Memorandum by the Association for the
Conservation of Energy
INTRODUCTION
The Association for the Conservation of Energy
is a lobbying, campaigning and policy research organisation, and
has worked in the field of energy efficiency since 1981. Our lobbying
and campaigning work represents the interests of our membership:
major manufacturers and distributors of energy saving equipment
in the United Kingdom. Our policy research is funded independently,
and is focused on four key themes: policies and programmes to
encourage increased energy efficiency; the environmental benefits
of increased energy efficiency; the social impacts of energy use
and of investment in energy efficiency measures; and organisational
roles in the process of implementing energy efficiency policy.
In light of the Association's remit, we shall
be confining ourselves to responding to questions 3 and 10 of
the Committee's Inquiry.
SUMMARY
— The Government is not on track to
meet its own carbon reduction and energy efficiency targets.
— Current targets are merely set as
aims or goals and should be made mandatory.
— The Government should back Anne Snelgrove
MP's Public Sector Buildings (Energy Performance) Bill which makes
mandatory the Government's commitment to procure buildings in
the top quartile of energy performance.
— Government has failed to introduce
new requirements for the procurement of energy efficient public
sector buildings pursuant to Article 5 of the Energy Services
Directive.
— All targets should be extended to
cover Executive Non-Departmental Public Bodies, in addition to
Government Departments and Executive Agencies.
CARBON EMISSIONS
AND ENERGY
CONSUMPTION TARGETS
3. Why has progress in reducing carbon emissions
from the Government Estate been so poor? What should be done to
accelerate progress?
1. In the Sustainable Development Commission
(SDC) Fifth Annual Report of 2006, Sustainable Development
in Government, one of the key findings stated that Government
was not on track to meet its target to reduce carbon emissions
from energy use by 2010. A year later the Government is no closer
to meeting this target: in fact the 2007 SDC Annual Report
highlights that carbon emissions from Government offices (excluding
Ministry of Defence) have increased by 22%. If the Government
were on track to meet its target to reduce carbon emissions by
12.5% by 2010, Departments should have reduced emissions by 1%
per annum—which would have meant a 6% reduction by 2005-06.
However, the actual reduction achieved across the central government
estate was only 0.5%.
2. According to the latest National Audit
Office report, Energy consumption and carbon emissions in government
departments, 16 out of 21 departments are not on track to
meet their carbon reduction targets and there is no downward trend
in emissions. Last year 14 out of 21 departments were less energy
efficient than they were in 2000; this year that has risen to
15 departments.
3. ACE believes that the reason for this
lack of progress is that currently all targets are merely set
as aims or goals and it is not mandatory for targets to be met.
To this end the Association for the Conservation of Energy is
supporting Anne Snelgrove MP's Public Sector Buildings (Energy
Performance) Bill. This Bill gives legal force to the Government
commitment to require all buildings on the Central Government
Estate to be procured in the top quartile of energy performance.
This commitment was first made in Defra's Energy Efficiency Action
Plan in April 2004 and subsequently restated in the Common Minimum
Standards for the Procurement of Built Environments in the Public
Sector, published by the Office of Government Commerce in September
2005. The most recent restatement of the commitment was in the
2007 Energy White Paper. By supporting the Public Sector Buildings
(Energy Performance) Bill, the Government will put itself back
on track to meet its targets. This will also create a demand for
low carbon buildings across the rest of the commercial sector.
4. The Government should seize the opportunities
provided by Article 5 of the Energy End-Use Efficiency and Energy
Services Directive to introduce requirements to procure energy
efficient public sector buildings. Article 5 of the Directive
requires the public sector in member states to fulfil an exemplary
role in driving forward energy savings. In particular member states
must ensure that energy efficiency improvement measures are taken
by the public sector, focussing on cost-effective measures which
generate the largest energy savings in the shortest span of time.
To do this member states must introduce at least two energy efficient
public procurement measures from a list of six eligible measures.
5. Instead of seizing these opportunities,
in its recent consultation Defra proposed that the UK Government
fulfil its obligations under Article 5 merely by implementing
requirements to purchase energy efficient equipment and
vehicles. It has opted not to introduce new requirements
for the procurement of energy efficient public sector buildings.
We believe this is a huge missed opportunity to improve on the
poor energy performance of public sector buildings. By introducing
such requirements in addition to those for equipment and vehicles
and by supporting the Public Sector Buildings (Energy Performance)
Bill, the Government will demonstrate unequivocally that it is
serious about leading the way in the fight against climate change.
By setting its own house in order, it can encourage others to
do so from a position of strength.
10. SOGE targets currently cover core Departments
and Executive agencies. Is this adequate, or should they be extended
to cover all Executive NDPBs especially given the growing volume
of Government business covered by arm's-length bodies?
6. ACE believes that all public sector sustainability
targets should be extended to cover all Executive Non-Departmental
Public Bodies. This would mirror the scope of the Common Minimum
Standards for the Procurement of Built Environments in the Public
Sector, which quite clearly covers Non Departmental Public Bodies
as well as Government Departments and Executive Agencies.
21 April 2008
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