Carbon and Energy Issues
Affecting IT in Higher
Education
- Current Regulations and Schemes
Version 1.0, May 2011
(Comments welcome – please contact l.m.hopkinson(at)bradford.ac.uk )
Peter James and Lisa Hopkinson
Higher Education Environmental Performance Improvement Project,
University of Bradford
Contents
About HEEPI, SUSTEIT, JISC, Acknowledgements and Disclaimer .................................................4
Glossary of Acronyms .................................................................................................................5
Introduction ...............................................................................................................................6
Section 1 - Background ...............................................................................................................7
Figure 1: Key Requirements Relevant to IT-Related Energy, Carbon and Environmental Issues ............. 9
Table 1: Statutory/Mandatory Requirements Relevant to IT-Related Energy, Carbon and Environmental
Issues ............................................................................................................................................... 10
Table 2: Non-statutory/optional Schemes Relevant to Energy, Carbon and Environmental Issues ....... 11
Section 2 – Statutory or Mandatory Requirements on Energy and Carbon ................................. 13
2.1
Building Regulations - Part L .................................................................................................. 14
2.2
Building Energy Certificates - DECs and EPCs .......................................................................... 15
2.3
Inspection of Cooling Systems ............................................................................................... 17
2.4
EU Emission Trading Scheme ................................................................................................. 17
2.5
CRC Energy Efficiency Scheme (Carbon Reduction Commitment) ............................................ 18
2.6
Renewable Energy/Low Carbon Requirements ....................................................................... 20
2.7
Funding Body Requirements and Guidance ............................................................................ 21
Section 3 – Non-statutory/Optional Schemes on Energy and Carbon ......................................... 23
3.1
EU Code of Conduct on Data Centre Energy Efficiency ............................................................ 23
3.2
British Computer Society CEEDA Scheme ............................................................................... 25
3.3
Government Buying Standards and other Procurement Initiatives .......................................... 25
3.4
Energy Star............................................................................................................................ 27
3.5
EPEAT ................................................................................................................................... 29
3.6
ECMA Eco-Declaration ........................................................................................................... 30
3.7
TCO-Certified ........................................................................................................................ 31
3.8
Other Eco-Labels ................................................................................................................... 31
3.9
BREEAM ................................................................................................................................ 32
3.10
Universities that Count .......................................................................................................... 33
3.11
Green League ........................................................................................................................ 34
Table 3: 2010 Green League Criteria and Scoring ............................................................................... 35
3.12
Carbon Trust Programmes ..................................................................................................... 35
3.13
ISO14001 and Related Standards ........................................................................................... 36
3.14
EcoCampus ........................................................................................................................... 37
3.15
Green Impact Universities ..................................................................................................... 38
3.16
The Universities and Colleges Climate Commitment for Scotland (UCCCfS) ............................. 39
Section 4 - Financial Opportunities ........................................................................................... 40
4.1
Incentives for Zero and Low Carbon (ZLC) Technologies .......................................................... 40
4.2
Salix Finance ......................................................................................................................... 40
Section 5 - Analysis................................................................................................................... 42
Figure 2: A Strategic Process for Energy and Environmental Issues ..................................................... 44
Appendix 1: Statutory and Non-Statutory Requirements on Other Environmental Issues ........... 45
A1.
WEEE Regulations ................................................................................................................. 45
A2.
ROHS Regulations.................................................................................................................. 45
A3.
Batteries Directive and Regulations ....................................................................................... 46
Appendix 2: Practices from the EU Code of Conduct on Energy Efficient Data Centres ................ 47
3
About HEEPI, SUSTEIT, JISC, Acknowledgements and Disclaimer
Partners
This guide has been produced by the University of Bradford based HEEPI project (see below), as part of the
JISC-funded SusteIT project. A general version of this paper is available at www.goodcampus.org
About HEEPI
The Higher Education Environmental Performance Improvement (HEEPI) project supports sustainable
development, and especially environmental improvement, in universities and colleges through: identification
and dissemination of best practice; creation and maintenance of networks; development of benchmarking
data and processes; and in other ways. It is based at the University of Bradford, and has mainly been funded
by the Leadership, Governance and Management (LGM) initiative of the Higher Education Funding Council
for England (HEFCE). Since its inception, HEEPI has run almost 100 events, with over 4,000 delegates;
prepared many case studies, guidance documents, and tools (see www.goodcampus.org). Its main projects
at present are S-Lab (Safe, Successful and Sustainable Laboratories) and SusteIT (focused on energy efficient
ICT).
About SusteIT
The Sustainable Information Technology in Tertiary Education (SusteIT) project was a strategic review of
sustainable ICT in Higher and Further Education funded by JISC. This led to further funding for two
projects under JISC’s Greening IT programme: one focussing on scientific computing and one on
videoconferencing.
About JISC
The Joint Information Systems Committee (JISC) advises the four UK higher education funding bodies (in
England, Northern Ireland, Scotland and Wales) on issues and policy with regard to information and
communication technology (ICT) – see www.jisc.ac.uk. It also funds ICT-related research and
implementation programmes, and provides a number of digital services to further and higher education
institutions. This includes a high capacity network (JANET). The JISC Board and its sub-committees include
senior managers, academics and technology experts from a wide range of universities and colleges. Since
2009 JISC has run a formal Greening ICT programme, with around £3 million of funding allocated to a
variety of projects.
Acknowledgements
The authors wish to thank the following for advice and information on this report: Ian Barham, Defra;
Charlotte Bonner, NUS Services Ltd; Stephen Bowes-Phipps, University of Hertfordshire; Alan Brookes,
The Energy Consortium (TEC); Steve Butcher, HEFCE; Andrew Chamberlain, EAUC Scotland; Chris
Cowburn, HEFCW; Oliver Fry, Salix Finance; Janine Hamilton, Sustainable Procurement Centre of
Excellence (SPCE); Louise Hazan, People & Planet; Mike Kilner, London University Purchasing Consortium
(LUPC); Sarah Lee, EAUC; Alex Mcfarlane, Association of University Procurement Officers (AUPO);
Gerald McInerney, Communities and Local Government (CLG); Richard Meddings, EcoCampus; Alison
Meldrum, Scottish Funding Council; Sarah O Brien, EPEAT; Iain Patton, EAUC; Tim Pryce, Carbon Trust;
Joanna Simpson, HEFCE; David Stutchfield, University of St Andrews; Paul Smyth, Salix Finance; Martin
Whiteland, University of Cambridge.
Disclaimer
Every effort has been made to ensure that the information in this document is accurate. However, it should
not be used as a substitute for professional advice on detailed matters of regulation, or their implications.
4
Glossary of Acronyms
AUPO:
Association of University
Procurement Officers
ETS:
Emission Trading Scheme
BiTC:
Business in the Community
EU:
European Union
HE:
Higher Education
BREEAM:
Building Research Establishment
Environmental Assessment
Method
HEFCE:
Higher Education Funding
Council for England
CCC:
Committee on Climate Change
HEFCW:
Higher Education Funding
Council for Wales
CCL:
Climate Change Levy
ISO:
CIF:
Capital Investment Framework
International Standards
Organisation
CLG:
Communities and Local
Government
LZC
Low and zero carbon
MW:
MegaWatt
CO2:
Carbon dioxide
NCM:
CR:
Corporate Responsibility
National Calculation
Methodology
CRC:
Carbon Reduction Commitment
NMO:
National Measurement Office
DEC:
Display Energy Certificate
NUS:
National Union of Students
DECC:
Department for Energy &
Climate Change
PDU:
Power Distribution Unit
ROC:
Renewable Obligation Certificate
SAP:
Standard Assessment Procedure
DEFRA:
Department for Environment,
Food & Rural Affairs
EAUC:
The Environmental Association
for Universities and Colleges
SBEM:
Simplified Building Energy Model
SFC:
Scottish Funding Council
EMS:
Environmental Management
System or Estate Management
Statistics
SPCE:
Sustainable Procurement Centre
of Excellence
EPC:
Environmental Performance
Certificate
UCCCFS:
University and Colleges Climate
Change Commitment for
Scotland
ESR:
Environment and Social
Responsibility
UPS:
Uninterruptible Power Supplies
UTC:
Universities that Count
5
Introduction
Higher education (HE) is currently dealing with a plethora of initiatives intended to reduce energy usage,
carbon emissions, and other environmental impacts in universities and colleges (summarised in Tables 1-2
and Figure 1). Many of these have implications for the procurement and use of ICT within universities and
colleges. This is creating difficulties because:

Most require a commitment of time and/or financial resource;

The sheer number makes it difficult to understand their requirements, and how they relate to each
other; and

These and other factors mean that they can sometimes be diverting attention from, rather than
encouraging, real environmental improvement.
This paper aims to assist senior managers within the sector – and especially senior IT managers – in making
sense of the current situation, and by suggesting ways in which it can be addressed for maximum
environmental benefit. It is structured as follows:

Section 1 provides a brief explanation of the general pressures which are driving the initiatives
being discussed;

Section 2 summarises the main statutory or compulsory requirements affecting universities and
colleges on energy and carbon which are currently in existence, or scheduled for introduction in
the near future;

Section 3 summarises the main non-statutory or optional measures affecting universities and
colleges on energy and carbon which are currently in existence, or scheduled for introduction in
the near future

Section 4 describes the main opportunities for funding energy efficiency and carbon reduction
projects which are currently in existence, or scheduled for introduction in the near future; and

Section 5 provides the authors’ personal vision of a sensible way forward for individual institutions,
and the sector as a whole.
Section 1 - Background
In 2008/09 universities and colleges were responsible for these resource use and environmental impacts1:

Consumption of 7.7 TWh of energy (all fuels);

Emissions of 2.6 million tonnes of carbon dioxide (CO2) equivalent; and

Creation of nearly 347,000 tonnes of waste, of which 57% was ultimately disposed of.
IT-related CO2 emissions have been estimated at 275,000 tonnes for UK higher education, which had an
estimated IT-related energy bill of £61 million in 2009.2
In addition, the sector’s buildings and equipment contain large amounts of ‘embedded’ or ‘embodied’
energy and carbon, i.e. the energy consumed and CO2 emitted in creation of the materials and components
they contain, and any associated transportation. There are no precise figures for this, but its impact is
considerable. For example, a 2004 Defra study suggested that each domestic house has 35 tonnes of CO2
equivalent of embodied energy associated with it, which is around 8 times the annual occupational energy
consumption.3
The supply and use of this energy has many environmental impacts, including:

Ecological impacts, land take and sterilisation;

Water consumption and pollution associated with production and distribution facilities;

Air pollution associated with both production and distribution, and – in the case of fossil fuels –
end use; and

Emissions of CO2 and other greenhouse gases, which are especially associated with the production,
distribution and use of fossil fuels.
Fossil fuels are also a non-renewable resource and will be depleted at some point in the future.
Universities and colleges are under increasing pressure to reduce their energy consumption and carbon
emissions as a result of:

Rising energy prices – most experts expect costs, especially of electricity, to resume the increases
of recent years once the credit crunch has ended;

Challenging carbon reduction goals - the UK Government has ambitious targets to reduce
greenhouse gas emissions by 80% by 2050 and at least 34% by 2020 against a 1990 baseline, and
these are now cascading into a number of initiatives and regulations, such as the Carbon Reduction
Commitment;
1
Estate Management Statistics, Environmental Information 2008/09. Available at:
http://www.hesa.ac.uk/index.php/component/option,com_datatables/Itemid,121/task,show_category/catdex,4/
2
James P and Hopkinson L, 2009. Sustainable ICT in Further and Higher Education. Available at
http://www.susteit.org.uk/publications/index.php
3
Entec UK, Richard Hodkinson Consultancy and Economics for the Environment Consultancy. Study into the
Environmental Impacts of Increasing the Supply of Housing in the UK. Final Report, April 2004. Study for the Department
for Environment, Food and Rural Affairs (Defra). Available at:
https://statistics.defra.gov.uk/esg/reports/housing/mainrep.pdf.
7

Funding council requirements – the HE sector has developed carbon reduction targets in line with
the 2050 80% reduction target and are linking capital funding to performance against carbon
management plans. In addition HEFCW and the SFC require all new build to achieve an Excellent
rating, and refurbishments Very Good, in the BREEAM scheme; and

Stakeholder pressures – many staff and students pay attention to the environmental and social
performance of institutions when making study or work choices, and other bodies such as local
authorities also take it into account when making decisions.
As later pages demonstrate, there are now many different statutory and de facto mandatory requirements
on institutions, as well as a number of voluntary initiatives. The reasons for this, often confusing,
fragmentation include:

Different public sector mandates and approaches (e.g. at national Government level four
departments - Communities and Local Government; the Department of Energy and Climate
Change; the Department for Environment Food and Rural Affairs; and the Department for
Business, Innovation and Skills – are sponsoring different actions whilst the Funding Councils also
have different approaches);

Similar differences in mandates and approach – and occasional competition – between organisations
assisting with implementation, e.g. Carbon Trust, Business in the Community;

‘Laissez faire’ methods of funding sector initiatives, so that individual institutions (or groups of
them), and/or sector representative bodies, can relatively easily find funding for projects intended
to influence the sector as a whole;

Differing areas of focus – from individual items of equipment, through buildings, to campuses and
whole institutions;

Differing timescales; and

Differing objectives.
Four basic objectives which can be identified are:

Comparison – concerned with comparing the performance of buildings, campuses or organisations
for purposes such as a) continuous improvement through benchmarking, or b) assisting stakeholder
judgements of performance;

Control – ensuring that specific performance levels or requirements are met;

Incentivising – creating financial or other tangible rewards/penalties to drive improvements in
performance; and

