logo

The expert voice for energy efficiency in the UK.
Follow us:

ACE’s response to the Mayor of London’s draft London Environment Strategy

ACE welcomes the vision and principles of the Mayor of London’s draft London Environment Strategy and the ambition for London to be a zero-carbon city by 2050.

We agree that the city’s most pressing environmental challenges are harming Londoners’ health and the city’s economy, and that the current pace of change is too slow. The Mayor highlights that big problems need ambitious responses. Therefore, we would like to see the Mayor’s activity and focus on air quality continue, but also expanded in relation to improving the energy efficiency of buildings, improving the lives and reducing health inequalities of those households that are in fuel poverty, whilst supporting economic growth in the environmental goods and services sector.

Our full response to consultation on this strategy can be found here.

 

Continue Reading No Comments

Energy Efficient Buildings,Non-domestic building,Public Buildings

Energy efficiency policy for workplaces: quick wins for the next Government?

We all know that there is no single ‘magic policy bullet’ that will support the growth of a self-sustaining market for energy efficiency investments, and that a jigsaw of policy pieces is needed to build the necessary framework.

This is the first in a series of blogs looking at ACE’s new policy tracker, and it considers commercial buildings.  It asks, are all the jigsaw pieces in place?  What more can we do easily? And what is going to be a little more difficult?

Where we are now

The Committee on Climate Change identified a least-cost pathway to meeting the 5th carbon budget.  Our analysis of the gap between this and the Government’s projection of emissions given the current policy landscape, shows that – by 2030 – commercial buildings will be emitting 42% more carbon than the ideal, and public sector buildings 34% more.  And the excess energy use involved is costing businesses a lot of money: in London alone, businesses spend over £4 billion per year on gas and electricity; if they could reduce their energy use by a third, that would mean over £1.3 billion every year for these businesses to use on something more productive.

In policy terms, a quick look at the policy tracker clearly shows that we’re really not doing very well.  We don’t appear to have a vision for our commercial buildings, nor do we have an overall target for their energy efficiency.  And we’re not very good at celebrating the achievements of those companies that are working hard to improve their energy productivity.

We have no comprehensive and engaging tax incentives to encourage energy efficiency investments, and there is little action by government to encourage the development of attractive finance offerings.

On a more positive note, the minimum efficiency standards for offices in the Private Rented Sector will result in improvements to our worst commercial buildings, making them better workplaces and hence supporting happier and more productive workers.  We do have energy performance certificates to give organisations information about the premises they are buying or renting, although the requirement for these could be better enforced.  And, in the past, central and local government has taken the lead, through energy demand reduction targets and National Indicators on carbon emissions.

And finally the good(ish) news: products policy has driven up the minimum efficiency standards of widely used appliances, and ESOS has ensured that larger business at least have the tools to understand their energy use and the potential for improvement.  Both these success stories are potentially at risk during Brexit, but we can act to avoid this.

The quick wins

There are some politically and practically easy steps that government and business can and should take right now. The Clean Growth Plan needs to set a high level of ambition for our offices, offering a vision of healthy, comfortable workplaces that support increased productivity; setting a target for commercial buildings energy efficiency and a trajectory towards achieving that target.

The public sector needs to once again set an example: we need targets for energy efficiency in the sector, and public reporting on progress towards these.  Implementing this will help Government achieve the efficiency improvements that it is looking for from the sector without taking money away from public services.

We need a clear message from Government that existing minimum efficiency standards for products, and requirements for energy auditing, will be retained as we exit the EU; and indeed that these policies, which have reduced business energy bills, will be enhanced in the future.

And we as businesses should collaborate on schemes that recognise those companies that are taking a lead in managing their energy use and celebrate their success.

Next steps

Beyond these easy wins, there are other things that won’t be quite as straightforward, but which really do need to happen.

Our existing minimum energy performance requirements for new buildings should be strengthened – by reinstating the trajectory to zero carbon – and our requirements to report on the energy performance of all buildings better enforced.

