Carbon Penalties & Incentives Project Report Launch
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1 Carbon Penalties & Incentives Project Report Launch A presentation of the findings of a review of policy effectiveness for carbon reduction and energy efficiency in the commercial buildings sector Sir Robert Finch Bill Hughes Louise Ellison Miles Keeping Jon Lovell Nina Reid Sylvie Sasaki Chairman, Property Industry Alliance Managing Director, Legal & General Property (Chairman, Green Property Alliance) Head of Sustainability, Hammerson (Chair, Green Construction Board Valuation and Demand Working Group) Partner, Deloitte (Carbon Penalties and Incentives Project Team) Global Practice Leader - Real Estate Sustainability, Deloitte (Carbon Penalties and Incentives Project Team) Director: Responsible Property Investment, M&G Real Estate Plan A Project Manager, Marks and Spencer
2 The GCB/GPA Carbon Penalties & Incentives Project A review of policy effectiveness for carbon reduction and energy efficiency in the commercial property sector Launch Presentation 18 June 2014 Jon Lovell [@lovell_jon] #GCBGPACPI
3 Context Government should conduct a comprehensive assessment of nonresidential low-carbon policies to ensure they work effectively. Committee on Climate Change, Carbon Penalties & Incentives
4 Guiding Principles Carried out independently and impartially based on objectively assessed evidence from published sources. Builds upon and complements what has been and is being done elsewhere, including GCB studies. Neutral of all political parties and individual commercial interests. Does not make detailed recommendations on the design or implementation of individual policy instruments, but seeks to: make observations on the types of policies which have been successful in encouraging emissions reductions in commercial property; make positive recommendations for improvements to existing policies based on empirical observation; and make observations as to particular factors which are hampering the success of policies. Informed by structured dialogue with a range of stakeholders 4 Carbon Penalties & Incentives
5 Briefly, methods Scoping: Long-list of instruments prepared - those affecting/concerning the design, implementation and operation of commercial buildings in England & Wales Short-listed in agreement with study Steering Group Literature Review: Instruments consultation documents and responses from industry Regulatory Impact Assessments Academic, professional/industry publications Questionnaire: Online, 330 useable individual responses Respondents involved at all stages of the property lifecycle responded, with broad geographical & organisational size spreads Workshop: 25 participants from stakeholder groups and identified experts from government and industry Examined nature and complexity of instruments 5 Carbon Penalties & Incentives
6 Headlines Disconnected pre-conditions of policy effectiveness Strong consensus on the principles of good policy-making and execution Notable gap between stated importance and perceived adequacy of existing approaches Considerable scope for improving effectiveness of the policy framework Perceptions of complexity and burdensome administration Certain policy types held to be more effective than others Notable trend of declining effectiveness through policy implementation amongst certain policy types Opportunities for simplification, policy bundling and better targeting Overcome heavy bias on operational carbon Transparency and collaboration deficits on policy implementation Harness strong connection between policy familiarity and perceived benefit Clearer sign-posting and trajectories Better bottom-up data collection and analytics Greater independent scrutiny and stronger collaboration between government and industry on policy monitoring 6 Carbon Penalties & Incentives
7 Disconnected pre-conditions of policy effectiveness 7
8 Pre-conditions of policy effectiveness 1. Confidence in policy direction 2. Comprehensive consultations within prescribed timescales 3. Adequate framework for return on investment 4. Policies that make use of markets 5. Incentives that address the risks of efficiency improvements Clear sign-posting Encouraging markets 6. Policies that address all building areas and can be bundled 7. Effective co-ordination between policies 8. Alignment of energy efficiency with wider policy Policy connectivity 9. Complementary Government-led demand creation policies 10. Comprehensive, enforceable review mechanisms 11. Institutions that have resources to oversee implementation Enforcement 8 Carbon Penalties & Incentives
9 Gap between importance and adequacy Current Status Importance E D C B A Strong Weak Low High 9 Carbon Penalties & Incentives
10 Considerable scope for improving effectiveness of the policy framework 10