Risk management – concerned with achieving a full understanding of environment-related issues
and risks, and taking appropriate actions to ensure that the risks are controlled and mitigated.
As all of these factors seem likely to persist, there is always likely to be confusion, and sometimes conflict,
between the many different approaches. Section 5 makes some suggestions on how this can be reduced.
Before that, the following sections provide brief summaries of the main regulations and schemes which are
relevant to IT.
8
Figure 1: Key Requirements Relevant to IT-Related Energy, Carbon and Environmental Issues
Statutory/Mandatory Requirements
Building
Building
Certificates
– DEC; EPC
Regulations
Inspection
- Cooling systems
Key
Renewable &
Low Carbon
Requirements
HE Funding Body
Requirements – targets,
BREEAM, EMS
Emission
Trading
Scheme
CRC Energy
Efficiency
Scheme
Campus
Holistic – all
impacts
Energy &
Carbon only
Equipment
/Systems
Inter-linked
Building
s
Carbon Trust
- HE Carbon
Management
- Standard
Organisation
n
BREEAM
Higher
Education
Procurement
-Energy Star,
Buying Standards
EPEAT, TCO etc.
Universities
That Count
Green
League
Table
Environmental
Management
Systems – 14001,
EcoCampus
Data Centres – EU
Code of Conduct,
BCS CEEDA Scheme,
BREEAM for DC
Non Statutory/Optional Requirements
Green
Impact
Universities and
Colleges Climate
Commitment
9  for
Scotland
Table 1: Statutory/Mandatory Requirements Relevant to IT-Related Energy, Carbon and Environmental Issues
Legislation/Regulations
Building Regulations
Display Energy Certificates
(DECs)
Energy Performance
Certificates (EPCs)
Inspection of Cooling
Systems
Carbon Reduction
Commitment (CRC)
Renewable/Low Carbon
Energy Requirements
Carbon Sector Targets
SFC/HEFCW requirements
HEFCW EMS
Requirements
What’s affected?
All new build and
retrofits
All existing buildings over
1,000m2
All new build; substantial
retrofits; building sales or
rentals
Cooling systems
Organisations with annual
half hourly metered
electricity > 6000MWh/y
Energy supply
All activities generating
greenhouse gases
All new build or major
refurbishment
All activities creating
environmental impacts
Key Requirements re Universities and Colleges
Requires minimum energy performance requirements in new buildings or retrofits. There are
differences between England (where regulations were tightened in 2010) and Scotland.
Requires public display of a performance rating certificate detailing a building’s CO2 emissions
over the last 12 months, and ranking it on an A-G scale (England and Wales only).
All new buildings or those that are substantially modified, sold or rented, to display EPCs
detailing design CO2 emissions. (NB England uses a standard model – SBEM – to calculate; this
can be used in Scotland, which requires EPCs for large public buildings, but so too can others).
Requires, in England, inspection (with improvement recommendations) of cooling installations
(such as those in laboratories and data centres) every five years.
Requires monitoring and reporting of fossil fuel and electricity consumption, and participation
in a scheme that ranks them in a league table. Organisations pay a ‘tax’ to Government
(currently £12 per tonne) on their CO2 emissions.
2008 Planning and Energy Act allows local councils in England and Wales to require a certain
proportion of renewable energy in new developments.
HEFCE-funded institutions will be required to produce plans to reduce carbon emissions –
performance against the plans will be a factor in future capital allocations.
New buildings must achieve BREEAM Excellent, and refurbishments Very Good, for both the
Design and Procurement, and Post Construction stages.
Institutions will be required to develop an Environmental Management System, externally
certified to a recognised system, by early 2011.
10 
Table 2: Non-statutory/optional Schemes Relevant to Energy, Carbon and Environmental Issues
Activity/Scheme
EU Code of Conduct on Data
Centres
Certified Energy Efficiency
Data Centre Award
Government Buying Standards
Energy Star
EPEAT
ECMA
TCO-Certified
Other Eco-labels
BREEAM
Universities that Count
Green League
What’s affected?
Data centres
Key Requirements re Universities and Colleges
Informs data centre designers and operators and encourages them to reduce energy
consumption through a series of best practice recommendations which focus on design in areas
such as software, IT architecture and infrastructure.
Data centres
An award scheme based on the EU code of Conduct on Data Centres which is verified and
audited on behalf of the British Computer Society.
Wide range of energy
These implement the EU Energy End Use Efficiency and Services Directive. Actions will be
using products, including supported by the EU’s Ecodesign Directive, which will mandate minimum performance
ICT
requirements for many products, including ICT. This year the voluntary Efficiency
Measurement Model (EMM) reporting system which reports on university Value for Money
targets will include data on efficiencies delivered based on the Energy Services Directive (i.e.
energy savings as a result of procuring Energy Service Directive-compliant products.
Computing equipment
A widespread voluntary eco-labelling scheme for office products which is based on a minimum
performance of energy in use.
Computing equipment
A US-developed ecolabel for computing equipment whose environmental criteria cover
environmental design, manufacture, end-of-life management and corporate performance. EPEAT
compliant products are available in the UK.
Computing equipment
A European eco-labelling scheme for computing equipment
Computing Equipment
A Swedish based eco-labelling scheme that aspires to be the most rigorous in the world
Computing equipment
Various eco-labels which cover computing equipment and some of which are independently
verified.
New/refurbished
A building certification system which assesses design against a number of criteria. Scoring
buildings, including data undertaken by licensed Assessors. Since summer 2009 a HE version has lowered costs and
centres
provided known criteria from the start of the process.
Whole organisation
An index of an institution’s corporate social responsibility (CSR) performance, enabling
universities to benchmark themselves against each other and business.
All activities (including
An annual ranking of Universities and Colleges based on (in 2010) 11 assessment areas covering
energy) creating
both systemic environmental management, and actual performance. Utilises publicly available
11 
Carbon Trust HE Carbon
Management Programme
Carbon Trust Standard
Environmental Management
System (ISO 14001)
EcoCampus
Green Impact
University and Colleges
Climate Change Commitment
for Scotland
Incentives for Zero and Low
Carbon Technologies
Salix Finance
environmental impacts
Whole organisation
All energy using
activities
All activities (including
energy) creating
environmental impacts
All environmental
impacts (including
energy use)
All environmental
impacts (including
energy use)
All activities generating
greenhouse gases
Activities generating
carbon
Capital investments in
energy efficiency
information as well as questionnaires.
A year-long 5 step process of calculating carbon footprints, identifying improvements, and
formulating a carbon management plan.
Requires organisations to measure their carbon footprint, achieve an absolute reduction in it,
and demonstrate appropriate management and governance.
An internationally recognised Environmental Management System based on 4 stages: plan, do,
check and act. Organisations can use the standard as a guide or achieve formal certification
after a compliance audit by an external assessor.
Provides a support package to enable institutions to implement a robust and effective EMS
through the provision of a variety of tools and guidance including software applications, training
workshops, advice and external audit.
An environmental accreditation scheme with an awards element – based on a bespoke set of
simple, practical actions developed for the institution.
A voluntary scheme for Scotland’s universities and colleges, requiring signatories to prepare and
implement a 5-year Climate Change Action Plan.
Various financial incentives for zero and low carbon technologies including Feed In Tariffs,
Renewable Obligation Certificates and refunds of the Climate Change Levy.
Interest-free funding for capital investments in energy efficient and low carbon technologies for
Higher Education Institutions
12 
Section 2 – Statutory or Mandatory Requirements on Energy and Carbon
Government environmental targets are implemented through legislation and detailed regulation, which are
having a growing impact on the sector. Many of these are the UK implementation of European Union
Directives, which often result in multiple UK initiatives. The Energy Performance of Buildings Directive, for
example, has been implemented through three main routes in England and Wales:

Revised Building Regulations;

Requirements for energy consumption measurement (Display Energy Certificates and Energy
Performance Certificates); and

Stand alone measures, such as requirements for regular assessment of air conditioning systems.
The Directive has also been implemented differently in Scotland to England.
UK Government carbon targets will require much more legislation, regulation and other public initiatives in
future. In addition to the current situation, several strategic initiatives are also likely to cascade down into
specific legislation and regulation over the next few years. For example, the Sustainability of the
Government Estate (SOGE) initiative requires that all new non-domestic public sector buildings to be zerocarbon from 2018, and in England all domestic buildings will need to be zero-carbon from 2016 and nondomestic buildings by 2019. Until now, progress has been hampered by the absence of detailed definitions,
but this is now being addressed.4 The Welsh Assembly also expects all publically funded new non-domestic
developments in Wales to be built to BREEAM Excellent standards.
Future regulations are also likely to be more incentive-based than in the past. Such regulations do not
compel improvement, but aim to create new drivers – including raised awareness, and concern about
public perceptions – to encourage action by organisations.
There are also a number of mandatory requirements such as carbon targets and carbon management plans
which all English universities are required to comply with.
Table 1 (above) summarises the main legislation and regulations, and the following pages provide further
details.
4
The Zero-Carbon Hub, a public/private partnership will take day-to-day operational responsibility for co-ordinating
delivery of low and zero carbon new homes. See http://www.zerocarbonhub.org/ In the 2011 Budget announcement,
details of the 2016 zero carbon new homes policy have been clarified and include only the emissions covered by
Building Regulations (heating, fixed lighting, hot water and building services). Therefore, emissions from cooking or
from plug-in appliances such as computers and televisions will not be addressed as part of this policy.
13 
2.1
Building Regulations - Part L
What is it?
In England and Wales Part L of the 2010 Building Regulations5 deal with Conservation of Fuel and Power.
They set minimum energy performance standards for new buildings and major refurbishments of existing
buildings.
Successive revisions of the building regulations (in 2002, 2006 and 2010) have progressively reduced carbon
emissions with an ambition for all new non-domestic buildings to become zero carbon by 2019 (the date
for schools is 2016 followed by public buildings in 2018). The 2010 revision6, which came into force on 1
October 2010, is intended to reduce carbon emissions per m2 by 25% over the 2006 Building Regulations,
which is an overall improvement of 44% on the 2002 regulations. In 2006 the reduction was based partly
on how the building was serviced but this has had some unintended consequences (e.g. it was easier to
achieve a compliant air conditioned building than a naturally ventilated one). The 2010 amendments are
based on the fact that it is more difficult to reduce the carbon emissions of some types of building than
others. This means that some buildings will deliver more than 25% relative to 2006 standards, and some
less. However, the aggregate target is 25%. Some analysis on how different types of non-domestic buildings
might be affected by the aggregate approach can be found in the Implementation Impact Assessment.7
Part L 2010 majors on energy efficiency improvements and on-site Low and Zero Carbon (LZC) systems in
a performance based way that tries not to stifle innovation or future allowable solutions. As well as
introducing a timetable for zero carbon dwellings, the updated standards also introduce a proposed phased
improvement for zero carbon non domestic buildings beginning with 25 per cent in 2010.
The strengthening of the energy efficiency standards in Part L has been accompanied by two other changes:

The move towards more airtight buildings has resulted in amendment of Part F of the Building
Regulations to ensure that adequate means of ventilation is provided; and

The National Calculation Methodology (NCM) of building carbon emissions, and the Simplified
Building Energy Model (SBEM) which applies in the areas of Building Regulations and Energy
performance Certificates (see Section 2.2), has been revised and updated.
A number of Approved Documents set out set out more details on the changes.8 These changes apply to
England and Wales only. However, the UK Government is planning to transfer responsibility for Building
Regulations in Wales to the Welsh Assembly on 1 January 2012.
In Scotland, the Building (Scotland) Amendment Regulations 2010 came into force on October 1, 2010.9
This has resulted in changes to mandatory standards and associated guidance, and the publication of new
documents. The regulations are enforced by the Building Standards Division. The latest 2010 Technical
Handbook for non-domestic buildings provides guidance on meeting the standards.10 Section 3 covers the
5
Available at: http://www.communities.gov.uk/planningandbuilding/buildingregulations/
Available at: http://www.communities.gov.uk/publications/planningandbuilding/circular032010
7
CLG, 2010. Implementation Stage Impact Assessment of Revisions to Parts F and L of the Building Regulations from
2010. March 2010. See Talbe 7, pp30. Available at:
http://www.communities.gov.uk/documents/planningandbuilding/pdf/1531558.pdf
8
Available at:
http://www.planningportal.gov.uk/england/professionals/buildingregs/technicalguidance/bcconsfppartl/bcconsfppartlappd
oc/
9
Available at: http://www.scotland.gov.uk/Topics/Built-Environment/Building/Building-standards/tech2010changes
10
Available at: http://www.scotland.gov.uk/Topics/Built-Environment/Building/Buildingstandards/publications/pubtech/thb2010nondom
6
14 
environment (ventilation, combustion appliances and biomass fuel standards) while Section 6 covers energy.
The standards specify minimum energy performance levels and require the calculation of carbon dioxide
emissions using a specified National Calculation Methodology. This includes SBEM, as well as others. The
technical guidance provides for a 30% improvement in CO2 emissions for new buildings. Future
amendments are planned in October 2013 and 2016/17.
The Scottish Government are also considering introducing sustainability labelling to provide recognition to
buildings of higher standards than the current regulations require.11 This is proposed to include more
demanding sustainability standards based on two areas: (1) climate change, energy and water and (2) quality
of life; material use and waste. It is proposed to have five levels of award: bronze, bronze star, silver, gold
and platinum where gold is a 75% improvement and platinum a 100% improvement on the 2007 CO2
emission standards for non domestic buildings. The award of an overall upper level depends on an
integrated holistic design, which does not allow trade-offs to achieve a score.
Implications
The 2010 amendments will increase the costs of constructing new buildings in England and Wales, as
developers will need to invest to a greater extent in energy efficient building fabric and services in order to
comply with the lower limit on carbon emissions. In addition to the higher capital costs of constructing new
buildings, developers may also incur additional testing and administrative costs. To balance this, the
occupiers of properties built to the new standards should benefit from lower energy bills. Overall there
should be a net saving.12
2.2
Building Energy Certificates - DECs and EPCs
What is it?
The EU Energy Performance of Buildings Directive requires energy certification of buildings in England and
Wales (see below for Scotland).13 This has been implemented by the 2007 Energy Performance of Buildings
Regulations, which introduced:

Energy Performance Certificates (EPC) – required whenever a domestic or non-domestic building
is constructed, significantly modified, sold or rented. The exact form of the EPC varies according to
the use and size of the building, but is always calculated from the design specification, using a
slightly amended version of the SBEM methodology (in the case of non domestic buildings) required
by Building Regulations. It is therefore termed an asset rating. EPCs are valid for 10 years, but must
be renewed each time the building is rented, refurbished or sold. EPCs are produced by accredited
Energy Assessors, and are accompanied by an advisory report on what could be done to improve
energy performance.

