Scotland’s Approach to Building Energy Efficiency

This post originally appeared here on the UKGBC blog, to which we are regular contributors.


 

Scotland’s ‘competitor’ to the much publicised Minimum Energy Efficiency Standards (MEES), due to be introduced in England and Wales in 2018, has been finalised and will be introduced next month. The approach is markedly different to the plans in place for the rest of the UK.

The scheme in summary

In Scotland, building owners who plan to sell or lease space will need to comply with the new regulations for units over 1,000 square metres in size, from 1 September 2016[1].  An energy performance certificate (EPC) is required, as usual.  However, an Action Plan must also be established to identify energy saving opportunities.  Action Plans can be issued by qualified Section 63 Advisors (many EPC assessors are in the process of gaining this additional accreditation) who use approved software to calculate improvements.  The software has been developed to consider the feasibility of seven improvement opportunities.

  • Draught-stripping windows and doors
  • Upgrading lighting controls
  • Adding central timer controls to the heating system
  • Insulating hot water storage
  • Improving lighting
  • Improving insulation
  • Replacing boilers if existing units are older than 15 years

Following completion of the Action Plan the owner can then decide to implement the relevant measures or produce an operational energy rating in the form of a Display Energy Certificate (and maintain this on an annual basis). Owners have 12 months to decide which approach to take and have a further 3.5 years to implement improvements if progression of the Action Plan is chosen as the approach.

Exemptions

It is also important to note that buildings constructed in accordance with a building warrant applied for on or after 4 March 2002 are exempt (for now)[2] – although there is a likelihood that this date will change over time to bring more assets into the scheme.  In many cases, exemption due to date of construction will be clear.  However, this rule has already raised questions.

For example, will a recently refurbished unit located in a building constructed prior to 2002 be exempt?

Consideration will need to be made on a case-by-case basis. The software used to generate EPCs and Action Plans will identify whether the unit meets the exemption criteria or not. As a result, the first part of the process, the EPC assessment, will need to be completed before the requirement for an Action Plan can be confirmed.

The Challenges

The approach, at first glance, seems practical.

Seven sensible improvement measures have been identified that, if feasible, need to be considered for implementation, and the bar has been set at the relatively low level of 2002 building warrant standards.  However, practical challenges remain.

Take the following scenario:

An owner wants to let an old (pre 2002) and large (over 1,000 square metre) office building on a Full Repairing and Insuring (FRI) basis.  The EPC and subsequent Action Plan will be produced.  To continue to comply, the owner will need to produce either a Display Energy Certificate or progress the implementation of the Action Plan.  However, lease structures for most FRI buildings will prevent compliance (as the owner will not have access to data and will not be able to implement improvements). 

To ensure compliance, owners of such buildings will need to ensure lease clauses are in place that require single-let FRI tenants to provide energy performance data to owners, as a minimum.

As a priority, landlords should review their portfolios and develop compliance plans to prevent problems in future.

[1] Units under 1,000 square metres will still need to produce an EPC, but will not be required to progress further.

[2] Transactions that are exempt from requiring an EPC are also exempt from additional action plan requirements.


If you have any questions, please don’t hesitate to get in touch.


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Publication of Energy Performance Certificate (EPC) Data

In an effort to make more data publicly available, the Department for Communities and Local Government will be releasing cumulative EPC data for domestic and non-domestic buildings.

Until 30th June 2016, owners and occupiers of commercial property who hold EPCs are able to opt-out of the data release should they not want their EPC information to be released to the public.

However, EVORA advises against blanket opt-outs, without careful consideration and defined reasons, on the following grounds:

  • Each EPC must be opted out individually – the opt-out process becomes very time consuming.
  • The reuse of addresses for other purposes (including marketing) is prohibited.
  • The information is valuable to researchers, whose goal will be to advise on the effectiveness of the regime and will help inform future government policy and the real estate industry is crying out for better informed Government Policy.

Information is still available via the national non-domestic EPC register (where it is possible to search for EPCs on an asset-by-asset basis – so interested parties can still check for individual asset EPCs).

Data was previously released in January 2015. You can download the data to see how it is displayed here.

Holders of EPCs can opt-out of the data release and can do so by visiting this site.

More information on this subject is provided here.

For further information or guidance please contact Paul Sutcliffe: psutcliffe@evoraglobal.com or 07557 529 104.


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Changes to the 2016 GRESB Survey- Part Two

This is the second part to our blog on notable changes to the 2016 GRESB survey.

