Scope of a Public Body

Key principles

The scope of reportable energy consumption is relatively broad. The following over-arching principles apply when determining the scope of reportable consumption.

Attributable consumption

Asset ownership, asset location and being the energy bill-payer are less relevant than whether consumption is attributable to your organisation. Therefore, the scope of your reportable consumption is not necessarily limited to the energy-using assets that you own, to the energy that your organisation pays for directly or to energy consumed at specific location(s).

Consistency of scope

You should adopt a consistent approach to scope in terms of what you report, i.e. if you deem a particular function, asset or activity to be within scope, then you should try to account for it in your activity metric value, as well as reporting energy data for it.

You should adopt a consistent approach to scope over time, i.e. if you include a particular aspect of consumption in your baseline, then you should include it for all subsequent years, and vice versa. This applies even if contractual arrangements evolve over time - you cannot 'reduce' your organisation's energy consumption or circumvent its energy efficiency obligation by outsourcing or subcontracting an activity.

Operation & maintenance versus construction

In general, the energy consumed directly in the construction of capital projects (e.g. building a new school or hospital) is not within scope, while the energy consumed in the operation and maintenance of such assets is.

Landlords and tenants

Your organisation pays its own energy bill

If your organisation pays the bill, then you should report the energy used by your organisation in the normal way.

Landlord or another organisation pays the energy bill

Even though your organisation does not pay an energy supplier directly, your organisation still consumes energy and has an obligation to report. You should request the bill-payer (e.g. landlord) to give you access to as much relevant data as possible for the building (e.g. bills, meter readings, MPRNs, GPRNs, consumption data).

To facilitate good energy management practices, you could consider the installation of sub-meters on your organisation’s share of the energy supplies.

Your organisation pays another organisation's energy bill

If your organisation pays an energy bill on behalf of another organisation and your organisation is reporting on its behalf, then you should include the corresponding data with your submission. If you are not reporting on behalf of the other organisation, then the relevant consumption should be excluded.

Private contractors

Services provided to third parties on your behalf

If a contractor provides a service to third parties on behalf of your organisation, then you must report the consequent energy use by the contractor. Examples include:

• Waste contractors contracted to local authorities to provide waste management services
• Public private partnership (PPP) projects
• Operation of local authority leisure centres

Services provided to your organisation

The energy consumed by functional activities undertaken by a contractor on your organisation’s behalf is also reportable. Examples include:

• Staff canteen services
• Shared services
• Data centre services
• Cloud computing (large scale)
• ESCo-operated energy facilities

Public private partnerships (PPPs)

For the purposes of M&R, the following PPPs are considered to be within 'parent' public bodies' scope:

• Design build operate projects and close variants: the facility is financed by the public sector and remains in public ownership throughout the term of the contract.
• Other PPP projects: concession projects and design build projects financed by the private sector

The energy consumption of these facilities must be included in the parent public body’s annual submission. If you believe that a specific PPP project should not be included in your annual submission, then you should make the case for this to SEAI. These will be considered on a case by case basis. Public bodies should ensure that the provision of energy consumption data by PPP partners to public bodies is a contractual requirement.

Assets owned by private contractor

Even if a private contractor owns energy assets serving a public body (e.g. boiler equipment, CHP plant) the energy consumed by these facilities must be included in the relevant public body’s annual submission.

Out of scope

Examples of contracted services that are not within the scope of your organisation’s energy consumption include:

• Professional and legal services
• Delivery of goods or consumables to your organisation unless the delivery is a core activity of your organisation
• Outsourced cloud computing (small scale)

Shared services

Shared services are included in public sector consumption. There are two approaches to allocating the relevant energy consumption among public bodies:

Default approach

The portion of energy consumed by the public body is reportable by the public body that benefits from the service. Public bodies that provide shared services must exclude consumption attributable to the organisations they provide services to.

Alternative approach

The alternative approach is for the public body that provides the shared services to report all of the consumption associated with the provision of the services to all of its ‘customers’ as its own and to ‘account’ for this through its activity metric. None of the public bodies benefiting from the services should report any of the consumption attributable to the provision of the services.

This approach must only be used if the party providing the shared service is a public body reporting through the M&R system, and if all of the relevant public bodies agree to use the alternative approach.

