The Federal Government’s proposed mandatory disclosure of building energy efficiency is worrying building owners. Many want a less complex scheme that reflects the role of tenants in energy usage.

Under the proposed scheme building owners will need to provide a Building Energy Efficiency Certificate (BEEC) and Energy Efficiency Assessment Reports (EEAR) when a building is sold or leased, either in whole or part.

This raises the problem of owners being accountable for the energy efficiency of tenants.

Large building owners who spoke to The Fifth Estate are concerned that the proposed scheme places an inequitable and onerous cost burden on building owners and duplicates existing reporting requirements required of them. These include the National Greenhouse and Energy Reporting System (NGERS) and Energy Efficiency Opportunities (EEO).

Shauna Coffey, sustainability manager for Mirvac, says the scheme is in direct conflict with these two established legislatory programs as, unlike them, it requires building owners to be responsible for the operational control of the space occupied by their tenants and for the reporting of their energy use.

This also contradicts the methods used by the NABERS rating tool, proposed for use in the scheme. By using three different ratings types – base building, tenant and whole building – NABERS associates each rating with the party that influences the outcome of that rating, says Coffey. This is lacking in the proposed scheme, which assumes building owners have control over the energy usage of tenants.

“A building owner has little ability to influence energy usage in a tenancy apart from provision of base building air conditioning, electrical and lighting systems. The tenants’ energy efficiency will depend on the equipment used in the tenancy fitout and they way they use the space,” says Coffey.

“And because historical data is used for NABERS, a new tenant would only see what had happened in the past. This would not be relevant since past performance is no indication of future performance.”

Mirvac wants the scheme to be modified so that building owners are only responsible for base building ratings and disclosure of base building services and fittings that impact on a tenant’s energy efficiency. This would include information on heating and lighting systems and zoning capabilities of the air conditioning system.

“Tenants can then look at what the base building offers and work with their designer and fitout consultant to achieve energy efficiency,” says Coffey.

Property Council of Australia CEO Peter Verwer, says the scheme as it is currently proposed is poorly designed and will not ultimately result in more energy efficient buildings or lower usage of carbon based energy.

“We have always said that some form of disclosure is appropriate for large buildings and tenancies. But the current scheme is too complex and its planet saving potential is severely limited,” says Verwer.

“The current scheme is too complex and its planet saving potential is severely limited,” – Peter Verwer.

Problem areas of the scheme cited by the PCA include its application to strata property, the lack of individual floor power metering in older buildings and the assumption that building owners should pay for ratings.

Proposals that the advertising of new commercial space should include NABERS energy rating of previous tenants are impractical, uninformative and potentially misleading. The energy use of tenants varies widely.

“We may as well just give them [interested parties] the electricity bill to look at,” says Verwer.

Much of the problem stemmed from a lack of understanding of the property sector and an unrealistic idea of the costs involved in the greening of buildings.

“We’ve seen from the research by people who really understand the industry, that the payback [for upgrading buildings] is not the four to five years quoted by theoretical models used in devising this scheme. It is 20 years,” says Verwer.

The answer, he says, is to continue to improve the energy efficiency of existing building stock by offering tax incentives such as accelerated depreciation tied to a building’s energy performance.

This would provide a very clear and effective method of getting the 330 million square metres of commercial stock in Australia upgraded.

“The ultimate objective is lost in a lot of the debate – that is, to achieve more energy efficient buildings with a smaller carbon footprint,” says Verwer.

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