Pilot Indicators

Six new Pilot Indicators have been included in the 2016 survey. These are indicators that are not scored this year, but will be included in 2017. This level of transparency is a great method of promoting action and allowing participants to respond to a range of environmental impacts not currently scored by GRESB. Pilot indicators include completion of assessments to measure and improve water efficiency, waste management and health and well-being. Tracking the impact and uptake of green clauses also features.

Health and Well-being

GRESB has released a new Health and Well-being module in recognition of the rapidly emerging and important area of opportunity for the real estate industry. The module seeks, firstly, to address efforts to promote health & well-being of the employees responsible for real estate entities and secondly, to address efforts to provide products and services that promote health & well-being of tenants and/or customers.

A 2014 report issued by the World Green Building Council identified that staff costs typically account for about 90% of business operating costs; rental costs 9% and utilities 1%. The report identifies the “overwhelming evidence which demonstrates that the design of an office impacts the health, wellbeing and productivity of its occupants” –productivity improvements of up to 11% are identified as achievable where good indoor air quality conditions are maintained at recommended standards.

This is clearly an area that needs greater focus and GRESB has taken steps to start addressing the topic. It is noteworthy that some organisations are demonstrating leadership on this issue, but the message (and actions to be taken) needs to reach the masses.

New Assessments

In addition to the health and well-being module, three new separate assessments have been released:

  • GRESB Developer Assessment – for organisations that develop projects or acquire properties exclusively for redevelopment and resale.
  • GRESB Infrastructure Assessment – for assessing infrastructure assets and funds, such as airports, railways, ports, waste/water and energy management facilities.
  • GRESB Real Estate Debt assessment – launched in 2015 to private real estate funds, the 2016 survey is open to banks, life companies, pension funds and mortgage REITs, in addition to real estate debt funds.

Asset Level Interface

Although not new to the 2016 survey, using the asset interface as a way of entering data is a tool that we recommend highly. The Asset Level Interface provides significant advantages over manual upload. For example, data outlier (validation) checks are made prior to upload. Automation reduces the risk of errors and the response speed to data queries is quicker and more specific. These are all important benefits as erroneous or unexplainable data will receive zero points. We are using our SIERA software platform to deliver this, which simplified the GRESB process enormously in 2015, delivering significant efficiencies.

More on SIERA

Overall, changes in the 2016 GRESB survey appear progressive in supporting the long term aim of improving Environmental, Social and Governance impacts within real estate. As stated in the first blog, the key to scoring well in GRESB remains the same:

  1. Plan your strategy based on current and future risks and opportunities.
  2. Prioritise delivery according to the value proposition.
  3. Measure and report the ongoing impact.
  4. Review new risks and opportunities and repeat from step 1.

GRESB Premier PartnerAs a GRESB Real Estate Premier Partner, we are perfectly positioned to provide GRESB support. View our official Premier Partner profile.

We can work with you to complete the submission and understand your scoring, as well as develop a sustainability plan that will improve your future GRESB performance and align with your organisation’s key environmental objectives.

Changes to the 2016 GRESB Survey- Part One

The GRESB 2016 Real Estate survey was released on 1st April and with it came the detailed (231 page) reference guide. GRESB has always been transparent about the categorisation and scoring of their indicators, which is useful if you have the time and inclination to go through those 231 pages. In this first blog of two, I have set out my thoughts on the more notable changes.

Increased focus on performance

GRESB’s goal is to “provide investors with the ESG information they need to make more informed investment decisions“. You can’t knock this goal, but there are questions as to how GRESB portfolio level assessments can provide investors  with sufficient information at the asset level. That said, GRESB scores clearly indicate how sustainability has been incorporated into participant business strategies.

GRESB results can be analysed and broken down in a number of ways.  However, fundamentally GRESB assesses sustainability across two broad levels (or dimensions as GRESB calls them):

  1. Management and Policy – a measure of the intent of your ESG programme
  2. Implementation and Measurement – a measure of the impact and performance the intent is delivering.

The GRESB quadrant is shown in the Figure 1 below.

GRESB graph

Figure 1: GRESB Quadrant Scoring Model and Global Average Scores 2011 – 2015

Participants scoring more than 50% in both dimensions are placed within the Green Star quadrant. Lower than 50% in both dimensions places you within the Green Starter quadrant. A strong Management and Policy score but weak Implementation and Measurement score results in a Green Talk score (i.e. you have good intent but it is not backed up by performance). Conversely, a strong Implementation and Measurement score but weak Management and Policy score results in a Green Walk score (i.e. you have good performance but seemingly no co-ordinated management structure behind it).

