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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.

To facilitate this, participants are offered many different ways with which to comply. That is thoroughly sensible. In principle. But there is one option being offered which will probably be of interest to vast numbers. But using which in practice will mean directly contradicting the operation of an existing scheme.

This concerns measurement of the use of energy in any non-residential building. It is covered by section 34 of Part 6 of the new regulations.

This offers two ways in which participants can utilise existing activities to comply. One is to undertake a Green Deal Assessment. Such assessments are being undertaken by the thousands each month in the housing sector. In contrast, there have been very few Green Deal Assessments yet undertaken in non-residential buildings. Just how few is not certain – suffice it to say that in standard auditing parlance it would be deemed “not a material number”. This is not terribly surprising, because right now there is no Green Deal Finance package available for buildings that are not lived in.

And while there have been a number of proposals as to how this might be done (including back in 2012 from the Green Deal Forum I chaired for the DECC minister Greg Barker), to date there has been no attempt to progress this either within government or commercially.

Compliance option

Which leaves the other compliance option – when “a display energy certificate (DEC) has been issued during the compliance period, and remains valid on the compliance date.”

Since first required under European law in 2008, there have been well over 150,000 DECs issued, each duly put on display “in a prominent place.” This provides an annual snapshot of actual energy usage in the building in question, labeling that building from A to G. So there is certainly a lot of experience by auditors of how to undertake such surveys, and make recommendations based upon them.

But to date all these surveys have only been done in relation to the 42,000 eligible public sector buildings. And this is precisely the category of building not covered by the ESOS, which overtly excludes any part of the public sector from needing to comply.

Certainly there are regulations which require that, when the occupiers of most larger private sector buildings alter, an energy certificate must be produced and displayed, also “in a prominent position”. But perversely that is not a Display Energy Certificate, providing details of actual usage. But an energy performance certificate (EPC), which provides details only of a building’s theoretical energy performance.

The result is that any company that complies with the existing change-of-occupancy requirements, and acquiring and then displaying prominently this EPC, will not be able to claim that they have already done the necessary ESOS work. Because by definition ESOS is all about auditing actual rather than theoretical consumption.

Under ESOS each enterprise will have to collect all the information about actual usage that would qualify them to have a display energy certificate, of the kind to be found in public buildings. But they will be breaking the law if this is the certificate they do actually end up displaying.

This is truly madness. Every single objective commentator has argued that the sensible conclusion is to have the same type of energy information displayed in both public and private buildings. And that this should relate to the actual rather than theoretical energy performance of the building.

Bearing in mind that those wishing to comply with ESOS in their buildings are being encouraged to do so by using a DEC, it makes sense to avoid unnecessary duplication. Government needs to alter the bizarre interpretation of what is useful to be displayed in buildings which occupiers alter.

Let us display Display Energy Certificates everywhere that they are required by European law. Because, as with the Energy Savings Opportunity Scheme, the clue to the objective lies in the name.

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