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ECEEE SUMMER STUDY PROCEEDINGS 189
Challenges of designing and delivering
eective SME energy policy
Sam Hampton
Environmental Change Institute
University of Oxford
South Parks Road
Oxford
OX1 3QY UK
samuel.hampton@ouce.ox.ac.uk
Tina Fawcett
Environmental Change Institute
University of Oxford
South Parks Road
Oxford
OX1 3QY, UK
tina.fawcett@eci.ox.ac.uk
Keywords
SME, policies and measures, energy demand
Abstract
SMEs (small and medium enterprises) are widely acknowledged
as a dicult target for energy policy. is is in part due to their
diversity: they operate in every sector, in all property types and
vary from one person operations with no business premises,
to manufacturers with up to 250 employees. eir energy use
is poorly understood: evidence on where, why and how much
energy they use is incomplete. is paper uses theory, literature
review and examples from the UK and France to investigate
where the major diculties arise in designing eective, eco-
nomic and equitable policy for SMEs, and suggests how this
might be improved. Firstly, the policy context is described with
reference to the scale and characteristics of SMEs. Available
data on their energy use and potential for savings are presented
from literature, followed by a discussion of dierent models
of understanding SME decision-making. ree categories of
options available to policy makers are described: (1)designing
‘universal’ policy (2)developing organisational policy designed
with minimum obligation thresholds, and (3)deploying meas-
ures specically targeted at SMEs. We argue that the focal unit
of policy design is the crucial factor inuencing whether SMEs
are likely to be included in scope. Where the organisation is the
primary focus, SMEs are more likely to be exempted, whereas
universal policy such as those focused on products, buildings
or technologies may hold potential for extending the benets of
energy eciency to SMEs. Targeted SME policies largely con-
sist of incentives and information provision, and are typically
delivered by business support organisations with primary aims
to support economic growth. We argue that while there are
benets from utilising existing support networks for delivering
energy eciency programmes, SMEs with stable business plans
are deprioritised, and contradictory eects may arise.
Introduction
With the Paris Agreement (UNFCCC, 2015) now ratied by the
majority of nations in Europe, the emphasis shis to developing
energy and climate policy t for meeting the ambitious target
of limiting global average temperatures to 2°C of warming.
Emissions reductions from all sectors of the economy will be
required for this feat, including the commercial and industrial
sectors, of which small and medium-sized enterprises (SMEs)
represent a signicant proportion. A recent study estimates that
SMEs collectively consume more than 13% of energy globally,
and that signicant opportunities exist to implement energy
eciency measures with potential for savings of up to 30%
(IEA, 2015). However, in many priority areas such as energy
eciency and low-carbon heat, ‘SMEs are poorly addressed by
existing policies’ (Committee on Climate Change, 2016).
Whereas a range of policies have been developed in the UK
and France to ensure that corporations take steps to mitigate
climate change according to the ‘polluter pays’ principle, SMEs
are oen exempted from regulation, taxes and market-based
mechanisms. e rationale for these exclusions is expressed by
a narrative of protecting SMEs from the burden of bureaucracy
and paper-work, which are perceived as barriers to growth and
productivity (Cabinet Oce, 2016). SMEs are considered to
have limited capacity for economies of scale, to suer from lack
of information, time or expertise to deal with regulations or
Contents Keywords Authors
1-353-17 HAMPTON, FAWCETT
190 ECEEE 2017 SUMMER STUDY – CONSUMPTION, EFFICIENCY & LIMITS
1. FOUNDATIONS OF FUTURE ENERGY POLICY
administrative rules, and to nd it more dicult or expensive
to access capital than larger organisations. us regulation has
a disproportionate eect in terms of cost and administration
on SMEs (Nyman, 2016). e term ‘red tape’ (excessive bureau-
cracy or adherence to ocial rules) dates back to the 16th cen-
tury, being used to bind the eighty petitions issued to the Pope
by King Henry VIII when seeking a divorce from Catherine
of Aragon (Dickson, 2014). Its negative connotations still per-
vade European political discourse today. e European Com-
mission has held a conference and competition for ‘Red Tape
Reduction’ (High Level Group on Administrative Burdens,
2014), while the UK regularly surveys businesses’ perceptions
of regulation (BEIS, 2016) and has created a programme called
‘Cutting Red Tape’ which reviews policy in dierent sectors on
a rolling basis (Cabinet Oce, 2016).
Acknowledging the strength of resistance to SME regula-
tion, this paper identies the challenges faced by policy mak-
ers tasked with reducing energy consumption and carbon
emissions from the commercial and industrial sectors, and
presents some alternative options. e authors’ research on
SMEs is focused on the UK. However, including perspectives
from another country adds both interesting case study mate-
rial, and the opportunity for comparisons to enrich the analy-
sis of policy design and implementation. France was chosen
as it was thought likely to be reasonably similar to the UK -
and that therefore the intersection between energy policy and
SMEs could be understood without a full comparative analysis.
e next section provides context to the policy challenge. It
describes the scale and characteristics of the SME population
and provides a summary of the available evidence relating to
their energy use. e third section describes three categories
of energy policy (1) ‘universal’ approaches (2) organisational
policy designed with minimum obligation thresholds, and (3)
targeted SME policy. Because SMEs are largely excluded from
the second category, a policy gap is identied, and the discus
-
sion proposes options for lling this gap by designing policy,
which is not focused on the organisational unit. A variety of
alternative focal units for policy are identied from academic
literature, including legal status, data availability and business
practices. Given the prevalence of targeted SME policy taking
the form of ‘business support’, the discussion describes the pit-
falls of delivering energy eciency policy through organisa-
tions with a primary remit to deliver economic growth. e
conclusion summarises the challenges faced by policy makers,
and suggests areas for further research.
