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ECEEE INDUSTRIAL SUMMER STUDY PROCEEDINGS 151
White certificates as a tool to promote
energy eciency in industry
Dario Di Santo
FIRE – Italian Federation for the Rational Use of Energy
Via Anguillarese 301
00123 Roma
Italy
disanto@fire-italia.org
Enrico Biele
FIRE – Italian Federation for the Rational Use of Energy
biele@fire-italia.org
Daniele Forni
FIRE – Italian Federation for the Rational Use of Energy
forni@fire-italia.org
Keywords
white certicates, energy eciency obligation, industrial ener-
gy saving, ESCO market development, cost-eective measures,
energy eciency assessment, additionality
Abstract
White certicates (WhCs) or, more generally, energy eciency
obligation schemes (EEOs) are used in many EU countries as a
policy measure to reach energy eciency targets. Some of the
rst schemes (UK, Italy, France, Denmark) have been capable
to reach positive results over the years, although with impor-
tant dierences, as clearly demonstrated by the IEE ENSPOL
project. Only the Danish and the Italian schemes show a pre-
dominance of industrial projects.
e Italian scheme, in particular, in the last three years has
produced 80% of the white certicates from the industrial sec-
tor. e energy savings are transformed in certicates keeping
into account the additionality, with respect to the market and
regulatory baseline, and the technical lifetime of the project
(through the so called tau coecient). e presence of a trad-
able market ensures an important involvement of voluntary
parties and supported the development of a dedicated energy
service market.
is EEO scheme, which started eectively in 2004, provides
a target of 7.6Mtoe1 of annual savings in 2016 and showed a
progressive shi from the tertiary and household sectors and a
prevalent use of simplied procedures for the assessment of en-
ergy savings, to the industrial sector and a predominant use of
1. Toe: primary ton of oil equivalent. In the Italian scheme it corresponds roughly
to 5.3MWhe and 11.6MWht.
metered savings procedures. e scheme is thus an interesting
example of a policy measure capable of achieving signicant
results in the industrial sector and it could be useful to analyse
the main design rules that inuenced this result.
Based on FIRE2 activities and experience, with a focus on
the industrial sector, the paper will illustrate the main facts and
results and how additionality, non energy benets at system
level, certicates trading, scheme costs, and measurement and
verication procedures have been dealt with. e paper will
also address the issues that will lead to a major redesign of the
Italian scheme in 2016.
Introduction
e 2012/27/EU directive on energy eciency (EED) dedicates
article7 to the energy savings targets and support schemes.
In particular Member States are required to save 1.5% annu-
ally with respect to the total energy sold to nal costumers by
distributors or by all retail energy sales companies, averaged
over the most recent three-year period prior to 1 January 2013.
Member States have the possibility to exclude transport and
companies under the emission trading scheme. In order to
reach this target Member States shall either impose an obliga-
tion to some parties (e.g. distributors, traders, nal users, etc.)
2. The Italian Federation for energy eciency – FIRE – is an independent non-
profit organization founded in 1987, whose purpose is to promote the ecient use
of energy.FIRE has around 450 members, which cover all the energy sector (e.g.
energy eciency technologies producers, power producers, distributors, ESCOs,
large and medium enterprises, universities and research centers, energy manag-
ers and energy professionals). Since 1992 FIRE manages the Italian energy man-
ager network on behalf of the Ministry of Economic Development. For information:
www.fire-italia.org/fire-in-english.
1-141-16 DI SANTO ET AL
152 INDUSTRIAL EFFICIENCY 2016
1. POLICIES AND PROGRAMMES
through an EEO scheme, or adopt alternative measures (e.g.
nancial schemes, loans, carbon taxes, voluntary agreements,
etc.), or a mix of both.
e ENSPOL project (www.enspol.eu)3, which lasted from
2014 to 2016, was dedicated to the analysis of all the EU sup-
port schemes covered by EED art.7, both existing and planned.
Reports and guidelines covering all the aspects of EEO schemes
and alternative measures (e.g. obliged parties, measurement
of energy savings, baseline and additionality, controls, costs,
etc.) are available in the project website [13,19]. Besides a web
platform (www.article7eed.eu) is available to confront the dif-
ferent schemes or go into details of a single measure. Both the
ENSPOL website and platform are useful resources for experts
and practitioners interested in EE support schemes and people
interested in these topics, but not already familiar with them,
are strongly encouraged to access the ENSPOL resources prior
to read this paper.
is paper is based on the activities implemented by the au-
thors in FIRE about energy eciency policies and in particular
white certicates4. Besides being partner of the ENSPOL pro-
ject, FIRE is also involved in the EU-MERCI project (www.eu-
merci.eu), aimed at analysing the industrial case studies collected
through some of art.7 EED schemes and disseminating and
promoting the best practices. e paper will briey summarise
the basis of the Italian WhC scheme, illustrate the main results
obtained since its creation in 2001 and eective launch in 2004
– with a focus on the role of the industrial sector –, and go into
details about how the scheme deals with the main issues related
to EEO schemes. Aerwards, the paper will explain some of the
problems the scheme incurred during the last three years and in-
troduce the new guidelines that will be released in 2016 in order
to proceed towards the 2020 target. e conclusions will show
the importance of a continuous improvement approach to reach
the best results with complex schemes such as the Italian WhCs.
3. FIRE was the Italian partner of the ENSPOL project, financed under the Intel-
ligent energy for Europe programme.
