OPINION


THE WRONG TOOLS FOR THE JOB


The government’s choice of asset rating tools is misguided and causing confusion among property owners who face the reality of ‘operational’ bills, says Deloitte’s Andrew Cooper


The UK faces some real and pressing problems when it comes


to reducing energy and carbon. Unfortunately, its solution has been to create an unreal world of energy use that could sabotage its achievements. Some of the real problems we face


include an international commitment to reduce carbon emissions by 80% in fewer than 40 years (based on a 1990 baseline) and a reduction in energy


supply to a capacity margin of around 4% within three years. Expert opinion varies, but there


are some who suggest we face an immediate future of power cuts at times of peak demand. Managing that demand is seen as vital to ‘keeping the lights on’. The problem is that managing demand and increasing energy effi ciency is just as much about behavioural change as technological change; a low energy light bulb still uses energy if left on when not needed. Among many engineers, it has


long been understood that placing energy modelling at the heart of government policy to help manage energy effi ciency is a mistake. The importance now placed on the National Calculation Method (NCM) and on NCM-compliant tools, such as SBEM, is worrying. Outputs of SBEM include Energy Performance Certifi cates (EPCs) and Building Regulation UK Part L Compliance Certifi cates. EPCs are required to comply with


the Energy Performance of Buildings Directive, they are needed to gain the higher Feed in Tariff (FiT) level, and are now proposed to form a tool to implement the Energy Act 2011 requirement for Minimum Energy Performance Standards. To deal with real energy problems we are required to live our life in a model, where, on a good day, a model might almost replicate actual consumption. To compound the problem, the NCM only deals with emissions from so-called


18 CIBSE Journal May 2013 Even if your lighting system is low energy, leaving lights on in an empty offi ce is still wasteful


CIBSE Guide F tells us that in a standard air conditioned offi ce,


unregulated uses from small power and lifts can account for 55% of carbon emissions


‘regulated’ uses associated with HVAC, lighting and hot water – yet CIBSE Guide F tells us that, in a standard air conditioned offi ce, unregulated uses from small power and lifts can account for 55% of carbon emissions. This virtual world of energy and


carbon leads to complacency and market confusion. Complacency as landlords pass off buildings as energy effi cient because of a good EPC, and occupiers, who often have other things to worry about, take this at face value. Confusion because the EPC rating


is variable – dependent upon the skills, knowledge and aptitude of the assessor – and dynamic through its link to targets under Building Regulations Part L. The built estate is responsible for


about 40% of energy consumption. To help meet the 2050 CO2


targets, new and


existing buildings will have to become, operationally, as close as possible to zero carbon. By this I mean real carbon emitted from real energy, with real action at an asset level, supported by the development and improvement of building technologies. It is frequently claimed that SBEM


is not a design tool. I disagree. SBEM, together with other NCM-compliant tools, promote mediocrity in design and


act as a disincentive for innovation. Developers wish to dispose of their investment as soon as possible and if a property cannot obtain planning or pass Building Regulations, then it cannot be built. SBEM is an integral part of the design process because a technology or design solution that cannot be modelled under the NCM will almost certainly be discounted in favour of one that is. The government has, to date, championed modelled asset ratings over operational ratings, in spite of clear advice from industry to the contrary. This is leading to further fragmentation of benchmarks as a disillusioned and confused property industry tries to develop its own systems, such as the Landlords Energy Rating that is being developed by the Better Buildings Partnership. Our carbon targets are real, our


energy security problem is real, the cost of energy is increasing and this leads to real costs. Logically, the system that determines the basis of a building’s effi ciency should also be, operationally speaking, real – and the process must be supported and adopted by government.


● ANDREW COOPER is a senior consultant at Deloitte Real Estate


www.cibsejournal.com


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