Context setting: SMEs as energy consumers
SMEs are dened by only one parameter: size. e European
Union denes SMEs as independent organisations with fewer
than 250sta and a turnover or balance sheet of up to €50m
or €43m respectively. ere are an estimated 23million SMEs
in the EU, providing between 53% and 70% of employment in
dierent member states (Eurostat, 2015).
SMEs operate in every sector of the economy, varying by
sector, management structure, legal status and premises type.
SMEs are inuential in the energy system as a whole, beyond
their role as consumers. For example, representing 86 % of
employment in the UK construction sector (1.8million) and
employing 46% of workers (2.3million) in the motor vehicles
trade and repair industry. As such they inuence the ways in
which energy is consumed in the built environment and by the
transportation system. In this paper however they are primar-
ily addressed as energy consumers, for which data is imper-
fect. Whereas the USA measures energy used for manufactur-
ing by business size, and gures are available for SME energy
consumption by fuel in Australia, in Europe, gures are largely
unavailable at the national scale. For example, while the IEA
quotes estimates that 70% of energy used in the Italian indus-
trial sector comes from SME manufacturers (2015), its cited
source (Trianni and Cagno, 2011) includes only an estimate of
‘over 60%’, with no further reference provided.
e UK government estimates that SMEs in the UK spend
£49.6bn (€58.6bn) annually on all forms of energy consump-
tion (DECC, 2016). Of all energy use in non-domestic build-
ings, SMEs are estimated to represent 57% of electricity and
50% of gas demand (DECC, 2015). However, these national
gures are approximations, subject to a range of assumptions
and currently being revised as part of eorts to improve data on
non-domestic buildings and energy consumed by their inhab-
itants (Nicholls, 2014). Energy consumption in non-domestic
buildings does not represent the totality of SME greenhouse
gas (GHG) emissions however. 59.4% of SMEs operate from
domestic premises in the UK (BIS, 2015a, 2015b) meaning that
when designing policy, simple segmentation based on building
type is insucient to capture the breadth of SME energy de-
mand. Transport also represents a major source of energy con-
sumption by SMEs. It has been suggested that travel demand
management may represent the largest opportunity for savings,
however disaggregating national travel data to identify SME be-
haviours is a complex and error-prone task (DECC, 2016).
Context setting: Energy saving potential and decision
making
Collecting reliable, representative data on energy used by SMEs
at a national scale is a dicult task. is paucity of data poses
a challenge to policy makers aiming to quantify and evaluate
the impact of existing energy policy on SMEs, and to design
new instruments on the basis of evidence. Nonetheless, there is
evidence to suggest that energy eciency opportunities are sig-
nicant amongst SMEs (IEA, 2015) . UK government research
estimates that SMEs could reduce energy costs by 18–24% by
maximising on energy eciency opportunities (DECC, 2014).
A report identies the scale of the ‘missed opportunity’ for
UK SMEs to save between £1.26bn (€1.49bn) and £2.63bn
(€3.11bn) in buildings, with 37% of the savings requiring zero
capital investment (ibid.). Despite the availability low-cost op-
portunities such as behavioural change and improved opera-
tion of energy using equipment to SMEs (ibid.), a recent survey
found that more than 60% of SME owners do not regard en-
ergy eciency as a key priority, and only 1 in 10 had made en-
ergy savings in the previous 12 months (Scottish Power, 2016).
Understanding the decision making processes of SMEs is es-
sential for policy-makers encouraging the take up of energy
eciency measures. A considerable literature has focused on
the barriers to uptake of energy eciency measures by SMEs
(Brown, 2001; Crocker, 2012; Sorrell et al., 2011; Trianni and
Cagno, 2012, 2011). Barriers analysis is based on an economi-
cally rational model of decision making, and typically com-
Contents Keywords Authors
1. FOUNDATIONS OF FUTURE ENERGY POLICY
ECEEE SUMMER STUDY PROCEEDINGS 191
1-353-17 HAMPTON, FAWCETT
prises studies using interview and self-reported survey data by
owners and managers. ere are critiques of both the meth-
ods used and the underlying theoretical assumptions from re-
searchers in that tradition, and from those outside (Sorrell et
al., 2011; Banks et al., 2012). To highlight one methodological
problem, in their sample of Italian SMEs for example, Trianni
and Cagno (2012) unsurprisingly nd that their interviewees
reported that ‘lack of managerial awareness’ was their least sig-
nicant barrier, compared to access to capital or information
on investment payback times relating to energy ecient tech-
nologies. It seems unlikely that owners and managers would
identify their own lack of awareness as a signicant barrier, as
it is dicult to have insight into personal unawareness. e va-
lidity of self-reported barriers is open to question, particularly
as an isolated form of evidence. More signicantly, if policy
makers share the ‘rational economic actor’ model of SMEs,
then policies will be designed to overcome barriers found by
research. If this framing only gives a partial account of decision
making, removal of the barriers identied is unlikely to deliver
the anticipated improvement in energy eciency.
