Written evidence submitted by the Combined
Heat and Power Association |
- Government buildings must decarbonise their energy
supply in order to meet emissions reductions targets.
- Decarbonising heat supplies should be given parity
- Quick Wins should be prioritised.
- The failure to install CHP solutions as a Quick
Win is most likely due to:
- CHP being an unfamiliar technology to estates
- the lack of available technical information in
the Cabinet Office, Defra and BuyingSolutions;
- the lack of systematic training for estates managers
on low carbon energy provision;
- the lack of procurement frameworks making the
process more complicated and expensive.
There are two key areas that will be addressed in
this submission: the delivery of energy to public buildings, and
the utilisation of Combined Heat and Power (CHP) as a Quick Win.
The policy of Quick Wins has not been successfully
embedded within procurement and construction processes. As a specific
example, opportunities for CHP on the Government estate have been
neglected and targets have not been met. This does not appear
to be due to recognition that CHP is a good option for the government
estate, rather that the capability to support delivery on the
ground is limited.
NB. References in this response to the Cabinet
Office reflect the fact that they now have ownership of the Office
of Government Commerce, where many of these responsibilities originally
1. Energy consumption has been identified as
a priority area in which carbon emissions from the Government
estate can be reduced, but there are significant problems with
the focus of efforts and the lack of progress. Changes have been
made by, for example, selling buildings, improving lighting, and
procuring more efficient electrical goods, but these have all
been on the demand side; little has been done to address the greater
issue of where the government's energy comes from. In order to
make emissions reductions on the scale required (and to support
the Government's agenda for decentralised energy) estates managers
will need to develop onsite low carbon heat and electricity provision.
2. The word energy has also been used interchangeably
by the Cabinet Office, Defra and BuyingSolutions with the word
electricity. Heat is another form of energy, and one that is responsible
for more carbon emissions in buildings than electricity. There
is no SOGE target for renewable heat, only electricity, and the
SOGE target for CHP only measures electricity provision, despite
the fact that the main benefit of a CHP plant is an efficient,
low carbon heating supply. Confusing references are made in official
documents to "CHP heat" and "renewable energy",
targets for which do not exist.
This is indicative of a lack of understanding of both CHP and
3. Government has fallen short on its renewable
electricity SOGE targets and the majority of electricity used
is supplied from the grid rather than generated onsite, which
raises questions over whether this process encourages renewable
generation or if it simply denies it to another consumer - the
problem of additionality. Objectives on low carbon energy and
decentralisation would be better served by providing energy onsite
4. A focus on using renewable electricity rather
than energy efficiency to reduce carbon emissions has had the
perverse effect of limiting options for more cost-effective measures.
Much of the Government estate consists of old buildings in urban
areas, which are unsuitable for many renewable technologies, yet
are ideal for forming the basis of a CHP district heating scheme.
This would generate cost and carbon savings in the short term,
while the heating infrastructure installed could be used to delivery
renewable heat with economies of scale in the future.
5. There is very little advice available to public
sector estates/energy managers on how to implement onsite low
carbon generation technologies. The Cabinet Office and BuyingSolutions
websites and documentation offer little in these areas and the
Cabinet Office have suspended their programme of technical "Masterclasses"
that provided practical support to estates managers, leaving individual
departments to procure training separately, at greater cost, if
6. CHP is ideally suited to many buildings in
the public estate. There is often little that can be done to improve
the fabric of the building (lack of cavity walls for insulation,
or listed status preventing external cladding or solar panels)
and their urban location limits the possibilities for technologies
such as wind or hydro power. The NHS Sustainable Development Unit
has identified that in hospitals for example, there is a typical
payback for CHP of just 2.8 years
and Trusts such as St Thomas' and Guy's are saving around £1.5 million
per year on their energy bills. Indeed, the SDU have identified
a negative marginal abatement cost for CHP, meaning that switching
to low carbon heat/electricity through CHP saves you money as
opposed to being more expensive, as is the case with other technologies.
7. CHP has been identified as a "Quick Win"
(now "Government Buying Standards") by both the Office
of Government Commerce (OGC) and the EU sustainable procurement
programme, Green Public Procurement (GPP). In addition to its
obvious meaning, Quick Wins are mandatory minimum standards for
products that should be implemented as part of the EU Energy Services
Directive. The standard for CHP is "Good Quality" CHP
(GQCHP), which was created to fulfil UK obligations for the CHP
Directive and translates to a primary energy saving of at least
10% over business as usual. Despite these policies, there has
been very little progress in the uptake of CHP on the public estate.