4. The activities performed by FIRE about WhC: participation in institutional work-
ing groups and auditions, management of the national WhC observatory in coop-
eration with GSE, surveys, researches and advanced training, also in cooperation
with ENEA, information campaigns, also in cooperation with the Ministry of Envi-
ronment, and national annual conferences.
More information on how EEO schemes work and useful
comparisons among them can be found in [1, 2, 3, 5, 6, 9, 12,
13, 14, 15, 18, 19].
Basics about the Italian WhC scheme
e Italian WhC scheme [4, 7, 8, 10, 11, 13, 21, 22] is an EEO
in which the electricity and gas distributors with more than
50,000clients are obliged to reach increasing annual energy
eciency targets (Figure1)5. It is a exible mechanism, since
the EE savings can be obtained through interventions from
market operators (i.e. non obliged distributors, ESCOs, com-
panies with energy manager or energy management system),
managed by GSE6.
White certicates are used to certify the savings and obliged
distributors can buy them from voluntary parties besides ob-
taining them directly. All energy eciency projects in all sec-
tors are allowed. e exchange of white certicates between
obliged and voluntary parties takes place on a dedicated plat-
form managed by the GME7, either as a spot market exchange,
or as a bilateral agreement over the counter. e WhC scheme
can thus work as an incentive for the voluntary parties, consid-
ering that the WhC price can vary over the time and that there
are no assurances that the certicates can be sold every year8.
Each certicate corresponds to one toe of annual savings. Fig-
ure2 shows the annual target expressed both as number of cer-
ticates and as toe. e dierence between the two values is due
both to the tau coecient and to an increasing amount of savings
that will come from projects that don’t receive white certicates
(e.g. interventions on the electricity and gas grids, savings related
to mandatory energy audits for non SMEs and ISO50001, etc.).
e savings are additional, meaning that only savings over a
regulatory and market baseline are accounted for, and gener-
5. Global targets are split among the obliged distributors considering the energy
delivered in the previous year by each of them.
6. Italian Energy systems manager (public company in charge of operating the
Italian scheme).
7. Italian Energy market manager (public company owned by GSE in charge of the
Italian power exchange IPEX and of environmental and energy eciency markets,
that is emission trading, green and white certificates).
8. In case of oversupply the price of the certificates drops and it can become dif-
ficult to sell the owned certificates.
Figure 1. Basics of the Italian WhC scheme.
1. POLICIES AND PROGRAMMES
ECEEE INDUSTRIAL SUMMER STUDY PROCEEDINGS 153
1-141-16 DI SANTO ET AL
ate white certicates for ve years9. e number of certicates
issued annually is the sum of the yearly savings over the WhC
lifespan and of the savings from the sixth year to the end of the
technology lifespan appropriately reallocated due to the tau co-
ecient, as shown by Figure3 (for further information on the
tau coecient [10, 13]).
e costs incurred by the obliged distributors, being regu-
lated companies, are partially reimbursed through a tari reim-
bursement component dened by AEEGSI10 and linked to the
weighted average price of the certicates in the spot market the
previous year (for more information, see [13, 18]). at means
that the cost of the scheme can be calculated as the product of
the cancelled certicates11 and the tari reimbursement com-
ponent. In 2014 the cost was around 600millioneuros, with
5,8million of cancelled certicates, whereas in 2015 it should
rise around 700millioneuros. e costs incurred by GSE for
information, evaluation and control should be below 10mil-
lioneuros.
Measurement of energy savings
Presently three methodologies for the measurement and veri-
cation of energy savings are used:
• Deemed saving;
• Scaled savings;
• Metered savings.
9. For building envelope projects the duration is eight years and for high eciency
cogeneration, as defined in the EED, ten years.
10. Italian Authority for electricity, gas and hydric systems (in charge of defining
the tari reimbursement for obliged parties and of applying fines in case of un-
reached targets within the Italian WhC scheme).
11. A certificate is cancelled when is presented by an obliged distributor to GSE
to fulfil its target.
e rst one requires no meters and savings are assessed in
terms on installed units. e procedure is simple and white
certicates are issued quarterly and placed on the GME account
of the proponent. Deemed savings have played an important
role in the rst years of the scheme, when they used to account
for over 90% of the savings.
Scaled savings are limited to particular technologies, charac-
terised by a good level of standardization, but also by the need to
link the savings to the eective use. us they provide for an al-
gorithm used to evaluate the savings based on the measurements
derived from dedicated meters12. e baseline and additionality
are evaluated in a standardised way as for deemed savings.
Metered savings require the proponent to present a project
and measurement and verication (M&V) proposal (known
as PPPM in Italy), in which the solution to be implemented,
M&V procedure, consumption baseline and additionality, and
algorithm to evaluate the savings with respect to the metered
quantities are dened. Aer the PPPM is approved, the project
can request the white certicates by communicating – usually
annually or twice a year – the metered quantities, as in the case
of scaled savings.
During the years the role and usage of metered savings has
been increasing, with the important advantage of ensuring that
most of the accounted savings are measured. Figure4 illustrates
the trends of the three M&V methodologies over the years. It is
worth noticing the sudden fall of the assessed savings in 2015,
both for new projects and for the total. is outcome is ex-
plained below, in the main issues paragraph.
Generally deemed saving and scaled savings procedures
worked quite well, requiring in some cases a revision of the
additionality coecient or the withdraw of particular les aer
some years of use to take into account the evolution of the mar-
12. For example, a centralised boiler installed in a oce building requires the
measure of the thermal energy produced and of the fuel and electricity used.
Targetsascer*ficatesandannualsavings
(dataupdatedtoMarch2016expressedasthousands)
Figure 2. Targets over time. The values about 2017–2020 are based on the art.7 EED notification and can vary.
