Abstract/Summary

This paper provides an international comparative analysis of pioneering minimum energy efficiency standards (MEES) policies in the Scottish, English/Welsh, Dutch and French commercial real estate sectors. These are the four national policy regimes to employ MEES to date in the commercial real estate sector with varied timelines spanning from 2009 to 2050. Drawing upon a document review of policy texts produced by policy makers and other stakeholders, the four policy regimes are evaluated in terms of their policy design focussing on minimum performance standards, forward guidance, scope and exemptions. The analysis indicates that, given the range of intervening factors, side-effects and uncertainties, there are difficult choices in finding a balance between phasing implementation, providing forward guidance and adjusting policy in response to evaluation. Whilst it was initially expected that most EU jurisdictions would default to an Energy Performance Certificate (EPC) related standard, evidence from the four policy regimes shows that there has been a shift towards MEES that are linked to actual rather than modelled energy consumption. However, for leased stock where the owner may have limited operational control, the separation of owners’ responsibility for compliance and the users’ responsibility for operations makes designing consumption-based instruments more challenging. A central issue in policy design has been the trade-off between minimising the financial costs to property owners and occupiers of complying with performance thresholds and maximising reductions in energy consumption. There is growing recognition that regulatory economies of scale may be achieved by targeting large properties which allows for a large proportion of the total area of the stock to be covered whilst exempting a large proportion of transactions or properties.