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Posts Tagged ‘DCLG’

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.

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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.

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Building Regulations,DCLG,Department for Communities and Local Government,Display Energy Certificates

A disaster for energy efficiency inside DCLG

The following is a piece written by Andrew Warren and published in ENDS Report 467, January 2014, pp. 30-31.

The past three and a half years for Eric Pickles appears to have been a litany of failure, countering the prime minister’s energy efficiency aim for Britain.

Prime minister David Cameron has set a challenge for his cabinet: “I want Britain to be the most energy-efficient nation in Europe.” But seemingly there is one member working in the opposite direction.

Eric Pickles has been the secretary of state for the Department for Communities and Local Government since the coalition took office in May 2010. During that time, he has presided over, indeed sometimes personally made, a series of policy decisions which completely undermine Cameron’s objective.

The list of failures is as consistent as it is long. In each case Pickles seems wilfully to have sought to obstruct progress. This is despite his having been the chairman of the Conservative Party which promoted the catchphrase “vote blue, go green”.

At the start of the century, the government and the building sector came together to agree a pathway to higher new-building energy standards, at a time when they were many years behind European countries with similar climates. In exchange for a roadmap providing relative certainty on timing and extent of change, the construction industry invested in training and product development, towards zero-carbon (or very low-carbon) buildings.

The deal stuck. In 2006 and 2010, the improvements were made smoothly. The next round of changes were due to start last April – the final round before zero-carbon homes were due to be introduced in 2016. Despite issuing a consultation document in January 2012 promising these upgrades, they did not go ahead as scheduled. Instead they will come into force 12 months late, in April 2014.

Even when they do proceed, they will deliver far less than intended: a 6% rather than a 25% improvement for new homes and a 9% rather than a 20% improvement in non-residential buildings, based on 2010 levels.

But it has long been established that vast numbers of new homes fail to comply with the minimum building regulation standards. Almost inexplicably, there appears to be no government system for monitoring compliance.

If a washing machine or refrigerator is put on the market that does not deliver the promised energy savings, the National Measurement Office can take out criminal proceedings. Yet nobody has ever been prosecuted for failing to comply with the energy conservation parts of the building regulations. And countless independent studies have revealed that, once you get beyond one or two bedroom apartments, it is a minority of homes that meet even the minimum energy standards. The rest are all breaking the law and Pickles is apparently wholly unconcerned.

The position is, if anything, worse for existing buildings. New EU laws state that all advertising for a building sold or leased should include its A-G energy label. And each new occupant must receive energy performance details and how it can be improved.

Independent surveys have revealed that these legal requirements are seldom observed. Pickles’ department has not only failed to adequately monitor compliance, it has not ensured that council trading standards officers are monitoring the advertising requirements – so buyers and lessors are not informed of buildings’ energy efficiency standards. But last September Pickles had to compensate the scheme administrators, Landmark (a Daily Mail subsidiary), with a whopping £5.7m from public funds, because at least six million lodgement fees of £5.36 for energy certificates had not been paid.

An earlier EU directive had led to display energy certificates being displayed in the foyers of 42,000 public buildings. Renewed annually and reflecting annual energy usage, they were stimulating big efficiency improvements. But since 2010 there has been no pressure to keep these updated: so many are not, in part because now Pickles has also whimsically decided that smaller buildings need only renew every ten years. And he is not requiring the commercial sector to display such certificates, but instead mandating that “in a prominent place” there will only be details of a building’s theoretical performance. His department has been unable to cite any support for such a perverse interpretation of a European directive.

Such idiocy occurred largely because he omitted to consult about how the final text of the new buildings directive should be implemented. Perhaps it is because he knows that, even if he does run a public consultation, he may subsequently reverse his position – even if 82% of respondents endorse his original proposal. This is what happened in the case of his infamous ‘consequential improvements’ consultation – a policy he now rejects despite having initially claimed an £11bn saving to the economy and the stimulation of 2.2 million Green Deals.

Other examples of bad faith include the failure to set any energy efficiency targets in the revised guidance for local authorities for the Home Energy and Conservation Act. And it is an open question whether landlords really believe that DCLG is committed to enforcing the requirement of the Energy Act 2011 that F and G-rated properties cannot be leased after 2018.

Pickles is currently consulting on removing from the statute book the Planning and Energy Act. This permits local authorities to set higher minimum standards for new buildings – an act much deployed by the London mayor Boris Johnson, who requires new commercial and residential buildings to deliver 40% better energy performance than the regulations mandate.

A damaging u-turn
This act was an unusual one. It was put onto the statute book in 2008 by opposition Conservative backbencher Michael Fallon (now an energy minister) cheered on by his then party chairman as an excellent mix of localism and environmentalism. Who was this chairman? Why, Eric Pickles, who five years on is apparently seeking another personal u-turn, further damaging the environment.

I am not qualified to form a judgment on Eric Pickles’ effectiveness in other policy areas but what I do know is that to date his period in office has been an almost unmitigated disaster so far as the energy efficiency agenda is concerned – and certainly so far as achieving the prime minister’s declared objectives.

As Cameron reminds us: “In a race for limited resources, it is the energy efficient that will win the race.” Perhaps Pickles should be donning his running shoes?

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