In general, participants score better in Management and Policy (2015 global average 63%) compared to Implementation and Measurement (2015 global average 52%). This is to be expected – it is relatively easy to develop plans and policies, the biggest challenge lies in achieving the results.

The global average result in 2015 for all participates was Green Star (the best rating).  To put it another way, more than half of participants achieved this GRESB rating. This has led to criticism of the GRESB scoring mechanism, as it was seen as too easy to achieve a Green Star, without performance being sufficiently scrutinised. In the 2016 survey, the overall weighting for Implementation and Management (or performance) has increased by 2 percentage points from 70% to 72%. The goal posts have shifted.

The increased focus on performance may well be significant, particularly noting the 2015 global average Implementation and Measurement score was 52% in 2015. The 2% weighted increase for Implementation and Measurement could see a large group of borderline participants shift from the Green Star quadrant to the Green Talk quadrant,

Participants should expect a greater scoring emphasis on Implementation and Measurement to continue in the future. Current participants will need to maintain forward thinking ESG strategies that deliver results to keep pace. New participants may find themselves significantly behind the curve on first submission (fortunately a grace period provides anonymity in the first year’s submission). Wherever you are in your sustainability journey, it is clear that neither complacency nor inactivity is an option.

In the second part of this blog, I will highlight the key changes to the Real Estate assessment and also introduce new GRESB assessments and modules.

Regardless of the changes introduced by GRESB, our message to achieving an impact driven Environmental, Social and Governance strategy remains the same:

  1. Plan your strategy based on current and future risks and opportunities.
  2. Prioritise delivery according to the value proposition.
  3. Measure and report the ongoing impact.
  4. Review new risks and opportunities and repeat from step 1.

 

To read Part 2 of this blog, click here.


GRESB Premier PartnerAs a GRESB Real Estate Premier Partner, we are perfectly positioned to provide GRESB support. View our official Premier Partner profile.

We can work with you to complete the submission and understand your scoring, as well as develop a sustainability plan that will improve your future GRESB performance and align with your organisation’s key environmental objectives.

Budget 2016: Changes to the UK Government Energy Efficiency Strategy

Significant changes to the Government’s energy efficiency strategy were announced in today’s budget (16 March 2016).  Key points are summarised below:

  • The Carbon Reduction Commitment (CRC) energy efficiency scheme will be scrapped at the end of the 2018-19 compliance year (the end of Phase 2). Obligated businesses will be required to surrender allowances for the final time in October 2019.
  • Lost revenue will be recovered through an increase in the Climate Change Levy (CCL).  This will come into effect from 1 April 2019.  This is designed to cover the cost of CRC abolition (although 2019 appears to be a bumper year for the Government – with increased CCL rates and a final CRC payment).
  • CCL rates and CRC allowance prices will increase in line with RPI annually until 2018-19.
  • The CCL discount for sectors with Climate Change Agreements will be increased to cover increases in CCL main rates.
  • The Government will retain existing eligibility criteria for Climate Change Agreement schemes until at least 2023.
  • The main rates of CCL for different fuel types will be rebalanced to reflect recent data on the fuel mix used in electricity generation. In the longer term, the Government intends to rebalance rates to deliver greater energy efficiency savings and reach a 1:1 ratio of gas and electricity rates by 2025.
  • Finally, the Government will consult later in 2016 on creation of a simplified energy and carbon reporting framework planned for introduction by April 2019.

Please contact Paul Sutcliffe at EVORA for more information (psutcliffe@evoraglobal.com)

Pre-Budget: Rethinking the Energy Efficiency Taxation Landscape

With the energy efficiency taxation review just around the corner, it is expected that the CRC Energy Efficiency Scheme will be scrapped or at least changed significantly.  Below, we make three key predictions:

What are the key predictions for the upcoming budget review?

  1. A simpler energy efficiency taxation landscape: A single new tax based on the climate change levy and a single reporting framework
  2. Scrapping of the CRC Scheme
  3. Further developments based on ESOS supported by an incentivisation scheme to drive the implementation of improvement measures.