Display Energy Certificates (DEC) – required for all publically accessible buildings in the public
sector over 1,000m2 in England and Wales. They contain data on the last 12 months of energy
consumption, verified by an approved Energy Assessor (who can be an internal member of staff).
The Assessor must also produce a short report on improvement opportunities. The data is used to
11
The Scottish Government, 2010. Consultation on Sustainability Labelling within Building Standards, 1 Nov 2010 – 24
Dec 2010. Available at: http://www.scotland.gov.uk/Topics/Built-Environment/Building/Buildingstandards/publications/pubconsult
12
Communities and Local Government, 2010. Implementation Stage Impact Assessment of Revisions to Parts F and L
of the Building Regulations from 2010. April 2010. Available at:
http://www.communities.gov.uk/documents/planningandbuilding/pdf/1531558.pdf
13
Communities and Local Government, 2008. Improving the energy efficiency of our homes and buildings: Energy
certificates and air-conditioning inspections for buildings. Available at:
http://www.communities.gov.uk/publications/planningandbuilding/improvingenergyefficiency
15 
classify the building on an A-G scale, based on comparison with a benchmark. This is termed an
operational rating. The Certificate must be publicly displayed. For 2008-9 (the first year of
operation) institutions could produce a single DEC for the whole campus. Since 2009-10 each
building must display its own DEC and must also have a building specific advisory report.
New or refurbished publically accessible buildings over 1000 m2 therefore require both certificates – an
EPC when completed, and annual DECs after the first year of operation.
It was assumed that almost all higher education buildings would require DECs but in practice universities
have interpreted the requirements differently. Some have prepared DECs for all buildings over 1000 m2 but
others have confined it to only some. For example, many laboratories have been excluded on the grounds
that there is no general public access.
The EU revised the Directive in November 2008 to extend its scope and strengthen it.14 This expected to
be incorporated into UK domestic law at the end of 2012 or the beginning of 2013. Changes expected
include:






DECs to be displayed in buildings larger than 250m² that are occupied by a public authority;
EPCs to be displayed in commercial buildings larger than 250m² that (a) are frequently visited by
public and (b) where an EPC has previously been produced on the sale, rent or construction of that
building;
The energy performance of existing buildings of any size that undergoes major renovations to be
upgraded in order to meet minimum energy performance requirements;
Minimum energy performance requirements to be set in respect of technical building systems, e.g.
boilers, air-conditioning units etc.;
European Commission to establish common principles for definition of low and zero carbon (LZC)
buildings; and a
Requirement to set targets for increasing the number of LZC buildings in a) new and refurbished
dwellings, b) new and refurbished commercial buildings, and c) buildings occupied by public
authorities.
In Scotland, the Energy Performance of Buildings (Scotland) Regulations 2008 came into effect in January
2009.15 Buildings when constructed, sold or rented out, including homes, public sector buildings and
business premises will require an Energy Performance Certificate (EPC). For existing buildings, an EPC will
be required when the property is sold or rented out to new tenants. Once in place an EPC is valid for 10
years.
Implications
Building certification is an example of incentive-based regulation. It can have an especially great impact in
higher education, by providing information for stakeholders to compare building performance, both within
and between institutions. The Estates Management Statistics now require information on the amount of
non residential area within each DEC category and it is likely that pressure groups or others will use it to
produce a ranking of buildings, similar to People & Planet’s Green League (see section 3.11). This effect will
be exacerbated by the relatively poor ratings achieved by many higher education buildings, many of which
only have the worst (G) score. This is often explained by their unusually high energy intensity (e.g. in
14
Communities and Local Government. Recast of the Energy Performance of Buildings Directive. October 2009.
Available at: http://www.communities.gov.uk/publications/planningandbuilding/recastepbdconsultation
15
Guidance available at: http://www.scotland.gov.uk/Topics/Built-Environment/Building/Buildingstandards/publications/pubepc
16 
laboratories) but in nonetheless looks unimpressive to many observers. A key issue in future is whether
there will be greater consistency in which university buildings provide DECs.
Individual metering of relevant buildings greater than 1,000m2 will soon be required as part of DEC
certification, and in the medium term this could be extended to buildings greater than 250 m2. There will
also be considerable expenditure on energy calculations for EPCs, and Energy Assessors for DECs. There
may be opportunities to cut costs, and strengthen sector capacity, by creating more in-house expertise in
these areas. There could also be benefit in collaboratively procuring assessor services to achieve best value,
and to go beyond the basic report requirements. Indeed, universities employing external consultants will
probably gain more from extending the report requirement into a short energy survey – maximising the
benefit of having a trained engineer in the building and applying their professional judgement to complement
the software outputs. Until DECs are fully metering based and/or related to building specific benchmarks,
rather than based on campus averages, research intensive universities will be at a disadvantage, as their
relatively high number of energy intensive facilities will bring down the average level of building
performance, compared to less research intensive institutions.
2.3
Inspection of Cooling Systems
What is it?
The 2007 Energy Performance in Buildings Regulations requires regular inspection of air-conditioning
systems in buildings in England and Wales with a rated capacity over 250 kW from 4 January 2009, and
over 12 kW from 4 January 2011.16 The inspection must be carried out at intervals not exceeding 5 years,
and be conducted by an accredited energy assessor. The inspection covers not only the energy efficiency of
the cooling equipment, but also whether the cooling capacity is appropriately sized for the load. Current
requirements do not require action to be taken as a result of the inspection but, as with building
certification, the aim is to stimulate improvement through better understanding. Another driver may be
some or all reports entering the public domain, either because future revisions of the regulations require it,
or because of Freedom of Information requests from external bodies.
Implications
The impact of this regulation will depend upon the depth of analysis by energy assessors. It could be a tick
box exercise. However, if taken seriously, it could challenge existing practices, and result in more critical
analysis of the need for cooling; a move towards much more variable systems which can better track loads;
and greater take-up of other energy efficiency measures. This could be made more likely if universities
commissioned a small enhancement of the advisory reports to incorporate related recommendations for
controls and management of the chilling systems. If successful, it is also likely in the medium-long term that
the approach will be extended to other equipment and activities, such as boilers or mechanical ventilation
systems.
2.4
EU Emission Trading Scheme
What is it?
The EU-ETS is an example of incentive-based regulation. It involves the European Commission – in
consultation with national governments – setting an annual ‘cap’ on permitted carbon dioxide emissions
from all sites with an aggregated thermal input capacity of 20MW.17 A National Allocation Plan for each
country then shares out the total permitted emissions between these sites, on an annual basis (e.g. 50,000
16
Communities and Local Government. Improving the energy efficiency of our buildings: A guide to air-conditioning
inspections for buildings. July 2008. available at:
http://www.communities.gov.uk/publications/planningandbuilding/airconditioning
17
Guidance available at: http://www.environment-agency.gov.uk/business/topics/pollution/32232.aspx
17 
tonnes of CO2 emissions for a university). The sites must then report their annual emissions, with
independent verification.
The scheme involves tradable allowances (each for one tonne of CO2 emissions). If a university emits less
than its permitted level over the year, it can either sell the surplus allowances on the EU-wide carbon
market, or bank them for use in subsequent years. If it emits more than its allowance, it has to either
purchase sufficient to cover the overrun, or pay a fine. The improvement impetus of the scheme is
therefore related to the price of allowances. Unfortunately, although these have occasionally risen to
€30/tonne, they have generally been lower than anticipated, and hit an all time low of €8/tonne in early
2009. This was due to excess supply arising from generous allocations in many countries, and the effects of
the credit crunch in driving emissions down. The EU has said that it will take measures to drive prices up,
but it remains to be seen if this will happen.
Phase 1 of the scheme ran from 2003-8, and involved around 40 universities. Phase II runs from 2008-2012,
and – due to rule changes to exclude smaller organisations – now involves around 20. Further five-year
phases are expected beyond this. They may also extend the scheme to cover other greenhouse gases, as
well as CO2.
According to one report, because the economic crisis has driven down industrial activity while the cap
remains at the same level the estimated carbon savings for 2008-12 could be less than 1% of total
emissions.18 It is proposed there will be a tighter cap for 2013 onwards.
Implications
For those universities that are part of the ETS there are significant administrative costs, and for those that
exceed their allowances there are also the costs of buying additional carbon credits. However the scheme
can, in theory, financially benefit universities who have taken early action on reducing carbon emissions
(and can therefore sell surplus credits), and provide financial incentives to those who are lagging. In
practice, the low price of carbon has reduced the importance of the ETS as a driver of energy efficiency
(except with regard to large scale CHP Investments).
2.5
CRC Energy Efficiency Scheme (Carbon Reduction Commitment)
What is it?
The CRC Energy Efficiency Scheme (previously known as the Carbon Reduction Commitment) was
intended to be an incentive-based UK-wide scheme which built on the experience of the EU-Emissions
Trading Scheme (see Section 2.4).19 However, the ‘carrot’ aspects of the incentives were reduced in late
2010, leaving mainly ‘sticks’ (see below). It extends the ETS central feature of detailed carbon auditing to
cover all medium-large sized organisations which have not previously been involved. It also covers
electricity consumption – indeed the criterion for entry is organisations with an annual half-hourly metered
electricity use over 6,000MWh per year. (Universities already in the ETS carry on with that for fossil fuels,
and participate in CRC for electricity and any fossil fuels not covered in the ETS). Participants are required
to:


Calculate their total organisation-wide energy use-related carbon emissions for each year
and provide self-certified statements to the Environment Agency;
At the start of each compliance year, purchase allowances (from the Government) to cover
their anticipated total emissions; and
18
Sandbag, 2010. Cap or Trap. How the EU ETS risks locking in carbon emissions. September 2010. Available at
http://sandbag.org.uk/files/sandbag.org.uk/caportrap.pdf
19
Scheme details available at: http://www.decc.gov.uk/en/content/cms/what_we_do/lc_uk/crc/crc.aspx
18 

Surrender sufficient allowances to cover actual emissions at the end of each compliance year
(buying additional ones if required, or selling surplus ones if emissions have been reduced).
The original scheme envisaged that the scheme would be ‘revenue neutral’, and that the money used to
purchase allowances would be ring fenced, and returned to participating organisations at the end of the
accounting year according to a ‘league table’ based on a combination of actual carbon performance,
installation of metering, and conformance to the Carbon Trust Standard or equivalent (see section 3.5).
However, much was changed in late 2010 by the Government's Comprehensive Spending Review. The
Government will now keep the money paid for allowances.20 In effect, the scheme has been turned into a
carbon ‘tax’, with some extras.21 Following amendments in early 2011 these are the key features of the
scheme:22

Phase 1 of the CRC will run until 31 March 2014, and subsequent phases will each last for 6 years.
The first year of 1 April 2010 to 31 March 2011 was turned into a ‘practice run’ which just
required organisations to monitor their consumption. The first sale of allowances will take place in
2012 instead of the originally anticipated 2011. Participants will be able to purchase allowances to
cover their 2011/12 emissions at the end of the 2011/12 compliance year.

During Phase 1, initial allowances will be priced at a standard £12 per tonne of CO2. If a university
has a shortfall in allowances at the end of the reporting year it must buy sufficient allowances to
cover it. Two sources will be available: 1) buying allowances from other participants who have a
surplus, or 2) from the official scheme Administrator (a mechanism known as ‘the safety valve’).
The Administrator will cover the allowances sold under the CRC by purchasing equivalent
allowances from the EU Emission Trading Scheme (see above). It is likely that either route will cost
more than £12 per tonne (and possibly much more).

The performance league table is to be retained. While it will not be used to recycle revenue back
to participants, the government hopes that it will act as a reputational driver to lower energy use
and emissions. The first table will be compiled and published in October 2011 as originally
proposed.

The requirement to make organisations using less than 6,000MWh, but with a half hourly meter, to
make an annual information disclosure has been removed.
After Phase 1 it was intended that the Government will abandon the fixed price of £12 per tonne and set a
total number of allowances (which will reduce annually). Scheme participants would then bid for allowances
via an auction, with the assumption that would drive up prices considerably and so increase the incentives
for energy efficiency. However, the Committee on Climate Change recommended that the fixed price
allowances should be extended into Phase II and it may well be that this is adopted.23
20
Available at: http://www.hm-treasury.gov.uk/spend_sr2010_documents.htm
Heap, R., 2010 Spending Review: Warning over CRC “Stealth Tax”. Article, Property Week, 20 October 2010.
Available at: http://www.propertyweek.com/professional/spending-review-warning-over-crc-stealth-tax/5007600.article
22
DECC, 2011. Government response to consultation on amendments to the CRC Energy Efficiency Scheme Order
2010. February 2011. Available at:
http://www.decc.gov.uk/en/content/cms/consultations/crc_amendment/crc_amendment.aspx
23
Committee on Climate Change, 2010. The CRC Energy Efficiency Scheme – advice to Government on the 2nd
phase, September 2010. Available at: http://www.theccc.org.uk/reports/carbon-reduction-commitment
21
19 
Implications
Over 100 further and higher education institutions are expected to be full participants in the CRC. The
CSR changes have made the scheme more financially negative in the short term, and will probably cost the
sector over £10 million a year. However, the fact that it can no longer look forward to receiving this
money back will considerably increase the incentive for energy efficiency.24 It is also the case that the
scheme is only likely to survive in the long run if it is clearly effective in driving energy efficiency, which will
require much higher prices for allowances than the current £12 per tonne. (However, the experience of
the ETS shows that this is not inevitable). The league table is also likely to become an important method of
comparing the performance of institutions.
2.6
Renewable Energy/Low Carbon Requirements
There are currently a confusing number of targets, regulations and incentive schemes, and local authority
requirements, to increase the proportion of building energy supply from renewable or low carbon
(renewables + ultra efficient fossil fuel) sources. Some of these are ambitious national targets which will
start to impinge directly on universities and colleges via sector mechanisms such as funding body
requirements (see Section 2.7). These include:

The carbon targets set by the Climate Change Act (legally binding UK greenhouse gas emissions
reduction targets of at least 26% by 2020 and at least 80% by 2050, compared to 1990 levels);25 and

