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Restricting urban biomass: A chance to improve city air quality

Reducing the volume of emissions for real estate activities and subsequently improving air quality is something EVORA Global supports clients in committing to. Often, this involves changing the way factors such as energy and heat consumption are managed. Switching from traditional fossil fuel to cleaner means is a great way to start, however, alternative means of heating still need to be carefully considered in terms of the overall impacts tied to them. 

Biomass systems are an example of an alternative heating source requiring such attention, due to implications for air quality from what they emit. In this blog we explore the potential issues with biomass and what the alternatives are for asset owners looking to move towards renewable heat. 


UK non-domestic renewable heat

The topic of renewable heat has been rising up the agenda as a key part of UK decarbonisation and net zero targets. According to BEIS it is estimated that a third of energy consumption in the UK is from heating, with  a substantial portion of this stemming from fossil fuel sources. 

Traditionally heating has been sourced predominantly from gas (~78%) in the non-domestic space, with only a small proportion from electricity (~8%) and even less from alternative sources (~6%) according to an Imperial College London and Vivid Economics analysis in 2018. As a result, to advance decarbonisation efforts, subsidy schemes such as the Renewable Heat Incentive (RHI) have been introduced. 

The Non-domestic RHI serves organisations that use alternative heating, incentivising the switch by paying generators for generated heat. In this way, renewable heating systems can be paid for in the long term, due to bill savings and cash flow from set tariffs lasting 20 years. Biomass, organic matter used for fuel, has been the most popular alternative, leading the way in terms of the RHI’s contribution to energy system decarbonisation. In fact, as of the end of August 2019, biomass accounted for 16,776 accredited systems across GB, with a capacity of approximately 4.1GW. This represents around 85% of the total number and generating capacity under the non-domestic scheme as shown in Figure One.

Figure 1 – Proportion of alternative heating installations by number and installed capacity (MW) across GB under the non-domestic RHI. 
Source: BEIS – RHI Monthly Official Statistics Table August 2019

Biomass is a carbon neutral fuel as carbon emitted is offset by that absorbed during the growth of the fuel (assuming that a sustainable supply chain is created with a continuous carbon sink and replenishment strategy in place). When compared to other fuelled boilers in Figure 2, data from the UK Houses of Parliament in 2016 suggests that the direct emitted carbon from biomass is lower than other conventional systems. This builds a strong case for using it in heat intensive settings.

Figure 2 – Average emitted carbon from conventional boilers of different fuel types
Source: UK Houses of Parliament 2016

Issues with air pollution

However, biomass has come under scrutiny due to other emissions which result from the combustion of the wood pellet fuel. Fine particulate matter (PM 2.5), ammonia (NH3), nitrogen oxides (NOX), sulphur dioxides (SO2) and other harmful substances have been found in high volumes on average from biomass systems. 

PM 2.5 is an air pollutant that is a major concern for people’s health and wellbeing due to reducing the quality of the air we breathe, causing respiratory difficulties and affecting lung function in the long term. This is primarily from the particulates themselves, however, PM 2.5 can act as a sink for other toxic substances which are produced from transport and industry which can also be drawn into the lungs. Therefore, it is of interest that the volume of PM 2.5 emissions is reduced in urban areas, due to the general proximity of the public to sources of emissions, as well as the relative density of pollution in these regions and other toxins that can be mixed in.

Data from EMEP/EEA air pollutant emission inventory guidebook 2016 illustrates the issue that biomass presents in Figure 3 below, with PM 2.5 emissions being the second highest of the comparative boiler fuels. When these systems are concentrated in an urban area, the issue is only exacerbated.

Figure 3 – Average PM 2.5 emissions from standard boilers of different fuel sources (*electricity does not factor source combustion)
Source: EMEP/EEA air pollutant emission inventory guidebook 2016

A BEIS consultation – restricting urban biomass

Due to issues arising from the continued rise in popularity around biomass and potential to impact air quality, Government outlined in an October 2018 consultation – Renewable Heat Incentive: Biomass Combustion in Urban Areas – the potential to restrict biomass facilities in urban areas. In effect, this will remove the financial incentive for all new biomass installations including combined heat and power (CHP). It has been a year since this consultation was introduced and Government has yet to provide a public response, however it is be speculated that the commitment to restrict urban biomass will follow through, as the Clean Air Strategy 2019 published in January 2019 reiterated the intention to do so.