8. The government had a SOGE target to procure
15% of its electricity requirements from CHP by March 2010. According
to the SDC in 2009, a figure of only 8.7% was reached, with no
improvement on the previous year.
As mentioned above, the majority of this capacity is procured
from off site, and over 90% is used by just three departments.
In addition, only 6% of the CHP electricity that was used meets
the GQCHP standard. Analysis of UK policies for complying with
the Energy Services Directive commissioned by DEFRA in 2007 stated
that they would not realise any of the potential for CHP.
9. The failure to embed Quick Wins in procurement
has been raised by the SDC, the National Audit Office
and the Environmental Audit Committee. In its response to the
6th report of the Environmental Audit Committee's Inquiry,
Greening Government, the government suggested that its
failure to improve the uptake of Quick Wins would be remedied
through the creation of a Centre for Expertise in Sustainable
Procurement within OGC, but the figures above demonstrate that
this has not been the case. The government has provided no response
to recommendations on CHP put forward by the SDC in their annual
10. The gap between political support for CHP
and delivery on the ground highlights an important issue with
the Government's ability to meet its objectives for the estate
- estates managers are rarely experts on energy. Energy is a complex
field and low carbon energy is new and rapidly changing, so extensive
support must be provided in order for them to make informed choices
when replacing their existing supply. For the Government to embed
sustainability in a systematic fashion, resources must be made
available to simplify the process for estates managers. As an
example, there is currently no basic information on what CHP is
or how to procure it in Cabinet Office documents relating to sustainable
procurement, sustainable construction or sustainable energy.
The technical "Masterclasses" mentioned above could
have filled this gap, but they were not mandatory and the programme
has been cancelled.
11. The lack of energy expertise within estates
management could be compensated for by the creation of procurement
frameworks for the relevant technologies. This would reduce the
risk involved in procurement by having approved suppliers providing
pre-agreed results. They would also serve to eliminate waste by
reducing the time and cost involved in procurement.
12. In the Household Energy Management Strategy
published earlier this year, Government acknowledged the important
role that public buildings play in providing "anchor loads"
for district heating (DH) schemes, and made a commitment to consider
connecting buildings to DH schemes where feasible. By fulfilling
this pledge, the Government would be in a position to decarbonise
its own heat supplies and those of the wider community. The aggregating
of heat demands allows for economies of scale for any heating
technology, as well as enabling the possibility of more efficient
solutions such as CHP.
13. This concept however, has not reached other
departments such as the Cabinet Office. DH schemes are understandably
more complex than individual heating systems, so in order for
estates managers to be able to consider it as an option, guidance
and support must be provided.
- Establish a "one-stop shop" for low
carbon energy solutions on the Cabinet Office website. There should
be links to relevant technical, commercial and procurement information
for each technology. Quick Wins should be clearly highlighted.
- Provide systematic training for estates managers
on low carbon energy provision. The most obvious method for this
is to restart the Cabinet Office's programme of technical "Masterclasses"
and to make their attendance mandatory.
- Develop procurement frameworks for low carbon
energy technologies to simplify the process, reduce costs, reduce
risk and eliminate waste.
- Bring decarbonising heat and cooling into parity
with decarbonising electricity as a priority for the estate in
the replacement to the SOGE framework.
13 October 2010
18 E.g. Energy Efficiency Measures in the Government
Civil Estate, OGC 2009. Back
NHS Carbon Reduction Strategy for England, NHS Sustainable Development
Unit, 2009. Back
Sustainable Development in Government, Sustainable Development
Commission, 2009. Back
Options for Implementing Article 5 of the Energy Saving Directive,
BRE, 2007. Back
Sustainable Procurement in Central Government, NAO, 2005. Back
Government Response to the Sustainable Development Commission,
Cabinet Office, Defra, OGC, 2008. Back
E.g. Guidance to Sustainable Operations on the Government Estate,
OGC, 2008; Considering Energy Efficiency in Procurement, OGC 2009;
Priority Actions for Improving Energy Efficiency across the Government
Estate, 2010. Back
Household Energy Management Strategy, DECC, 2010 Back