Government consultation proposes the abolition of Display Energy Certificates (DECs)

Earlier this month the Department for Communities and Local Government (DCLG) published a proposal to either significantly reduce the need for DECs or abolish the need for DECs completely.

There are various proposals in the consultation, “Display Energy Certificates: Current regime and how it could be streamlined and improved” Click Here. Elmhurst Energy strongly recommends that all our members respond to the consultation and may also like to pass this invitation to colleagues and like minded clients. The deadline for this consultation is the 11th of March.

The proposed changes to the requirements of Display Energy Certificates are contentious on almost every level and Elmhurst Energy encourages all energy assessors, in whatever sector, to respond and prevent the government eroding the concept of DECs and energy assessment generally.

The Government’s consultation is primarily concerned with improving enforcement and reducing the burden of compliance. However the suggestions for improving compliance are fairly weak while those for reducing the burden of compliance are strong, some of the proposed options are;

  • Redefine the definition of a public building visited frequently by members of the public so that buildings such as schools are excluded
  • extend the exemptions in the Directive which currently apply to Energy Performance Certificates (EPCs) to DECs
  • exempt those buildings that have and display their EPC from the requirements to have a DEC
  • to set the validity period of all DECs and their accompanying recommendation reports to five years
  • set the validity period of all DECs and their accompanying recommendation reports to ten years
  • abolish the use of DECs entirely for EPBD and fulfil the requirement to display by using an EPC

Public authorities leading by example?
One of the key requirement that the government is legally required to address is within clause 23) and 24) of the Energy Performance of Buildings Directive itself;

23) Public authorities should lead by example and should endeavour to implement the recommendations included in the energy performance certificate. Member States should include within their national plans measures to support public authorities to become early adopters of energy efficiency improvements and to implement the recommendations included in the energy performance certificate as soon as feasible.

(24) Buildings occupied by public authorities and buildings frequently visited by the public should set an example by showing that environmental and energy considerations are being taken into account and therefore those buildings should be subject to energy certification on a regular basis. The dissemination to the public of information on energy performance should be enhanced by clearly displaying these energy performance certificates, in particular in buildings of a certain size which are occupied by public authorities or which are frequently visited by the public, such as shops and shopping centres, supermarkets, restaurants, theatres, banks and hotels.

This is the requirement that the legislation tries to address and we believe that the current solution fails to meet these requirements and, if the proposals in the consultation where to be implemented then it will make matters worse.

Schools aren't public buildings?
Clause 24) (first sentence and reinforced in the second) clearly refers to two type of buildings

1) Public buildings and

2) {Buildings} frequently visited by the public

Accepting that pupils may not "legally" be members of the "public". However schools are "public buildings" and by virtue that members of the public make frequent visits (parents appointments, out of hours social events, adult education, letting of facilities etc), they are within scope on both counts.

DECs are a cost burden?
In 2013 the Department for Energy and Climate Change (DECC) published their report; "Energy Trends: June 2013, special feature articles - Display Energy Certificates" Click Here. This reported that public buildings achieved average energy savings of 12.1% over buildings without DECs and yet the consultation uses a figure of 2% from a 2008-2009 report. Even so with Schools in England and Wales spending an estimated £400 million on energy, the lower figure of 2% still equates to £8million of savings; many times more than the cost of having the DEC assessments completed.

We can re-assess buildings less frequently and use an EPC?
Government, building owners and occupiers all need to have accurate and reliable information on how their buildings perform and, when improvements are made, reliable data on which to demonstrate that improvement. If DECs are produced only every ten years it will not be possible to demonstrate that improvement and return on investment that is needed to drive energy efficiency. A DEC is a far better tool than an EPC for allowing a building occupier to measure, understand and implement recommendations as it relates to the real energy use of the occupier in the building not to a generic model.

In summary
The Directive is correct to require the owners of high profile buildings to take a lead in demonstrating commitment to energy efficiency, and to draw attention to the significance of energy use in buildings. Schools, in particular, use DECs as a practical demonstration of the importance of energy management which will instil good practice in the future generations.

Elmhurst Energy will be asking that the consultation to conclude that;

  1. All buildings visited by the public on a regular basis (whether privately or publicly owned) should be required to hold and display a Display Energy certificate.
  2. Almost all schools are visited by the public (sporting events with visitors from other schools, "out of hours" events such as Staff / Parent Consultations, PTA meetings etc) on a frequent basis and therefore should be required to hold and display a Display Energy certificate- schools should be assumed by default to require a DEC unless they can prove otherwise.
  3. Enforcement should be strictly applied and preferably by a national body. Asking local authorities to be responsible for policing their own activities, or the activities of a neighbouring authority, is impractical.
  4. The validity period of all DECs should be standardised at 12 months, to reflect the volatility of fuel prices and to accurately measure the improvements made.
  5. The regulatory impact assessment should be redone taking into account the cost savings that have been instigated by the use of DECs- this we believe would outweigh the cost of the DEC regime and would show ultimately a bigger saving for the public purse.

What next?
Elmhurst strongly recommends that all our Members respond to the consultation Click Here and also take this up with your MP and MEP, find your local politician here.

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