An Open Letter to Ed Miliband, Secretary of State for Energy Security and Net Zero

by | Aug 7, 2024 | Blog

James Cutter, Director.

Dear Ed Miliband,

We are writing to express our support for your priorities as the Secretary of State for Energy Security and Net Zero, particularly your commitment to making Britain a clean energy superpower and addressing the climate crisis.

We understand that your priorities are:

  • delivering our mission to boost energy independence and cutting bills through clean power by 2030
  • taking back control of our energy with Great British Energy
  • upgrading Britain’s homes and cutting fuel poverty through our Warm Homes Plan
  • standing up for consumers by reforming our energy system
  • creating good jobs in Britain’s industrial heartlands, including a just transition for the industries based in the North Sea
  • leading on international climate action, based on our domestic achievements

In line with your goals, we have outlined several recommendations to improve the effectiveness of non-domestic Energy Performance Certificates (EPCs) and promote energy efficiency in the commercial property sector, a key component of addressing many of your commitments.

Link Non-Domestic EPCs to Energy Procurement Strategies

By linking non-domestic Energy Performance Certificates to energy procurement strategies, we can enhance the accuracy and utility of energy performance data, ultimately driving more informed decision-making and promoting sustainability. We believe that the following initiatives are essential to achieve this integration:

  1. Utilise 12 Months of Energy Data
    Leveraging a full year’s worth of energy data will provide a more accurate and comprehensive assessment of energy usage, ensuring that energy procurement strategies are based on realistic and complete information.
  2. Review Green Deal Functionality
    It is imperative to re-evaluate the Green Deal within the National Calculation Methodology (NCM) for all EPCs to ensure its effectiveness and applicability, enhancing its role in improving energy efficiency.
  3. Incorporate Renewable Energy
    Allowing the selection of Renewable Energy as a heating fuel, where Renewable Energy Guarantees of Origin (REGO) or on-site microgeneration is provided, will promote the use of sustainable energy sources and reduce reliance on fossil fuels, tying into your drive for cleaner energy.
  4. Evidence-Based Approach
    Ensuring that all strategies and policies are based on robust evidence will maximise their effectiveness and lead to better energy management and reduced environmental impact.

Promote Energy Efficiency Upgrades

By investing in energy-efficient technologies and practices, we can reduce energy consumption, lower carbon emissions, and create healthier environments for businesses and tenants – and contribute to your goals of boosting energy independence and leading on international climate action.

To achieve these benefits, we propose the following measures to incentivise and support energy efficiency improvements:

  1. Increase Funding and Incentives
    Greater funding and incentives are essential to encourage landlords and tenants to invest in energy efficiency improvements, making such investments more financially viable and attractive.
  2. Grant Programs and Low-Interest Loans
    Introducing or expanding grant programs and low-interest loans specifically aimed at upgrading commercial properties with poor EPC ratings (e.g., C, D, E, F, and G rated) will accelerate the improvement of energy efficiency across the sector.
  3. Enhanced Capital Allowances
    Enhanced Capital Allowances for HVAC upgrades linked to EPC performance improvements will provide financial benefits for businesses investing in energy-efficient systems, promoting widespread adoption.

Mandate Minimum EPC Standards for Each Building Type

Legislating minimum EPC rating requirements is essential for ensuring that all leased and owner-operated properties meet a specified energy efficiency standard. This will help drive improvements across the sector and reduce overall energy consumption. To support this goal, we propose the following:

  1. Legislate Minimum EPC Ratings
    Setting minimum EPC rating requirements for all properties will ensure that no property can be leased or sold unless it meets a certain energy efficiency standard, driving improvements across the market.
  2. Clear Timelines and Support Mechanisms
    Establishing clear timelines and providing support mechanisms for landlords will help them bring their properties up to the required standards, ensuring compliance and facilitating smoother transitions.

Integrate EPCs with Climate Goals

Integrating EPC policies with the UK’s broader climate objectives is crucial for achieving net-zero emissions by 2050. By aligning EPC strategies with national climate goals, we can ensure that energy efficiency improvements contribute effectively to reducing carbon emissions. To this end, we recommend the following:

  1. Align with UK Climate Goals
    Ensuring that EPC policies are aligned with the UK’s broader climate objectives will enhance their effectiveness in reducing carbon emissions and supporting the transition to a net-zero economy.
  2. Inform National Strategies
    Using EPC data to inform and shape national strategies for reducing carbon emissions in the commercial property sector will ensure that policies are based on accurate and comprehensive information.

Enhance Accuracy and Transparency

Improving the accuracy and transparency of non-domestic EPC assessments is vital for building trust and ensuring the effectiveness of energy efficiency measures. By enhancing training for assessors and making the calculation methodology transparent, we can improve the reliability of EPC ratings. We propose the following measures:

  1. Improve Assessment Accuracy
    Enhancing the accuracy of  EPC assessments through better training for assessors and more stringent quality control measures will ensure that EPC ratings are reliable and reflect true energy performance.
  2. Ensure Methodology Transparency
    Making the methodology used for non-domestic EPC calculations transparent and easily understood by both landlords and tenants will build trust and encourage proactive improvements in energy efficiency.

Improve Public Awareness and Engagement

Increasing public awareness and engagement regarding EPCs and energy efficiency is essential for driving widespread improvements across the commercial property sector. By educating organisations and tenants about the benefits of energy-efficient properties, we can promote more informed decision-making and greater investment in energy efficiency. We suggest the following initiatives:

  1. Public Awareness Campaigns
    Launching public awareness campaigns to educate organisations and tenants about the importance of EPCs and the benefits of energy-efficient commercial properties will increase engagement and drive improvements.
  2. Provide Clear Guidance
    Offering clear guidance and support for landlords and tenants to understand their EPC ratings and take steps to improve them will facilitate more effective energy management and enhance overall energy efficiency.

We believe that these measures will significantly enhance energy efficiency across the commercial property sector and contribute towards meeting the UK’s climate goals. We would greatly appreciate your support in advocating for these changes.

Thank you for your attention to these important issues.

Yours sincerely,

James Cutter

Director, Lynx Energy and Carbon Assessors

If you’re interested in enhancing the energy efficiency and sustainability of your commercial buildings, contact the Lynx Energy and Carbon Assessors team today to learn how we can assist you.