ere is evidence showing that non-economic factors can
be important in SME decisions on energy. For example, envi-
ronmental values can be a signicant factor for motivating ac-
tion on energy eciency, and the attitudes of individuals can
have greater signicance for SMEs than for larger organisations
(Williams and Schaefer, 2013). However, one of the problems
for all empirical research on SMEs is that given their breadth
and diversity, it tends to be limited in scale and geography, fo-
cusing on individual sectors. What is true for one SME sector,
may not be true for others. Whereas pro-environmental values
were found to be signicant in a small sample of SME owner
managers (ibid.), a survey of IT professionals found that envi-
ronmental issues were factored into investment decisions less
frequently for SMEs compared to larger organisations where
decision making is comparatively more structured and proce-
dural (Quocirca, 2016).
A UK government commissioned report adds depth to a lit-
erature focused on drivers and barriers. Building on the energy
eciency ‘paradox’ (DeCanio, 1998) which uncovers ways in
which enterprises do not behave according to rational eco-
nomic principles, Banks et al. (2012) develop a more complex
model for energy behaviours and decision making processes in
non-domestic organisations (of all sizes, not just SMEs). ey
argue that energy behaviours and eciency investments are
embedded in the ‘socio-technical landscapes’ of organisations,
which in turn are framed by broader social, material, market
and regulatory domains. is model can help explain empirical
evidence of economically ‘irrational’ behaviours, such as that
from a recent study of SME tourism businesses in the south
west of England, where energy management was largely absent
as a practice, despite energy representing a signicant cost base
for many surveyed businesses (Coles et al., 2016). While Banks
et al’s model helps to build a more complete picture of the mul-
tiple factors contributing to decision-making by SMEs, it does
not easily lead to simple policy solutions. However, the report
did make a number of suggestions for policy, including: making
energy use more visible and salient; highlighting the strategic
importance of eciency investments; focusing policy on the
earlier stages of decision-making - noticing opportunities and
assembling options.
It is beyond the scope of this paper to more fully debate the
dierent implications of these decision-making models to pol-
icy design. e barriers model is probably still most inuential
in policy-making, albeit with increasing interest in more com-
plex explanations of organisational behaviours around energy.
For the remainder of the paper, policies, which are based on
dierent models of decision-making, are explored equally.
Energy policy approaches
When compiling a list of national and European level policies
aimed at reducing GHG emissions from organisations, three
categories emerged. Firstly, ‘universal’ policies include promot-
ing smart technology, innovation or raising eciency standards
for all organisations including SMEs. e second is focused on
the organisation as unit, usually taking the form of taxes and
regulation, with a minimum size threshold excluding most or
all SMEs. A third category of policy includes instruments for
SMEs directly, usually in the form of information or incentives
such as funding and advice. is section expands on these cat-
egories with reference to energy policy in the UK and France.
UNIVERSAL POLICY APPROACHES
Universal policy rarely focuses on the organisation as the tar-
get for regulation, tax or incentives, but most oen addresses
products, markets, infrastructures and technologies. SMEs,
like larger organisations and householders, are included in
the scope of these policies. e EU’s eco-design and energy
labelling directive is one example, where minimum eciency
standards are applied to energy consuming products used by
all sectors of the economy, such as air-conditioners, refrigera-
tors and lighting appliances. Similarly, the Energy Performance
of Buildings Directive (EPBD) sets standards for eciency in
new buildings - domestic and commercial - and requires the
publication of energy performance certicates when premises
are advertised for sale or rental.
e uptake of smart technologies has been identied by the
UK government as holding potential for energy eciency, rep-
resenting a potential £8.6bn (€10.2bn) savings for SMEs in the
UK (DECC, 2016). e report identies seven signicant smart
technologies suitable for SMEs, including integrated building
management systems (IBMS), remotely managed demand re-
sponsive equipment and eet management soware. It nds
greatest potential in the accommodation and food service sec-
tors, which consumes signicant quantities of energy for space
heating, food processing and transportation.
Despite not being identied as one of the technologies with
greatest potential in the UK government report, smart meters
are being rolled out as a major universal policy, aecting all
domestic dwellings and non-domestic buildings.
Most large or-
ganisations in the UK have already installed smart or advanced
meters, so SMEs are at the heart of the UK roll-out, which aims
to be complete by 2020. France has a similar smart meter de-
ployment programme, and the approaches to these policies
reect the dierent traditions of the two countries. Whereas
in France the regulated network operator is named as the re-
sponsible authority for implementing the roll-out of smart me-
ters, UK electricity suppliers are mandated to install all smart
meters. France has selected a single device called ‘Linky’, and
plans to deploy 35 million before the end of 2022, while the UK
Contents Keywords Authors
1-353-17 HAMPTON, FAWCETT
192 ECEEE 2017 SUMMER STUDY – CONSUMPTION, EFFICIENCY & LIMITS
1. FOUNDATIONS OF FUTURE ENERGY POLICY
regulator has permitted competition amongst suppliers, each in
the process of distributing their own branded devices.