Renewable targets – the EU has a binding target of 20% of total energy consumption coming from
renewables by 2020, and is generating individual targets for members, with 15% proposed for the
UK. UK electricity generators are also required to source 15% of their supply from renewable
sources by 2015.
The 2008 Planning and Energy Act26 allows local councils in England and Wales to set reasonable
requirements in their development plan documents for a) the proportion of energy used in a development
from local renewable sources and/or local low carbon sources, and b) for energy-efficiency standards which
go beyond Building Regulation requirements. This provides statutory backing for the ‘Merton Rule’, the
planning policy developed by Merton Council, which requires 10% energy supply for large new
developments to come from renewables. This was subsequently adopted by many other councils and has
become part of national planning guidance. Some Councils have adopted even higher figures, e.g. 20% in
Oxford City.
The Funding Councils for England, Scotland and Wales have also introduced or are planning sector level
targets (see Section 2.7). A minimum level of zero/low carbon energy is also a mandatory requirement for
BREEAM Excellent (see section 3.9).
Section 4 describes the various actual or potential financial incentives for installing renewable energy
technologies/CHP.
Implications
Many different drivers are converging to require more development of renewable/low carbon energy
supply on higher education campuses.
24
Schoon, N., 2010. CRC bombshell: Bad government, good for the environment. ENDS blog, 27 October 2010.
Available at: http://blogs.endsreport.com/carbonandenergy/
25
Information available at: http://www.decc.gov.uk/en/content/cms/legislation/cc_act_08/cc_act_08.aspx
26
Campbell, L., 2008. Planning and Energy Act 2008 Receives Royal Assent, Simpson Millar solicitors website.
Available at: http://www.simpsonmillar.co.uk/news/news.aspx?newsid=318
20 
2.7
Funding Body Requirements and Guidance
HEFCE
In response to Government requirements that it respond to the requirements of the Climate Change Act
in early 2010 HEFCE published, in collaboration with Universities UK and Guild HE, a Carbon Reduction
Target and Strategy.27 This strategy comprises, amongst other things:

A sector-level target for scope 1 and 228 carbon reductions of 34% by 2020 and 80% by 2050
against a 1990 baseline, in line with UK targets; and

A requirement for institutions to set their own targets for 2020 for scope 1 and 2 emissions against
a 2005 baseline.
HEFCE also require annual monitoring and reporting on progress, through the Estate Management
Statistics (these are now administered by the Higher Education Statistics Agency). HEFCE will also assess
what is required to monitor and report scope 3 emissions, and this data will be collected after 2012.
HEFCE expect a baseline of emissions from procurement to be measured by December 2012 and this will
be followed by target(s) for scope 3 emissions by December 2013.
To provide funding incentives HEFCE will link capital funding to performance against carbon management
plans. This will be achieved by adapting the Capital Investment Framework (CIF), developed in 2007 to
assess the extent to which institutions had a strategic approach to infrastructure planning and investment.
The revised CIF is referred to as CIF2. The CIF2 process29, published in July 2010:

Expands the metrics to include carbon emissions30

Amends the strategic questions to include a more specific and demanding requirement in relation
to carbon

Requires institutions to report on progress in implementing the carbon plans, and on the results.
HEFCE have also published guidance on developing carbon management plans.31 They have indicated
potential ‘big’ and ‘quick’ wins as lighting and electrical appliances (including ICT); building energy and space
management; building fabric upgrade; efficient energy supply; renewable energy; and behavioural change and
new ways of working.
Scottish Funding Council (SFC)
The Climate Change (Scotland) Act 2009 introduces targets to reduce emissions by at least 80% by 2050
with an interim target of 42% by 2020.32 Sections 70 and 71 of the Act require the Scottish Government to
extend permitted development rights for micro-generation technology for domestic and non-domestic
27
Available at: http://www.hefce.ac.uk/lgm/sustain/carbon.
Where scope 1 emissions are direct emissions that occur from sources owned or controlled by the organisation;
scope 2 accounts for emissions from the generation of purchased electricity and scope 3 all other indirect emissions.
Source: the World Resource Institute. See HEFCE Carbon Reduction Target and Strategy footnote 3.
29
HEFCE, 2010. Arrangements for the Second Capital Investment Framework (CIF). Circular letter 17/2010. 5 July
2010. Available at: http://www.hefce.ac.uk/pubs/circlets/2010/cl17_10/
30
Carbon reduction metrics include tonnes of CO2 per £ of income and tonnes of CO2 per student and staff ull time
Equivalent (FTE). Environmental performance metrics include waste mass (tonnes) per student and staff FTE and
water consumption (m3) per student and staff FTE.
31
HEFCE, 2010. Carbon Management Strategies and plans: a guide to good practice’ (HEFCE 2010/02). January 2010.
Available at: http://www.hefce.ac.uk/pubs/hefce/2010/10_02/
32
The Scottish Government, 2010. Towards a Low Carbon Economy for Scotland: Discussion Paper. March 2010.
Available at: http://www.scotland.gov.uk/Publications/2010/03/22110408/0
28
21 
buildings. Section 72 of the Act requires local development plans to include policies on greenhouse gas
emissions for all new buildings in their areas. Such policies will be considered in the preparation of new
local development plans.
The Scottish Funding Council’s (SFC) issued revised guidance on reducing carbon emissions and other
environmental impacts. 33 It also requires a minimum of BREEAM ‘Excellent’ for new build, and ‘Very Good’
for refurbishment, for the Design and Procurement, and Post Construction, stages of all major capital
works projects (see Section 3.9). In addition, SFC has part funded, and supported, the Universities and
Colleges Climate Commitment for Scotland (see section 3.16).
HEFCW
HEFCW’s Corporate Strategy and Corporate Plan and Operational Plan 2007-08 to 2009-10 states: ‘The
delivery of HEFCW’s strategic aims will demonstrate our clear and positive support for the outcomes targeted in
Wales: A Better Country. We will ensure that its crosscutting themes of sustainable development, social justice,
equality of opportunity and bilingualism continue to be mainstreamed into all of our core activities and business
processes. ’
In HEFCW Circular ‘Education for Sustainable Development and Global Citizenship (ESDGC)34, it states:
‘All HEIs are encouraged (via good practice examples) to develop a suitable environmental management system
(EMS) and equivalent measures which cover all their operations in order to minimise their overall resource use to
sustainable levels….HEFCW will not prescribe a single system of accreditation or EMS, but requires that all systems
utilised by HEIs should obtain external certification to a recognised standard within a period of three years. We
anticipate that most institutions will seek certification to ISO 14001, EMAS, BS 8555, or Eco Campus. Where
institutions are proposing to use an alternative accreditation standard this should be clearly stated.’
As with the SFC, HEFCW now requires BREEAM Excellent for both the Design and Procurement and Post
Construction stages of new buildings funded by them.
Implications
The finding bodies’ different approaches may mean that English, Scottish and Welsh respond differently to
energy and carbon issues. The more specific BREEAM requirements of HEFCW and SFC, for example, may
over time result in better energy performance in new build than in England. However, HEFCE, UUK and
Guild HE have set the most challenging overall targets for the sector as well as a strategy for reaching
those. The requirement to monitor and develop strategies for carbon reduction will ensure that
institutions who do not already have detailed carbon management plans will develop them, and probably
that those who do not perform well will lose out in terms of capital funding. This will particularly hit the
research-intensive Russell Group Universities, and they will need to start addressing emissions from
laboratories and scientific computing. Universities will also have to start turning attention to their scope 3
(indirect) emissions which could prompt a sea-change in procurement and travel strategies, e.g. by
encouraging greater use of videoconferencing.
33
Scottish Funding Council, 2008. Sustainable Development Guidance for Estate Management. March 2008. Available at:
http://www.sfc.ac.uk/web/FILES/ReportsandPublications/Sustainable_Development_Guidance_March_2008.pdf
34
HEFCW Circular W08/07HE, February 2008. Available at:
http://www.hefcw.ac.uk/documents/publications/circulars/circulars_2008/W08%2007HE_circ.pdf
22 
Section 3 – Non-statutory/Optional Schemes on Energy and Carbon
3.1
EU Code of Conduct on Data Centre Energy Efficiency
What is it?
The EU Code of Conduct on Data Centre Energy Efficiency35 is a voluntary scheme developed by the
European Commission in consultation with a group of European stakeholders. Version 1 was released in
2008 and version 2 in 2010. The key aim is to inform data centre operators and encourage them to reduce
energy consumption without hampering the performance of such facilities. This is achieved through a series
of best practice recommendations which focus on design in areas such as software, IT architecture and
infrastructure.
The Code focuses on two areas:
1. IT Load – the power consumption of computing and related IT equipment; and
2. Facilities Load – the power consumption of the mechanical and electrical systems that support the
IT electrical load such as cooling systems (chiller plant, fans, pumps), air conditioning units,
Uninterruptible Power Supply (UPS), and Power Distribution Units (PDU).
However the Code of Conduct considers the data centre as a complete system, trying to optimise the IT
system and the infrastructure together to deliver the desired services in the most efficient manner.
In common with other industry bodies the Code of Conduct will initially use the ratio of IT Load to
Facilities Load as the key metric in assessing infrastructure efficiency. This is referred to in the Code as
‘facility efficiency’. It is a slight variant on the Green Grid’s Power Usage Effectiveness (PUE) metric, which
is the ratio of all load to IT load.36
The Code of Conduct will also be concerned with the efficiency with which the IT equipment utilises the
power delivered, which is referred to as ‘asset efficiency’. As efficiency metrics for data centres are further
developed and agreed, it is expected that the Code of Conduct will adopt more comprehensive metrics
which may also cover the IT system design, the IT hardware asset utilisation, and the IT hardware
efficiency.
There is also a 2010 Best Practices Companion Guide which identifies a range of best practice measures for
data centres, and assigns each with a score.37 There are 112 best practice measures in 7 different
categories38 (see Appendix 1 for the measures which score highest). The 2010 Best Practice Guide also
lists 6 practices that are to become the minimum expected in future updates of the Code (see Appendix 1,
Table 2).The EU also automatically adopts US Energy Star standards so that the Energy Star scheme for
servers (see next section) is applicable in the UK.
Some of the measures recommended by the Code of Conduct include:
35
Available at http://re.jrc.ec.europa.eu/energyefficiency/html/standby_initiative_data_centers.htm.
See www.thegreengrid.org and also SusteIT Briefing Paper No. 5 on PUE in Data Centres, available at
www.goodcampus.org.
37
2010 Best Practices for the EU Code of Conduct on Data Centre Available at
http://re.jrc.ec.europa.eu/energyefficiency/pdf/CoC%20DC%20new%20rep%20form%20and%20guidelines/Best%20Prac
tices%20v2.0.0%20-%20Release.pdf.
38
Data Centre Utilisation, Management and Planning; IT Equipment and Services; Cooling; Data Centre Power
Equipment; Other Data Centre Equipment; Data Centre Building; and Monitoring.
36
23 

Buy energy efficient IT devices

Use virtualised servers and storage

Switch off hardware for unused services

Virtualise little used services

Separate cold air from heated return air

Use free or economised cooling

Increase temperature set points.
The University of Hertfordshire was the first university in Europe to fully comply with the EU Code of
Conduct, in a refurbished data centre.39
Implications
The demand for greater data centre capacity in further and higher education is rising rapidly: the SusteIT
survey found that 63% of responding institutions were expecting to make additional investments in housing
servers within the next two years.40 This has considerable implications for future ICT costs, and makes data
centres one of the fastest growing components of an institution’s ‘carbon footprint’. It also creates a
potential constraint on future plans in areas where the electricity grid is near capacity, such as central
London. UK higher education has an estimated 215,000 servers, which will probably account for almost a
quarter of the sector’s estimated ICT-related carbon dioxide (CO2) emissions of 275,000 tonnes, and ICTrelated electricity bill of £61 million, in 2009.41 To meet carbon and energy targets universities, particularly
research-intensive ones, will therefore need to address their server energy demand.
The traditional approach to designing data centres has been to try and anticipate future needs, add a
generous margin to provide flexibility, and then build to this requirement. This has the major disadvantages
of incurring capital and operating costs well in advance of actual need, and higher than necessary energy
consumption because cooling and power supply is over-sized in the early years, and an inability to take
advantage of technical progress. The EU Code of Conduct therefore advocate more modular approaches,
so that new batches of servers and associated equipment can be installed on an ‘as needs’ basis. Overprovisioning can also be avoided by careful examination of actual power requirements, rather than
manufacturer’s claims.
The Code of Conduct is helpful both in highlighting specific improvement opportunities, and in fostering
effective collaboration between IT and Estates. This is crucial because many of the key decisions are around
physical layout of building, cooling and power supply, for which Estates are often ‘suppliers’ to IT
customers. The SusteIT case studies on Cardiff, Hertfordshire and St Andrews Universities show how this
can pay off through a very energy efficient data centre.42
39
University of Hertfordshire Case Study available at: http://www.goodcampus.org/susteit/susteit-cases/index.php
James P and Hopkinson L, 2009. Results of the 2008 SusteIT survey. Available at
http://www.susteit.org.uk/publications/index.php
41
James P and Hopkinson L, 2009. Sustainable ICT in Further and Higher Education. Available at www.susteit.org.uk
42
Berry D and James P, 2008. Saving power and space in the data centre at Cardiff University. Available at
http://www.susteit.org.uk/cases/long-case-studies.php. Hertfordshire and St Andrews cases available at:
http://www.goodcampus.org/susteit/susteit-cases/index.php
40
24 
3.2
British Computer Society CEEDA Scheme
What is it?
The British Computer Society (BCS) have developed a Certified Energy Efficiency Data Centre Award
(CEEDA). This is designed to provide verifiable evidence that an organisation is not only claiming it follows
(or plans to implement) best practice but that it has actually implemented them.43 The evidence provided is
checked by an independent CEEDA certified assessor. The assessment will measure the performance of
the data centre against the following key areas which are based on the EU Code of Conduct, and defined in
detail within the CEEDA programme:

Data Centre Utilisation

IT Equipment and Services

Cooling

Data Centre Power Equipment

Data Centre Building

Monitoring.
Based on the result of the assessment and the audit, BCS determines whether the data centre will receive
an award and, if appropriate, the level of the award: bronze, silver or gold. For example a gold award
requires, among many other things, a PUE of less than 1.5 for the 12 months prior to certification.
Implications
Although in its early days, the BCS scheme could be very useful to UK universities because it takes national
circumstances into account, and provides a tangible Award for action.
3.3
Government Buying Standards and other Procurement Initiatives
What is it?
There are several inter-linked schemes of relevance to IT in higher education:

