[Guest Blog] Are post-Brexit building standards lacking energy?

In April the Official Journal of the European Union published the full details of the fourth iteration of the bloc’s Energy Performance of Buildings Directive (EPBD). In this blog, Andrew Warren, chair of the British Energy Efficiency Federation explores the significance of this Directive, and the divergence emerging with UK policy.

Over the past twenty years, this single Directive has had more impact upon minimising energy wastage in the 24bn square metres of European Union buildings than any other initiative. Its new objective is by 2030 to double the number of deep energy renovations currently undertaken across Europe, to cut current final energy consumption by 14% and heating and cooling by 18%.

Not for the UK

The first three versions of the EPBD remain operational under UK law. In truth, practically all of the measures currently helping to improve the energy efficiency of the buildings we live and work in have come as a result of this Directive, because we had been members of the European Union.

But, as yet these latest set of improvements won’t apply to anybody living or working in the UK, although they will in other non-EU states like Norway and Switzerland.

Also in April, the annual international gathering of building control professionals, ASHRAE, met for three days in Madrid.  I was invited to be a keynote speaker. I swiftly gathered that this was because, at the start of this century, I had been appointed by the Industry Department of the European Commission to chair an intergovernmental and inter professional task group on Sustainable Construction & Energy Efficiency. Which came out with a whole set of (then) radical ideas to improve the energy performance of buildings. 

Practically all of these then became the basis for the original version of the European Energy Performance of Buildings Directive. The new version was positively the hottest topic of the event, because no other OECD member has yet developed such a detailed legal blueprint for improving energy usage in buildings.

Let me just run though the initiatives which have already sprung directly from this Directive, and which still officially apply in the UK.

Introducing energy performance labels

The entire concept of having a comparative label measuring the running costs of a building was mandated. The original directive ensured creation of an “energy performance certificate” (EPC). It had to be made available to prospective occupiers not just when a building is sold, but whenever a building’s occupants change following the granting of a new lease.

It must include advice on the most cost-optimal improvement options available. All advertising must include information on the rating, between A for (admirable) to G (for ghastly). Note the use of that phrase “cost optimal”, rather than just “cost effective”. That signifies a desire to reflect the full lifetime benefits of including any specific measure, rather than restricting improvement recommendations to the limiting concept of commercial “payback times”.

To ensure quality assurance of certificates, an independent control system was created to verify the validity of both energy performance certificates and heating/cooling systems.

Additionally, any building occupied by a public authority, to which members of the public have access, must display an energy certificate “in a prominent place”, and brought up to date each year. Initially such ratings were to be seen in every public building in the UK. This had been an excellent way for voters to monitor just which public authorities are being frugal, and which profligate. It does seem that, ever since Brexit, an absence of overt oversight by central government has led to much anecdotal evidence of an increasing failure to comply, including even in several central Government departments like the energy department itself. An authoritative survey of compliance is urgently required.

The directive also mandated such key issues as regular inspections of air conditioning systems, of intelligent (or smart) metering systems, and facilities for electric vehicle charging. All these areas are being strengthened in the latest version.

Net zero buildings

Building codes for new buildings needed to be upped every 5 years, a timetable the UK adhered to up until 2015 – when plans to deliver nearly net zero buildings (required under article 9) were unilaterally dropped on a whim of then Chancellor George Osborne. The new EPBD mandates all publicly funded buildings to be absolutely net zero by 2028, and those privately built by 2030. All new buildings are to be “solar ready.”

Britain still has no official benchmark for net zero homes. “If anybody is saying that their building is net zero at the moment, they may be doing that with good intentions. Or it may be something more mythical. The problem is, without a clear standard that allows people to make a credible claim, anything can be challenged,” says Smith Mordak, the chief executive of the UK Green Building Council. The industry body has been working with over 500 organisations to come up with the UK’s first Net Zero Carbon Buildings Standard. A draft version is due this summer.

Mordak agrees it is staggering that no net zero standard exists. “We have known that climate change is real for some time now,” she says wryly. “The barrier is there not being a clear signal from government that, yes, this is important. It is very, very difficult for the industry to adopt a credible pathway to net zero without those clear signals.”

The new version of the EPBD concentrates primarily upon existing buildings, largely because 85% of those we shall be using in 2050 are already constructed. Each government is now charged with updating a strategic Building Renovations plan for delivering energy efficiency, including any financial incentives and penalties- again, a long established EPBD requirement.  The last vaguely equivalent UK plan was issued back in 2014.

These strategic renovation plans will be created using an identical template, with national targets and key mandatory indicators. Importantly all of these comparative details will be public documents, giving voters the information to reward or to chide

Critically, and at last, building passports will be created- as originally recommended by my Sustainable Construction task group over 20 years ago. This will provide practical information about energy saving artefacts in each individual building, of direct use both to building professionals, and to administrators. This information will be recoded in a national database with easy access to relevant parties, and new provisions to ensure interoperability.  

Commercial buildings are traded goods

 But within these plans, each government is charged with paying particular attention to the non-residential building stock. After all, unlike residences, commercial buildings are frequently occupied by non-national corporations, and so are effectively “traded goods” across frontiers.  Governments are required to identify the worst performing buildings, and to move 16% of these by 2030, and 26% of these by 2033, into the higher performance categories. In EPC terms, it means upping E, F and G ratings to B or even A ratings. A new Smart Readiness Indicator will be required for buildings over 1,000 square metres.

A similar, if less detailed, improvement exercise is required for the housing stock, where currently 43% are classed as being currently in the worst performing part of the stock (below EPC grade C). At least 55% of any identified savings should come from improving this sector.

There are to be no more subsidies of any kind for stand-alone boilers powered by fossil fuels, and “policies and measures” to phase out all fossil fuel boilers by 2040

All of these new requirements have long been common currency amongst building professionals in the UK.  None are yet mandatory. It would make sense for the new UK government to implement at pace all the initiatives which our European competitors are now adopting with enthusiasm.

Andrew Warren is chair of the British Energy Efficiency Federation


Views expressed in this piece and all guest blogs are the views of the author and not necessarily of IEEP UK

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