1-141-16 DI SANTO ET AL
154 INDUSTRIAL EFFICIENCY 2016
1. POLICIES AND PROGRAMMES
ket and the diusion of the related technologies (e.g. compact
uorescent lamps, aerators, etc.) [4, 13, 16]. Nevertheless some
particular technologies procedures were characterised by im
-
portant issues. Some of them, such as heat pumps for the resi-
dential sector or natural gas cars, showed little use due to the
cost of the requested documents with respect to the expected
value of the white certicates. Others, on the contrary, had a
large success due to some defects in the requirements, which
translated in undesired eects13.
Metered savings worked quite well, increasing their share
of the total savings over 80%. e main issues that are under
investigation are related to the energy consumption baseline
14
(the new guidelines will introduce stricter requirements on its
calculation) and to the reliability of the installed meters.
Results
e Italian WhC scheme in over ten years has been capable
of producing impressive results in terms of total savings, data
collection, qualication of market operators. e main gures
[16, 20]:
• targets from 200ktoe in 2005 to 7,600ktoe in 2016;
•
over 22millions cumulated savings and 36millions issued
white certicates till 2015;
13. For example, due to a flaw in the UPS file, some rogue traders started giving
low quality UPS for free to end users, aiming at the good margin granted by WhC to
such low cost devices. The file was then withdrawn by the Ministry.
14. Please notice that with “baseline” we refer to the threshold that makes sav-
ings additional (additionality baseline), whereas with “consumption baseline” we
refer to the energy consumption before the energy eciency intervention. The two
baselines can coincide in particular cases, but usually the additionality baseline
is higher as the consumption baseline due to minimum requirements, technology
evolution and market trends.
• ≈85% of savings are metered and ≈82% are metered saving
projects (in 2007 ≈90% were deemed savings);
•
≈62% of the savings assessed in 2015 are related to the in-
dustrial sector;
•
average dimension of each proposal between 300 and
550toe in the last three years;
•
4,693operators registered in 2015 to the GSE platform, of
which 1,233presented projects;
•
ESCOs have been the main actor in presenting projects both
in terms of registered subjects (3,693), proposals (96%) and
toe (70%, whereas 25% come from companies with energy
manager);
• exible managing agencies needed to deal with the growing
proposals (13,717requests for certicates presented in 2014
and 1,034PPPMs VS ≈150 in 2007 and ≈550 in 2012);
•
cost eectiveness is high (0.017 euro/kWh according to
ENEA15 annual report on energy eciency).
Figure5 illustrates the trend of the issued certicates and sav-
ings, compared with the annual targets. In 2015 the average
tau coecient has been equal to2.9 (calculated as total annual
certicates divided by total annual toe). Since the introduction
of this coecient in 2011 the value of annual issued certicates
is no more equal to the value of the savings, due to the anticipa-
tion of future savings.
15. Italian Agency for new technologies, energy and environment (in charge of
information campaigns for WhC and supporting GSE in verifications, audits and
controls).
Figure 3. The tau coecient explained.
1. POLICIES AND PROGRAMMES
ECEEE INDUSTRIAL SUMMER STUDY PROCEEDINGS 155
1-141-16 DI SANTO ET AL
Two eects emerge from Figure5: the drop of certicates in
2015, aer years of continuous improvements, and the reduc-
tion trend of annual savings starting from 2012. e rst is a
consequence of the 2012 guidelines that allowed the presenta-
tion of PPPMs only before the start of the EE project begin-
ning with 201316. e second is most probably due to a mix
16. Previously there was no particular limit: it was for example possible to present
a project implemented even 3–4years before. The reason of this choice is related
to the long time it took to launch the scheme (2005 instead of 2002 as provided
by the first ministerial decrees) and to the need to allow project implemented in
the meantime to access the mechanism.
of factors: completion of the ve years lifespan for many large
projects, less low hanging fruits remain to be collected in the
industrial sector, the evolution of the market reduced the addi-
tionality of some solutions (e.g. heat recovery), the new guide-
lines increased the period of time from the submission of the
PPPM to the request of certicates, the introduction of stricter
rules in the verication and control activities. is decline of
the annual savings is unlikely to be reversed considering the
evolution of these factors. It will be interesting to see if the sav-
ings’ trend will be a continuous decline or a stabilisation in the
next years.
Figure 4. Contribution of the dierent M&V procedures to the total savings.
Table 1. Comparison among the dierent M&V methods.
Deemed savings Scaled savings Metered savings
The method is easy to use and facilitates
the evaluation.
Savings are not measured and
monitoring can be complex if multiple
solutions are considered.
Required documentation: choice to go
easy or bureaucratic, which usually
implies a failure, unless the incentive is
very high.
On eld controls are expensive.
Effort required to evaluate baselines,
additionality, and other needed
information.
High cost-effectiveness.
Possibility to pre-evaluate EE products
in order to ensure the required
performance.
The method is easy to use and facilitates
the evaluation.
Savings are measured.
Required documentation: choice to go
easy or bureaucratic, which usually
implies a failure, unless the incentive is
very high.
On eld controls are usually a viable
option.
Effort required to evaluate baselines,
additionality, algorithms and meters to be
used, and the other needed information.
High cost-effectiveness.
Simplied monitoring plans?
The method is usually complex,
especially if additionality or detailed
adjustments are present.
Savings are measured.
Required documentation: is usually
substantial, but the size of the project
allows it.
On eld controls are usually a viable
option.
Effort required to evaluate baselines,
additionality, algorithms and meters
to be used, and the other needed
information for both the proponents and
the evaluators. Shall data be available
for everybody?
