Memorandum Submitted by the Association
for the Conservation of Energy ACE
INTRODUCTION TO
THE VIEWS
OF ACE
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 three key themes: policies and programmes to
encourage increased energy efficiency; the environmental, social
and economic benefits of increased energy efficiency; and organisational
roles in the process of implementing energy efficiency policy.
SUMMARY
Radical and urgent steps are needed to
ensure that Government meets its own carbon reduction and energy
efficiency targets.
Current targets are merely set as aims
or goals and should be made mandatory.
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.
Display Energy Certificates (DECs) should
be widened to cover all public buildings and the Department for
Communities and Local Government (DCLG) should share this information
with the Office for Government Commerce (OGC).
The public sector must acknowledge its
capacity to transform the wider commercial property market.
Targets must be met through improving
the energy efficiency of the Government estate and not through
offsetting.
The public sector must lead by example
to demonstrate unequivocally that it is serious about leading
the way in the fight against climate change.
The role of the Centre for Excellence in Sustainable
Procurement and the Minister for Transformational Government in
co-ordinating and driving forward activity across Government.
1. In September 2008 the Community
Energy Saving Programme was announced, also with the initials
CESP; we find it extraordinary that Government is running two
programmes with the same initials as this will inevitably be very
confusing.
2. Nevertheless, the Association welcomes
the creation of a central body to take on sole responsibility
for meeting sustainability targets and agrees that a Cabinet Office
Minister should be responsible for ensuring that Government meets
its sustainable operations and sustainable procurement targets.
This will help to overcome the problem of fragmentation of policy
responsibility amongst Government bodies for improving environmental
and sustainability performance.
3. However, the Sustainable Operations on
Government Estate (SOGE) targets are merely aims or aspirations
and unless these targets are made mandatory and a duty placed
on the responsible Minister for reaching them, the Association
has limited confidence that they will be met.
The Extent to which Government Commitments and
Mandated Targets are being Enforced
4. The Sustainable Development Commission
(SDC) Annual Report of 2007, Sustainable Development in Government,
highlights that individual Government departments are not on track
to meet their SOGE targets and nearly two-thirds of departments
are not on track to meet their own 12.5% carbon emission reduction
target by 2010-11[1]
5. 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 annumwhich would
have meant an 8% reduction by 2007. However, the actual reduction
achieved across the Government estate was only 4% in total.[2]
6. The energy performance of departments
varies widely with 17 out of 21 Government departments
not on track to meet their energy efficiency targets and 13 out
of 21 Government departments not on track to meet their carbon
reduction targets.[3]
The Environmental Audit Committee (EAC) themselves has voiced
their concern that the "trajectory (for carbon emissions)
is going so dramatically in the wrong direction"[4]
The reasons behind the continuing poor progress
on reducing carbon emissions from offices
7. 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.
8. 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, focusing 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.
9. Instead of seizing these opportunities
the UK Government has deliberately opted to fulfill 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, the single biggest energy user. We believe this
is a huge missed opportunity to improve on the poor energy performance
of public sector buildings. We would urge the Government to revisit
the potential identified under Article 5.
10. The Government has itself identified[5]
that strong leadership on the energy standards of the buildings
it purchases, leases or procures can start to transform the wider
commercial property market. This is an extremely important and
perceptive statement and recognises that the public sector is
always the preferred tenant by any landlord for the simple reason
that it always (eventually) pays its bills and never goes bankrupt.
Few landlords wish to rule their properties out from consideration
by this preferred tenant, and will be prompted to improve their
properties in order to encourage such tenants to consider their
properties.
11. In the 2004 Energy Efficiency Action
Plan, the Government committed themselves to "procure only
buildings in the top quartile of energy performance" and
to widen this to the rest of the public estate as soon as practicable.[6]
This commitment has been restated several times over the last
four yearsmost recently in the 2007 Energy White Paper.
