String 1 - The Performance Gap…EPCs…non-domestic DECs…what should the Edge do next.

So Sunand started this 26/11/2012
Dear Edge
If you have not already seen it, take a look at the new report from Jones Lang Lasalle/ Better Buildings Partnership

Max replied 26/11
Thanks for this. I do not think there is anything surprising here. The important issue is that calculations to try to predict energy use of buildings are an essential design tool. Surely anyone who has any understanding of the problems of predicting a value must realise that the error must also be predicted. Then the measure of a building is obviously going to be different from the prediction. That is what the study shows. The differences are important and will help us to design and understand buildings better.

Peter Clegg replies 27/11

I agree Max and we do need to figure out how to warn clients about the differences that are likely to occur between predictive tools and actual performance. What seems really surprising…and rather depressing… is the complete lack of correlation between the relative EPC ratings and the relative performance of each building. If I am reading the data correctly the average of 82 buildings rated C and D is much worse than the average of 30 buildings rated E to G.
It does support the premise, that we all knew, that it’s the way buildings are used that is more significant than the way they are designed but I hadn’t anticipated what almost seems to be a reverse correlation!
Doug King added 27/11

Could this be an example of the Jeavons Paradox in action? Perhaps if occupants believe that their building has a good energy efficiency rating then they don’t bother so much with their own energy conserving behaviours.

Also the metric of kWh or kgCO2 per m2 of building area is almost useless as a comparison between buildings as it fails to take into account intensity of use. A better measure would be kWh per workspace or even better kWh per productive hour.

Bill B is exasperated 27/11

Oh, dear, this is such old news. We have been going on about it for two decades! But at least DECs are beginning to break through the shell of denial.

In terms of the nominally better buildings sometimes performing worse, we find three main reasons for this:

1. Unmanageable complication. The more complicated they are, the more there is to go wrong; and many allegedly low energy and carbon features can make things worse not better. We can’t even get many of the simple things right but today we have mandated complication: legislative, contractual, technical. While modelling proposes ever more complicated operating strategies which are not realisable in practice.

2. Stress factors. Some of the more highly specified buildings are also more intensively used. This is not yet fully captured in the benchmarking. Why? Because there has been no direct government investment in in-use energy benchmarking at all for the past ten years since the Energy Efficiency Best Practice programme ended. It is exasperating.

3. Tick-box processes: so you get the EPC result based in success in the virtual world, not for paying the necessary attention to detail to get things to work in the real one.

And it is not just predicting the error bars but positively striving to bring the error bars down and set up virtuous circles of improvement. This means much more pointed discussions between designers and clients, rather than washing one’s hands of “unregulated loads” (a term I hate) and blaming everything else on poor management.

Chris Twinn 27/11

I am tempted to say that the fact that these lower grade building owners have got in someone reasonably competent to look after their buildings means they do not represent the average for these bands!
As far as I can see this document is responding to the need for today’s politicians to have clear ‘evidence’ based logic for policymaking. It may be data cherry picking but the point it makes is absolutely correct!
Bit galling that politicians are more likely to listen to this form of presentation then a more balanced impartial professional approach.
Paddy 27/11

Not only is the lack of correlation between EPCs and DECs perverse, but EPCs can drive inappropriate solutions.
EPCs include mandatory fields with default values that the energy modeller must use. For example, an EPC model of an airport pier describes an intensely populated building with large annual cooling demand and little need for heating. But replacing the defaults with factual data (e.g. populations derived from flight schedules) reveals a building with 22hours of sparse (or nil) occupancy – with little cooling but much heating energy use (and enormous opportunity to turn things off).
While the JLL report centres on existing stock, Edge’s paper in July 2010 (prepared at TSB’s behest) raised many of the points in this email string. It proposed replacing EPCs for new build with DECs (theoretical and modelled at design but duly populated with metered data in use) - similar to the Australian NABERS system. Thus designer, builder, owner and occupier start on the ‘same page’, with equal interest in explaining deviations from predictions. Whereas, (as the JLL paper shows), it’s barely possible to reconcile EPCs and DECs.
Robin asks for a short statement 29/11
Any volunteers to draw up a short Edge statement about the missed opportunities here, symbolically emerging in the middle of COP 18 and with Chris Beauman’s call for UK and Europe to take the lead.
Richard S drafts a short statement for comment 29/11