These restrictions are aimed at steering potential installers of RHI systems away from biomass toward different measures, namely, those with a zero PM 2.5 emission status, as well as energy efficiency measures. As a result, BEIS suggest that the potential net present value of banning urban biomass from January 2019 could be as much as £89mn, with £23mn sourced from air quality impact savings alone due to lower social resource costs. Furthermore, carbon saving of 0.6MtCO2e per annum could also be achieved if other RHI technologies are deployed instead such as heat pumps and solar thermal.


Alternatives for asset owners to consider

Despite heating systems being a staple in all buildings, the reliance on them is still up for debate. It can be considered that in a temperate region like the UK, the need for external heating systems providing heat to buildings is unnecessary, especially in new builds where most new installations are likely to be targeted. In the case of biomass systems, they may not even need to be considered if energy efficient measures can be designed into a construction in the first instance. Furthermore, when looking at older structures energy efficiency and heat dependence can be improved through retrofitting. 

New build thermal efficiencies are expected to increase in the next decade or so, with the tightening of Part L Building Regulations and promotion of better standards such as Passivhaus including improved insulation, reduced air flow and intelligent design to take advantage of solar thermal energy. This could, in the longer term, negate the need for external heating completely, biomass or otherwise as room temperatures are maintained through the day. Therefore, alternative heating arrangements can be put in place, these being smaller and possibly modular RHI accredited systems which can adapt to a growing company throughout the year. This would promote flexibility, energy savings and reduced emissions overall.

…alternative heating arrangements can be put in place, these being smaller and possibly modular RHI accredited systems which can adapt to a growing company throughout the year. This would promote flexibility, energy savings and reduced emissions overall.

However, for existing buildings, which make up most of the real estate stock, external heating will still be required regardless of energy efficiency measures put in place. But real estate within urban regions can still tap into the benefits of renewable heat while avoiding localised air pollution by investing in other generator types. Air source, ground source and water source heat pumps, solar thermal arrays and geothermal installations are RHI accredited systems that do not combust material and therefore have zero PM 2.5 or carbon emissions as a result. 

Utilising these technologies therefore help investors to contribute to sustainability standards, improve health and wellbeing overall and act as an alternative to sometimes expensive energy efficiency retrofitting as well as receiving subsidy for their contribution. 


In summary, though biomass is a good alternative to carbon emitting fossil fuel boilers, in the urban environment emissions of PM 2.5 are problematic and undesired. As a result of the BEIS consultation, newly installed urban biomass is likely to lose subsidy. However, there are alternatives in place which can keep buildings warm but will help to improve air quality, through either complete replacement of biomass systems, or by using intelligent design to negate the need for large external heating in the first place. 

For more information surrounding urban RHI systems or energy efficiency measures, please get in contact with the team. 

MEES: Consultation calls for EPC rating to be raised to band B for commercial buildings by 2030.

On 15th October 2019 the Government’s Department for Business, Energy & Industrial Strategy (BEIS) published its future trajectory for Minimum Energy Efficient Standards (MEES) for non-domestic commercial buildings. 

The consultation follows the government’s earlier commitments in the year to hit net zero carbon emissions by 2050. Under the current consultation the government propose a new plan to raise the minimum EPC rating from ‘E’ to ‘B’ by 2030.

Under the original MEES legalisation, from 2018 landlords are not permitted to grant any new tenancies or extend/renew any existing properties with an EPC rating of an F or G. Plans to keep the existing regulatory policies are still underway and the legislation will still be extended to ‘all existing leases’ from 1 April 2023.  The consultation to raise the minimum EPC rating from an ‘E’ to ‘B’ by 2030 will significantly impact energy management planning for landlords across the UK. 