12. ACE promoted a Private Members' Bill
in the last Parliamentary session which aimed to give statutory
effect to this "top quartile" commitment. The provisions
of this Bill are now enacted in the Climate Change Act 2008. Section
86, Report on civil estate, requires Government to report on the
progress made in ensuring that buildings that become part of the
civil estate fall within the top quartile of energy performance.
If a building does not fall within the top quartile of energy
performance the report must state the reasons why the building
has nevertheless become part of the civil estate.
13. The OGC is responsible for ensuring
that buildings are procured in the top quartile and the Association
hopes that this commitment will be met and that the EAC will track
progress on this initiative. This will not only reduce emissions
from public sector buildings but will help transform the wider
property market by creating demand for low carbon buildings. Government
will be much better able to monitor this commitment as the performance
of the building stock is easily known through DECs.
14. Another reason behind poor performance
is that energy costs form a very small part of departmental budgets.
Facilities managers are far down the hierarchy and have little
control over budgets.
15. It is vital that as much information
as possible on the energy performance of public buildings is in
the public domain. DECs displaying clearly the actual energy usage
of buildings will perform this function. The information provided
will be examined every year and this will be a great advantage
as for the first time we will have an objective method of analysing
how wasteful our publicly funded buildings are. We would commend
the Scottish executive's example of using DECs for all public
buildings including those substantially smaller than 1000m2.
16. There are currently 17,000 public
buildings which are required to have a DEC. However the OGC's
role is merely to look at buildings in the central Government
estate, only around 1,500 buildings. ACE strongly believes
that the OGC remit should be widened to cover all public buildings.
17. The use of DECs will also help circumvent
the problems the EAC encountered in the past when trying to compare
different Government Departments. Now that energy performance
is directly related to buildings, comparisons can be made much
more easily and provide a truer picture.
18. This too will avoid situations where
distorted pictures of performance have been reported, such as
last year when Government reported a 4% decrease in carbon emissions
which was due to the privatisation of part of the defence agency;
if the Ministry of Defence was excluded emissions went up by 22%.[7]
19. The relevant statutory instrument has
led to DCLG holding the details of the DEC ratings for all Government
buildings but not being able to share this information with any
other Government department. This has created the ludicrous situation
where, for instance, the OGC is having to gather this same information
again from scratch. ACE strongly recommends that DCLG not only
shares the information of the DEC ratings with the OGC, but with
the rest of the public sector, in order to help spread best practice.
20. ACE believes that 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. The Department of Work & Pensions
has recently entered into a Private Finance Initiative (PFI) to
manage the monitoring of emissions from their offices. They have
sought to publicise the results and have reduced energy consumption
by 10.8% in 2008 due to improved monitoring and targeting.[8]
ACE recommends that other departments follow suit and ensure that
their energy use is made available to the public.
The reasons for the wide variations in departmental
performance
22. ACE believes that the reason behind
wide variations in Departmental performance is due to the relative
importance attached to meeting these targets by the relevant Ministers
and civil servants within each department. The SOGE targets set
by Government are not overly ambitious, and could be easily attained
as long as concerted efforts are made and programmes are put in
place as soon as possible.
23. It is therefore a matter of great concern
that Eland House, the headquarters for DCLG, has been given an
F rating. The Department of Energy and Climate Change, responsible
for implementing DECs, has one of the very worst of the G ratings
yet recorded.
The gap between the level of ambition set for
the UK by Government policies and the level of ambition the Government
sets itself within the SOGE framework
24. The targets for offices are broadly
in line with the targets as set out in the Climate Change Act
2008 of reducing carbon emissions by 30% by 2020 relative
to 1990 levels. However, ACE believes that the Government
should be leading by example and should therefore exceed the UK
targets, in order to 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.
25. Michael Kelly, the Chief Scientist at
DCLG has said that the amount of carbon emissions from homes have
fallen from 154 to 147 million tons of Carbon from 1990-2005 which
is a 4% drop. In order to reach the Government's target of a 26%
reduction in emissions from 1990 levels, domestic emissions
have to come down to 114 million tonnes of carbonthis
would be a 24% drop. This means that in order to reach the target
there will need to be six times the amount of activity as has
been happening over the last 15 years. We have every reason
to believe that the same sixfold level of activity is needed
in the public sector.