Energy market design forms an important part of the na-
tional context within which SME policy is set. e key impact
of energy markets on SMEs will be on energy prices. Compari-
sons of national statistics on prices paid by SMEs are not avail-
able. Using the prices faced by both households and industrial
consumers as a proxy, the data show gas prices are similar in the
UK and France, but electricity is signicantly cheaper in France
(approximately 50% cheaper for industrial customers in 2015)
(Eurostat, 2016)1. Other market eects on SMEs could include:
the incentives available for generating energy or engaging in
demand response; the prevalence of ESCOs; and whether in-
novations in energy supply and service are encouraged.
ORGANISATIONAL ENERGY POLICY DESIGNED TO EXEMPT SMES
A number of policies set at the national and EU level are de-
signed to target large organisations, and exempt smaller en-
ergy users. e EU Emissions Trading Scheme (EUETS) for
example, seeks to limit emissions from the largest energy-using
installations, such as power stations and industrial plants, while
the UK’s Carbon Reduction Commitment (CRC) – a manda-
tory carbon reporting and pricing scheme – requires only
businesses consuming more than 6,000MWh of electricity per
year to participate. Article 8 of the Energy Eciency Direc-
tive (EED), transposed into national law as France’s Manda-
tory Energy Audit programme and the UK’s Energy Savings
Opportunity Scheme, requires only large enterprises to carry
out regular energy audits. While the rationale of focusing on
the largest energy consumers to deliver the greatest change at
minimal administrative cost is reasonable, the scale of change
required to meet the EU’s 40% GHG reduction target by 2030
(UNFCCC, 2015) means that excluding the collectively signi-
cant contribution from SMEs poses a risk to policy-makers.
While policies such as the EUETS and CRC exclude all
SMEs, another major UK policy – an energy tax called the Cli-
mate Change Levy (CCL) – does aect many SMEs. e CCL
exemption threshold is low meaning that a large number of
SMEs therefore pay the CCL (Enerdata, 2014)
2
. Very signicant
reductions in Levy rates are available for signatories to Climate
Change Agreements (CCAs)3 (Environment Agency, 2014).
However it is likely that the majority of SMEs do not benet
from these reductions, as industries which are dominated by
SMEs such as construction, vehicle repair and maintenance
and those oering professional services are not represented by
CCAs. us, while the smallest SMEs are excluded from the
scope of this policy, most have to pay tax at the full rate and
cannot participate in a reduction scheme designed to benet
larger businesses.
Public policy tradition varies between France and the UK,
with the former typically implementing policy from the ‘top
down’, with central agencies responsible for administering
1. Market design is far from the only influence on price: underlying costs due to
fuels, electricity generating technologies and infrastructure are clearly critical, as
are government decisions on taxation and levies.
2. This tax is payable on gas (0.195p/kWh, €0.22c/kWh) and electricity (0.559p/
kWh, €0.64c/kWh) consumption for all businesses using more than 4397 kWh/
month and 1000kWh/month respectively.
3. Signatories’ CCL payments are reduced by 90% for electricity and 65% on other
fuels based on commitments to energy and emissions reductions.
regulation; as opposed to publicly funded non-governmental
organisations and market based mechanisms more common
in the UK. is is typied by an example of resource eciency
policy (where energy is a key resource) - the Producer Respon-
sibility regulations. In force since 1997, the UK’s Packaging
Regulations have helped to substantially increase recycling
rates by placing obligations on manufacturers, processers,
wholesalers and retailers of packaging products. A complex
market structure was created to share the burden of responsi-
bility, and a market established for trading recycling certicates
for each of seven packaging materials (paper, plastic, glass etc),
with 50organisations registered with the Environment Agency
as approved ‘compliance schemes’. France on the other hand
implemented the EU Directive from the ‘top down’, with only
one government-run scheme administering compliance and
collecting fees from producers to subsidise the recycling of
packaging waste. Given the complexity of compliance in the
UK model, small contributors – dened as handling less than
50tonnes of packaging and with a turnover of less than £2m
(€2.4m) – are excluded from the regulations. In France on the
other hand, where compliance is administratively straightfor
-
ward, companies of all sizes handling packaging are required
to register and contribute towards its recycling subsidy. is
example of resource eciency regulation shows how the dif-
ferent traditions of policy design can inuence SMEs; where
compliance is considered administratively burdensome, small-
er producers are excluded.
TARGETED SME ENERGY POLICY
SMEs are directly aected by universal policies which address
technologies, appliances or markets as their focus, whereas
when energy policy is designed to target the organisation as
the obligated entity, SMEs are oen excluded from scope. is
leaves a policy gap relating to the signicant consumption of
energy by SMEs. Table 14 describes energy policy measures
designed specically to target SMEs. Data is drawn from the
ODYSSEE-MURE project, which produces a database of en
-
ergy eciency data and policies across the EU, including classi-
fying SME measures (ODYSSEE-MURE, n.d.). Consistent with
the narrative of cutting red tape for SMEs, energy policies for
smaller organisations are largely designed as ‘carrots’, including
incentive schemes and information provision. No ‘sticks’ such
as taxes, regulations or standards exclusively designed for SMEs
could be identied across the EU, although as discussed above
in relation to the Climate Change Levy in the UK, exemptions
may systematically exclude SMEs.
