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Government proposing 'Performance-Based Policy Framework' in large commercial and industrial buildings


On 19th March 2021, the Department for Business, Energy & Industrial Strategy (BEIS) launched a new consultation called ‘Introducing a Performance-Based Policy Framework in large Commercial and Industrial Buildings in England and Wales’. This consultation focuses on the implementation and development of a new occupational based methodology for non-domestic buildings.

Only 7% of non-domestic buildings are above 1,000m² in England and Wales. However, these buildings account for approximately 50% of the total floor area, and it can be estimated that these buildings use over 53% of the total energy used in non-domestic buildings. Does this mean we should change our approach towards assessing the energy efficiency of larger buildings when trying to reduce the UK’s carbon emissions?

Elmhurst has been busy analysing the effects of the proposed methodology for our members and will soon be publishing our full consultation response. In the meantime here is a brief summary of the proposed Performance-Based Policy Framework.

  • Change in methodology for assessing the occupational efficiency of larger buildings – NABERS style
  • The Government considers that the rating framework itself should look to build on and modernise the Display Energy Certificate (DEC)
  • Propose that owners and single tenants of buildings above 1,000m² will be required to obtain a rating for their building on an annual basis, and have that rating disclosed publicly online
  • Government could allow building owners to use their annual performance-based rating to satisfy some of the current ‘trigger points’ that exist under Energy Performance Certificate (EPC) regulations, specifically where the building is sold or let. That would mean building owners will not have a regulatory obligation to get a different building rating, on top of the annual performance-based rating they will be required to provide annually
  • Instead of needing to get EPCs alongside performance-based ratings to prove compliance, landlords will be able to agree a set of cost-effective measures that they need to install under Non-Domestic PRS MEES with the scheme administrator when they are first required to get annual performance-based ratings

Elmhurst’s Non-Domestic Team Leader, Josh Wakeling, comments:

“It’s great to see BEIS consulting on a new methodology that can help modernise the current DEC, which we believe is outdated and in need of suitable modernisation. However, this should not proceed at the compromise of the current EPC requirements. We must be able to assess the fabric and services of a building along with its occupational data, in order to obtain a fair and valid overview of a buildings energy efficiency. This consultation suggests a move away from the NCM for buildings over 1000m2 and their responsibility to obtain an asset rating. EPC’s have been the foundation for analysing the energy efficiency of buildings and reducing the amount of carbon in the UK. Elmhurst will continue to support the use of the NCM and SBEM calculations in the industry and we must utilise the NCM in conjunction with other methodologies, not at the cost of one another”.

Consultation available to view here: https://www.gov.uk/government/consultations/introducing-a-performance-based-policy-framework-in-large-commercial-and-industrial-buildings