The process for the launch of the implementing decree of the Transition 5.0 plan is substantially concluded. This was confirmed by Marco Calabrò, head of the technical secretariat of the Ministry of Business and Made in Italy, in an interview with Andrea Gallo, editor of the portal FASI.eu.
“It took us a few more days, but they were days well spent, because we closed the negotiation just this morning (July 1st, ndr) with the European Commission, in particular on the so-called ‘do not cause significant harm to the environment’ (DNSH) criterion”, says Calabrò. “We tried to agree with Brussels some openings with respect to the rigid application of these criteria, which would have led to the de facto exclusion of entire sectors, such as agriculture and energy-intensive sectors (paper, ceramics, glass, chemicals, and so on). I think we achieved a good balance, but this required a few more days of discussions with the European Commission”.
The last step is now a moment of final comparison with the other ministries. “After a final round in concert with the other administrations, this week the decree will be sent to the Court of Auditors for registration. In the meantime, we have already prepared the communication platform for businesses, so on the same day the registration takes place we will be ready to go online”. The hope is that “by mid-July everything will be fully operational”.
The four situations for calculating energy savings
During the chat with Gallo, Calabrò touched on several topics of interest, from timing to certifications, cumulation and maintenance of requirements, reiterating what we had already anticipated in this article.
However, he focused on one aspect in greater detail, namely the four situations that the implementing decree will provide for the calculation of energy savings.
The first situation is that of companies that have been operating for more than 12 months and have energy consumption data from the previous year. “Here the comparison is relatively simple. Just compare the energy consumption resulting from the new investment with that recorded in the previous year. This scenario is the most direct and transparent, since it is based on easily available historical data,” says Calabrò.
Then there is the case of companies that, despite having been operational for more than 12 months, have never specifically recorded the energy consumption of the production processes involved. “These companies must make an estimate based on technical documentation and traceable data, such as technical data sheets of the machinery, on-site tests, technical literature data, market analysis and production volumes. A certifying technician with experience in energy diagnostics must validate this estimate, ensuring that it is based on accurate and traceable data”.
The third case concerns companies established for less than 12 months but at least 6 months, which therefore do not have a full year of energy consumption data. “In this case, it is necessary to project the energy consumption of the available months over a period of 12 months. This approach helps reduce the impact of seasonality on consumption, offering a more realistic picture,” explains Calabrò.
And finally there is the case of newly established companies, which include – according to the definition contained in the implementing decree, those established less than 6 months ago and those that have significantly changed their processes. “In this case, companies must build a counterfactual scenario. For each good that is part of their innovation project, they must identify at least three alternative goods available on the European market in the last 5 years, calculate the average energy consumption of these alternative goods and use this average as a basis for comparison. The sum of the consumptions thus identified will constitute the reference scenario”.
It is a solution – adds Calabrò – that should allow all companies to have a certain freedom in identifying the counterfactual scenario. However, “if companies were not able to find all three goods but only two or one, the choice – if adequately motivated – can also be reduced to a comparison limited to the alternative goods available on the market”, he says.
Wanting to create a synthetic diagram of what has just been exposed, we therefore have the following picture.
- For companies that have been operating for more than 12 months and have energy consumption data from the previous year, it is necessary to compare the energy consumption of the new investment with that of the previous year to verify the reduction in consumption.
- for companies that, despite having been operating for more than 12 months, have never specifically recorded the energy consumption of the production processes involved, an estimate must be made based on traceable data and technical documentation. This documentation may include:
- Machinery technical data sheets.
- Prove in situ.
- Literature data (eg BAT – Best Available Techniques).
- Market comparison analysis.
- Production volumes.
- for companies established for less than 12 months but at least 6 months, which therefore do not have a full year of energy consumption data, it is necessary to check the energy consumption of the available months and project it over a period of 12 months. The 6-month time horizon was chosen to reduce the impact of seasonality on consumption.
- For companies established less than 6 months ago or those that have significantly changed their production process in the same time frame, it is necessary to construct a counterfactual scenario:
- identify at least three alternative goods available on the European market in the last 5 years for each good of your innovation project.
- calculate the average energy consumption of these alternative goods.
- The sum of the average consumption of these alternative goods constitutes the counterfactual scenario.
- If the firm is unable to find three alternative goods, it can reduce the comparison to two or one good, provided that the choice is adequately motivated.