Very exible, but potentially costly and
complicated (viable for high targets).
1-141-16 DI SANTO ET AL
156 INDUSTRIAL EFFICIENCY 2016
1. POLICIES AND PROGRAMMES
It is also worth noticing that the tau coecient didn’t appar-
ently have the eect of accelerating the savings. Figure4 and
Figure5 show that new metered savings proposals started ris-
ing between 2009 and 2010 and didn’t display any acceleration
aer 2011.
Moreover, the introduction of the tau coecient has the ef-
fect to rise the system cost of the saved toe, both in terms of
total costs (increasing the number of years over which the sav-
ings are assessed) and annual costs (anticipating over the WhC
lifespan the savings over the h year). At the same price, an
average tau of2.9 means that the toe that used to cost around
one hundred euros now costs almost three hundred euros. is
can be accepted if it is proved that the multiplier is useful in
terms of presented projects. Something that is dicult to be
conrmed.
An important aspect of the Italian scheme is the trade of cer-
ticates between obliged and voluntary parties. is inuences
both the total cost of the scheme and the possibility of working
as an incentive for ESCOs and end-user companies. Figure6 il-
lustrates the trend of the spot market price over the years17. Re-
garding the liquidity of the spot market, 43% of the certicates
have been exchanged on the real time platform in 2015 and in
the period 1
st
June 2014–31
st
May 2015 9.1millioncerticates
17. Prices varies depending on the saved energy source. The huge dierences
in the first years were due to the obligation for electricity and gas distributors to
fulfil at least 50% of their targets with savings related to the respective distributed
energy sources: the scarcity of certificates linked to gas savings determined their
higher prices. Since 2008 all types of certificates can be used and thus prices are
almost equal (but not exactly the same since dierent types of certificates are
traded separately on the spot market). For further information on this, see [4, 9,
13, 16, 21].
have been exchanged, to be compared with the 6.8millions of
issued certicates and the 6.7millioncerticates of the target
[16]. e price on the bilateral market is quite similar (slightly
lower mainly because of intra-groups exchange at zero or low
price). e drop of certicates in 2015 translated in a strong
increase in the price starting from February 2016. e avail-
able certicates don’t represent an issue in terms of reaching the
exibility thresholds of the distributors’ targets18, but evidently
many operators expect a short market with respect to the 2016
obligation.
Why the industrial sector took the lead
e Italian scheme started with a large majority of projects
related to the civil sector, as usual in almost all the white cer-
ticates schemes. Over the years, as Figure7 shows, the role of
the industrial sector in terms of achieved savings has rapidly
grown, becoming the main sector (in terms of issued certi-
cates the gure is even higher, due to a slightly higher sectorial
tau, over 62%).
e industrial sector started to rise in 2009, with a strong
acceleration in 2012. As stated in the previous chapter, the tau
coecient didn’t apparently accelerate the savings, but had a
clear eect on the participation of the industrial sector to the
scheme. Interestingly, the savings for the industrial sector in
2015 seem to be in the trajectory of a linear growth with the
18. Distributors have time till May31st to present the required certificates. This
is the reason why the white vertical bands are represented in Figure6. Besides,
distributors are fined if they are not able to cover at least 60% of the target for a
given year. The quota of the target that remains uncovered is added to the follow-
ing year target.
Figure 5. Annual and cumulated savings, certificates and targets.
1. POLICIES AND PROGRAMMES
ECEEE INDUSTRIAL SUMMER STUDY PROCEEDINGS 157
1-141-16 DI SANTO ET AL
2009–2011 trend. In between the steep rise can be explained as
the dopant eect of the tau coecient, that helped the indus-
trial enterprises overcoming the perceived barrier of complex-
ity associated with the white certicate scheme.
Moreover, this result could be expected. FIRE, in its reply to
the 2003 consultation to the rst WhC guidelines stated that
the scheme appeared to be biased toward the industrial sector
in terms of simple economics. e reasoning, illustrated in de-
tails in [11], is that the shorter pay-back time in the industrial
sector increases the weight of white certicates with respect to
the investment CAPEX.
e reason of the slow participation of the industrial sector
in the rst phase can be easily explained with the longer time
needed to digest the complexity of concepts like additionality
and to start making some baseline measurements in the pro-
cesses due to energy requalication.
Figure 6. White certificate price over the years and distributors reimbursement value.
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2006 2007 2008 2009 2010 2011 2012* 2013 2014 2015
Breakdownofsavingsamongsectors(%)
(Source:FIREonAEEGSIandGSEdata;2012datarefersonlytoJan-May)
Industry Householdsandservices PubliclighBng Transport
Figure 7. Breakdown of WhC savings among dierent sectors over the years.
1-141-16 DI SANTO ET AL
158 INDUSTRIAL EFFICIENCY 2016
1. POLICIES AND PROGRAMMES
Main issues
An incentive scheme running over a long-time obviously has
to deal with various challenges during the years. e revisions
of the guidelines over the years – in 2004, 2007, 2011, and
2012 – have been essential to overcome such problems in the
past, ensuring the evolution and growth of the scheme. e
introduction of the new guidelines, expected since 2014, has
been delayed for many reasons. e eect is that presently the
scheme is facing some important challenges in the last decade.
e main ones are:
• the reduction of the annual savings;
• the rise of the total cost of the scheme;
• the shared responsibilities between ESCOs and clients;
•
the diculties in evaluating the consumption baseline and
the additionality in the industrial sector;
•
the uncertainty related to the introduction of the new guide-
lines and targets;
• the materiality of the scheme for certain projects.
e rst point has been discussed in the previous chapter. e
rise of the cost of the scheme is not per se a negative eect, since
it can be justied by the rising targets and by more complex
projects. But of course it means that the tari component that
every end-user pays to reimburse part of the costs incurred
by the distributors increase over time. e drop of certicates
in the last year has apparently reduced the cost of the system,
but of course this can be oset by the increase in the white
certicates price. Figure6 shows the increase of the WhC price
in the rst ve months of 2016 due to a number of available
certicates lower than expected by market operators. e eect
has been an increase of the weighted average price from 105to
116euro/toe.
