Defra wants focus on individual buildings, while the British Property Federation says it should aim at organisations.

The British Property Federation (BPF) has criticised Government proposals to extend the principle of emissions trading to large commercial – but non-energy-intensive – organisations. The organisation, which represents large property owners, says the suggested measures could fail because they are targeting the wrong people.

The proposals would involve supermarkets, hotel chains, rail operators, large offices, hospitals, universities, central government departments and large local authorities. A Government consultation document has proposed that these organisations should help deliver carbon savings of up to 1.2mt of carbon by 2020.

The BPF, which represents the owners of large commercial property portfolios, says “Defra is proposing to introduce an emissions trading scheme that is focused on individual buildings. However, as many are occupied by a variety of different organisations and increasingly house a mix of uses – including retail, commercial and residential – the responsibility for energy use is far from straightforward.”

It said it believed that “focussing the energy performance commitment at the building level will significantly increase the complexity of the emissions trading scheme. Instead, the scheme should be aimed at organisations, requiring them to submit details on all the energy use for which they are responsible, regardless of where it is used.”

Such an approach, says the BPF, “would avoid the complexities of the space occupied and ensure that organisations fully account for their total energy usage. It would also give them the incentive, with their landlords’ assistance, to drive down their energy consumption.”

The Defra consultation concentrates on organisations with electricity consumption higher than 3,000MWh – in late 2006 prices annual electricity bills would be of the order of £250,000 and above. Under business-as-usual projections, the sectors covered would be expected to increase their carbon emissions by over 10% by the year 2030. Yet the potential for reducing emissions is high.

The 5,000 or so large non-energy-intensive organisations within the category under consideration could – cost-efficiently, according to the Government – save 0.5MtC per year by 2015 and 1.2MtC by 2020.

The measures being proposed include:

•   an Energy Performance Commitment (EPC) which is essentially a mandatory cap-and-trade scheme covering building energy use

•   a voluntary system of benchmarking and reporting of energy use

•   further changes to the Building Regulations (although this would not happen in the short term as they have only just been amended)

•   greater provision of information and advice to business

•   industry-led agreements on reducing emissions. Defra says there are a number of successful initiatives already, such as the Carbon Disclosure Project; these could be developed further to secure agreement to reduce emissions in this sector

The Government may also consider a mix of these measures. The Energy Performance Commitment would be the most controversial option though, including as it does a mandatory requirement for organisations to take part.