Whether attainment of SOGE targets at the level
at which they are currently set would result in sustainable operations
26. According to the latest SDC report energy
efficiency across the Government estate (excluding MOD) has worsened
by 3.3% over the past year
27. ACE believes that the target for departments
to increase their energy efficiency per m2 by 15% by 2010 and
by 30% by 2020, although not very ambitious, is sufficient in
terms of keeping to a trajectory towards an 80% cut in emissions
by 2050, but it must be achieved.
28. Because this target measures energy
use per square meter it can provide a misleading picture. The
SDC has pointed out that a department could be seen to be to becoming
more energy efficient when in reality they have just increased
their floor area. We greatly sympathise with the EACs own proposal
that the energy efficiency target should be replaced with a target
for reducing absolute levels of energy use.
29. Government has committed the Central
Government's office estate to be carbon neutral by 2012. ACE is
concerned that the majority of these carbon emissions will merely
be offset and that little effort will be made to improve the energy
performance of the buildings. Work needs to be done now to set
the UK on a low carbon path of development. This will ensure that
we start an early transition to a low carbon economy, rather than
allow ourselves to be locked in to a high carbon path which will
be virtually impossible to break out of in the years to come.
We strongly urge Government to step up their progress to ensure
that this target is met through improving the energy efficiency
of central Government offices and the use of local low carbon
energy, not through expending taxpayers' money on dubious offsets.
The potential for interdepartmental carbon trading
30. The concept of keeping track of carbon
trading between several different departments could turn into
an extremely complicated and overly bureaucratic system. Much
of Government is already involved with the forthcoming Carbon
Reduction Commitment. ACE advocates that departments choose to
reduce their emissions rather than trying to trade their way out
of it.
The use of credits and offsetting in achieving
targets
31. Given the EAC's concern with the validity
of some current offset arrangements, particularly outside the
UK, the Association would not advocate the use of credits and
offsetting in achieving targets. If offset funds are created,
it would make sense for these to paid into, for instance, a Warm
Front scheme.
32. Long term investment in increasing the
energy performance of buildings in the UK is an investment that
will bring about savings in the future. It will reduce energy
bills in the long term and reduce carbon emissions. The UK should
start focusing policies and resources on using energy more efficiently
in all sectors of the economy and money should rather be spent
on decarbonising our energy systems than paying other countries
to enable us to carry on polluting.
The planned review of the SOGE framework
33. ACE agrees that the present energy efficiency
and carbon reduction targets are just about adequate. However
we cannot, from a climate change point of view, afford for these
targets not to be met. ACE recommends that the Government first
meet these targets before performing endless reviews.
34. Over the last 20 years there have
been at least seven House of Commons Select Committee reports
examining energy use in the public sector. One of the complications
is that the reports in question are seldom seen across Whitehall,
but tend to be "pigeon holed" with the relevant Departmentpresumably
now the Minister for Transformational Government. Given the demise
of the green Ministers, it is unclear who else in Government will
be alerted to this report. Who will be reading this report, and
more importantly who will be implementing its recommendations?
35. Although Government is improving slightly,
the improvements are a far cry from what is needed to ensure that
we reach an 80% reduction in carbon emissions by 2050. The public
sector needs to take radical and urgent steps to ensure that firstly
its own targets are met so that it can then set an example to
other sectors.
April 2009
1 Sustainable Development Commission, "Sustainable
Development in Government 2007", March 2008 Back
2
Ibid. Back
3
Ibid. Back
4
Making Government operations more sustainable: A progress report,
Seventh Report of Session 2007-08, 1 July 2008 Back
5
Energy Efficiency: The Government's Plan for Action, DEFRA, April
2004 Back
6
Ibid., pg 47 Back
7
Sustainable Development Commission, "Sustainable Development
in Government 2007", March 2008 Back
8
http://www.defra.gov.uk/environment/climatechange/uk/business/crc/pdf/crc-casestudy-dwp.pdf Back
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