Anonymous

Published name

Anonymous

Please rate your level of awareness and knowledge about the Commercial Building Disclosure (CBD) Program.

high

Please rate your level of awareness and knowledge about the National Australian Built Environment Rating System (NABERS)

high

What type of building/s are you responding about:

office building
office tenancy
shopping centre
warehouse
cold store

If you are responding about a particular building, does that building currently have a National Australian Built Environment Rating System (NABERS) rating?

Yes

Who is most interested in your buildings’ energy use?

ownership [owner/board/shareholder/partners]

Are there barriers to you getting and disclosing your building’s energy rating?

No

Do you have any suggested improvements to the current program and how it operates?

Be stricter and quicker to act on non-compliance. Review the usefulness of the TLA component of the BEEC, as it is not as well known as the NABERS rating and less useful for tenants.

What benefits do you think there are in having a valid NABERS rating?

better able to know and control building energy use (cost savings)
able to know and reduce the buildings carbon emissions
making buildings more attractive to potential buyers/renters/investors/stakeholders/the public

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)?

It should be expanded sooner rather than later, but carefully considering the nuances of each sector. Some sectors might be more appropriate to have the renewal requirement longer than 1 year.

What do you see are the key opportunities and benefits to expanding the coverage of the CBD Program?

Educates tenants and owners about energy efficiency.

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?

Costs of increased regulation [Fees and charges]
Poor rating of building

Please outline any issues specific to a building type that would need to be considered if the program was expanded to that building?

Warehouse and Cold stores - the rating is a reflection of tenant activity, rather than the building efficiency. A lot of buildings will also not be ratable due to manufacturing facilities.
Shopping centres - there are a lot of different type of shopping centre comparisons and the tool is very sensitive to specific variables. This can create very varied rating results based on the building configuration, what kind of tenants the building has.
Apartments - Cost would be prohibitive as the strata committee would likely not agree to pay. It might make sense to have 2 or 3 year validity period to reduce number of times to be completed.
Office tenancies - Annual review is unnecessary and costly since the tenancy would not have changes made unless there was a change in fitout. It would make sense to have a longer validity period for this rating tool.

In addition to the NABERS Energy rating, select any other information that should be disclosed

Other

If other, please specify

Electricity, gas, diesel usage explicitly stated.

Select which of the following ownership structures should be included in any expansion of the CBD Program:

All

Provide Reasons for all to be included

All buildings should be included if possible rather than it being determined by the type of structure.

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)? 

Other

Please specify

Office tenancy NABERS rating measures also the tenant activity, so does not aid a new tenant in determining the efficiency of a space. TLA however does have weaknesses in the way it is assessed so is an approximation of the lighting efficiency of a spaces.

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?

I can see a need to set minimum energy performance standards to ensure that buildings that do not adequately respond through disclosure make improvements

Further comments

It should be a high ceiling where low performing buildings would actually benefit cost wise by upgrading the efficiency of the building and the MEPS is a way to educate laggards.

For the following two questions select the building types you wish to provide feedback on:

Office Buildings
Office Tenancies
Shopping Centres
Warehouses
Cold Stores
Retail Stores
Other [e.g. Galleries/sport facilities]

Office Buildings

Sale or lease of building space of 500 m2 or more meters

Office Tenancies

Other

Please specify

Every 5 years, similar to TLA

Shopping Centres

Sale or lease

Warehouses

Sale or lease

Cold Stores

Sale or lease

Retail Stores

Every 24 months

Other [e.g. Galleries/sport facilities]

Every 24 months

Office Buildings

Disclosure on Government Register
Disclosure on real estate advertisement
Disclosure on website

Office Tenancies

Disclosure on Government Register

Shopping Centres

Disclosure at premises
Disclosure on website
Disclosure on real estate advertisement

Warehouses

Disclosure on real estate advertisement
Disclosure on Government Register
Disclosure on website

Cold Stores

Disclosure on Government Register
Disclosure on website
Disclosure on real estate advertisement

Retail Stores

Disclosure at premises

Other [e.g. Galleries/sport facilities]

Disclosure at premises