In the UK and France, SME policy is led by the idea of
‘business support’, with a focus on economic growth, job
creation and skills development. In the UK, business support
is characterised by continual reform, including the creation
and dissolution of a plethora of publicly funded national and
local organisations. Blackburn (2012) describes how the na-
tional ‘Business Link’ programme and the Regional Develop-
ment Agencies were continually restructured throughout the
4. Non-domestic Smart Meter roll-out: Situation diers in France as gas meter roll-
out not mandated. Regulated Network Operator (ERDF) is responsible for funding
roll-out (as opposed to suppliers). Although this may be considered a universal
policy approach, in practice SMEs are targeted as nearly all larger organisations
have smart meters installed.
Contents Keywords Authors
1. FOUNDATIONS OF FUTURE ENERGY POLICY
ECEEE SUMMER STUDY PROCEEDINGS 193
1-353-17 HAMPTON, FAWCETT
1990s and 2000s, leading to a complex marketplace ‘crowded
with initiatives’. e Business Link service was closed in 2011
and Local Enterprise Partnerships (LEPs) have since become
increasingly inuential, supported with signicant resources
by central government and administering European Struc-
tural and Investment Funds, worth €10.8bn (£9.1bn) from
2014–2020. Economic growth remains at the heart of busi-
ness support strategy, with the 39LEPs mandated to produce
‘strategic economic plans’ which include transport, skills and
inward investment strategy. Energy and environment feature
sporadically in LEP strategies, but is sometimes attached to
funds they are responsible for handling, such as the European
Regional Development Fund (ERDF), which has a funding
stream for supporting SMEs in ‘the shi towards a low car-
bon economy’. With its priorities set at the EU level, ERDF
represents the single largest source of funding for SME en-
ergy eciency in both the UK and France, with over €769m
(£650m) awarded to date for sustainable development and
risk prevention projects in France alone (L’Europe s’engage
en France, n.d.).
As illustrated in Table 1 the majority of policy designed
with SMEs at the centre takes an incentive based approach,
with a large proportion of ‘business support’ taking the form
of grants, loans or face-to-face advice. In the UK, business
support policy has had varied success. e Richard Report
(2008) heavily criticised business support programmes op-
Table 1. Energy eciency policies focused on SMEs in France and the UK.
Policy type
Policy sub-type
Policy Detail
Incentives
Business
Support
initiatives:
e.g. Grants,
loans, advice
FR&UK: The European Regional Development Fund specically targets SMEs, with a
focus on sustainable growth and job creation. Regional projects focus on local needs,
for instance reducing reliance on vehicles, saving time, money and emissions (Hampton,
2016a).
UK: Local Enterprise Partnerships are handling increasingly signicant funds, with a
focus on delivering local growth. Many offer direct support to SMEs (e.g. through EU
funding), including energy efciency advice, grants and loans.
UK: The Energy Saving Trust is funded by government to provide advice, including to
SMEs. Loans are available to Scottish SMEs.
UK: The Carbon Trust hosts an SME network and offers nance and training for energy
efciency.
FR: ADEME’s ‘Investment for the Future programme’ (“Investissements d’Avenir”:
Includes various schemes:
‘SME Initiatives’ funds innovative SMEs are funded (up to €200,000 granted over 3
years).
Ecotechnologies Fund is an SME equity investment fund worth €150m.
FR: Energy saving certicates (Energy Efciency Obligation Scheme): A list of energy
efciency products may be paid for with a low interest loan.
FR: Green Loans: Loans (up to €5m) have low interest rates, and require no guarantee.
Used to nance energy efcient or less polluting process or manufacturing eco-products.
Information
provision
Energy
efciency advice
and publications
UK: DECC’s ‘SME guide to energy efciency’ provides simple advice on low-cost
measures in non-domestic buildings.
FR: ADEME provides information targeted at businesses on energy efciency, reducing
pollution, transport management and renewable generation.
UK: Energy utilities are increasingly offering energy savings advice to SMEs (as required
by their licence to operate).
Technology
adoption
Non-domestic
Smart Meter
roll-out
UK: Energy suppliers are mandated to install smart meters in all non-domestic properties
by 2020. Anticipated benets include 2.8% energy reduction from improved energy
management.
Contents Keywords Authors
1-353-17 HAMPTON, FAWCETT
194 ECEEE 2017 SUMMER STUDY – CONSUMPTION, EFFICIENCY & LIMITS
1. FOUNDATIONS OF FUTURE ENERGY POLICY
erating under the Labour government (1997–2010), nding
that only 34% of local schemes had been evaluated in any
way, and that only 0.5% of small businesses both used and
were satised with government funded support services. De-
spite its national scope and branding, Business Link services
achieved between 1 and 20% market penetration between
2005/6 and 2010/11 (Blackburn, 2012). Such gures appear
to illustrate the failure of business support approaches to SME
policy, but may in fact be a reection of targeted approaches.
