First published in Building Magazine, August 14th 2009 - Online Article
Ask anyone interested in the energy efficiency of buildings what
has been the greatest influence on their market over the past two
or three years and they are likely to talk about the EU Energy
Performance of Buildings Directive.
As EU Directives go, this one has pretty much escaped the wrath
of the Daily Mail, but it is responsible for many of the energy
efficiency requirements enshrined in UK law today, including Energy
Performance Certificates and Display Energy Certificates.
Now the EU has published its proposals to recast the EPBD. A
consultation was launched a couple of weeks ago by Communities and
Local Government to consider how the UK should respond (a copy of
the Consultation can be downloaded from the DIAG website www.diag.org.uk ).
There is much to welcome in the proposals, including
improvements to Energy Performance Certificates (EPCs) to make the
energy saving recommendations that are given to people selling,
buying and renting homes much more bespoke to the property and with
extra advice to encourage their implementation. Similarly, I'm
pleased to see that the energy rating of a home will be required in
property advertisements.
The proposed requirement for an early assessment of the
technical, economic and environmental feasibility of alternative
energy systems for all buildings, as part of gaining planning
permission or building regulations compliance, will also bring
detailed energy efficiency discussions to a much earlier stage in
the design programme. This can only be a good thing, as genuine
sustainability demands a more integrated approach from day one.
Of course, as with any new legislation, the devil is in the
detail. There are several small - but crucial - issues still to be
thrashed out. For example, what are the EU's principles for a
common definition of 'low and zero carbon'? The UK is creeping
closer to a consensus on these terms, but our definition may be
threatened by a rather ridiculous suggestion from one European
Commissioner that zero carbon means all energy consumed by a
building being generated onsite by solar panels or heat pumps (and
no more 'allowable solutions' that UK housebuilders are relying on
in order to reach Code level 6). That's certainly one to watch.
There is also one bizarre and much bigger anomaly within the
EU's proposals which appears to have our Government's support, but
which makes no sense to me or others concerned to see tangible
improvements in the energy efficiency of the UK's building
stock.
The proposal in question suggests that all commercial buildings
over 250 square metres (such as shops, restaurants and other
buildings visited frequently by the public) should display an
Energy Performance Certificate - the energy rating they would have
received when the building was built, sold or leased.
Now there may be some merit in making the display of EPCs
mandatory, if only to ensure such certificates are actually
produced. Recent research by National Energy Services
suggests that the majority of High Street commercial properties are
flouting the law and do not have an EPC available.
However, EPCs show only the theoretical energy performance of
buildings based on standardised data and assumptions that rarely,
if ever, reflect the true energy performance of a property in use.
Only Display Energy Certificates (DECs) give the true picture. For
example, the MPs new office building opposite Big Ben, Portcullis
House, would probably be awarded an EPC rating of A (or possibly
B), but actually only achieves a DEC rating of G.
The proposal for displaying EPCs is probably supported by CLG
because it's an easy thing to do. The thinking goes: these
commercial properties will have to have an EPC produced if they
change hands anyway, so the certificates might as well go up on the
wall.
But it's an entirely pointless exercise from a market
transformation point of view.
Company directors only sit up and take notice when DECs come
into play. Buildings are only improved when the truth is published.
Ministers told us exactly this when Eland House (home of CLG)
received its DEC. This year's ESTA Energy Manager of the Year, Andy
Stanton at TFL, specially acknowledged the use of DECs as
significantly aiding his work to get energy efficiency taken
seriously.
So what would make far more sense is for the EPBD threshold for
DECs to be extended beyond public buildings over 1,000 square
metres to all commercial buildings of a similar size. Thus large
hotels, supermarkets and privately owned buildings visited
frequently by the public would have to tell the truth every year
about the actual energy performance of the premises. This is a much
more logical progression in our efforts to reduce carbon emissions
from existing buildings.
I shall be beating a track to CLG's doors to discuss these
issues with them as soon as possible. For I have no doubt the new,
recast Directive could have just as important an impact on our
industry as the first.
I also know that, while the CLG consultation continues until
October, the EU Council is already developing its position, ready
for negotiations with the Parliament and Commission straight after
the summer break. There is no time to lose.