Residential accommodation

If your organisation provides residential accommodation for your staff or ‘customers’, then the energy consumption of this accommodation should be reported. This includes university, college and school residential accommodation, and barracks. Neither local authority housing nor housing provided by the HSE or HSE-funded organisations is counted.

Data centres

You should report the consumption of data centres in the same way as any other energy consuming facility or building, even if the data centre is owned and/or operated by a third party.

The physical location of a data centre is largely irrelevant in the M&R context. In the same way that your organisation could have two buildings in two different counties, it could have a data centre that is remote from its other energy facilities. If your organisation shares a data centre, then the consumption attributable to your organisation should be calculated in an appropriate manner.

Local authorities

Local authority housing

Local authority housing is not within scope.

Waste management services

The energy consumed in the provision of waste management services (e.g. collection, processing etc.) should be included in a local authority’s consumption in both of the following cases:

• The local authority provides the services directly
• The local authority has a contractual relationship with one or more private contractors to provide the services to third parties

In the latter case, the consumption of the private contractors should be included in the data reported by the local authority. In future, local authorities should ensure that the provision of energy data by private contractors to local authorities is a contractual requirement.

Public lighting

Some energy consumption for public lighting on national routes is paid for by the relevant local authority and reimbursed by Transport Infrastructure Ireland (TII). This electricity consumption is included in the scope of local authorities' reportable energy consumption. It should be reported by the relevant local authority, not by TII.

Public lighting is mostly un-metered, with billing based on a flat rate for each lamp type. You should report the Group MPRNs (GMPRNs) corresponding to your organisation’s public lighting bills.

Group water schemes

The energy consumed in supplying water to public group water schemes should be reported as part of relevant public bodies' consumption for relevant years. The energy consumption of a group’s private or co-op operator in distributing the water is not considered. Private group water schemes are not within the scope of any public bodies.

Transport energy consumption

The same principles apply to determining the scope of transport energy consumption. The following are all within the scope of reportable consumption:

• Energy consumed in leased vehicles
• Provision of public transport services by the organisation
• Fuel procured by the organisation that is used in staff members’ vehicles
• Transport or mobility-related activities that fulfil a fundamental element of the organisation’s function, including activities provided as a service by independent parties
• Provision of other passenger or freight transport services by the organisation
• Fuel used in mobile plant and equipment (unless used in the construction of capital projects)

Out of scope

The energy consumption attributable to the following items is not reportable:

• Staff mileage
• Staff travel on public transport services and commercial transport services
• The fuel consumed directly by peat harvesting equipment/vehicles
• Ad hoc deliveries to the organisation’s facilities where the delivery activity does not fulfil a fundamental element of the organisation’s function
• Energy consumed by a private operator for transport services (taxi services, coach services, couriers, etc)
• Gas consumption used in the transportation of natural gas through the gas network

Facilities in the EU Emissions Trading Scheme (ETS)

The 2020 energy efficiency target and the obligation to report data annually to SEAI through M&R apply to all public bodies, including those with facilities that participate in the EU Emissions Trading Scheme.

Power stations and energy sector

Power generation facilities which are owned/operated by a public body and located within the meter boundary of their own energy-consuming facilities are included. Overhead energy consumption is also included.

Power stations outside of the meter boundary are not reportable, including smaller power generation facilities. The only exception is the electrical output from landfill gas generation plants, which is included. The fuel consumed in the direct transportation of fuels to power stations is not included.

Peat harvesting

The fuel consumed directly by peat harvesting equipment and vehicles is not reportable.

Natural gas transmission & distribution

The gas consumed in the operation of the natural gas network is not reportable.

Energy consumed outside the State

Energy that is consumed outside the State but is attributable to a public body is within scope.

Merged organisations

If two or more public bodies have merged, the subsuming organisation should log in to the online system and submit a merge request. SEAI will merge the data already in the system for each entity, which will entail some direct interaction between an SEAI representative and the organisation to establish an agreed baseline period and a common activity metric. (If you cannot provide robust historical data for a merged activity metric, SEAI will assign a new organisation-level EnPI based on one of the two mandatory activity metrics, i.e. FTE employees or TUFA.)

You should report data for the merged organisations in the normal way. Historical data for the period prior to the merge must be reported as if the merged entities were a single organisation at the time, i.e. combined energy consumption, combined activity metric. There is no need to report separate figures for the different entities.

It would be useful if you reported the names of the now-defunct organisation(s) for which you are currently reporting as sub-organisations.