With economic growth and job creation at the heart of busi-
ness support policy, many programmes are specically tar-
geted at businesses with employees (32% of all businesses),
and some further focusing on those with the greatest growth
potential (ibid.). Business Link identied ‘Growth’ and ‘Cor-
porate Growth’ businesses, dening these as ‘critical to the
productivity agenda [requiring] pro-active and intensive re-
lationship management by Business Link’. In contrast, more
than 2.5m ‘Lifestyle’ businesses were identied, characterised
as providing the ‘lowest opportunity for value upli in terms
of each individual business and the UK’ (Business Link Seg-
mentation Model 2005–06, cited by Blackburn, 2012). ese
approaches to targeting growth-oriented businesses continue
to dominate the strategic plans of business support organisa-
tions such as LEPs, inuencing the ways that energy eciency
incentive programmes are implemented.
Despite the signicant provision of incentive-based policy
for SMEs, little eort is made to quantify and aggregate emis-
sions and energy savings brought about by business support
initiatives at the national scale, and neither the UK or French
Article 7 submissions – setting out how national energy savings
targets will be met under the EED – include any reference to
SME business support policies (European Commission, 2016).
In the ex-post evaluation of the 2007–2013 ERDF programme
which included an estimate of 152,219jobs created, the only
mention of CO2 emissions savings was in a small scale case
study, despite being a strategic priority (European Commis-
sion, 2016). If incentive based schemes such as those funded
by ERDF were to be quantitatively evaluated and formally in-
cluded in the UK’s energy reduction targets, they may benet
from greater prominence, monitoring by central government
and rigorous evaluation. Such an exercise would pose a signi-
cant challenge however, as estimates of emissions savings for
projects delivered at the local level oen fail to follow carbon
accounting principles (Hampton, 2016a).
Discussion
Energy policy focused on the organisation as the target unit in
the UK and France frequently includes minimum thresholds
and exemptions for SMEs, particularly in relation to taxes and
regulatory instruments. is is strongly inuenced by a nar-
rative, which seeks to minimise red-tape for SMEs, acknowl-
edging their comparatively lower administrative capacity. e
approach to policy making seems similar in both countries,
with EU-level policy obviously being inuential in reducing
national dierences. However, the UK’s more market-focused
approach to policy design can increase complexity, and result
in SMEs being exempted from policy initiatives (e.g. recycling
of packaging). Where eorts are made to plug the gap created
by regulatory exemptions, these are led by ‘carrots’ such as in-
centive schemes, advice and information provision. However,
the fact that energy and emissions savings from these policies
are not included in national targets suggests that there is little
pressure from central government to rigorously and quantita-
tively evaluate and aggregate impacts.
is discussion builds on these ndings by presenting two
distinct arguments. Firstly we argue that while ‘carrot’ ap-
proaches are crucial for reducing emissions from SMEs, these
are not sucient to achieve the scale of carbon reductions re-
quired to meet the EU’s emissions reductions targets. Universal
approaches such as building regulations and product standards
present opportunities for extending energy eciency through-
out the economy, but usually involve hard-fought legislation.
Approaches, which focus on smart technologies, building
tenancy infrastructures or business practices may help policy
makers at the national level to target policies at SMEs in ways
which avoid additional administrative burden. Second, we ar-
gue that while incentive based programmes, which target SMEs
are essential, questions remain over the ways in which these are
delivered by business support organisations, which primarily
exist to promote economic growth and job creation. We argue
that low carbon initiatives and energy eciency programmes
are ‘bolted-on’ to these priorities, meaning that SMEs with sta-
ble business plans are deprioritised, and ‘contradictory’ eects
may arise (Marsden et al., 2014).
POLICY FOCUS AND FRAMING
SMEs are less likely to be excluded from policy when the unit
of focus is not the organisation, but technologies, products,
accreditation or buildings. ese policies are more politically
palatable than taxes and regulations placed on businesses and
can have signicant impact on emissions reductions (Euro-
pean Commission, 2015). erefore, in the design of such ap-
proaches, the target of the policy becomes crucial. Table 2 sets
outs a number of ways in which energy policy can dene its
unit of focus.
Table2 shows that there are a number of options for policy
makers to design approaches other than by focusing on char-
acteristics of organisations such as size, sector, location or busi-
ness strategy. As a diagnostic category, size highlights the nature
of the SME energy policy gap, but as organisations with fewer
than 250employees are so diverse, it is not an adequate basis on
which to designing eective solutions. As described in section
3.2, the number of policies targeting the organisation as the
unit of focus which exclude smaller users implies that seeking
alternative approaches may oer potential to include SMEs in
scope, and help to close the policy gap.
Alternative policy approaches serve dierent purposes.