In case of non conformities or other problems concerning a
proposal, with a request to return the money to GSE, problems
can arise if the proponent is an ESCO. e issue can be looked
at from two sides. On the one hand, if an end-user changes
something of the project with respect to the proposal – or,
worse, the plant is being shut down – the ESCO can be harmed
without having the possibility to avoid the issue. On the other
hand, in such cases GSE will request the ESCO to return the
money; money that almost entirely have been forwarded to
the end-user19. is can translate in serious nancial problems
for the ESCO, especially in case of large projects. To reduce
such problems it is fundamental to have adequate contracts in
place between the parties, an obvious consideration that unfor-
tunately many small ESCOs have not taken into account. e
new guidelines will try to overcome this issue, possibly asking
for nancial guarantees (e.g. sureties) for large projects.
e measurement of the energy savings is a complex activ-
ity. Not surprisingly protocols such as the IPMVP20 have been
created over the years. In the case of an EEO and metered sav-
ings, the issue is magnied since a common approach is needed
and it is impossible to opt for dierent level of complexity and
19. ESCOs usually keep a small percentage of the issued certificates, in the order
of some percentage point.
20. For information about the IPMVP protocol: www.evo-world.org.
precision on a case by case method. Besides there is the need
to evaluate the additionality of the single projects, an activity
that can appear relatively easy in the household and service sec-
tors, but that can be quite dicult in the industrial one. Both
these aspects are under discussion: the consumption baseline
since in the last decade sometimes baselines established on an
insucient set of data have been accepted21, the additionality
because there are a lot of variables to be considered and it is of-
ten complex to compare dierent production processes even in
the same industrial sector
22
. Apart from the choices of MiSE
23
in the new guidelines in terms of more precise requirements, it
is fundamental to dedicate time to meetings with the industrial
stakeholder, an approach that GSE has started to adopt in 2016.
e uncertainties about the new targets and guidelines is an
important factor, especially since the more rigorous approach
in terms of verication and control adopted by GSE has disori-
ented many operators. is will be discussed in the next chap-
ter.
Finally, the materiality of the scheme has never been evalu-
ated in details. In the rst phase, with extremely convenient
deemed saving les, the decision to invest in those technologies
was totally driven by the scheme and thus the materiality was
really high. In the last year, with many convenient industrial
projects, there is the possibility that some projects are carried
out just as they are attractive on their own, even without the
additional benet of the white certicates. It is impossible to
evaluate the materiality on the basis of some interviews or eco-
nomic evaluation; nevertheless it is an issue that should deserve
more attention.
Verification and control
As discussed in the previous chapter, verication and control
(V&C) is an important and delicate activity within any EEO
scheme. Most of the measures analysed under the ENSPOL
project don’t have in place strong procedures on this respect,
and most of the schemes consider mainly documental controls
and no or very limited on-site controls. is can be explained
in many cases since most of the admitted solutions are related
to deemed savings in the building sector, something dicult
and costly to approach with on-site controls due to the diuse
nature of the interventions. Nevertheless, this represent an is-
sue since no controls means higher risk of non conformities or
non adequate installations.
For almost ten years in Italy the situation has been similar to
other EEO schemes: all the proposals were subjected to a docu-
mental analysis, but then no on-site controls. e guidelines in-
troduced in 201224 stressed the importance of V&C, requiring a
relevant action both on documental analysis (verication) and
on detailed documental and on-site control. Figure8 represents
the present procedure.
21. That is based on a limited month of ex-ante measurements and on insucient
or questionable adjustment factors.
22. Also the reference to the best available technologies of the industrial emis-
sion directive (IED, formerly IPPC) sometimes is not easy, especially for small and
medium enterprises.
23. Italian Ministry for Economic Development (in charge of defining the Italian
scheme targets and guidelines).
24. Ministerial decree 28December 2012.
1. POLICIES AND PROGRAMMES
ECEEE INDUSTRIAL SUMMER STUDY PROCEEDINGS 159
1-141-16 DI SANTO ET AL
counter informing on the situation in terms of presented, veri-
ed and approved projects is updated on the main GSE website
every week (Table2 shows some data extracted in April 2016).
e main issues incurred in the verication and control pro-
cess are:
•
requests for additional information and/or documentation
not listed in the deemed saving and scaled saving les or in
the PPPMs;
• request for proof of CAPEX of the implemented project and
the cost of energy for PPPMs;
• issues linked to the shared responsibilities;
•
issues related to the closure or modication of plants prior
the end of the technical life.
Verications before the release of 2012 guidelines were mainly
related to the information and documentation indicated in
the les or PPPMs. Aer the introduction of the new guide-
lines, GSE – which assumed the management of the scheme in
2013 – started a more rigorous approach. In particular, many
All the proposals are investigated prior to recognize the re-
quested white certicates. is ensures that the requested doc-
umentation has been presented and that the project is sound
and compliant with the deemed saving or scaled saving les or
with the approved PPPM. GSE can then subject the project to
a documental and/or on-site control. e projects to be con-
trolled are indicated in a plan submitted annually to MiSE.
