The sword of Damocles still hangs over DECs

Over two years ago the Government announced that Display Energy Certificates could be abolished. This policy has still not yet been confirmed and is now detrimental to energy saving in the UK.

No less than 28 months ago, the former Communities Secretary Sir Eric Pickles announced that he intended to abolish all Display Energy Certificates (DECs) for public sector buildings England.

These are the A to G ratings which for the past nine years you should have expected to find exhibited “in a prominent position” in each of the 58,000 buildings occupied by the public sector, that you might be visiting. That means central and local government offices, libraries, sports centres, schools and colleges, hospitals and surgeries, museums, and so on.

Each is supposed to be renewed annually, and to contain details of how well the building in question is doing compared with the past three years.

Subsequently, no formal announcement has yet been made as to how Sir Eric’s threat will be implemented. But its Sword of Damocles still remains. Those consulting the website, consultations/improving-the-display-energycertificates- regime-for-public-buildings, will see that even now, officially “we are analysing your feedback.”

It is known that the many indignant responses criticising this proposal were filed during February 2015, when a (very short) public consultation on this proposal was held.

This included submissions from the Chartered Institution of Building Service Engineers, the Property and Energy Professionals Association, the Association for the Conservation of Energy, the UK Green Building Council and sundry others. None of these have yet been formally published by the Communities Department; doubtless hard-working civil servants are still “analysing” the feedback.

So, while no formal announcements has been made, the unfortunate consequence is that many Trading Standards Offices – officially charged with ensuring compliance across the public sector – have simply assumed that the February 2015 consultation’s proposals are now effectively government policy.

And hence have reduced efforts to monitor whether any public authorities are continuing to modernise their DECs. Certainly some government departments have removed their DEC from their foyer.

There is one exception to this strange omerta. In a letter written to a constituent back in May 2016 a Communities Junior Minister, James Wharton, did write to a constituent: “I am happy to confirm that we have no current plans for changes to display energy certificate requirements”.

Strangely, neither Wharton nor any of his (several) successors has ever reiterated this policy statement publicly. Critically, no Minister has yet bothered to inform Trading Standards of that apparent U-turn decision.

That is a real shame. After all, the objective has long been to raise public awareness of energy consumption in public buildings, make the sector more accountable for their energy consumption to tax-payers, and act as a driver and tool to reduce energy consumption in buildings and convince building owners to invest. The rating on a DEC can be improved by both energy efficiency works - and by getting building users to cut back on unnecessary energy use (Energy Performance Certificates don’t register the latter).

According to a study actually cited in Pickles’ hostile consultation, just a year into their introduction, between 2008 and 2009 public buildings with DECs had reduced their energy consumption by 2 per cent more than their private sector counterparts.

The pointed wording of the consultation states that as DECs are not needed to comply with the EU Energy Performance of Buildings Directive (EPBD), they therefore constitute ‘gold-plating’ - and can be abolished altogether. All building energy certificate requirements in England and Wales might in principle be satisfied by an Energy Performance Certificate (EPC, based on theoretical rather than actual energy consumption), renewed only every ten years.

The consultation’s cost-benefit analysis was completely one-sided. It highlighted only the cost of doing DECs, but not their benefits in terms of triggering energy saving activity.

Although it may be difficult to say categorically how much the presence of a DEC per se influences reductions in energy use, there was a definitive study of all DECs lodged up to June 2012, by Hong and Steadman of University College London. This shows that where DEC compliance was taken seriously, renewed each year, the buildings in question collectively achieve substantial energy savings that completely outweigh the relatively trivial cost of each energy survey.

When DECs were first introduced, the original UK Statutory Instrument Explanatory Memorandum justified their annual renewal as cost effective (as against any ten-year renewal) by estimating the increased energy savings DECs would generate. Table 14 of that document estimates annual DECs to be more cost beneficial by £457m net present value. Its Annex C set out all the reasons why DECs are preferred to EPCs and why annual renewal is the most cost effective option.

For some curious reason, Pickles’ “public consultation” made no reference to that initial impact assessment nor to the subsequent empirical study from UCL. Nor to the losses to the public purse of the failure ever to have displayed any DEC at all in around half of the qualifying 58,000 public buildings. Nobody has ever been fined for that breach of the law.

When becoming Prime Minister in 2010, David Cameron promised his government would actually extend the requirements for DECs to buildings in the commercial sector. He left office without fulfilling that commitment. Let us hope that whoever is Prime Minister after June 8 intervenes to accelerate the use of DECs. And certainly not to confirm Pickles’ foolish proposal, by scrapping them altogether.

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