When focused on individual technologies, problems, or
building types, policy is driven by particular outcomes, such
as increasing the proportion of distributed renewable energy
generation, reducing air pollution in urban areas, or increas-
ing eciency in space heating or lighting. Although such
pro-environmental policies inevitably face resistance from
a variety of sources such as industry incumbents, the lobby
which seeks to protect SMEs from burdensome regulation is
not mobilised to the same degree as when policy targets or-
ganisations. For example, whereas the UK roll-out of smart
meters is set to cost more than £10bn (€11.8bn) in total, op-
position from SME representatives has been limited. Empha-
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ECEEE SUMMER STUDY PROCEEDINGS 195
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sising the benets of greater control and cost saving potential,
as well as capitalising on the opportunity for energy advice
to be oered during installation have helped to gain support
from SMEs, and may oer insights for the promotion of other
smart technologies such as Integrated Building Management
Systems (IMBS).
e ‘split-incentive’ is a signicant barrier to energy ecien-
cy investments for SMEs occupying non-domestic premises
(DECC, 2014), and so segmenting on the basis of legal status
of building tenancy can help to direct policy instruments tar-
geted at overcoming this principle-agent problem. Focusing
on legal infrastructure cuts across organisational size catego-
ries, as large businesses are also aected, such as retail chains
leasing large numbers of small properties (Janda et al., 2016).
Green leases represent one possible way through this ‘wicked’
problem for businesses of all sizes, and could be promoted by
local or national government, for instance by using their own
purchasing power to introduce the practice (ibid).
Table 2. Options for energy policy focus.
Segmentation
approach
Detail and examples
Size of organisation
The EU SME denition differentiates between sizes based on employee numbers: Micro <10
employees; Small 10–49 employees; Medium-sized 50–249 employees; Large >250 employees.
Sector
Trade associations seek to represent businesses in sectors such as construction, retail and
manufacturing. However, SME representative organisations tend to be seen to represent SMEs
across sectors, and there are few examples of SME specic sector associations.
Location
This segmentation approach is dominant in the UK as Local Enterprise Partnerships explicitly
address economic challenges and strengths in the local geographic area. Regional Councils and
Chambers of Commerce provide business advice in France.
Business strategy
Organisations can be segmented according to their plans for growth. Business Link in the UK
for example developed approaches to identify businesses with most job creation and growth
potential.
Building type
The UK Building Energy Efciency Survey (BEES) gathers evidence on energy use in non-
domestic buildings, accounting for size and sector of business occupants.
Building regulations in France and UK set energy efciency standards.
Technology
Renewable generating technologies are supported by policies such as feed-in-tariffs and the
renewable heat incentive.
Product standards target energy consuming technology such as vacuum cleaners and
refrigerators.
Problem-focused
Waste regulations, including producer responsibility and landll tax incentivise recycling as an
environmental practice.
Low Emissions Zones in urban areas are enforced to reduce air pollution.
Data availability
Energy data availability is variable for SMEs (Janda et al., 2014). Whereas some organisations
have advanced or smart metering capability and an employed energy manager, others have
legacy meters and no energy analysis.
The smart meter roll-out directly addresses elements of this discrepancy.
Legal infrastructure
Janda et al (2014) argue that owner occupiers, landlords and tenants vary signicantly in relation
to energy practices and investment potential.
Practice
Powells et al (2015) call for a focus on common business practices, including how technology
and spaces are used, and the role of knowledge, skill and organisational meanings in energy
consumption.
Determinants of
behaviour
Anable et al (2015) seek to segment business travel by looking beyond the behaviour, to the
determinants and drivers. These include aspects of organisational culture, governance and
strategic mission.
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1. FOUNDATIONS OF FUTURE ENERGY POLICY
Recent academic work has suggested that an attention to
business practices, and the drivers behind behaviours may help
to produce eective policy. With increasing proportions of in-
termittent renewables on the electricity grid, there are nancial
and emissions-based benets from increasing exibility on the
demand side. Realising the potential £8.6bn (€9.9bn) savings
resulting from the use of smart technologies as identied by
the UK government depends however on the integration of
smart technologies into energy users’ existing practices. Look-
ing in depth at SME activities for example, Powells et al. (2015)
identify exibility in some everyday business practices, such as
those reliant on mobile ICT technology, or heating practices
and rigidity in others. e growing use of portable ICT equip-
ment, ‘cloud-based’ systems and even storage-heating may en-
able SMEs to take advantage of time-of-use taris and partake
in ‘active network management’ in future smart grids. In-depth
social scientic studies such as this may help policy makers to
target instruments at particular practices, rather than approach
the organisation as the focal unit, potentially encountering re-
sistance to red tape.
One practice relevant to a large proportion of SMEs is work-
ing from home, which is undertaken by more than 25% of the
workforce in the UK, and 19% in France. A number of stud-
ies have sought to quantify the energy and environmental im-
pacts of the practice, nding potential savings of up to £3bn
(€3.55bn), and over 3m TCO2e in the UK (Carbon Trust, 2014).
However, the environmental benets of home working depend
on a number of variables, including the length of the commute
and the exible use of oce space by employers, meaning that
the precise circumstances of telework can inuence net energy
demand (Banister et al., 2007). Based on interviews with a sam-
ple of UK workers, one study indicated that home workers may
be likely to tolerate lower ambient temperatures when working
from home, and are likely to conduct energy using practices
such as laundry during the working day: both of which have
potential benets for the electricity system (Hampton, 2016b).
Designing public policy which intervenes in behaviours in the
domestic setting is problematic both practically and politically,
and encouraging working from home may therefore be best
pursued as intra-corporate policy. Nonetheless, examples exist
of central government initiatives to support the spread of ex-
ible work, including the UK Department for Transport’s (DfT)
‘Anywhere Working’ initiative. Social scientic energy research
can contribute to these initiatives by highlighting the factors
with most impact on energy and emissions savings.