In 2014 GSE started with 56 controls (11 on-site), includ-
ing high efciency cogeneration. In 2015 the controls raised
to 146 (23 on-site), of which 95 were completed and 59 had
a negative outcome, resulting in an administrative procedure
to recover the money received by the proponents25. In an ef-
fort to increase transparency, GSE created a website to monitor
the results of all the controls, including the ones referred to re-
newable energy sources, CHP, and other support schemes26. A
25. It should be noted that GSE chose categories of projects that were expected
to show issues. So this figure should not be considered a picture of the general
situation.
26. The website is http://bancadativerifiche.gse.it. To give some figure, in 2014
GSE made overall 3,792controls (3,008on-site).
Figure 8. Control and verification process activities. Source: FIRE.
Table2. Status of the proposals presented since 2015 at the end of April 2016.
Proposals PPPM Requests of
certicates Total
Verication completed
Approved
Rejected
Other (suspended, retired or not receivable)
752
467
261
24
10,037
9,622
251
164
10,789
10,089
512
188
Under verication 247 728 975
Total 999 10,765 11,764
1-141-16 DI SANTO ET AL
160 INDUSTRIAL EFFICIENCY 2016
1. POLICIES AND PROGRAMMES
On the issue of the revision of the tau coecient, the con-
sultation document proposes two options: reduction of the
technical life up to 15years, with recognition of white certi-
cates for the same period of time, or certicates life of 5years
with the introduction of a rewarding factor between1.5 and2.0
for complex projects with long pay-back time. e rst option
– which appears to be the chosen one – has the advantage of
avoiding issues in case of anticipated shut down of the incen-
tivised plant (simply no more requests for certicates will be
issued), while guaranteeing more certicates for complex and
long time projects. e disadvantage with respect to the present
situation is that is even more dicult to rely on the certicates
as an incentive, since on longer periods of time the uncertain-
ties on the WhC price trends are higher.
In relation to additionality and consumption baseline, MiSE
anticipated that more dened criteria will be introduced in or-
der to reduce uncertainty and litigation. In the consultation was
also proposed to consider the incurred investment cost as an
element to dene the market baseline on, in order to avoid the
over-compensation of some investments. As illustrated in the
previous chapter, GSE opted to put in place this rule on its own.
With regard to the eligibility of technological solutions,
MiSE proposed to exclude the civil sector technologies already
covered by alternative measures (for rationality purposes, since
it is already forbidden to access more than one support scheme
for the same project) and to introduce or expand the possibil-
ity to present interventions linked to electricity and water net-
works, mobility and transport, and behavioural changes, with
methods to be dened in the new guidelines. Finally, for renew-
able sources it is expected to take into account only the energy
eciency improvement, and not the replacement of fossil fuels
(thus decisively reducing the impact of these sources, especially
in the industrial sector).
In terms of ownership of the project, MiSE proposed that
only end-users may submit proposals, unless ESCOs play an
active role in the implementation and management of the pro-
ject (e.g. with an energy performance contract, EPC), and only
in presence of adequate economic and nancial capacity com-
pared with the size of the project. e alternative is to continue
to accept ESCOs proposal by requiring adequate securities, but
the result will be similar to the rst option, considering the cost
of securities. So in the end the result should be a limitation of
the role of ESCO as proponents, leaving nevertheless the possi-
bility to act as consultants. e idea is to leave open the support
for certied ESCOs to propose and use EPC contracts.
Finally, the document proposes the introduction of a new
methodology for the assessment of savings (PPPMS, or stand-
ardised PPPM, designed for widespread homogeneous projects
with possibility of metering on a sample of interventions), more
stringent criteria for the measurement of the savings for me-
tered projects, the possibility of having discounts on the fee to
pay to submit a proposal for projects linked to the energy audits
carried out under EED art.8, and strengthened verication and
control activities.
e measures proposed in the consultation document ap-
pear to solve many of the existing problems and to increase the
cost eectiveness and materiality of the scheme. Nevertheless,
the eects on the trend of proposals and certied savings are
all to be seen, depending on the actual guidelines and on the
capability of involving new projects and solutions.
small ESCOs found it dicult to provide the additional infor-
mation requested by GSE, due to a too simplistic approach to
the scheme27. is is the reason of the high percentage of non
conformities cited above. Nevertheless, the new approach, aer
this initial traumatic phase, will traduce in an improved quality
of the projects and of the proposals, and will also favour the
qualication of small ESCOs.
Among the additional information, especially for requests
of white certicates linked to industrial PPPMs, GSE started
asking for economic information, such as the CAPEX of the
implemented project and the cost of energy. e resulting pay-
back time was used28, together with the regulatory and market
baseline, to determine the additionality. is request has been
largely contested by ESCOs and large companies, since previ-
ously it was an optional data and the 2012 guidelines didn’t re-
quire it29. GSE in practice anticipated one of the proposal con-
tained in the consultation document about the new guidelines,
aimed at excluding from the scheme projects characterised by
a short pay-back time. Nevertheless, many legal disputes start-
ed on this aspect. It is worth noticing that the possible issue
of over-incentivised projects was presented by us both in an
ECEEE and in an IEPPEC papers in 2014 [10, 11].