Government Buying Standards44;

The Energy End Use and Services Directive45; and

The EcoDesign Directive.46
The Government’s Buying Standards (formerly known as 'Buy Sustainable – Quick Wins' standards) are a
set of purchasing specifications that encourage the procurement of more sustainable goods and services,
they are developed to show that through good sustainable procurement you can cut costs and reduce
carbon whilst looking after the environment. They have been developed by a Cross-Government
Stakeholder Group under the auspices of Defra. Specifications are available for a range of commonlypurchased products, including IT equipment. There are 3 levels:
43
More information available at: http://www.ceeda-award.org/?src=bcsceeda
Information available at: http://www.defra.gov.uk/sustainable/government/advice/public/buying/index.htm
45
http://ec.europa.eu/energy/efficiency/end-use_en.htm
46
Information available at: http://ec.europa.eu/enterprise/policies/sustainable-business/ecodesign/index_en.htm
44
25 

Mandatory – a set of criteria that are mandatory for central government, e.g. Energy Star or
equivalent performance requirements, and spare parts are available for 5 years;

Best Practice – these set the bar higher for existing criteria or add further criteria that need to be
fulfilled, e.g. maximum sound levels; and

Class leader – signals the direction of travel for suppliers and buyers and encourages innovation. eg.
the requirement for workstation that all cover/housing plastic parts over 25g weight are halogen
free.
See SusteIT Briefing Paper No. 4: Green ICT Product Labelling Schemes for more information.47
The standards will be updated every few years to ensure that they are keeping up with market
developments. For example, all the office machinery product standards underwent extensive review in
2009. The specifications for office IT equipment will be changed during 2011.
The EU Energy End Use and Services Directive requires the implementation of cost-effective sustainable
procurement and energy efficiency measures. It places particular emphasis on the public sector which is
expected to play an ‘exemplary role’ and undertake at least two of 6 measures listed in Annex VI. The UK
government has to report to the European Commission on the following measures48:

promoting the purchase of equipment and vehicles based on lists of energy-efficient product
specifications of different categories of equipment and vehicles to be drawn up by Defra, using,
where applicable, minimised life-cycle cost analysis or comparable methods to ensure costeffectiveness;

promoting the purchase of equipment that has efficient energy consumption in all modes, including
in standby mode, using, where applicable, minimised life-cycle cost analysis or comparable methods
to ensure cost-effectiveness; and