The review of business energy efficiency taxation has simplified the system but we are still not at the point where all fuels for all users are taxed equitably according to their impact on the climate; and we need to complement the tax with a requirement for public reporting on energy performance for larger companies.

And Government needs to work with the finance sector to ensure that all businesses wishing to invest in energy efficiency (including SMEs) can access attractive finance offerings to support these investments.

If we get these things right, and if we work with the construction trades, we could begin to tap into the already significant market for building refurbishment to ensure that energy performance improvement is a core part of any refurbishment project.

Difficult to do, but we must work out how

Expanding the use of minimum energy performance standards in existing buildings seems to be very difficult politically, and yet business is quite able to deal with regulation in all sorts of areas, provided that it is given sufficient warning and helped to understand how best to respond.  So we should be looking at how we can widen these standards out from the Private Rented Sector and how we can strengthen them.

And we need to bring energy efficiency investments to the top of the pile for business decision-makers: tax incentives for businesses to invest in energy efficiency again seem to be something that Government is reluctant to think about and yet, without them, energy audit recommendations risk being nice projects that get left on the shelf when something more interesting comes along.

 

We’re really not doing that well at the moment, but surely it is time now for Government to act on some of the easy wins whilst working with us on plans for the next steps.  And we should not shy away from the more difficult steps  – the prize: more competitive businesses, a happier and healthier workforce, and greater energy resilience, is too important!

 

Do have a look at the details in our snapshop policy tracker and let us know what your view is.  And if you are interested in finding out more about why we think some policy changes are easier than others, have a look at Chapter 6 in our 2016 report on Buildings and the 5th Carbon Budget.

We look forward to policies developing over the coming months and we will be updating the tracker in response to these changes.

Continue Reading No Comments

commercial sector,ESOS,policy design

Non-domestic energy efficiency – policy design principles

Dr Peter Mallaburn is Director of Policy and Governance at the Energy Institute, University College London, and Editor of Climate Policy Journal. He has represented the UK on air pollution, climate modelling and energy policy in the EU, OECD and the IEA and worked on international climate negotiations. Peter helped write the UK’s first Climate Change Programme, set up the Carbon Trust, was Salix Finance’s first CEO, and set up his own consultancy, Policy to Practice, in 2008.

The government is currently reviewing its non-domestic energy efficiency policies as well as its wider policy portfolio as part of the Carbon Plan. DECC’s 2016 Departmental Plan provides some context:

Although the energy intensity of the UK economy has fallen by 24% since 2004, there remains significant untapped potential for energy saving in the business sector. Realising this potential will improve businesses’ productivity and will also support growth. But the business energy tax and policy framework is complex and businesses tell us it does not provide the incentive it could to reduce energy consumption. 

This article contributes to this process by outlining our state of knowledge on energy efficiency and identifies some key policy principles around which a new energy efficiency programme could develop. It is drawn both from the literature and from direct policy experience in the UK and overseas.

Continue Reading No Comments

Display Energy Certificates,Energy Performance Certificates,European Energy Performance of Buildings Directive,Zero Carbon Homes

Our response to the European Commission’s consultation on the Energy Performance of Buildings Directive

This consultation forms part of the evaluation of the Energy Performance of Buildings Directive. Under the terms of the Directive, the Commission is required to carry out this evaluation by 1 January 2017, with assistance from a Committee of Member States’ representatives. The evaluation should reflect the experience gained and progress made since the adoption of the Directive. If necessary, the Commission should make proposals on the basis of the evaluation.

The evaluation also follows on from the Energy Efficiency Communication of July 2014, which indicated that additional measures to be introduced to improve energy efficiency would need to primarily address the energy efficiency of buildings and products if progress is to be made by 2030. The Energy Performance of Buildings Directive is the main legislative instrument in force at EU level covering the energy efficiency of buildings.

With a primary focus the UK energy efficiency market, our response to the consultation highlights: the uncertainty following the abandonment of the zero carbon trajectory; the missed opportunities with respect to driving higher rates of renovation; the low level of compliance with EPBD’s provisions and the virtual absence of enforcement; the question marks hanging over Display Energy Certificates; the need to make EPC data more widely accessible; and the need to plug skills and capacity shortages in the energy services and energy auditing sectors.