Moving away from the older policy environment, the translation of theory to practice will present new opportunities to utilise ESOS to spur the uptake of energy efficiency measures. Following on from our reflections on ESOS, it makes sense for businesses to develop strategies to address energy regulations in a coordinated fashion and to reap the benefits of a combined approach. A good example of this is having a combined approach to ESOS and MEES, where meeting minimum energy efficiency requirement aligns with the broader achievement of reducing energy costs in the building.

Please stay in tune for the budget announcement on the 16th of March 2016 and our post-budget review.

Links:

Reforming the business energy efficiency tax landscape

http://www.lse.ac.uk/GranthamInstitute/wp-content/uploads/2015/11/Consultation_reforming_the_business_energy_efficiency_tax_landscape1.pdf

http://uk.practicallaw.com/3-623-4911?source=rss#

 

 

Reflecting on ESOS: The Next Steps

Going forward, what are the prospects for ESOS? EVORA highlights the next steps for the scheme.

A Coordinated compliance and improvement approach?

EVORA recommend that clients should consider the establishment of a collective approach to address all regulatory risks and opportunities. It makes sense for example, for real estate businesses to develop a strategy addressing both ESOS and the Minimum Energy Efficiency Standards (MEES).

ESOS: a burden or an opportunity for businesses?

On the whole, we believe that businesses have found the compliance process more challenging than regulators anticipated. ESOS is new and businesses will certainly feel that they had a short period of time in which to prepare. Nevertheless, EVORA is already seeing evidence that assessment results are being incorporated into energy action plans. Overtime, ESOS has the ability to deliver the energy savings the UK industry needs. However, ESOS needs to form part of a structured and stable energy policy framework.

ESOS and ISO 50001

In the latest round of ESOS, only 0.9% of businesses chose ISO 50001 as a route to compliance. EVORA believes that, over time, an energy management system approach will help deliver the best results. However, the ISO 50001 approach is also the most time and resource intensive. Nevertheless we believe that, ISO 50001 will grow in popularity over time. The low level of initial uptake will have been restricted by the long time it takes to gain certification and the lack of available certification assessors.

For more information, Paul Sutcliffe will be speaking at the UK Green Building Council (UK-GBC) ESOS Showcase Event in London on the 15th of March. The link to the event can be found on the website: http://www.ukgbc.org/event/esos-showcase

Stay in tune for further updates on the energy efficiency taxation review budget to be announced soon!

Reflecting on ESOS: The EVORA Experience

Over the last six months, EVORA has supported a broad range of clients to meet ESOS requirements. Through our support programmes we have engaged with 27 companies from Real Estate to a Big Six energy provider.

Energy spend assessed equated to £55m and saving opportunities of £2.8m (5.2%)  where identified (this equated to 27,000 MWh per annum).

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ESOS routes to compliance

It was also interesting to explore the ESOS routes to compliance. From an analysis of all ESOS participants and responses to the notification questions (excluding personal data) across the UK and a selection of industry sectors, 65% of the notifications were made during or after December 2015.

The breakdown by compliance routes was as follows:

  • ISO 50001 – 0.9%
  • DECs – 5.3%
  • Green Deal – 0.2%
  • Audits -90%
  • De Minimus – 3.6%

Audits formed the main route to compliance; although ISO 50001 could become a popular option in the future.

EVORA predicts an increase in the take-up of ISO 50001, although significant time investment is required. This reflects the opportunities that energy management system frameworks present for target-setting and monitoring for continual improvement in the long-term.

How about transport?

This is often neglected since traditionally businesses have focused on health & safety when considering travel. Many opportunities exist including training, installation of tracking-systems, promotion of alternatives to travel including video conferencing and introduction of site-specific green travel plans. Focusing on transport could present new ways to achieve significant energy and cost reductions.

Please check out our Reflecting on ESOS: The Next Steps article for more on our reflections on ESOS and the next steps going forward.

For more information, Paul Sutcliffe will be speaking at the UK Green Building Council (UK-GBC) ESOS Showcase Event in London on the 15th of March. The link to the event can be found on the website: http://www.ukgbc.org/event/esos-showcase

Stay tuned for further updates on the energy efficiency taxation review budget on the 16th of March.

 

 

70% of organisations on the road to ESOS compliance

Latest figures from the Environment Agency show 6000 organisations have complied with the Energy Savings Opportunity Scheme.

In the two days before 29 January deadline, the agency received a further 1,015 notifications of compliance. This last-minute action reflected earlier fears of a slow start to compliance by organisations covered by the scheme.

More information via The Environmentalist