promoting energy efficiency and energy savings as a possible assessment criterion in competitive
tendering, including supporting guidance.
For central government this voluntary agreement is set within the framework of Government Buying
Standards, that all Government Departments are mandated to use.
While HEFCE cannot mandate universities to comply with the measures, they have agreed they will make
all efforts to make the sector aware of the measures and monitor them.49 Promotion is being done
through sector bodies such as the Sustainable Procurement Centre of Excellence (SPCE) and the
Association of University Procurement Officers (AUPO) and letters to university procurement heads, while
monitoring is being done though the voluntary Efficiency Measurement Model (EMM) reporting system
which reports on Value for Money targets.50 This year the EMM annual return will include data on
efficiencies delivered based on the Energy Services Directive (i.e. energy savings as a result of procuring
Energy Service Directive-compliant products).
47
Available at www.goodcampus.org under publications.
http://www.decc.gov.uk/en/content/cms/what_we_do/consumers/saving_energy/esdirective/esdirective.aspx
49
Btucher, S, HEFCE, Personal Communication, Dec 2010
50
Carpenter, R., 2010. Efficiency Measurement Model Annual Report for 2009-10. In Procurement Matters, Issue 7,
December 2010, available at: http://www.procureweb.ac.uk/about-the-sector/procurement-matters-news
48
26 
Any actions will be complemented by the EU Ecodesign Directive. This allows the European Commission
to set performance requirements for the manufacture and use of many kinds of product that are sold
within the EU market. The Directive also requires Member States to put in place a Market Surveillance
Authority (MSA), which has powers to carry out checks on products, request relevant information from
manufacturers and request the withdrawal from the market of non compliant products. To date, Member
States have approved Regulations for ten product groups.51 These measures are coming into force
throughout 2011. They will eventually cover many more (30+). Once introduced, Government Buying
Standards are likely to be changed to reflect them.
Implications
Buying Standards provide useful criteria for purchasing a range of equipment and should be a central part of
institutional procurement policies. They can provide an easy win for institutions to make significant
reductions in carbon at little or no extra cost, through specifying more energy efficient products, especially
when these will be switched on for much of the time. In England HEFCE is also working with AUPO’s
Sustainable Procurement Group and the sector’s Sustainable Procurement Centre of Excellence (SPCE) to
promote the Energy Services Directive requirements and encourage monitoring of efficiency savings as a
result of procuring more energy efficient equipment.
3.4
Energy Star
What is it?
Energy Star is a voluntary eco-labelling scheme for office products which is based on a minimum
performance of energy in use. It was originally developed by the US Environmental Protection Agency (USEPA) and applies to a variety of products in the USA, including data centres. However, its application to
office products is now a joint activity with the European Commission.52 This means that specification of
Energy Star compliance in tenders is compatible with EU procurement rules, provided the text states ‘not
less than Energy Star or equivalent’.53
The Energy Star database lists the most energy efficient models, within the group of Energy Star qualified
office equipment. It has specifications for desktop computers, notebook computers, integrated desktop
computer, thin clients, small-scale servers (i.e. non data-centre), workstations, game consoles and
monitors. A list of compliant models can be obtained from the website.
The latest version of Energy Star (Version 5) for computing equipment came into effect in July 2009, and
for displays in October 2009.54 Energy Star 5 raised the bar for energy performance significantly – based
on the top 25% performing products on the market. Performance of computing equipment is based on a
Typical Energy Consumption (TEC), which is the typical electricity consumed over a year assuming nominal
time in idle, sleep and off modes. The principles are similar for other office products.
51
Standby and off mode power Consumption, Simple Set Top Boxes, External Power Supplies, General and Tertiary
Lighting, Motors, Televisions, Circulators and Refrigerators.
52
http://www.eu-energystar.org/en/index.htm
53
Defra legal advice, Personal Communication I. Barham, October 2010. When putting the Government Buying
Standards relating to Energy Star in contracts in the wider public sector, the text needs to say “not less than Energy
Star or equivalent.” Under Article 6, central government buyers should insist that products meet Energy Star or
equivalent. The wording in the relevant directive states “energy-efficiency requirements not less demanding than the
Common Specifications” which, by implication, means any requirements (ie equivalent) that are not less demanding
than Energy Star.
54
http://www.eu-energystar.org/en/index.html
27 
Typical Energy Consumption
Energy Star 5 introduced a new method of testing and comparing the energy performance of computers,
based on the Typical Energy Consumption (TEC) of a product while in normal operation during a year.
TEC is based on the following formulae for desktops and notebooks (ETEC) and workstations (PTEC):
ETEC = (8760/1000) * (Poff * Toff + Psleep * Tsleep + Pidle * Tidle)
PTEC = 0.35*Poff + 0.10*Psleep +0.55*Pidle
where Px are power values in Watts, all Tx are time values in % of year for different operational modes
(off, sleep and idle), and ETEC is annual energy consumption in kWh. The time spent in different
operational modes is specified by Energy Star.
The maximum TEC requirement for desktops, depending on performance, ranges from 148 – 234
kWh/y.
80-Plus
80 PLUS qualified power supplies are an integral part of the latest ENERGY STAR label specification for
computers. The 80 PLUS performance specification was developed in 2004 requires multi-output power
supplies in computers and servers to be 80% or greater energy efficient at 20%, 50% and 100% of rated
load with a true power factor of 0.9 or greater. In addition to producing less heat, this also means they
waste less electricity.
There are 5 levels of 80 Plus Certification - 80 PLUS as well as Bronze, Silver, Gold, and Platinum criteria
levels for energy efficiency and power factor. For example an 80 Plus Gold is 88% efficient at 20% or
100% load and 92% efficient at 50% load for a 230V supply. In June 2010 out of 2278 80-Plus certified
desktop/workstation power supplies, about 9% received Gold. Platinum is reserved for redundant data
centre power supplies.
More information: http://www.plugloadsolutions.com/80PlusPowerSupplies.aspx and
http://solidlystated.com/hardware/should-i-buy-80-plus-power/
There is also an Energy Star (Version 1) for Computer Servers which was under revision at the time of
writing.55 The current Energy Star specification for Enterprise Servers (Version 1, released May 2009)
measures energy use only under limited circumstances and for specific types of machines. It primarily
measures whether a server's power supply has good efficiency across a range of workloads (e.g. a server in
idle mode can’t exceed a certain energy consumption for its classification). The new Version 2 will set a
benchmark for energy performance across the entire server load i.e. what type of workload you can do for
each unit of energy consumed. It will use the SPEC (a non-profit standards body) Server Efficiency Rating
Tool (SERT) to evaluate active mode efficiency. This will provide an estimate of energy efficiency across a
broad range of applications. The new version will also include blade servers.
US-EPA is also developing a new product specification for data centre storage (Version 1 released April
2010).56 There is also an Energy Star rating for Data Centres.
55
56
http://www.energystar.gov/index.cfm?c=revisions.computer_servers
http://www.energystar.gov/index.cfm?c=new_specs.enterprise_storage
28 
Implications
Because of the wide availability of this eco-label, specifying energy-star compliant ICT equipment is the
simplest and easiest way of ensuring good energy performance in use and reducing carbon emissions from
ICT. The difference in energy consumption between two computers of otherwise similar computing
specification could be 100 -200 kWh/y which translates into energy costs of £60-£120 over a 5-year
lifetime. Certainly before any procurement decisions are taken the whole life costs of any ICT equipment
should be compared.
However, covert testing by the US Government Accountability Office (GAO) found that because Energy
Star is a self-certification programme and does not verify energy-savings data reported by manufacturers it
is vulnerable to fraud and abuse. 57 The US EPA have proposed an enhanced testing and verification
programme but the EC Energy Star Board consider this is disproportionate to the risks in the office
equipment category and could increase costs for Small and Medium Enterprises (SME).58 It appears that
changes to verification will be made for Version 6.59 The EU side considers that spot checks on compliance
of qualified products should minimise costs to manufacturers and public authorities and suffice to protect
the credibility of the label.
Because it is an EU scheme, Energy Star rated devices are readily available in the UK. For example in April
2011 there were over 2,000 desktops and over 3,000 notebook models listed in the EU database
conforming to the existing version 5.0 specifications for computing equipment. Note that Government
Buying Standards and most eco-labels for computing equipment require conformity with the latest Energy
Star standards.
3.5
EPEAT
What is it?
The Electronic Product Environmental Assessment Tool (EPEAT) is a US-developed eco-label which is
managed by a non-profit organization, the Green Electronics Council (2008).60 The system currently covers
desktop and laptop computers, thin clients, workstations and computer monitors. Desktops, laptops and
monitors that meet 23 required environmental performance criteria may be registered in EPEAT by their
manufacturers in 41 countries worldwide, including all EU countries. Registered products are rated Gold,
Silver or Bronze depending on the percentage of 28 optional criteria they meet above the baseline criteria.
The environmental criteria cover environmental design, manufacture, end-of-life management and
corporate performance. EPEAT operates an ongoing verification program to assure the credibility of the
registry.
As with Energy Star the criteria are periodically refreshed to drive continuous improvement. The EPEAT
standard is formalized as Standard 1680 of the Institute of Electrical and Electronic Engineers (IEEE), which
addresses the overarching structure of the system (e.g. ratings based on combination of required and
optional criteria) and operations of the product registry, and Standard 1680.1 which contains the specific
criteria applied to computer and display products. The 1680 standard serves as an ‘umbrella’ standard for
all products, with additional IEEE 1680 standard for each specific product type or grouping (1680.1:
57
GAO 2010. Covert Testing Shows the Energy Star Program Certification Process Is Vulnerable to Fraud and Abuse.
GAO report 10-470. Report to US Senate, March 2010. Available at: http://www.gao.gov/highlights/d10470high.pdf
58
See minutes of June 2010 meeting, Available at: http://www.eu-energystar.org/de/250.shtml
59
Viegand J., 2010Technical Specifications. Presentation to EC Energy Star Board, Available at http://www.euenergystar.org/de/250.shtml
60
http://www.epeat.net/
29 
Computers and Displays; 1680.2: Imaging Equipment; 1680.3: Televisions etc). Every EPEAT registered
product must meet the current version of the applicable Energy Star standard.
As EPEAT was a requirement of US Government contracts it quickly became a market standard. In
December 2010 there were 141 desktops and 1275 notebooks registered in the US in the EPEAT scheme,
from 30 manufacturers. Of these, 85 desktops, and 605 notebooks, were gold rated, reaching the highest
standard.
IEEE/EPEAT standards for imaging equipment and televisions are currently under development, with UK
government staff involved as stakeholder participants. The standard should be final by mid 2011.61
Standards development is also planned for servers and mobile devices in upcoming years.
It is important to note that even though the majority of EPEAT criteria are inherent in a given product, and
thus apply regardless of geography, EPEAT registration, and product verification and surveillance, is by
country. This is particularly important because some EPEAT criteria (required and optional) address service
and support attributes – e.g. extended warranty, availability of spare parts, packaging criteria. To ensure full
support of the product declaration (and thus its rating tier) UK purchasers must specify products
registered in the UK. As of December 2010, there are over 500 products ( 80 desktops, ~250 notebooks,
~95 monitors) registered for the UK by 7 companies. Although EPEAT-compliant products are available in
the UK, there are questions over whether clauses in the EU Public Procurement Law may cause problems
for public sector organisations wishing to specify it, in that they strictly limit the use of company
performance standards in product specifications. However, the Environment Agency and other European
governments use an EPEAT specification and provided EPEAT-equivalency is allowed this should not be a
problem.62
Implications
As with Energy Star there are potential savings to be made by specifying EPEAT-compliant computers. The
UK offices of the Lehman Brothers financial services firm specified a minimum EPEAT silver rating for its
computer purchases of 7,764 desktops and 14,532 monitors in 2007, and estimated that this would save
over 11,000 MWh of energy and £1.14 million in costs – and also that, if all purchases were of EPEAT gold
products, this would increase to over 13,000 MWh of energy and over £1.3 million in costs.63 (Whole life
cost savings and environmental benefits can be estimated through a lifecycle environmental benefits
calculator).
3.6
ECMA Eco-Declaration
What is it?
The European Computer Manufacturers Association (ECMA) – which includes many suppliers from Asia
and North America who manufacture in Europe – has developed ECMA-370.64 This is intended to be a
global eco-labelling scheme, but is focusing on EU implementation in the first instance. The scheme specifies
environmental attributes and measurement methods for ICT and CE products according to known
regulations, standards, guidelines and currently accepted practices. It can be applied to finished products, or
subassemblies, components, accessories and/or optional parts. It addresses company programs and product
61
Personal Communication S. O’ Brien, EPEAT, May 2010.
ibid.
63
O’Brien, S., 2008. Green Electronics Purchasing. Presentation on behalf of Green Electronics Council at NYS Forum
event Green IT: IT’s easy being GREEN, 10 April 2008, Albany, New York. Available at:
http://www.nysforum.org/documents/ppt/2008/itgreening/EPEATOBrien.ppt.
64
http://www.ecma-international.org/publications/standards/Ecma-370.htm
62
30 
related attributes, not the manufacturing processes and logistic aspects. Supplier compliance is monitored
by a mandatory third party verification. The fourth edition of ECMA was released in June 2009.65
Unlike EPEAT and Energy Star there is no searchable database of published TED declarations. DEFRA uses
ECMA-370 (TED) for their market assessment when they design ‘green’ public purchase criteria.66
Implications
Although a preferred standard for some European vendors, ECMA does not have high visibility in UK
universities and colleges and this seems unlikely to change in future, given the availability of the other labels
discussed in this paper.
3.7
TCO-Certified
What is it?
TCO-certified is an international, third party, voluntary certification of information and communication
technologies (ICT products) that fulfill strict requirements on the environment and usability.67 This scheme
is managed by the Swedish TCO Development company. It now operates globally, and aspires to be the
most demanding labelling scheme, not only for green features but also in areas such as high performance
and ergonomic design. TCO Certified covers six ICT product groups – displays, desktops, notebooks, all in
one PCs, projectors and headsets – and requires third party verification of applications. There is also a
more demanding TCO Certified Edge specification, which requires the product to meet the TCO Certified
criteria as well as an additional criterion. Displays must be halogen free or contain a minimum of 65% post
consumer recycled plastic (PCRP), all in one PCs must contain a minimum of 50% PCRP, and notebooks
must have high brightness for daylight readability.
Implications
Because of the strict verification process, TCO-certified is supported by sector procurement specialists
(see SusteIT Briefing Paper 4) although it is not a requirement in any national or regional sector purchasing
agreements.
3.8
Other Eco-Labels
What are they?
In addition to the IT-specific Energy Star, EPEAT and ECMA eco-labels, there are a number of other
general eco-labels which are listed below.
Blue Angel - a German voluntary eco-label scheme for a range of products.68
Nordic Swan - the official ecolabel of the Nordic countries.69
EU Flower – a voluntary EU scheme based on life cycle analysis for a wide range of products including
some ICT.70
65
http://www.ecma-international.org/publications/files/ECMA-ST/ECMA-370.pdf
66
Hans Wendschlag, EMEA Environmental Program Manager, PErs comm. 12.8.10)
67
Available at: http://www.ecolabelindex.com/ecolabel/tco-development
68
http://www.blauer-engel.de/en/blauer_engel/index.php
69
http://www.nordic-ecolabel.org/About.aspx
70
http://ec.europa.eu/environment/ecolabel/
31 
Energy Saving Trust Energy Recommended Products - a list of products that meet strict energy
efficiency criteria. The standards are updated annually by an independent panel, and a percentage of
products are tested by EST.71
Implications
Some of these are more relevant to IT than others, and have varying degrees of quality control and
verification. Note that all of them require the latest Energy Star specification as a minimum energy
standard.
3.9
BREEAM
What is it?
BREEAM (Building Research Establishment Environmental Assessment Method) is used to assess the design
and specifications of buildings.72 (BREEAM Communities is also being developed to assess multi-building
sites). It has a number of criteria which are grouped into eight headings – management; energy; health and
well being; pollution; transport; land use; ecology; and materials. The design is assessed against the criteria,
and scored as Pass, Good, Very Good, Excellent or Outstanding (an exceptional category, intended for
only a few buildings a year). The 2008 revision of BREEAM has raised the bar considerably, with several HE
buildings which were rated ‘Excellent’ in the previous version only achieving ‘Good’ in the new one. It also
introduced a Post Construction Review to better ensure that the design is actually implemented in
practice. Another new scheme, BREEAM in Use, is available to assess the operation of buildings. BREEAM is
also becoming more international, with a number of national versions being developed.
To be certified, the scoring has to be undertaken by BRE-trained and licensed Assessors. Previously most
new or refurbished HE buildings have required a ‘bespoke’ assessment template, but almost all can now be
assessed under BREEAM standard templates. Most will fall under the new BREEAM (Higher) Education
scheme but some can be assessed under specialised schemes for Data Centres, Residences or Sports
Centres. (In BREEAM (Higher) Education most credits are common to all buildings, but some specialist
ones are only available for certain building types, such as laboratories). This will lower costs, provide
known criteria from the start of the design process, and enable greater comparison of schemes.
The main advantages for an institution adopting BREEAM are that it provides clear and recognised
guidelines for the design team to work to, and is now reasonably stretching, especially if Excellent is
required. It also enables clients to make a statement about their commitment to sustainability (although
this is only impressive if they aspire to Excellent for new buildings, and Very Good for refurbishments). If
the design is independently certified, there can be further reputational benefits from good performance,
and from the additional driver for improvement created by designers’ awareness that their plans will be
scrutinised more thoroughly.
Criticisms of BREEAM include its points-based nature (which can allow positive performance in some areas
to offset poor performance in others); its limited emphasis on carbon issues (which BRE says misses the
point that it is a holistic scheme covering all environmental impacts); poor value for money; criteria which
are not entirely relevant, or are difficult to apply, to HE buildings; a lack of integration to the design process
(a factor in many buildings only achieving Very Good when Excellent was the target); and a limited
emphasis on performance in use. Many of the points have been addressed in the 2008 BREEAM generic
revision and/or the specifics of the new BREEAM HE scheme.
71
72
http://www.energysavingtrust.org.uk/Energy-Saving-Trust-Recommended-products
http://www.breeam.org/page.jsp?id=158
32 
A number of organisations attach BREEAM conditions to public funding. For example the Scottish Funding
Council and HEFCW both require BREEAM ‘Excellent’ ratings on new builds and ‘very good’ is commonly
required for refurbishments.
The Scottish Government ‘s proposed new labelling system (See Section 2.1) will give recognition to
achieving compliance with the 2010 building standards as a base level of sustainability, as well as developing
awards that recognise higher sustainability standards. If this system is implemented, which is likely, it may
make BREEAM in Scotland somewhat redundant.
In England HEFCE is not currently requiring specific levels of performance for capital projects but BREEAM
policies and actions will influence the environmental assessment within the 2010 Capital Investment
Framework (see Section 2.7).
A new version of all BREEAM schemes is likely to be introduced in 2011, and should raise the performance
bar even higher than at present.
Implications
BREEAM’s credibility and impact has been significantly improved by the 2008 revision, and by its
internationalisation. Many public and private organisations are specifying its use, including HEFCW and SFC
who now require BREEAM Excellent for both the Design and Procurement, and Post Construction stages
of new buildings funded by them, and Very Good for major refurbishments. BREEAM HE now provides a
framework for more sharing of experience about, and benchmarking of, key sustainability features of
buildings in the sector. BREEAM for Data Centres is also of great relevance to new or refurbished buildings
containing them.
3.10 Universities that Count
What is it?
Universities that Count (UTC)73 assesses the state of an institution’s environment and social responsibility
(CR), based on the Corporate Responsibility Index developed by Business in the Community (BiTC). It
allows universities and colleges to benchmark themselves against other institutions and businesses. The
scheme has been developed by The Environmental Association for Universities and Colleges (EAUC),
following a national pilot exercise involving 25 sector institutions in collaboration with the Higher
Education Funding Council for England, , and Leeds Metropolitan University. Most of the index questions
are the same as in the main CR Index, but considerable work has gone into a new set of questions on
Teaching, Learning, Research, and Knowledge Exchange, designed by sector academics. Guidance notes for
the sector have also been developed. Universities commit to changing their current practices, with support
from UCT, then submit their results via a detailed index so that overall sector performance can be
recorded year on year.
There are two benchmarking options for universities:
(1) The Environmental and Social Responsibility (ESR) Index which starts with University Strategy, and
then looks at how strategy is embedded into behaviour and practice – and then how each of the
‘four pillars’ of ESR are managed – Environment, Community, Workplace and Marketplace
(students and suppliers). It also consider impacts on social and environmental performance,
including Teaching, Learning, Research and Knowledge Exchange. Finally, the survey examines
Assurance processes and Disclosure; the degree of sharing that universities engage in.
73
Information available at: http://www.eauc.org.uk/utc
33 
(2) The Environmental Index is shorter and focuses on environmental sustainability.
The use of a common set of Index questions between business and higher education (HE) respondents
enables cross-sector benchmarking and best practice comparison.
In 2009/10 54 institutions took part, of which 60% were Russell Group universities. The 2009/10 annual
report74 grades participants as gold, silver, bronze or participants, in line with BiTC’s Companies that
Count scheme. Three participants achieved the gold standard – University of Bradford, Nottingham Trent
University and HEFCE.
The scheme will next be run in 2011/12, i.e. it is skipping a year. This is both to give participants time to
reflect on how their performance can be improved, and to iron out teething problems in the way the
scheme works.
Implications
Providing the information required is time consuming, and requires inputs from many different areas of the
organisation. This can be a burden but can also make the scheme very effective in reaching the areas that
other schemes cannot. Its high public visibility could also make it a powerful driver in institutions
concerned about their public reputation in this field, especially if the revamp deals with some of the
criticism that have been made by users.
3.11 Green League
What is it?
An annual ranking of all UK universities according to environmental performance by student environmental
organisation People & Planet. The Green League75 considers both a commitment to systemic environmental
management and performance indicators, and in 2010 had 11 assessment areas, with a total of 70 possible
points (see Table 3). The information is collected from a combination of a People & Planet questionnaire,
the Estate Management Statistics, the Fairtrade Foundation, Soil Association/Sustain and the Sound Impact
Environmental Award Scheme.
The Carbon Management criteria covers Scope 3 emissions (specifically procurement, staff and student
business trips, commuting and travel by students at the start and end of term) even though these are
currently excluded from the sector wide targets at national level. This is because an estimated 50% of a
university’s footprint comes from the emissions embedded within the goods and services procured. Since
2010 the Green League awards points for sustainable food procurement in the Sustainable Procurement
section and this will widen to include other areas of procurement. Another change is the strengthening of
the criteria on student engagement to cover staff and this will be expanded to include the integration of
sustainability into the curriculum from 2011 onwards.
Organisations are awarded grades: first, 2.1, 2.2, third or ‘did not sit exam’ according to their scores.
Grade boundaries are set after the scores are collated. In 2010, 25 universities achieved a ‘first’ with
University of Plymouth ranked top.
There has been criticism of the Green League methodology, especially by estates and environmental
professionals. People and Planet say that these criticisms are being taken on board with adjustments to the
criteria each year.
74
75
Available at: http://www.eauc.org.uk/file_uploads/2009-10_utc_full_annual_report-complete-final_(big)_1.pdf
Information available at: http://peopleandplanet.org/greenleague
34 
Table 3: 2010 Green League Criteria and Scoring
Management and Policy
Publicly Available Environmental
Policy
Environment Management Staff
Environmental Auditing &
Management Systems
Ethical investment policy
Carbon management
Sustainable Procurement and
Fairtrade
Staff and student engagement
Sub-total
Score
6
Performance
Energy Sources
Score
6
8
8
Waste
Carbon emissions per head
8
8
4
8
3
Water consumption
8
Sub-total
30
0-3
40
Implications
The scheme attracts widespread media publicity and has been very successful in attracting the attention of
vice-chancellors (especially in the top and bottom ranked institutions). Hence, it has provided an extra
stimulus to action for poorly performing universities (or additional recognition for well performing
universities). However, the lack of consensus about its validity does make it less effective than it otherwise
might be.
3.12 Carbon Trust Programmes
What is it?
The Carbon Trust has three main programmes of relevance to higher education:

The HE Carbon Management Programme76;

The Carbon Trust Standard77; and

The HEFCE/Salix Finance Revolving Green Fund (see section 4.2).
The HE Carbon Management Programme is aimed at providing a framework, and practical support, for
institutions to assess and reduce their carbon emissions. It is administered by the Carbon Trust, with
support provided by sub-contracted consultants. At the time of writing it had been, or was being, run at
over 100 HE bodies.
The programme takes the form of a year long, five step, process - mobilising the organisation; setting
baseline, forecasts and targets; identifying and quantifying options; developing a fully-costed strategy and
implementation plan; and implementing the plan. Participants receive support from expert consultants in
areas such as provision of analysis software and tools, training and workshops for staff and senior
management, and identifying carbon saving projects. An average minimum university input of 2 days per
week for a year is also required.
Organisations going through the programme will have met many of the requirements of the Carbon
Standard (see below) and the carbon plan requirements for CIF2 (see section 2.7).
76
77
Information available at: http://www.carbontrust.co.uk/carbon/PublicSector/he/
Information available at: http://www.carbontruststandard.co.uk/
35 
The Carbon Trust Standard requires organisations to meet the following criteria:
1. Footprint measurement: an organisation must measure its footprint accurately and include all
required emission sources;
2. Reduction: an organisation must achieve an absolute reduction in its footprint, or an equivalent
relative efficiency improvement; and
3. Carbon management: appropriate carbon governance, accounting, reduction methods and targets
of an organisation.
Organisations can certify themselves, or have Carbon Trust assistance, paying a fee which is linked to the
annual energy bill (£8000 in the case of one large university). Regular recertification is required.
As of April 2011 39 universities, and HEFCE, had achieved the Standard. A major driver for this was the
fact that the Standard was meant to be an element in calculating the performance ‘league table’ of the CRC
Energy Efficiency Scheme (see Section 2.5), which in turn would influence the financial impacts on
participants. However, the changes and uncertainty in the CRC now seem to have made it much less
central to it.
Implications
The Carbon Management Programme has helped many institutions. However, there has also been criticism
that it leaves people at the point where they most need help, i.e. implementation of their plans. The
Carbon Standard is aimed at helping with this, and other support may be put in place in future – the Trust
are currently piloting implementation support offerings. However, some have doubts about how much the
Standard improves performance in universities and colleges which already have a strong commitment. The
changes in the CRC may also reduce the level of interest in achieving it.
3.13 ISO14001 and Related Standards
What is it?
ISO 14001 is the International Standards Organisation's standard for Environmental Management Systems
(EMS).78 It is built on the ISO 9001 standard for Quality Management Standards, and also has a number of
supporting ones such as ISO 14031, on Environmental Performance Measurement. The Standard is based
on four stages, plan, do, check and act:

