Published name
Please rate your level of awareness and knowledge about the Commercial Building Disclosure (CBD) Program.
Please rate your level of awareness and knowledge about the National Australian Built Environment Rating System (NABERS)
What type of building/s are you responding about:
If you are responding about a particular building, does that building currently have a National Australian Built Environment Rating System (NABERS) rating?
Who is most interested in your buildings’ energy use?
Are there barriers to you getting and disclosing your building’s energy rating?
What are the barriers?
If other, please specify
NABERS does not apply to all buildings and the CBD program is presently quite limited in its reach
What might be needed to help you overcome those barriers?
Do you have any suggested improvements to the current program and how it operates?
Yes - it should be expanded to incorporate more building types, and most importantly it should be expanded to include office tenancies (above 250m2 perhaps)
What benefits do you think there are in having a valid NABERS rating?
If other, please specify
Creating competitive tension. Improving transparency
What are your views on expanding the CBD Program to different types of commercial buildings in line with the suggested road map (see discussion paper for a description of the road map)?
Fully supportive - especially with respect to office tenancies
What do you see are the key opportunities and benefits to expanding the coverage of the CBD Program?
Just by knowing where you stand, building owners cant help but look to improve their environmental performance. A great way to drive meaningful improvement at very low cost
What are the perceived draw backs, key challenges, or areas of concern you have for the expansion of the CBD Program to your sector / building type?
In addition to the NABERS Energy rating, select any other information that should be disclosed
If other, please specify
Waste and water are two NABERS Ratings that should also be considered
Select which of the following ownership structures should be included in any expansion of the CBD Program:
Provide Reasons for all to be included
Better environmental performance is not limited by ownership type
If office tenancies are included in the CBD Program should offices still be required to have a Tenancy Lighting Assessment (TLA) as part of the Building Energy Efficiency Certificate (BEEC)?
Provide reasons
The tenancy rating is heavily influenced by the energy consumed by the lighting. Maintaining the TLA will give tenants insight to a major part of their energy consumption.
What are your views on the use of minimum energy performance standards in the road map to set a minimum standard for buildings to reduce their operational emissions and improve their energy efficiency?
Provide reasons
This is an area fraught with danger. MEPS is relatively straightforward with most types of new building (some new buildings will be higher energy users by virtue of needs to happen in them - and obviously MEPS needs to accommodate such situations) but existing buildings are not always amenable to high performance upgrades, so its important that we don't create a situation where assets are inadvertently stranded (or worse - eg demolished and rebuilt with a significant embodied carbon penalty).
For the following two questions select the building types you wish to provide feedback on:
Office Buildings
Office Tenancies
Hotel
Shopping Centres
Data Centres
Public Hospitals
Residential Aged Care
Retirement Living
Warehouses
Cold Stores
Schools
Retail Stores
Higher Education
Supermarkets
Private Hospitals
Medical Centres
Other [e.g. Galleries/sport facilities]
Office Buildings
Office Tenancies
Hotels
Shopping Centres
Data Centres
Public Hospitals
Residential Aged Care
Retirement Living
Warehouses
Cold Stores
Schools
Retail Stores
Higher Education
Supermarkets
Private Hospitals
Medical Centres
Other [e.g. Galleries/sport facilities]
Please provide any other comments you wish to make about the proposed CBD Expansion
By all reasonable measures there can be little doubt that the CBD Scheme has helped drive a significant improvement in the energy efficiency of commercial office buildings. From a Government perspective this has come at minimal cost, and whilst many building owners were initially reticent about their compliance costs, the successive improvements in building energy ratings clearly demonstrates the benefits these owners now seek. There is little reason to doubt that this improvement in performance can be achieved in other building sectors. Public disclosure shines a light on actual performance, and as a consequence people will find ways to improve.
We do note that the discussion paper was very light when it came to mandating tenant energy performance reporting. This is regrettable. Tenants once accounted for 35% of total building energy usage. As 'base' buildings have become better performers we have seen the tenant proportion of energy use increase to around 50%, suggesting there is a huge opportunity for improvement in this area. Tenant ratings can be conducted in tandem with a base building rating, at quite low cost (using the co-assess methodology) so we suggest that initially all tenancies over say 500m2 NLA should be compelled to disclose their NABERS Energy Rating on an annual basis.
From an operational carbon perspective, the implications of waste and water should not be ignored. There are compelling arguments to expand disclosure to these areas and we would certainly support such moves.