MEES: is it all plain sailing from here?

85 percent of existing commercial buildings in England and Wales would need improvements to achieve the EPC band B target, with investment costs up to £5 billion.

Granted there are stipulations in the proposal, for example if the payback period does not meet the seven-year payback rule, the landlord could still apply for an exemption worth five years. The government are also looking for ‘market-led’ solutions in order to tackle any issues regarding tenant consent to prevent landlords essentially attempting a ‘get out of jail-free’ card.

The consultation has also considered the idea of raising the EPC to a ‘C’ by 2030, or alternatively taking an incremental approach, with milestones for landlords to reach the rating of B by 2030 (for example, 2020 D, 2025, C…etc). However, both are deemed less favourable due to fewer emissions savings between now and 2030 and capacity issues. Could there in fact be a way to incentivise landlords to carry out works?

Overall, the fast-paced movement of the consultation appears positive (from an energy / carbon management perspective), it does go without saying though that the implications of such legislation could result in greater risks for business’ today, if no action is taken.

Are you at risk?

The answer is: you may well be

The government intends that responsibility for the energy efficiency of the building will continue to sit with the landlord. Therefore, failure to comply with regulations will result in fines between £5000- £150,000. All types of non-domestic properties may struggle to sublet standard space without undertaking improvement works, and therefore become difficult to let or sell due to their poor EPC rating. It is well known that landlords face many challenges with the current EPC rating system. EPC calculations are linked to building regulations, which means it makes it harder to achieve a satisfactory rating when targets are continually being strengthened. Therefore, business’ need to be able to identify where the gaps are in their data and ensure those most at risk by the new band increase are adequately prepared. 

With the consultation hinting greater rigour in its enforcement, there is no doubt that businesses should look to future proofing their assets against changing regulations in energy efficiency. It’s good to see this as an opportunity! The consultation even announced that the current regulatory framework which only considers the condition of buildings rather than their operational energy efficiency, has now been scheduled in for an additional consultation on the introduction of mandatory ‘in-use’ energy performance ratings in 2020. There is no denying MEES requirements are being accelerated in a short span of time. Therefore, it is expected that we will see more changes in the next coming years.


So, the key question here is how can you as a business combat against this measure? And how can we help you do so?

Well have no fear, EVORA is here…

EVORA have some nifty blogs that explain how your buildings can achieve EPC level B. But for a quick overview:

Landlords should identify where there are gaps are in the data and which are at most risk across their portfolios/funds. Having access to a central database that stores all key information in a consistent format will provide an easily aggregated view of which sites are at risk. EVORA can help clients with the use of its SIERA platform – a proprietary sustainability management software – to provide a cost effective and high-quality EPC service, that ensures accurate and more in-depth analysis of buildings and risk. With a combination of basic EPC information and lease data the SIERA EPC profiler can identify, categorise and rank potential MEES risk for each building. 

Figure 1: EPC MEES risk profiling in SIERA – Overview

Data is stored and displayed in a tabular and graphical format with the capacity to filter analysis based on a range of criteria including EPC rating, EPC expiry, lease event and estimated rental value. As result, the EPC profiler can breakdown risk and provided landlords with a simple and complete understanding of requirements and risks under the MEES regulations. 

Figure 2: EPC MEES risk profiling in SIERA – Filter

EVORA Edge have a multitude of cutting-edge modelling techniques, project management and mechanical, electrical and public health (MEP) consulting that could help mitigate against the implications of raising the minimum energy efficiency standard. Starting with dynamic simulation modelling that could provide predictions on your EPCS to ambitious strategies that align with your buildings planned maintenance programme. By managing MEES risks, landlords can safeguard building value, enhance energy management and promote resilience.


It is undeniable that energy efficiency of buildings is one of the key issues facing investors in the market today and that is why EVORA is here to help mitigate against those risks. For more information or a chat about drop us an email info@evoraedge.com or call on +44 (0)1743 341903.

