A consultation on improving the energy efficiency of non-domestic buildings was published in August. It takes forward the proposals of last December’s Sullivan Report, which set out how Scotland could lower the carbon emissions from its building stock.
There are strong arguments in favour of measuring the energy involved in a building’s construction and not just its energy use, the Scottish Government says.
A holistic approach would ensure better decisions on whether to refurbish a building or construct a new one, the consultation says. As well as the energy performance of individual components, the lifecycle of building materials and the interaction of moisture, heat and light in buildings should be considered, it adds.
The Scottish Government is researching a new method for assessing buildings that is sophisticated enough to be the basis for a statutory target.
However, at the moment, including embodied energy in building products could fall foul of the EU construction products Directive. Standards to measure the embodied impacts of construction materials are already being developed by European standards committees.
The proposals go further than those for England, where embodied energy is not measured for ‘zero-carbon’ homes.
The consultation also proposes extending the scope of the EU directive on the energy performance of buildings (EPBD) through the Scottish Climate Change Bill. This could require the owners of non-domestic buildings to obtain an "assessment of the carbon and energy performance" (ACEP) of their building, even if they are not required to have energy performance certificates under the EPBD.
The consultation considers whether it should be mandatory or voluntary for owners to act on this assessment and improve the performance of their buildings.
Legislation could also be extended to rate buildings according to how they actually perform as well as how they are designed to perform. This would give building managers the data needed to improve efficiency in how the building is used on a day-to-day basis.