As mentioned in the previous chapter, when a project is pre-
sented by an ESCO some issue may arise in case of non con-
formities or of modication to the project. is created some
problems in terms of controls and potentially it can be a serious
aw of the system if not resolved with the new guidelines.
e last point is due to the tau coecient. Since it anticipates
the savings from the sixth year to the technical lifetime of the
project, if this is stopped before reaching the expected dura-
tion (usually 15or 20years) GSE will require the return of the
money received and linked to the tau coecient. is is one of
reasons why MiSE will eliminate the tau coecient in the new
guidelines.
The new scheme guidelines consultation
In Summer 2015 MiSE opened a consultation on the directions
to follow for the new WhC scheme guidelines. e reasons be-
hind the introduction of new guidelines are summarized in the
document in consultation [16]. e main ones are: the need to
increase the eectiveness of the scheme, the uncertain deni-
tion of additionality in the industrial sector, the need to review
the technical life under which white certicates are generated,
the responsibilities on project management when the proposals
are not presented by the end user, the contrast of speculative
behaviour. While writing this paper the new guidelines are yet
to come, so the main points under consultation are discussed
with some news gathered at MiSE public presentation during
FIRE annual conference [22].
27. As an example, some ESCOs had to withdraw their proposals since they were
not capable to provide documents such as the certification of performance of the
installed windows or insulation materials, only because the document were not
mentioned in the deemed saving file.
28. There is no public available information on the projects’ pay-back time, apart
from what illustrated in [11].
29. For example in a workshop on April6th AICEP, an association of energy inten-
sive industries, declared that of 59projects presented in 2015 by its members
– with a potential of 275,000tep/year – 50% of the new PPPMs and 30% of the
request of certificates related to accepted PPPMs have not been approved by GSE.
1. POLICIES AND PROGRAMMES
ECEEE INDUSTRIAL SUMMER STUDY PROCEEDINGS 161
1-141-16 DI SANTO ET AL
with the reports on the socio-economical frameworks in the
examined countries [13]. An interesting outcome of the ENS-
POL project has been the increased sharing of information and
experiences among Member States policy makers, even beyond
the initiatives provided by the project (such as the EU observa-
tory, the multi-national workshops and the webinars).
Usually EEO schemes are complex and need some years of
ne tuning to work in the desired way (they can also fail, ob-
viously, as some cases demonstrate [13]. Besides, alternative
measures (such as grants, loans, tax deductions, etc.) can be
preferable to reach results in a short time, i.e. 3–4years. So the
pros and cons of an EEO should be adequately investigated.
If the objective is to create a support scheme capable of in-
volving all the sectors and the technologies, then white certi-
cates can prove eective and exible. One of the experiences
derived from the ENSPOL project is that there is no scheme
that is intrinsically more cost-eective than others, since much
depends on how, where, and when it is implemented. What
makes the dierence is the care and the commitment that
policy makers and managing agencies put into the action (see
also [13,14,19]).
us many issues will have to be faced over the years in such
schemes, but they can be overcome, provided timely interven-
tions from policy makers and a large involvement of the stake-
holder community are ensured. As shown also by the other
schemes analysed under the ENSPOL project, a continuous
improvement approach is fundamental to reach the targets and
ensure the higher cost eectiveness.
References and useful links
REFERENCES
[1] P. Bertoldi, S. Rezessy, “Tradable certicates for energy
savings (white certicates) – theory and practice”, 2006,
European Commission Joint Research Centre, Institute
for Environment and Sustainability, June 2006.
[2] R. Haas, N. Sagbauer, G. Resch, “What can we learn
from tradable green certicate markets for trading white
certicates?”, eceee 2009 Summer Study – Act! Innovate!
Deliver! Reducing energy demand sustainably, June 2009.
[3] N. Eyre, M. Pavan, L. Bodineau, “Energy company
obligations to save energy in Italy, the UK and France:
what have we learnt?”, eceee 2009 Summer Study – Act!
Innovate! Deliver! Reducing energy demand sustainably,
June 2009.
[4] D. Di Santo, D. Forni, V. Venturini, E. Biele, “e White
Certicate scheme: the Italian experience and proposals
for improvement”, eceee 2011 Summer Study – Energy
eciency rst: e foundation of a low-carbon society,
June 2011.
[5] “European Workshop on Experiences and Policies
on Energy Saving Obligations and White Certicates”
proceedings, http://re.jrc.ec.europa.eu/energyeciency/
events/WhC_Workshop.htm, 27–28 January 2011.
[6] RAP (e Regulatory Assistance Project), “Best Practices
in Designing and Implementing Energy Eciency
Obligation Schemes. Research Report Task XXII of the
International Energy Agency Demand Side Management
Programme”, June 2012.
Conclusions
e Italian experience with white certicates is a positive one
and shows that such a scheme can have many pluses:
•
exibility, in terms of eligible technologies, sectors and mar-
ket operators, etc.;
• capacity, being capable of covering a good percentage of the
national targets30;
•
market support, since voluntary parties can play a leading
role and use such a scheme both to increase their know-how
in complex sectors like the industry and to capitalize and
start oering advanced energy services, such as EPC;
• policy making support, due to the huge number of valuable
data collected through PPPMs;
• statistics, in terms of assessment of metered energy savings.