Continue Reading No Comments

DCLG,Display Energy Certificates,Eric Pickles,Public Buildings

Our response to CLG consultation on Display Energy Certificates (DECs)

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.

Continue Reading 1 Comment

DCLG,Display Energy Certificates,Eric Pickles,Public Buildings

Is Eric Pickles implementing a scorched earth policy ahead of the election?

Today, the Department for Communities and Local Government published a consultation which proposes to abolish Display Energy Certificates in England and Wales. DECs show actual energy consumption of public buildings on an A to G rating scale and need to be prominently displayed.  They are required annually for public buildings over 1,000m2, and every 10 years for buildings between 500m2 and 1,000m2. So far, 54,000 public buildings have them.

They raise public awareness of energy consumption in public buildings, make the sector more accountable for their energy consumption to tax-payers, and act as a driver and tool to reduce energy consumption in buildings and convince building owners to invest. The rating on a DEC can be improved by both energy efficiency works and by getting building users to cut back on unnecessary energy use (Energy Performance Certificates don’t register the latter). According to a study cited in the consultation itself, public buildings with DECs reduced their energy consumption by 2% more than their private sector counterparts between 2008 and 2009, just one year into their introduction. Little surprise that in 2011, David Cameron promised to extend the requirement for DECs to buildings in the commercial sector.

Despite this rollout to the private sector being supported by the CBI and the British Property Federation, Government reneged on that promise. Now they are proposing to row back to an extent that beggars belief. CLG says that abolishing DECs would save public authorities £760,000 each year.

When the Department of Energy and Climate Change moved into Whitehall Place, its DEC had a rating of G. That caught our attention – and the attention of countless others who visited the building.  The unflattering spotlight being shone on the Department will have played its part in stinging them into action and they’ve since improved their building’s energy consumption to a rating of C, saving £156,000 annually in the process. In one building (yes, a fairly large one). One building out of 54,000. Five such cases would exceed CLG’s savings estimate. The Government should make good on its original promise and extend DECs to the commercial sector, not abolish them. This staggering case of money-saving myopia must be stopped in its tracks.

Continue Reading No Comments

Display Energy Certificates,Energy Performance Certificates,Energy Saving Opportunity Scheme

ACElogo

Public or private – the displays should be the same

The clue is in the name. The Energy Savings Opportunity Scheme (ESOS) is the government’s latest flagship programme, designed to stimulate every large enterprise to invest in energy efficiency measures. In essence, it mandates having a full energy survey of each outfit’s energy using activities every four years. And identifying the energy saving opportunities.

After a year’s deliberation, at the end of June details were published by the Department of Energy and Climate Change detailing just how each eligible organisation can comply. Broadly, those involved include every business and third sector organisation employing over 250 people or turning over above £50m per year: in all, involving nearly 10,000 different entities.

Mindful that there is already a plethora of other reporting mechanisms in which many may already be involved, DECC seems to be making an overt effort to enable participants in other schemes to re-use any data collected. That is true for those in sectors involved with Climate Change Agreements. Or the European emissions trading scheme. Or the Energy Efficiency Carbon Reduction Commitment. Or greenhouse gas emissions data.

Continue Reading 2 Comments

Display Energy Certificates,Eric Pickles

DCLG takes top certificate in creating confusion

If you don’t measure your energy use, you can’t control it. A truism that has certainly stood the test of time.

Here is a second truism. If everybody is able to see just how well or badly you are doing your job, it is a very distinct spur towards better performance.

It was precisely with these two aphorisms in mind that, 11 years ago, every European Union government agreed that it would be a good idea to require in every public building, its occupants display its energy performance “in a prominent place.”

Continue Reading 7 Comments

CONTACT US | FIND US | US | © 2017 Association for the Conservation of Energy. CAN Mezzanine, Old Street, 49-51 East Road, London N1 6AH. Tel: 020 7250 8410. Registered company number 01650772