appropriate, however, as a convincing rationale is absent on the use of full cost of salaried time as cost of decision making.

Aggregated estimates . In Joskow and Marron study (1992, p. 10), estimated “administrative costs” (e.g. M&V, promotion of EE) was approximately 30% of the total costs for commercial and industrial energy savings programs. Whereas the estimated scale is still considered to generate cost-effective energy savings, the study conveys some skepticism about the estimates. First, it is argued that these costs are likely to be underestimated because of internal accounting problems. Second, energy savings – critical unit to estimate “administrative costs” as such – are likely to be overestimated due to the fact that they are based on engineering (ex-ante) studies rather than actual (ex-post) measured savings. Regarding the FCEA in Denmark, the estimated scale of TCs is provided in relation to the direct energy audit costs, as opposed to investment costs resulting from the energy efficiency measures. Mundaca and Neij (2006a, p. 11), based on information reported by electricity grid companies, estimated TCs are the range of 5% and 20% of audit costs. In turn, the costs of energy audits under the FCEA – including TCs – would range from 12.6 to 14.4 €cts/kWh respectively. When it comes to the British TWC scheme, TCs were estimated based on a cost-effectiveness analysis with data input provided by subject participants. Estimates of TCs are around 10% for lighting (CFL in particular) and 30% for cavity wall insulation of the total investment costs (Mundaca, 2007b, p. 4348). Easton Consultants (1999; in Mundaca and Neij 2006b) provide an estimation of TCs in relation to EE projects carried out by US Energy Service Companies (ESCOs). Based on a set of interviews, aggregate TCs were estimated to be between 20% and 40% of the total investment (Easton Consultants, 1999, p. 11). Results are summarized in Table 2.

**Table 2: Aggregated scale of transaction costs related to energy efficiency technology**

|**Case study**|**Identified nature of TCs**|**Scale of TCs**|**Reference**|
|---|---|---|---|
|Life cycle cost of<br>electrical efficiency<br>improvements from<br>utilities perspective|Administrative costs defined as<br>promotion, delivery, monitoring and<br>evaluation of conservation issues.|30% of the costs of the commercial<br>and industrial energy saving program.<br>Higher in the case of residential<br>programmes.|Joskow and Marron<br>(1992, p. 10)|
|FCEA in Denmark|Costs related to contacts and contracts<br>negotiation during the saving plan phase<br>in the case of the FCEA and the<br>implementation phase in the case of the<br>TWC scheme.|15 to 20% of the direct FCEA activity<br>costs.|Mundaca and Neij<br>(2006a, p. 11)|
|EEC (phase 1) in<br>Great Britain|Costs occurring during the planning<br>phase of the Energy Efficiency<br>Commitment (EEC1) under the British<br>TWC scheme including information and<br>measurement costs.|10% (lighting) and 30% (insulation) of<br>the total investment costs.|Mundaca (2007b, p.<br>4348)|
|ESCOs in the US|Prospecting, proposal, project<br>identification, measurement and<br>verification, funding premium and<br>closing fee.|20 to 40% of the total activity costs.|Easton Consultants<br>(1999, p. 11)|

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