ACE has responded to CLG’s consultation on ‘Display Energy Certificates: current regime and how it could be streamlined and improved‘. You can read our response here, and a summary of our response below.
When Display Energy Certificates (DECs) were first introduced, it was because CLG themselves identified that they were a) more appropriate for display in public buildings than Energy Performance Certificates (EPCs) and b) more cost-beneficial.
There is evidence referred to in the consultation itself, that DECs drive energy savings. There is also clear evidence from abroad, that regular operational ratings (of the kind contained in DECs) drive significant energy savings in the buildings in which they are used and displayed.
To remove schools and universities from the DEC regime totally contradicts the spirit of the recast Energy Performance of Buildings directive. Its intention is for DECs to apply to all buildings occupied by public authorities and also all buildings frequently visited by the public (the directive cites “shops and shopping centres, supermarkets, restaurants, theatres, banks and hotels” as examples). Schools and universities fall into both these categories, and the directive’s implication that they have to be included could not be clearer. Many more buildings should have been included as well, which is why the Government had intended in 2011 to extend DECs to the types of commercial buildings listed above.
The public sector should lead by example. The recast Energy Performance of Buildings directive states that “the public sector […] should lead the way in the field of energy performance of buildings” and “should set an example by showing that environmental and energy considerations are being taken into account and therefore those buildings should be subject to energy certification on a regular basis”. To remove or scale back the DEC regime would fly in the face of these requirements.
Recent analysis by University College London shows that 8,500 buildings with continual DECs over three years and larger than 1,000m2 achieved 3% annual energy savings in 2011 compared to 2009. In our estimation, this is roughly equivalent to £18m savings. If all 42,000 large buildings with DECs achieved the same saving, the total would be £89m. The total cost of the DECs regime is £7.8m, one eleventh of these savings. It is likely that DECs were a significant factor in starting these buildings on their energy management journey, which may well not have occurred in their absence. For every £1 saving on the DECs regime that CLG could achieve by abolishing it, the Department is putting at risk up to £11 of savings already achieved, and countless additional savings which an effective DECs regime would continue to drive. Furthermore, the savings calculated exclude the value of carbon savings achieved, employment and other spill-over benefits.
What CLG is proposing is to abolish (or severely truncate) a DEC regime which is proven to drive energy savings in public buildings and therefore make savings to the public purse. Far from freeing up resources for frontline services, abolishing DECs would at best reduce any energy cost savings being achieved and at worst enable the public sector to hide their wastefulness from the taxpayer and encourage profligacy. At a time of increasing pressure on public budgets and the need for more transparency to better account for public spending, the proposals to abolish or truncate a DEC regime which demonstrably saves far more money than it costs to run is plain stupidity.
The regime can be streamlined and improved, and a proper engagement and consultation exercise should be undertaken to find the best ways of doing so. As it stands, the current consultation, which has not even deigned to assess the benefits of the regime alongside its costs, is meaningless.