The Government’s decision not to insist on the publication of DECs creates a serious risk that its targets to reduce CO2 emissions will not be met. The built environment contributes 40% to these emissions, and so to damaging climate change. Reductions are vital but designing green buildings is only half the story. Experience and sound research both show that even the greenest buildings can produce high CO2 emissions if their occupiers manage them poorly, use equipment such as PCs and big screens inefficiently, or don’t occupy space intensively enough. EPCs only predict how green a building could be if well used. DECs are essential to enable businesses and public bodies to get on top of real world energy efficiency and suppression of greenhouse gases. With current technology they are not a burden to produce and will lead to both cost savings for industry, and massive benefits for our communities.
The Edge calls on the Government urgently to reconsider this decision and reinstate the introduction of DECs in the interests of business competitiveness and publc confidence in its promise to be “the greenest government ever”.
(Richard Lorch expressed his concern about Edge campaigning - to be pursued in the New Year)

Bill responds 29/11
Utterly exasperating. A complete void in the middle of what could have been a joined-up buildings and energy policy but is now a complete pile of junk. And totally demoralising in relation to my decade long fight to first put DECs on the scene and then get them sensibly adopted.

As it happens, I will be at the CIBSE benchmarks group meeting tomorrow which will be discussing this amongst other things.

Meanwhile, not sure if you have seen this recent ACEEE report which puts the UK at the top of the international league table. How wrong can you be?

Bill proposes (subject to Richard Lorch’s caveat) 29/11
There are strong global and national imperatives to save energy and greenhouse gas emissions from the operation of commercial buildings. If actual energy performance in use - the policy objective – was pinpointed for each building, its management would be motivated to avoid waste and to insist on better energy performance from its landlords and suppliers.
Evidence and sound research have shown that Energy Performance Certificates (EPCs) based on theoretical calculations have little relationship to energy performance in real life. Display Energy Certificates (DECs ) capture the information required and are mandatory in some public buildings. A DEC costs much less than an EPC, a cost that will fall as the process is streamlined, for example by integration with other developments like smart metering.
Leading commercial property owners and occupiers and the Confederation of British Industry support the concept of DECs: all they need is a little more work on benchmarking to suit the extended range of building types. Why, then, has the Government refused for the second time to extend DECs to commercial buildings?
The Edge calls on the Government to reconsider this decision. DECs are not a piece of red tape, but a window on performance and a stimulant to improvement that can provide cost savings for industry and government, benefits for our communities, and greater certainty in achieving policy objectives. To omit them leaves a gaping hole in the middle of our energy and carbon policy.
Richard responds 29/11
It doesn’t really read like a media release to me. It’s obviously very sound as a statement of the technical position but if the objective is to grab editorial attention it needs succinctly and sharply to: 1. state up front that what the problem is - in this case HMG dropping its commitment to DECs again; 2. why that’s a problem; 3. what works; and 4. what we want done about it. I’m not quite sure which media are the audience but this wouldn’t, for example, get airtime with mainstream national media. It might get noticed by some of the technical media but even then it would be better with a more attention grabbing opening.
Bill circulates his letter to DECC in response to the Call for Evidence for its Energy Efficiency Deployment Office of 4 April 2012
J Sartin Esq
DECC, 2nd floor Area 3
3 Whitehall Place
London SW1A 2AW by email to

Dear Mr Sartin
I am writing about improving the performance of non-domestic buildings, which the Call for
Evidence identifies as a key sector. This is the principal area of activity of the Usable Buildings
Trust charity, UBT. According to the Carbon Plan of December 2011, operation of these
buildings is responsible for 12% of UK greenhouse gas emissions. The Call also identifies the
important contribution that can be made by reducing the use of electricity; and here DUKES
2011 shows that non-domestic buildings account for a full 25% of UK electricity consumption.
Existing non-domestic buildings offer huge cost-effective potential for energy savings, see the
appendix on page 3 and references such as the Carbon Trust’s Building the Future, Today
(December 2009). Energy use in operation has not been a high priority in the sector, owing to
its low cost in relation to other outgoings. Action has also been inhibited by principal-agent
problems, including outsourced services and the landlord-tenant split. If management was to
become properly focused on actual energy use, all players could work together and transform
the performance of the sector rapidly. This needs to happen before advanced or innovative
technologies are applied. A robust system for analysing, benchmarking and reporting
performance will rapidly identify waste and lead to a prioritisation of energy efficiency.
The ultimate performance of non-domestic buildings in use depends on complex interactions of
human and technical systems, many of which fall outside the reach of their originators: the
construction industry. However, the step-change envisaged by government could be made to
happen, if management were to focus routinely on achieving results.
Fortunately, making actual performance properly visible does capture the outcomes of all these
influences, and can also feed through into property valuations, as is happening in Australia. It
will then inform and motivate all the players, so allowing (as stated in the Call) greater
investment than individual decisions would deliver. Sadly, at present industry and policy
measures do not join up well, and most fail to address actual energy use directly, and so bypass
the only thing that ultimately matters in achieving our targets. EEDO’s objective of
bringing coherence to the government’s offer creates the opportunity to rectify this situation.
For many years, UBT has drawn attention to the gap between design and actual energy use of
many new buildings. The gap is now being confirmed by others, e.g. Partnerships for Schools,
the Carbon Trust’s Low-Carbon Buildings Programme, TSB’s Building Performance Evaluation
Programme and the Carbon Buzz project. It is not unusual for a new office or school to use
three times the anticipated amount of electricity.
UBT sees unnecessary complication and expense, both in buildings and in the associated
policy measures. People are forced to jump through hoops and adopt complex and expensive
solutions before they have got the fundamentals of energy efficiency right, e.g. with welldesigned
fabric, efficient equipment and usable and manageable controls. One unintended
consequence is that many buildings that exploit renewable energy systems actually waste more
energy than their simpler, more conventional counterparts and cost too much to look after.
Designers and builders must learn to put efficiency before renewables, and occupiers need to
understand that renewable energy is precious, not free. A better focus on actual performance
will allow us to achieve our targets more robustly, simply and cost-effectively.