11 Policy mapping across the property lifecycle *Correct at the time of writing March Carbon Penalties & Incentives
12 Some key market perceptions On the question of whether or not the current framework is sufficiently effective to help meet carbon reduction targets, considerations arise from: Complexity of framework and of individual instruments Industry perception of administrative burden Potential for greater market familiarity, which is likely to lead to greater perceptions of benefit 12 Carbon Penalties & Incentives
13 Some key market perceptions On the question of whether or not the current framework is sufficiently effective to help meet carbon reduction targets, considerations arise from: Complexity of framework and of individual instruments Industry perception of administrative burden Potential for greater market familiarity, which is likely to lead to greater perceptions of benefit 13 Carbon Penalties & Incentives
14 Effectiveness of policy design 14 Carbon Penalties & Incentives
15 Effectiveness of policy implementation 15 Carbon Penalties & Incentives
16 Wide spectrum of perceived effectiveness 16 Carbon Penalties & Incentives
17 Policies having the greatest beneficial effect Building regulations, codes, standards are considered to be the most cost efficient and effective way of changing market participants behaviour it is important to ensure these are dynamic, ambitious, have a clear developmental trajectory and are supported by a broad policy package Choice-editing by prohibiting the use of particular products, e.g. of a specific technology (e.g. HCFCs); products which fail to meet performance criteria (e.g. Eco Products Directive); reducing the liquidity of assets which do not meet pre-determined standards, as per MEPS. Policy bundles are effective: set a minimum standard; devise a label; provide overperformance financial incentives Broad impact policies (e.g. CCL) tend to be less effective. Similarly, those which require a processes or the gathering of information without any compulsion to act on the findings (e.g. Air-Con Assessments) are not found to be particularly effective, 17 Carbon Penalties & Incentives
18 Transparency and collaboration deficits on policy implementation 18
19 Determining the carbon impact of policies Cumulative RIA impact estimates of policy instruments to Carbon Penalties & Incentives
20 Headlines Disconnected pre-conditions of policy effectiveness Strong consensus on the principles of good policy-making and execution Notable gap between stated importance and perceived adequacy of existing approaches Considerable scope for improving effectiveness of the policy framework Perceptions of complexity and burdensome administration Certain policy types held to be more effective than others Notable trend of declining effectiveness through policy implementation amongst certain policy types Opportunities for simplification, policy bundling and better targeting Overcome heavy bias on operational carbon Transparency and collaboration deficits on policy implementation Harness strong connection between policy familiarity and perceived benefit Clearer sign-posting and trajectories Better bottom-up data collection and analytics Greater independent scrutiny and stronger collaboration between government and industry on policy monitoring 20 Carbon Penalties & Incentives
21 Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited ( DTTL ), a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see for a detailed description of the legal structure of DTTL and its member firms. Deloitte LLP is the United Kingdom member firm of DTTL. This publication has been written in general terms and therefore cannot be relied on to cover specific situations; application of the principles set out will depend upon the particular circumstances involved and we recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Deloitte LLP would be pleased to advise readers on how to apply the principles set out in this publication to their specific circumstances. Deloitte LLP accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC and its registered office at 2 New Street Square, London EC4A 3BZ, United Kingdom. Tel: +44 (0) Fax: +44 (0)
22 Carbon Penalties & Incentives Project Report Launch PANEL DISCUSSION Sir Robert Finch Bill Hughes Louise Ellison Miles Keeping Nina Reid Sylvie Sasaki Chairman, Property Industry Alliance Managing Director, Legal & General Property (Chairman, Green Property Alliance) Head of Sustainability, Hammerson (Chair, Green Construction Board Valuation and Demand Working Group) Partner, Deloitte (Carbon Penalties and Incentives Project Team) Director: Responsible Property Investment, M&G Real Estate Plan A Project Manager, Marks and Spencer
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