verify the effective achievements of the final energy savings declared by the CAE applicant. As a result of their work, if the verification process is satisfactory, they will issue a favourable opinion that will be seen by the Regional Manager prior to issuing the CAEs. The number of CAEs issued by the Regional Manager will make the sum of the value of all of them correspond to the amount of recognized final energy savings.

So, the Energy Saving Verifier is a strategic and essential element of the CAE System, since, without his prior favourable opinion, it is not possible to proceed with applying to issue CAEs. It is the touchstone of the system.

For this reason, it was understood that accrediting those wishing to act as verifiers should be carried out in accordance with a regulated procedure that would give both the CAE System's National Coordinator and all the participating agents total confidence in the objectivity, impartiality, and robustness of the system.

That is why the Sub-Directorate General for Energy Efficiency (SGEFE) contacted ENAC's Technical Directorate, initiating a close and fluid collaboration over several months with the Certification and Verification Department, resulting in the Accreditation Scheme for Energy Saving Certificate System certification bodies (RDE-33) being prepared and published.

ENAC offers its support to regulatory bodies when incorporating the accreditation requirement into their legislative provisions. Could you tell us about your experience in collaborating with ENAC in this regard?

The experience of working with ENAC has not only been productive, achieving the objective pursued within the established deadline, but also very satisfactory.

All the working meetings, which have been numerous, have been characterized by dialogue, transparency, and mutual learning: by ENAC in relation to the CAE System's technical aspects necessary for being able to adapt the accreditation scheme to our needs, and by the SGEFE team in relation to aspects related to accreditation schemes and procedures.

Finally, I would like to highlight how available and flexible the ENAC Certification and Verification Department team assigned to this project have been at all times.

Accreditation is an increasingly popular mechanism for public administrations to ensure the safety and integrity of assessment and control activities in key sectors such as energy efficiency. In the future, and specifically in MITERD's action scope, do you consider that accreditation could be a useful tool for providing support in new areas?

Especially in those procedures where independent third-party participation is required, both to provide security to some of the procedure's formalities and later, in a potential inspection and control stage.

Although it is difficult to give examples without creating false expectations, a possible new source of collaboration between the Administration, specifically SGEFE, and ENAC will be the new Directive (EU) 2023/1791 on Energy Efficiency, recently approved and published. This text will need to be put into national legislation, and it includes relevant novelties, such as Article 3 of the principle "energy efficiency first". I am sure that throughout this process, accreditation will be a very useful tool to consider and for which we will once again need ENAC's support, knowledge, and experience.