On the other hand some points should be considered:
•
the complexity is high, especially involving the industrial
and transport sectors, and worthy the eort only in case of
ambitious targets;
•
appreciable results will require time to , so the scheme
should be designed with a medium or long time vision;
• as in other schemes, there is the need of an enlarging man-
agement structure and care should be taken in writing the
rules as to reduce the risk to have all the proposals submit-
ted in the same period of time to avoid unmanageable peaks
in the verication activities;
•
information and support activities31 are vital to ensure the
success of the scheme.
e idea to make comparisons with other EEO schemes is in-
triguing, and many attempts have been made in this direction
by many organizations (e.g. [1, 5, 6, 9, 12, 14, 20]) and projects
(like the already mentioned ENSPOL [13, 14, 19]). e wide
range of dierent parameters to be taken into account, however,
makes such comparison quite dicult and usually not eective,
unless related to specic aspects of particular schemes. Targets,
obliged and voluntary parties, M&V procedures, controls, ad-
mitted sectors and technologies, etc. are indeed dened in dif-
ferent ways. It is not a surprise then that ambitious programs
like the idea of dening the rules of a common EEO scheme
cherished by a CEN/CLC JWG2 was abandoned in front of too
many dierences and options and transformed in a report on
the existing EEOs [9].
Even assessing the cost eectiveness of a scheme is a dicult
task, considering the aspects to consider (costs, sectors and
technologies involved, targets, additionality and materiality,
non energy benets, etc.) and the lack of reliable information in
many cases [12]. Nevertheless the analysis of so many schemes
provides a lot of useful information for policy makers both on
positive and negative factors, especially if evaluated together
30. MiSE stated in the notifications of art.7 EED that WhC shall cover 60% of the
Italian 2020 targets.
31. Besides information and training activities, which are crucial, it is important
to put in place workgroups to discuss complex issues such as baseline and
additionality with the stakeholders. This will simplify and improve both the
proposals submission and the verification activities.
1-141-16 DI SANTO ET AL
162 INDUSTRIAL EFFICIENCY 2016
1. POLICIES AND PROGRAMMES
[17] MiSE, “Proposte per il potenziamento e la qualica del
meccanismo dei Certicati Bianchi”, www.sviluppoeco-
nomico.gov.it/images/stories/documenti/Proposte_ag-
giornamento_meccanismo_CB.pdf, July 2015.
[18] Workshop “Workshop on G7 Energy Ministerial Conclu-
sions”, Berlin, 11 November 2015.
[19] ENSPOL webinars on measurement and verication of
energy eciency savings, additionality and materiality,
lessons learnt from EEOs and alternative approaches,
obliged parties, costs and nancing of EEOs, http://ens-
pol.eu/events/webinars, 2015–2016.
[20] N. Labanca, P. Bertoldi, “Energy Savings Calculation
Methods under Article 7 of the Energy Eciency Di-
rective”, http://publications.jrc.ec.europa.eu/repository/
bitstream/JRC99698/report%20on%20eed%20art%20
7%20-%20publishable.pdf, January 2016.
[21] GSE, “Rapporto Annuale sul meccanismo dei
Certicati Bianchi”, www.gse.it//it/CerticatiBianchi,
March 2016.
[22] FIRE conference “Certicati bianchi: titoli di ecienza a
portata di mano”, Roma, www.certicati-bianchi.com, 12
April 2016 (previous editions of the conference proceed-
ings are also available on www.re-italia.org).
LINKS OF INSTITUTIONS RELATED TO WHITE CERTIFICATES IN ITALY
MiSE, Ministry of Economic Development, www.sviluppo-
economico.gov.it
AEEGSI, Italian Authority for electricity, gas and hydric sys-
tems, www.autorita.energia.it
GSE, Italian energy services operator, www.gse.it
ENEA, Italian Agency for new technologies, energy and envi-
ronment, www.enea.it
GME, Italian energy market operator, www.mercatoelettrico.
org
RSE, Energy System Research center, www.rse-web.it
[7] “White certicate for the industrial sector”, D. Di Santo,
D. Forni, E. Biele, ECEEE 2012 Industrial Summer Study –
Industry: A third of Europe’s energy use, September 2012.
[8] E. Biele, S. D’Ambrosio, D. Di Santo, G. Tomassetti,
“Metodo a consuntivo: analisi delle proposte di progetto
e di programma di misura 2005–2012”, www.re-italia.
org/analisi-delle-proposte-progetto-programma-misura-
pppm-dei-certicati-bianchi-2005-2012, 2013.
[9] CEN/CLC/TR 16567 “White certicates”, CEN-CLC, 2013.
[10] D. Di Santo, G. Tomassetti, D. Forni, E. Biele, S.
D’Ambrosio, “Italian white certicate: the shi towards
industry”, eceee 2014 Industrial Summer Study – Retool
for a competitive and sustainable industry, June 2014.
[11] D. Di Santo, G. Tomassetti, E. Biele, S. D’Ambrosio,
“White certicates in industry: the Italian experience”,
IEPPEC conference in Berlin, September 2014.
[12] Ricardo-AEA, “Study evaluating the national policy
measures and methodologies to implement Article 7 of
the Energy Eciency Directive”, http://rekk.hu/downlo-
ads/projects/Final%20Report%20on%20Article%207%20
EED.pdf, February 2015.
[13] ENSPOL, reports on EEOs and alternative measures
under art. 7 EED and on Member States context proles,
http://enspol.eu/results, 2015.
[14] P. Bertoldi et al, “How is article 7 of the Energy Eciency
Directive being implemented? An analysis of national en-
ergy eciency obligation schemes”, eceee 2015 Summer
Study – First Fuel Now, June 2015.
[15] Workshop “Applying common methods and principles
for calculating the impact of energy eciency obligations
schemes or other policy measures under Article 7 of the
Energy Eciency Directive”, Bruxelles, 10 June 2015.
[16] AEEGSI, “Stato e prospettive del meccanismo dei titoli
di ecienza energetica”, www.autorita.energia.it/allegati/
docs/15/309-15.pdf, June 2015.