Easy energy savings: Closing Up for Christmas

Easy energy savings: Tips & Tricks to minimise your energy consumption over the Winter break.

It’s that time of year again: the old Christmas jumper pulled from the depths of your drawers, Secret Santa gifts exchanged, every last drop of mulled wine in a three-mile radius consumed, and now Christmas is just around the corner and the office is closing up.

With all the occupants out and about, why not give your building a break too?

With all the occupants out and about, why not give your building a break too? Closing up for Christmas should be more than just locking the doors and turning on your out of office – the holidays present an ideal opportunity to shut down your building systems and avoid unnecessary wear & tear and energy usage.


These are our top tips for site teams on closing up the office for Christmas:

  • Shut down central plant– The 25thof December and the 1stof January are national holidays across Europe, so as a minimum plant need not run on these days. Many offices will shut on other days as well or even throughout the whole period so be sure to make the most of this. The majority of BMS front-end systems will allow you to set exceptions for specific days so that everything returns to the normal setup in the new year.
  • Turn off / turn down radiators– Any manually-controlled radiators around the building will continue to pump out heat unless you turn down the thermostats or switch off the LTHW system centrally using the BMS.
  • Check frost protection settings– Dealing with frost damage is no way to kick off the new year. Therefore, make it your early resolution to ensure that all internal temperature (stage 2) frost protection settings are adequate. EVORA recommends these be set to 10ºC.
  • Review tenant control panels– We all know what an office is like… Sarah’s too hot, Jonny’s too cold, and no one knows why Phil keeps opening the window. If you leave tenant HVAC control panels unchecked for too long, this battle of wills can quickly make a mess of the settings. As the office empties over the holidays this can be an ideal moment for the site team to step in and do a review, whilst minimising disturbance for the tenants.
  • Reduce fresh air delivery– Even if the office is open chances are occupancy is reduced, and with fewer people around CO2 levels in your building will increase much more slowly. If you’ve got a demand-driven system with CO2 sensors on the extract ducts then, nice work, your BMS is sorting it for you. If not, then consider monitoring building occupancy and internal air quality, then reducing the fresh air delivery rate and/or Air Handling Unit operating hours where possible based on this information. This will have the bonus effect of reducing heating demand, as less cold winter air will be pulled in from outside.
  • Finally, unplug the Christmas lights– I know you’re proud of your nicely decorated tree but come on now, nobody’s here to see it, just switch the lights off!

Happy Holidays from everyone at EVORA!

ESOS Phase 2 compliance: Have you got a plan in place?

With the compliance deadline for ESOS Phase 2 just a year away – 5 December 2019 – proactive organisations have started to prepare by planning and carrying out energy audits as part of the compliance process.

With only a few exemptions for public bodies, your organisation qualifies if on the 31st December 2018, it meets the ESOS definition of a large undertaking:

  • You employ 250 staff or more
  • You have an annual turnover exceeding €50m and a balance sheet exceeding €43m

Qualifying organisations that fail to undertake an ESOS assessment will be liable for a penalty of up to £50,000 and details of non-compliance would be published.


To avoid this action, organisations are required to complete the following compliance procedures;

  1. Measure and report energy use for a continuous 12-month period (overlapping the qualification date of 31 December 2018), to include energy consumed by buildings, industrial processes and transportation activities
  2. Identify your areas of significant energy consumption. ESOS assessments must be completed to cover at least 90% of an organisation’s total energy consumption
  3. Appoint a Lead Assessor to carry out, oversee or review your energy audits and overall ESOS assessment
  4. Undertake energy assessments for your areas of significant energy consumption using one or more of the following approved routes:
    • ESOS Energy audits
    • Display energy certificates
    • An ISO 50001 Energy Management System
  5. Report compliance to the National Scheme administrator – the environmental agency in England, SEPA in Scotland, NIEA in Northern Ireland and NRW in Wales and store your records of assessment.

Don’t forget to take advantage of the energy saving opportunities identified – EVORA identified £2.8M of energy savings in Phase 1 of ESOS.