In existing buildings, a focus on actual performance in use through monitoring and fine-tuning
will also help managers to become better-informed and more demanding clients for equipment
purchases (e.g. of office and catering equipment), for outsourced services (e.g. property,
facilities and energy management), and for construction, alteration and maintenance work.
This will motivate faster, more cost-effective and better-targeted improvements across the
board. Many owners, occupiers, managers and service providers also have portfolios of
buildings, providing opportunities for adoption at scale once they have learnt what to do.
Extraordinarily, and in spite of the now urgent policy drivers, the understanding and reporting
of actual energy performance of non-domestic buildings in use is poor and inconsistent. From
1988-2002, the government’s Energy Efficiency Best Practice programme was founded upon
benchmarking, with its series of Energy Consumption Guides and case studies. Unfortunately,
government then abandoned this vital area, while better benchmarking was not at the heart of
the Carbon Trust’s activities. One consequence is that many measures intended to improve
energy performance are based on what looks good in theory, not sound evidence of what really
works well in practice. Policy measures could also be better connected: they also tend to skirt
around actual in-use energy performance, rather than seeing it as their prime objective.
EEDO can help policy measures and industry drivers (such as reducing cost and enhancing
reputation) to converge, and focus everyone on improving actual energy performance in use.
Display Energy Certificates could play a big part in making performance visible, but this needs
proper investment in a coherent benchmarking system. In the past decade, benchmarking has
received no government funding at all, so it is hardly surprising that while welcoming DECs in
principle, the commercial sector is unhappy with the details. A soundly-based measurement,
reporting, benchmarking and potentially diagnostic system would get to the roots of energy
consumption in terms of buildings, their use, their management and their engineering systems;
and be transparent across all sectors, and between design and operation. It would also be able
to operate at a range of levels, from simple headline indicators to technical details.
In the Carbon Plan, the Government envisages a step-change in the energy performance of
buildings. To make this happen, all the players involved need to become focused on improving
actual performance in use; and supported in this effort by clear metrics and benchmarks,
persuasive communication together with effective guidance on what works in practice, what
doesn’t, what needs to be improved and how to go about it.
In its March 2011 report on DECs and the CRC, the UK Green Building Council recommended
an independent, authoritative and properly-funded technical body to review data and
benchmarks, provide advice to government, and maintain a sound Technical Platform for
communicating energy and carbon performance.
UBT has recently been exploring how such an independent Technical Platform might work,
providing evidence, insight and connection to support the step change and making better
connections between practice, research, industry and policy. Our consultations with
stakeholders in the non-domestic sector have revealed a strong desire for consistency across a
range of industry and policy measures, for urgent work on benchmarking, and for stability and
depth in developing a suitable evidence base and communicating the conclusions effectively.
We would very much like to discuss our findings with EEDO, if you were interested. The
Appendices on the next page provide supporting information and list the attachments provided.
Yours sincerely
Bill Bordass, research and policy adviser and co-founder, the Usable Buildings Trust