For SMEs in the service industry, transport is likely to rep-
resent a signicant proportion of energy consumption. In
a report commissioned by the UK DfT, Anable et al (2015)
argue that research on travel behaviour oen focuses on the
question of ‘why do you travel’, leading to narrow insights
based on individual motivation and conscious choice. is
in turn leads to policies dominated by the tradition of behav-
ioural economics or ‘nudge’, which has been found to have
limited impact on travel behaviours (Behavioural Insights
Team, 2017). e authors instead identify a need for policy
to address the wider ‘determinants of [business] travel behav-
iour’, which include contextual factors such as the economic,
social and regulatory operating environment, an individual
company’s mission, degree of employee autonomy and deci-
sion-making hierarchies.
Practice-based analyses typically provide policy recommen-
dations which imply a need for wide-reaching mechanisms that
cut across the boundaries of government departments’ juris-
dictions, and can be problematic for civil servants wishing to
develop and deliver policies inuencing SME travel with lim-
ited budgets and scope for intervention. For example, Eadson
(2014) appeals directly to business support policy makers in
proposing that pro-environmental behaviours could be fos-
tered through better engagement by SMEs within local civil
networks. However, the realisation of these measures would
require coordination beyond business support networks, in-
cluding local community groups, the charity sector and local
government. Further, although the social and spatial embed-
ding of SMEs may help to foster sustainable mobility practices,
these are priorities that are primarily supported by the DfT
rather than the Department for Business, Energy and Indus-
trial Strategy, implying a need for cross departmental support
and evaluation.
Given the scale of the challenge of meeting the emissions re-
ductions targets set during the Paris climate agreements, there
is certainly a case for radical changes to be made in the design
of policy. Stopping short of a policy paradigm shi however,
the alternative focuses identied in the examples above point
to smaller scale opportunities for intervention. Smart technolo-
gies such as IBMS and eet management represent areas for
policy makers to explore further, having already been identied
as having potential for nancial and emissions savings. Green-
leases, potentially introduced through government building
portfolios, may help to address the ‘split-incentive problem’,
oen cited as limiting the capacity for SME building tenants to
implement eciency savings. Finally, promoting the practice
of working from home and supporting SMEs to become more
embedded in local communities oer further potential.
BUSINESS SUPPORT AND THE GROWTH AGENDA
As illustrated in section 3.3, business-support represents a sig-
nicant proportion of the incentive-based policies targeted at
SMEs. In the UK, the ERDF represents the single largest source
of funds for SMEs, and in the 2014–2020 programme in Eng-
land, €792m (£670 m) has been allocated to supporting the
‘shi towards a low-carbon economy’, with a further €1.4bn
(£1.2bn) to support SME competitiveness (European Com-
mission, n.d.). Local Enterprise Partnerships are responsible
for distributing these funds through energy eciency pro-
grammes, which are designed and delivered according to the
priorities set out by LEPs’ ‘strategic economic plans’. As such,
energy eciency tends to be couched in the narrative of ‘re-
source eciency’, leading to maximal prot (OBS, n.d.), while
the low carbon sector is promoted on the basis of its above-
average growth and job creation potential (WOELEP, n.d.).
While there is merit in integrating energy eciency into exist-
ing networks of business support delivery, there are potential
pitfalls associated with this approach.
e rst is that the reach of energy eciency programmes is
inevitably inuenced by existing networks of advisors, attract-
ing well-networked, externally focused and growth-oriented
businesses (Open University, 2013). SMEs less likely to be
reached include those with business plans prioritising stability
and consolidation, and those operating for more than 5years.
From an energy perspective, an assumption worthy of empiri-
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1. FOUNDATIONS OF FUTURE ENERGY POLICY
ECEEE SUMMER STUDY PROCEEDINGS 197
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while others are at a very exploratory stage. We have brought
together a list of SME-specic policies from the UK and France
to show what is already in place.
Whichever focus or focuses are used, a signicant propor-
tion of SME energy policy is based on the provision of infor-
mation and incentives, primarily delivered in both the UK and
France by regional business support organisations. While of-
fering benets in terms of using existing networks and known
brands, there are disadvantages in that these organisations
tend to support only certain types of SMEs - and not necessar-
ily those with the greatest opportunity for energy savings. In
addition, their central goals are based on growth, rather than
promoting a lower carbon, more energy ecient economy.
It is clear that there are a number of challenges to design-
ing and implementing eective energy policy for SMEs, but
we have suggested that addressing this group as a whole may
not oer the best solutions. For the future, there is a clear need
for the improved evaluation and monitoring of local energy ef-
ciency programmes. Reliable, quantitative data, aggregated
at a national scale would help to formalise the SME contri-
bution towards energy eciency, leading to greater attention
from policy makers with a national remit. Energy researchers
from positivist traditions can help in these eorts. ere is also
a need for further research into the policy implications of al-
ternative units of focus; in highlighting opportunities in areas
such as building tenancy or working from home, social scien-
tists can help to support policy makers in bringing the benets
of energy eciency to SMEs.
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