With our expertise and data management solution SIERA, we can implement energy efficiency programmes, leading to substantial reductions in energy usage and associated costs. Our energy management team typically find quick win energy savings with payback in less than a year. Read more here on how ESOS can be a long-term investment to your business.


EVORA employs qualified Lead assessors and can support you to develop a practical compliance strategy that is appropriate for your organisation.  To ensure you fully comply with ESOS Phase 2, we offer a range of practical solutions. Find out more in our ESOS Compliance Guide .

ISO 50001 2018 revision

Earlier this week, the International Standard for Energy Management Systems (EnMS), ISO 50001 was given its official reboot through the launch of the 2018 revision; updating the 2011 issue. Organisations with existing ISO 50001 certifications have up to three years to transfer to the new standard. Whereas, businesses seeking energy management accreditation for the first time can progress directly with the 2018 version.


The ISO 50001 standard is an internationally recognised framework for the supply, use and consumption of energy in all types of organisations. As well as the direct benefits of saving energy, if you have an ISO 50001 energy management system that’s certified by an approved certification body and covers all your energy use, this can count as your company’s compliance route to Article 8 of the EU Energy Efficiency Directive (Energy Savings Opportunity Scheme- ESOS – in the UK) .

The revision follows similar recent updates to other standards including ISO 9001:2015, and ISO 14001:2015, to include common terms, definitions and structures to provide a high level of compatibility across the ISO suite of standards.


The main changes in the 2018 revision include:

  • Adoption of “high level structure” and common terminology already reworked into ISO 9001:2015 and ISO 14001:2015
  • Stronger focus of the role of top management and leadership engagement
  • More clarity on definitions, including “energy performance improvement”
  • Greater emphasis on risk-based approaches to improving energy performance
  • Clarification on exclusions of energy types
  • Clarification of energy performance indicator (EnPI) and energy baseline (EnB) text to provide a better understanding of these concepts.

The focus on continuous improvement remains active in the revised standard. Driving continual improvement is what EVORA specialises in and we can assist you in implementing and/or transitioning your energy management approach to the new ISO 50001 framework.


With our Plan, Do, Act approach, we can help you develop a tailored EnMS aligned to your business needs which takes account of practical measures in reducing your energy consumption. Contact our experts if you’d like to find out more.

Energy Savings Opportunity Scheme (ESOS) – a burden or an opportunity?

Regulatory reporting can often feel a burden, and in areas which are more specialist, such as energy and carbon reporting, it can be a daunting experience.

Energy and carbon reporting regulations have principally been introduced to highlight the materiality of the impacts and provide visibility of the opportunities to deliver both energy and cost savings.

The reality is that many organisations only want to be compliant and it is only the few who see the opportunity to push forward opportunities and create a competitive advantage.

A good example of this is the Energy Savings Opportunity Scheme (ESOS).


ESOS (Article 8 in Europe) is upon us again in the guise of Phase 2 and will impact large undertakings both in the UK and Europe, requiring them, in simple terms, to measure 12 months of energy across their organisation and identify energy efficiency initiatives through energy audits. For more information on meeting compliance read our ESOS compliance guide.

ESOS has been developed to help organisations understand their total energy use and identify opportunities to deliver energy and cost savings, which is presented to senior management. It is hoped by the government that ‘low hanging fruit’ with pay backs of less than a year will be a no brainer to organisations to implement.

Although the deadline is the 5thDecember 2019, there are advantages in kicking off early with the energy audits, firstly to have a project plan in place to ensure you meet the deadline and secondly to identify cost-effective energy efficiency opportunities, which could provide immediate benefit to the financial bottom line. In Phase One, EVORA identified £2.8M of low cost energy savings for its clients.

Do you see ESOS as a cost to your business or an investment?

ESOS only requires you to identify the opportunities and ironically many organisations did not implement the initiatives found in Phase One. This turns ESOS regulation into a cost rather than an investment – a significant missed opportunity.