UBT is a UK educational charity, dedicated to improving the performance of buildings in use.
We try to understand how buildings actually work in practice, and create a feedback loop from
in-use performance to improved delivery by the organisations that can make a difference. We
were set up ten years ago, because buildings policy and research was becoming very focused
on construction, but doing very little on performance in operation in the hands of their users.
Our background is in non-domestic building performance, though we are now increasingly
involved in housing. We investigate outcomes not just for energy and the environment, but
also in terms of technical performance and occupant satisfaction in new, existing and historic
buildings. We are also interested in management, not just in use but of procurement, for
example in developing the Soft Landings process, which is now being adopted by government.
Much energy used in non-domestic buildings is wasted; for example over a year many offices
and new schools will use as much electricity when empty as when they are occupied. Often
this is because systems and equipment default to ON for a whole number of reasons, from
specification, through construction and installation, to use, control and management. In many
buildings, one can save 15-20% at a low capital cost, and another 15-20% cost-effectively,
often with little or no alteration to the fabric and main services, and before adding renewable
energy supplies (which will of course go further in an efficient building). DECC’s own offices at
3 Whitehall Place are an example: since the department was set up in 2008, its Display Energy
Certificates reveal a 40% reduction in CO2 emissions, despite increased occupancy levels.
Although rarer than they should be, the performance improvements at 3 Whitehall Place are
not an isolated example. For instance:
• In 2008, the new owner of 5 St Philip’s Place, Birmingham was shocked to find that this airconditioned
building, which had a very good BREEAM rating when refurbished in 2003,
had a Display Energy Certificate (DEC) Grade of G 231 (or 2.31 times median level of
emissions per square metre per year). Working with the occupier (DCLG), the Grade for
2011 was reduced to D 97 (97% of the median). There are further savings in the pipeline,
with the aid of an automated metering and targeting system. Progress and plans for this
building were a case study in the OGC’s State of the Estate Report 2009 (March 2010).
• The developers and property portfolio managers British Land have reviewed sixteen similar
offices in its managed portfolio. Overall, 14% of the energy use was in their common parts
(reception areas, WCs, lifts and so on), 36% in shared services (typically heating, ventilation
and air-conditioning supplied to tenants), and 50% used directly by tenants (in particular
for ICT services and lighting). In 2008-2011, British Land achieved a 14% saving in
landlord’s energy. In 2010-11 it installed an automated metering and targeting system,
discussed the information with their mangers and tenants, and has sought to avoid waste,
e.g. from unnecessary running. The results have been dramatic, with a further 11% saving
in the six months to October 2011, and more now being realised.
Also attached are:
• A compilation of slides recently used by UBT to present some of the issues touched upon.
• A note on the power of Display Energy Certificates in the private sector.
• Two recent papers from the Institute for Market Transformation revealing the economic
benefits of energy disclosure, over and above the direct benefits of the energy savings.
Richard responds 30/1
Bill sent me Richard Lorch’s advice in confidence. I don’t know if you saw it but the gist was similar to a previous discussion: is lobbying of HMG through the media what the Edge is for? If that’s the general opinion I suggest that a measured article on the pros and cons would be better, if you can place it somewhere where it might be influential. A paper to DECC would probably be a waste of time. A closed doors Chatham House Edge debate with the relevant DECC Director could be interesting but, of course, this decision will have been made at the behest of the Treasury or Cabinet Office, probably with BIS’s deregulation unit in the vanguard. It may not be DECC’s preferred policy at all.

Peter Clegg offers 30/11
I know Don Foster quite well as he is MP for Bath
Happy to send him a personal email with Bills note attached if that would help

Max responds to Bill’s earlier exasperation 30/11
The statistics are useful, but the interpretation is completely naive with no ideas as to what can be done about it. The global use of world resources is being stretched by the demands of the population who want economic growth. Energy drives the economic growth.
The banked resource of carbon fuel is by far the easiest to lay our theiving hands on.
Sustainable energy comes as work/electricity and we should be developing means to collect it from the comparitively weak and expensive sources. Thers is enough provided we reduce our per capita demand by a afctor of say 10. (Ref David MacKay 2008). Nuclear energy offers a way out but it encourages the increased demand for other world resources. We should be working with the envelope of entropy increase defined by solar energy reaching the world at 5000K and leaving at about 300K.
Sorry to bang on about the same theme, but I hope it is getting clearer.

Robin wraps it up 2/12
I think I need to apologise for setting so many hares running and then upsetting some of you by letting my latent political zeal get the better of me. Richard L wants a chat so I will fix that up although time is even worse than usual - appraisals all last week, major bid this week and then off to Brazil to try and help with their popular housing programme next week.

So we should park the idea of a letter for now and think how best the Edge can contribute.

RN 21/12/12

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