Plan involves the identification of key customers and stakeholders, identifying opportunities for
improvement and the development of programmes to achieve them;

Do is the implementation of these programmes, through standardised procedures and other means;

Check is the monitoring and reviewing of progress, wherever possible against quantitative targets;
and

Act involves changing, if necessary, existing programmes and using the learning from them to begin
the cycle again with new plans.
Organisations can use the standard as a guide, or they can achieve formal certification by undergoing a
compliance audit from an accredited external assessor. The certification lasts for 3 years. An annual
surveillance audit (which can be done internally) is also required.
78
Information available at: http://www.iso14000-iso14001-environmental-management.com/
36 
In addition to direct environmental benefits, an ISO-compliant EMS can help universities and colleges to
• Have assurance that all environment-related risks are understood and managed;
• Achieve better internal communication, and integration of actions; and
• Create cost savings and other financial benefits.
The University of Glamorgan was the first UK university to achieve an ISO 14001 accredited EMS for all its
activities. A few others have followed. Some have also achieved ISO 14001 registration for part of their
activities, such as Leeds Metropolitan University who have concentrated on the areas of biggest
environmental impact (estates and financial services), or individual units, such as the National
Oceanography Centre at the University of Southampton. Cranfield University’s School of Applied Sciences
have gained an ISO 14001 accreditation for their Microsystems and Nanotechnology Cleanroom and
Precision Engineering Laboratory activities.
Implications
An EMS can help risk management, by ensuring that systematic efforts are made to identify environmental
effects and related risks, devise actions to mitigate them, and assign responsibility for their implementation.
The same benefits can also arise in areas such as energy consumption and carbon emissions, although other
initiatives such as the CRC (section 2.5) mean that these areas will be a focus in any event. Opinion tends
to be split on the value of a full EMS in higher education (as opposed to limited systems covering specific
topics). Some - including HEFCW, which is making them mandatory for Welsh universities and colleges
(see Section 2.7) - see them as a real, cost-effective, driver of awareness and action, but others regard
them as bureaucratic ‘tick box’ exercises and/or as ill-fitted to the complexities of university campuses.
3.14 EcoCampus
What is it?
EcoCampus provides a support package to enable institutions to implement a robust and effective
Environmental Management System (EMS).79 The scheme aims to develop participant’s skills, knowledge,
competence and expertise in implementing and operating an EMS through the provision of a variety of
tools and guidance including software applications, training workshops, advice and external audit.
Ecocampus conforms with the requirements of the international standard for EMS, ISO 14001, and
therefore offers a staged approach to achieving it if that is a desired outcome. As with all EMS, it is meant
to cover all aspects of environmental impact ranging from carbon emissions to biodiversity protection and
covering all aspects of an institution’s activities including transport to and from the campus, and supply
chain management. It was initially developed at Nottingham Trent University and therefore ‘fits’ further and
higher education.
EcoCampus has four stages:
79

Bronze (achieved by Planning actions such as an environmental review and developing a policy)

Silver (achieved by initial Implementation actions such as establishing objectives, targets and
programmes)

Gold (achieved by Operating actions such as training and preparation of documentation) and
Information available at: http://www.ecocampus.co.uk/
37 

Platinum (achieved by Checking and Correcting previous actions through auditing and other
means).
Progress through the stages is achieved by independent audit against the EcoCampus achievement criteria.
Audit is undertaken in partnership with UKAS accredited EMS certification body NQA. Details on this are
recorded on the EcoCampus register.
As of April 2011 46 Further and Higher Education Institutions had enrolled for eco-campus with 29
achieving gold, silver or bronze awards, and four achieving platinum.
Implications
As a purpose-designed scheme for the sector, EcoCampus is obviously very relevant to higher education. It
provides a flexible approach and enables institutions to gain recognition for their performance
improvements as they move towards a full EMS cycle, and the full rigour of an ISO14001 compliant scheme.
However, it has the same disadvantages as an ISO-based approach (see above), whilst some institutions
which want an EMS may feel that a full blooded commitment to relatively rapid implementation is the best
means of achieving it.
3.15 Green Impact Universities
What is it?
Green Impact Universities is an NUS (National Union of Students) environmental accreditation scheme
with an awards element designed for university and college departments. It is based on a similar initiative
developed for student unions (the Green Impact Awards) and was piloted at the University of Bristol. The
current scheme is project managed by the EAUC and delivered locally by participating universities and
Student’s Unions. It has run at 22 universities in 2009/10 and 37 in 2010/11.
University staff take part each academic year and, depending on the number of environmental actions, they
carry out, can achieve either: a working towards accreditation or Bronze, Silver or Gold awards for making
their workplaces greener. A bespoke workbook, containing a list of practical actions (which form the
bronze, silver and bonus criteria), is developed for each institution. These actions address a particular
institution’s bad habits and are worded so that they complement wider institutional environmental policy
and procurement processes. The criteria address energy and carbon directly (e.g. switching off lights) and
indirectly (e.g. reducing waste or through procurement) as well as addressing the wider sustainability
agenda (e.g. encouraging biodiversity and fundraising for charities).
Environmental champions are encouraged to form a team, or get their wider department onboard, and
they then complete the workbook to achieve as many of the criteria as possible. Staff are encouraged to
form Green Impact teams themselves, finding their own level, rather than prescribing fixed departments. A
team of volunteer student auditors are recruited and trained to verify the responses in the workbooks.
Teams or departments then receive confidential feedback showing how they fared. A local Green Impact
awards event is held to celebrate the individual and collective achievements, usually involving senior
management from the institution, resulting in positive local media stories. The scheme runs over an
academic year, starting with the workbook being developed in departmental audits taking part in August /
September, and concluding with an awards event typically between April and June.
Implications
Green Impact has been successful at a number of universities, partly because of the simplicity and positive
nature of the scheme, and partly because of the competitive element which pits departments against each
38 
other. By rewarding success with recognition, it can be a simple way of motivating staff and departments to
save energy and carbon.
3.16 The Universities and Colleges Climate Commitment for Scotland (UCCCfS)
What is it?
The UCCCfS is a voluntary initiative for Scotland’s universities and colleges to address the impacts of
climate change at an institutional level.80 Signatories must produce and publishing a 5-year Climate Change
Action Plan a year after signing the commitment. The Plans must include measurable targets and timescales
to achieve a significant reduction in emissions from all business operations and activities. Each of the
following UCCCfS headings should be addressed, either outlining what actions are to be implemented or
demonstrating why they are not a priority:

To enhance our learning and teaching through the provision of skills, modules and courses;

To promote our research capacity and knowledge exchange activity in sustainability;

To reduce our carbon emissions – cutting energy consumption and substituting energy sources;

To encourage waste reduction, recycling and responsible disposal;

To deliver sustainable estate development – through both maintenance and capital programme;

To achieve sustainable and active travel through sustainable travel planning; and

To engage with suppliers / service providers on responsible procurement of good and services.
Annual progress reports must also be published. As of April 2011, 58 institutions had agreed to sign the
Commitment, constituting over 92% of universities and colleges in Scotland. The UCCCfS was developed
with financial support from the Scottish Funding Council and through collaboration with other sector
bodies and is managed by the Environmental Association of Universities and Colleges.
In the Scottish Government’s new energy efficiency action plan for Scotland81 it states:
“Most colleges and universities have completed a Carbon Management Programme, and over 80% have signed up
to the Universities and Colleges Climate Commitment for Scotland (UCCCfS). The UCCCfS requires participants to
publish a 5 year Climate Change Action Plan with measurable targets to achieve emissions reductions, including from
energy consumption, and to report on progress annually. We will continue to support and work with colleges and
universities to help them build upon existing work, providing access to the Carbon Management Programme and
interest-free energy efficiency loans. Going forward we will engage with the Scottish Funding Council to encourage
colleges and universities to utilise this support and to sign up to the UCCCfS. Through the Scottish Funding Council,
we will also explore how they might feed in to the target setting and reporting which we are seeking from the public
sector under this action plan.”
Implications
The scheme has had considerable impact and has been adopted in several other countries. However, the
HEFCE targets mean that a similar scheme is unlikely to develop in England.
80
Information available at: http://www.eauc.org.uk/scotlands_principals_climate_commitment
Scottish government, 2010. Conserve and Save: The Energy Efficency Action Plan for Scotland. October 2010.
Available at: http://www.scotland.gov.uk/Resource/Doc/326862/0105383.pdf
81
39 
Section 4 - Financial Opportunities
4.1
Incentives for Zero and Low Carbon (ZLC) Technologies
There are a number of actual or potential financial incentives for these, including:

Feed-in tariffs, enabled by the 2008 Energy Act82, came into effect on 1 April 2010. These payments
to anyone who owns a renewable electricity system (5 MW ceiling), for every kilowatt hour they
generate, provide a good financial incentive for renewable energy technologies. The Government
proposed changing the tariff levels from August 2011.83 A Renewable Heat Incentive with payments
for heat is expected in 2011 which has limits on technology and heat output84 ;

Universities and colleges producing electricity from eligible renewable sources can sell Renewables
Obligation Certificates (ROCs – one per megawatt hour)85 to generators, who count them
towards their 15% target (see above); and

Refunds of the Climate Change Levy (CCL)86 – a surcharge on fossil fuel generated electricity – for
any use of CHP, or renewable energy sources which are not claiming ROCs.
In December 2010 the Government announced changes to the RO with mandatory reporting against
greenhouse gas and land sustainability criteria for solid and gaseous biomass, and mandatory sustainability
criteria for bioliquids. 87
The Government’s Comprehensive Spending Review88, published October 2010, announced £1 billion of
funding for a Green Investment Bank. This was a recommendation of an earlier Commission89, though only
limited details on how the bank will operate have been announced.
4.2
Salix Finance
Salix Finance Ltd provides interest free funding to increase capital investment in energy efficient and low
carbon technologies in Higher Education Institutions (HEIs), as well as other public sector bodies. Salix has
to date funded energy efficiency projects in 75 HEIs. In England it does this in partnership with HEFCE, via
the Revolving Green Fund for Institutional Small Projects Fund.90 This has to date pushed £18m into
projects that reduce carbon in the sector. Funding is provided jointly by HEFCE and Salix Finance as a
conditional grant to those HEIs that joined the scheme before March 2009. Institutions are then required
to add, as a minimum, a further 25% of the total grant to create a ring-fenced fund; this fund is used to
82
Information available at: http://www.decc.gov.uk/en/content/cms/legislation/energy_act_08/energy_act_08.aspx
Available at:
http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/renewable/feedin_tariff/feedin_tariff.aspx
84
DECC, 2011. Renewable Heat Incentive. March 2011. Consultation document available at:
http://www.decc.gov.uk/en/content/cms/consultations/rhi/rhi.aspx
85
Information available at: http://www.ofgem.gov.uk/Sustainability/Environment/RenewablObl/Pages/RenewablObl.aspx
86
Information available at:
http://customs.hmrc.gov.uk/channelsPortalWebApp/channelsPortalWebApp.portal?_nfpb=true&_pageLabel=pageExcis
e_InfoGuides&propertyType=document&id=HMCE_CL_001174
87
DECC, 2010. Government response to Statutory consultation on the Renewables Obligation Order 2011 (ROO
2011) & Consultation on changes to Renewable Energy Guarantees of Origin (REGOs). Available at:
http://www.decc.gov.uk/en/content/cms/consultations/ro/ro.aspx
88
See footnote 20.
89
Green Investment Bank Commission, 2010. Unlocking investment to deliver Britain’s low carbon future. July 2010.
Available at: http://www.climatechangecapital.com/thinktank/ccc-thinktank/publications.aspx?year=2010&month=6
90
Information available at: http://www.salixfinance.co.uk/higher_education.html
83
40 
finance energy-saving projects across the HEI’s estate. Salix recycling funds also operate in Scotland and in
Northern Ireland. In Scotland match funding is provided by the Scottish Executive Government and in
Northern Ireland the client institution has to match the funding.
Salix funds the installation of proven technologies (including insulation, lighting, combined heat and power
plants and low energy ICT) that:

Reduce carbon dioxide emissions; and

Realise long-term financial savings through reduced energy consumption.
The financial savings made from projects are then paid back into the fund to finance further energy-saving
projects.
Once a fund is established it becomes self-sustaining and can be in operation for 15-20 years as savings
generated by completed energy saving projects are recycled back into it, to finance further projects. Only
when the institution has exhausted all possible projects does the fund have to be repaid to HEFCE/Salix
Finance. It is expected that the money in each fund will be recycled at least 3 times.
The recoverable grant element of the fund can only be used to finance energy efficiency and renewable
energy projects with long-term CO2 savings and financial savings. They must comply with one of the
following criteria:

A payback period of 5 years or less with a cost of no more than £100 per tonne life-time carbon
saved; or

