Commercial Building Disclosure (CBD) Expansion Consultation

Yarra City Council’s Sustainability team are supportive of the expansion of the Commercial Building Disclosure (CBD) program. We recognise the importance of addressing energy use and carbon emissions in existing buildings and welcome the initiative. The CBD program is an important aspect of the National Trajectory to Low Energy Buildings which aligns with The City of Yarra’s Climate Emergency Plan, Council Plan and organisational priorities.
We welcome this opportunity to comment and identify a number of opportunities to enhance the proposed expansion of the program that we have highlighted here in this brief response.
The types of buildings identified are suitable and appropriate, however the following recommendations have been made for consideration by the CBD Expansion review process.
1. Include private hospitals in the same timeline as public hospitals. We believe that both public and private hospitals should be aligned to commence energy reporting in 2025 and included within ‘Group 2’ mapped out in the expansion roadmap Many private hospital owners also own Aged Care and retirement living facilities so they would otherwise be reporting on those one year earlier than the hospital assests in their portfolios, that can typically use more energy. Hospitals are significant energy consumers and should be encouraged to undertake energy reporting and take advantage of the benefits of energy management that comes with it.
2. We are supportive of the expansion including different ownership structures. The owner of the property shouldn’t determine what they have to disclose, where they are publicly or privately owned, and all properties of similar types should be disclosing the same information.
3. Mandatory disclosure should not be restricted to commercial buildings and should include residential buildings as well. Inclusion of residential building was originally intended when the mandatory disclosure initiative was first mapped out by the former COAG energy efficiency policy agreement. Leaving residential buildings out of this expansion process is a missed opportunity to assist residents, both owners and tenants, to undertake improved energy efficiency and energy management actions. Existing residential buildings have few incentives or requirements to manage and reduce energy consumption, largely excluded from benefits of reform to the National Construction Code.
This is particularly important in the current economic climate where the cost-of-living pressures include rising energy costs. Prospective tenants, particularly, should have the benefit of understanding comparative energy use of the rental market and be empowered to make informed decisions regarding the potential energy use of rental homes. Mandatory energy disclosure of residential buildings at the point of sale or lease would be a valuable addition to the current proposed CBD Expansion Roadmap.

Energy ratings should be included in all relevant advertising material of a building for sale or for lease (including online advertising), in addition we recommend the CBD team consider options for disclosure of energy rating information on business websites, annual financial and company reporting documentation and at annual general meetings. In addition, non-residential building should display energy ratings on primary building entrances, in a similar manner to the European energy rating system Basic guidance on how and where to display energy ratings should be developed and provided by the CBD team.
Display of energy ratings should be mandatory and updated on an annual basis.

Ownership structure shouldn't determine the reporting requirements and doesn't change the carbon impact of the building. If you own a property, you should be responsible for reporting on and improving the energy rating.

Yes, this brings material improvements to energy use and is ultimately going to save many smaller businesses in older buildings significant money.

Mandatory minimum energy standards (MEPS) for all existing buildings is supported. Given the significant performance gap between new and older buildings, some form of regulation should be considered carefully by the CBD Expansion team. Incentives such as Federal and State solar rebates and free energy efficiency equipment funded by initiatives like the Victorian Energy Efficiency Certificates, can only go so far.

However, given the potential challenges in shifting to a MEPS system for existing buildings, careful introduction of this type of initiative should be undertaken, including;
• Gradual introduction of building MEPS from large scale buildings down to small scale, with a clear timeline mapped out over a number of years.
• Supportive training and education across various section including property management, real estate industry and others.

MEPS for all buildings could assist in the following ways;
• Reduce fuel poverty and cost-of-living pressures for Australian households.
• Reduce operational overheads and increase productivity for Australian businesses.
• Assist in the transition to renewable energy and zero carbon energy networks by reducing energy demand.
• Assist inform the rental and sales market of buildings.
• Drive investment in local jobs and employment opportunities in energy efficiency and energy management.

As mentioned in the CBD Expansion discussion paper, including renewable energy in the energy ratings is supported for all commercial building types (Groups 1 to 4) as well as residential buildings. We recommend that commercial entities owning or leasing building should include both onsite solar generation contribution, disclosed in annual energy generation (MJ or kWh) as well as offsite renewable energy purchasing arrangements such as Green Power, Power Purchase and Offtake Agreements. The NABERS Renewable Energy Indicator would be valuable and those supporting the broader transition to net zero.
Residential buildings could also include mandatory disclosure of total rooftop solar kW capacity and point of sale or lease in a simple format.