An example of the quick win opportunities is highlighted by work EVORA delivered in collaboration with a property management company to deliver an energy efficiency programme utilising EVORA’s energy management software, SIERA. The graph below displays the weekly energy profile at the office building (110 Queen Street in Glasgow) before (light blue line) and after interventions (dark blue line) were brought about by the improvement programme.

Significant improvements in the energy profile can be seen, especially at the weekend, which has delivered savings of 30% (greater than £30,000 actual savings in the year) without any capital expenditure. This was achieved despite increased occupancy at the property throughout the year and payback was less than three months.

For more information on how we delivered these savings read the full case study here.

This is certainly not the exception and we have worked with an array of sectors including power generation, real estate, retail and hotel & leisure to optimise energy efficiency, often achieving surprising results.

If you’d to learn more about how we can support you with your ESOS regulation and turn a compliance cost into a long term investment, contact us.

£2.8m of energy savings identified by EVORA in ESOS Phase One

ESOS guidance was published by the government on 26th June 2014, with a deadline for ESOS Phase One of 5th December 2015 – 528 days for organisations to achieve compliance – simple, right?

Understandably, with the data for ESOS having to overlap the qualification date of 31st December 2014, a lot of organisations left it until 2015 to arrange compliance approaches. A large proportion of these left it late, with last minute requests rolling in, the last of these, very late requests was received in October 2017 (a mere 22 months after the original deadline)!

Managing large volumes of data for an array of clients is something EVORA is used to as part of our day job, but throw in the need for communication of ESOS findings to top management prior to notification and arranging multiple site visits across the UK at short notice, made for a busy end to 2015.

Read more about ESOS Phase Two here and here.


Our Approach to ESOS Phase One

Each company we worked with had an approach tailored to their requirements to ensure the ESOS assessment fit with their operations. We worked with a range of clients including a ‘Big Six’ energy provider, institutional real estate investors, a tyre manufacturer and a bacon packing firm. This resulted in a large breadth of energy saving opportunities identified across different industries.

Whilst many compliance routes were available to participants, after consideration of the options available, the completion of energy audits was the primary compliance route taken by EVORA. These provided tangible detailed savings across both utility and transport energy use.  However, we believe moving forwards, the uptake of ISO50001 (one of the compliance routes) may increase due to the additional benefits associated with operating a certified energy management system (in place of audits every four years).

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In October 2017, EVORA was instructed to complete an ESOS assessment which required submission within ten days. Our client had received an enforcement notice from the Environment Agency (which had been passed around departments for over two months prior to our involvement). A tight turnaround to say the least and shows that the Environment Agency are following up with companies they believe to be non-compliant almost two years after the original deadline.


Key Outcomes

28 Companies were supported in total with over 400 assessments (site visits, desktop analysis, transport audits) completed. Over 27,200MWh of energy savings (electricity, gas and transport based) were identified through these ESOS assessments. This equated to potential cost savings of £2m in electricity, £0.2m in gas and £0.6m in transport energy spend. All notifications of ESOS compliance were made to the Environment Agency in line with the defined timescales of the scheme.

[clickToTweet tweet=”Over 27,200MWh of energy savings were identified. This equated to £2m electricity, £0.2m gas and £0.6m transport” quote=”Over 27,200MWh of energy savings were identified through ESOS assessments. This equated to £2m in electricity, £0.2m in gas and £0.6m in transport energy spend”]

The ESOS assessment request received in October 2017, was submitted to the Environment Agency, inside four days, a full six days in advance of the deadline. A very tight turnaround (which we do not recommend!), but with full data available and buy-in from top management meant it was achievable.

One of the main learning outcomes we found, was that the smaller companies gained more new information through the energy audit process than the larger organisations. The savings identified via the energy audits were the first time a lot of the smaller companies (i.e. those just exceeding the qualification criteria) had been presented energy saving opportunities with clear payback and life cycle costs included. However, the availability of capital to invest in these opportunities was more restricted for the smaller organisations.


Our structured approach supported our success in ESOS phase one and means we enter ESOS phase two confidence of our ability to deliver ESOS compliance to an even wider range of companies.

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