A payback period of 7.5 years or less with a cost of no more than £50 per tonne life-time carbon
saved.
However, HEIs’ additional contributions can be used to finance projects with more relaxed compliance
criteria - a payback period of 10 years or less with a cost of £400 per tonne of lifetime carbon saved.
To help clients assess whether proposed projects meet the ISP Fund criteria, Salix provides a Project
Compliance Tool91: an easy-to-use Excel based tool which, once the client inputs basic information (project
costs, estimated savings, technology type and building life expectancy), automatically assesses whether the
project is compliant.
Salix has funded a wide variety of technologies, which are detailed on its web site. The best performing
categories in terms of payback in 2009/10 were Computers & IT; motor controls and office equipment.92
Two areas where Salix is more likely to be used in future are ICT and laboratories.93
At the time of writing Salix’s future was uncertain, but it is likely that the effectiveness of financing schemes
of the kind it has developed will mean that they survive in one form or another.
Implications
At a time of financial stringency, Salix funding is a beacon of light that can allow continued progress towards
low carbon campuses. However, there needs to be a transition from the Estates-focused schemes such as
91
Available at: http://www.salixfinance.co.uk/england_clients.html
Smyth, P., 2010. Salix Funding and ICT. Presentation to workshop on Energy Efficient ICT – Salix funded investment
opportunities. Nottingham Trent University, 23 September 2010. Available at:
http://www.goodcampus.org/events/info.php?siteID=&refnum=53&startnum=A0
93
SusteIT, 2010. Briefing 2: Salix funding for energy efficient ICT. Available at:
http://www.goodcampus.org/files/index.php?siteID=
92
41 
boiler renewal and CHP which have been a major element in the first stage, to ones which involve user
communities more e.g. IT, laboratories. This is where much of the ‘low hanging fruit’ is now situated but
achieving it often requires more awareness amongst users that Salix funds are available, and/or more
collaboration between them and Estates.
Section 5 - Analysis
The previous sections demonstrate the breadth and depth of the environmental requirements now facing
universities and colleges. They also demonstrate that they are likely to become more challenging, in order
to meet longer term Government targets and social expectations. In the case of carbon emissions, for
example:

The Government target of an 80% reduction target by 2050 would translate into a 2-3% annual
reduction for each individual institution if crudely allocated; and

The road map of planned building regulation tightening in England and Wales will require buildings
designed in 2013 to be almost twice as energy efficient as those in 2006, and new buildings to have
all of their energy from renewable or low carbon sources by 2019.
The trend towards disclosure- and incentive-based regulation also means that universities and colleges will
face increasing financial and reputational risk from poor performance. Combined with the financial squeeze
on universities with Government’s planned public sector funding cuts, the need to cut energy costs is both
an opportunity and a challenge.
Some institutions are responding proactively to this challenge but, in general, the sector has been reactive.
The price of this is that new or refurbished buildings are still being designed for the environmental demands
of 2010, rather than those of they will operate under in 2019 or 2029. This problem is compounded by
dealing with key regulations or activities such as BREEAM or the CRC Energy Efficiency Scheme in a shortterm, operations focused, way, rather than integrating them into a strategic process which exploits their
potential to drive improvement. In the absence of this, they all too easily become low level and/or tick box
exercises which actually distract attention from day to day energy management and other activities.
Figure 2 outlines such a strategic approach, and how the different regulations and activities described in
earlier pages can fit within it. Its central messages are that:

Institutions should be establishing their strategic goals – and the actions which flow from it – in
accordance with, but also to some degree independently of, specific regulations or activities. This is
because these can sometimes duplicate or overlap; because the best and most flexible way of
satisfying many – such as the Carbon Reduction Commitment – is as a consequence of ‘deep
change’ producing across the board improvement, rather than short-term actions to meet specific
requirements; and because the letter of regulatory requirements can change over time (although
their spirit will remain);

A key aspect of operational activities is metering, monitoring and targeting (MMT), with the aim of
building a full picture of energy and water use (and therefore, indirectly, many carbon emissions)
within the organisation. This enables the best improvement opportunities can be identified and
acted upon. Data centres are a particular opportunity for this as their self-contained nature and
clear management structure makes it relatively easy to take action as a result, Future regulations
are likely to require more of this anyway so a medium-term plan to achieve accurate information 42 
through metering and other means - on the consumption not just of individual buildings, but of key
activities within them (e.g. heating, ventilation, significant equipment) is vital;

EcoCampus or full ISO14001compliant systems can be useful in providing a ‘spine’ to support and
co-ordinate different activities, but this objective can sometimes be achieved through simpler
alternatives;

The outcomes reported under the CRC, or for building certification, are simply snapshots at a
point in time – the image they are capturing will be constantly changing (and improving) if stretch
targets are being met, and so to some degree they will take care of themselves; and

Schemes such as BREEAM Higher Education, building certification, and the Estates Management
Statistics are providing unprecedented opportunities to compare and benchmark performance,
which could be a key driver of continuous improvement over the medium-long term.
Existing buildings are likely to form the bulk of a university’s carbon emissions and better management of
these should be a key focus of this strategic process. However, new and refurbished buildings are the
targets of many of the previously discussed regulations and schemes, and – in an operational life which is
likely to be many decades – will strongly influence the sector’s future footprint. The Government’s
ambitious targets in this area mean that they are unlikely to be achieved without new technologies, and
changes in the design process to ensure that:

The professional design team and key sub-contractors have demonstrated experience of achieving
very low energy buildings with acknowledged environmental credentials;

There is a thorough pre-design process which rigorously analyses the requirements of a building;
defines clear, measurable, energy and environmental performance objectives to guide subsequent
implementation; and achieves good communication between, and shared assumptions amongst, the
design team and between the team, customers and key contractors;

There is a holistic design and development process which iteratively considers all the key building
elements and features in relation to one another, and which incorporates the views of key
stakeholders such as users and maintenance staff, as well as contractors. (This approach results in
better functionality and avoidance of expensive errors (such as over-sizing of equipment and
resultant wasteful energy consumption);

Effective project management which balances all the performance objectives (including the energy
and environmental issues), and ensures that key design features are not lost because of time
pressures, contractor resistance, or other factors;

There is sensible value-engineering based on whole life costing, and reflecting the long-term
requirements of the regulations described in this document. This should avoid the frequent practice
of eliminating relatively small amounts of capital cost only to incur much higher operating costs
through increased consumption of utilities, more expensive maintenance, and other unanticipated
outcomes; and

Effective quality control occurs throughout the process so that the performance objectives are
delivered in practice (e.g. by including independent commissioning engineers from the start of the
process).
43 
Figure 2: A Strategic Process for Energy and Environmental Issues
Strategic Commitments
Carbon Targets
Universities That Count
UCCCsF
Review
Effective Management
BREEAM
Carbon Management Programme
Building certification
Ecocampus
CRC Performance
Estate Management Statistics
Green League Table
ISO14000
Operational Activities
BREEAM
Metering, Monitoring and Targeting
Outcomes
Building certification
CRC reports
44 
Appendix 1: Statutory and Non-Statutory Requirements on Other
Environmental Issues
A1.
WEEE Regulations
What are they?
The Waste Electrical and Electronic Equipment (WEEE) Regulations brought the WEEE Directive,
2002/96/EC, into force in the UK in January 2007.94 The WEEE Directive and Regulations aim to minimise
the impact of EEE on the environment, by increasing re-use and recycling and reducing the amount of
WEEE going to landfill. It places requirements on EEE producers and distributors.95 Producers must be
registered with a Producers Compliance Scheme (PCS) and are responsible for financing collection and
recycling of WEEE by sending to authorised facilities or authorised exporters, as well as marking new
equipment with the date of manufacture and the crossed out wheeled bin symbol. Most IT equipment will
be subject to the Regulations.96 The WEEE regulations require end of life equipment to be collected, and
disposed of, separately to other waste. In addition, some WEEE may also be hazardous waste and additional
steps will be required to satisfy the Duty of Care.97
Implications
The separation, management and disposal of WEEE incurs operational costs and resources for institutions.
Although the Regulations place the responsibility on producers, some institutions, depending on the
arrangements with their suppliers, may bear the costs of the disposal of WEEE. Disposal of historic WEEE
(products purchased before August 2005) will also incur costs. Costs can range from zero to tens of
thousands of pounds per year. There are also a large number of different Producer Compliance Schemes
adding to complexity of compliance. For example, one university dealt with 24 in its last financial year.
Although the Regulations place the responsibility on producers, they allow them to negotiate alternative
financing arrangements with their customers. This can involve transferring the costs of recovering and
recycling goods to customers, which has happened with some institutions.
The Environmental Association of University and College’s (EAUC) recommends that all staff involved in
the purchasing EEE read the small print in future supply contracts to ensure that producers do not pass the
responsibility for recycling WEEE to the customer. Also institutions should ensure when purchasing EEE
through a distributor that they have been supplied with relevant details about the producer and the
compliance scheme of which they are a member so as to facilitate future disposal.98 There is also a Higher
Education National Working Group on WEEE, a nationally coordinated group comprising procurement and
user expertise drawn from members of all seven regional purchasing consortia, plus the Research
Council.99
A2.
ROHS Regulations
94
http://www.environment-agency.gov.uk/business/topics/waste/32084.aspx
Distributors or suppliers have the same obligations as Producers when they act as a Producer i.e. when they
manufacture/sell EEE under their own brand; resell under their own brand equipment produced by other suppliers; or
import/export EEE into a Member State. See http://www.conformance.co.uk/directives/weee.php
96
A list of ICT products covered by the WEEE Regulations can be found at
http://www.legislation.gov.uk/uksi/2006/3289/schedule/2/made Consumables for EEE (such as printer cartridges)
disposed separately are exempt though may be covered by ROHS.
97
for more information on Duty of Care see NetRegs page available at: http://www.netregs.gov.uk/netregs/63197.aspx
98
EAUC WEEE Insight Guide. 2007. Available at http://www.eauc.org.uk/sorted/weee_insight_guide
99
See http://weee.procureweb.ac.uk/
95
45 
What is it?
The Restriction of the Use of Certain Hazardous substances in Electrical and Electronic Equipment (RoHS)
Directive 2002/95/EC, and implementing UK ROHS Regulations 2008, bans the placing on the EU market of
new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury,
hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame
retardants100. Similar products subject to WEEE Regulations are covered by the Directive. There is a move
towards global compliance with China, Japan, South Korea, Taiwan, Australia, Canada and many US States
adopting similar restrictions.
Under the UK Regulations, any equipment put on the market after 1 February 2008 should not contain
more than 0.1% (or 0.01% in case of cadmium) by weight of hazardous substances listed in the Directive.
There are some exemptions.101
Implications
The RoHS Directive and Regulations do not require any direct action by Universities and Colleges as the
responsibility lies with the producer rather than the purchaser. However institutions should ensure that
they specify ROHS-compliant equipment. ICT equipment purchased after 1 February 2008 will have fewer
hazardous substances within them, or used in their production.
A3.
Batteries Directive and Regulations
What is it?
The Batteries and Accumulators and Waste Batteries and Accumulators Directive, 2006/66/EC, is a
producer responsibility directive which seeks to improve the environmental performance of batteries and
accumulators across their entire life cycle. It applies to all battery types, and requires collection schemes
for the return of used portable batteries, sets collection rate targets for household batteries and restricts
the levels of mercury and cadmium in batteries placed on the market.
The Directive is transposed into the UK via two regulations.102 The Batteries and Accumulators (Placing on
the Market) Regulations 2008 sets out requirements for designing and labelling batteries and accumulators
(rechargeable batteries) and battery-powered electrical and electronic equipment, to make it easier to
recycle waste batteries. The Waste Batteries and Accumulators Regulations 2009 establishes a legal
framework and schemes for collecting, treating and recycling portable, industrial and vehicle batteries. The
Regulations covering collecting, recycling and reprocessing portable batteries came into force on 1
February 2010.
Implications
Universities do not have obligations under the Batteries Regulations. However there are potential benefits
for Battery Collection Schemes and universities if they co-operate on portable batteries collection. For
universities that use portable batteries, suppliers will operate a take back scheme unless they sell less than
32kg of batteries per year. Laptop batteries are categorised as portable batteries under the Regulations.
100
http://www.rohs.gov.uk/ A 2009 Amendment corrects drafting errors and substitutes a new section on compliance
and enforcement notices.
101
see http://www.rohs.gov.uk/content.aspx?id=15
102
http://www.netregs.gov.uk/netregs/109281.aspx
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Appendix 2: Practices from the EU Code of Conduct on Energy Efficient Data Centres
Table 1: Most Beneficial Data Centre Practices, According to the EU Code of Conduct on Energy Efficient Data Centres103 (Measures scoring
5, on a 1-5 scale) Optional requirements are highlighted in yellow.
Category
No. and Name
Description
3.1
Involvement
3.1.1 Group
Establish an approval board containing representatives from all disciplines (software, IT, M&E). Require the approval
of Organisational
involvement
of this group for any significant decision to ensure that the impacts of the decision have been properly understood
Groups
and an effective solution reached. For example, this could include the definition of standard IT hardware lists
through considering the M&E implications of different types of hardware. This group could be seen as the functional
equivalent of a change board.
4.1 Selection and
4.1.1 Multiple
Include the Energy efficiency performance of the IT device as a high priority decision factor in the tender process.
Deployment of New
tender for IT
This may be through the use of Energy Star or SPECPower type standard metrics or through application or
IT Equipment
hardware - power
deployment specific user metrics more closely aligned to the target environment which may include service level or
reliability components. The power consumption of the device at the expected utilisation or applied workload
should be considered in addition to peak performance per Watt figures.
As above
4.1.3 Multiple
Starting 2012 new IT equipment should be able to withstand the air inlet temperature and relative humidity ranges
tender for IT
of 5°C to 40°C and 5% to 80% RH, non-condensing respectively, and under exceptional conditions up to +45°C as
hardware –
described in ETSI EN 300 019 Class 3.1.
Extended operating
temperature and
It should be noted that where equipment with differing environmental requirements is not segregated, the
humidity range
equipment with the more restrictive temperature range will influence the cooling conditions and corresponding
energy consumption for all of the IT Equipment.
From 40°C to 45°C intake temperature it is acceptable for equipment to implement performance reduction
mechanisms to continue delivering the intended service at lower speed whilst preventing damage. These
mechanisms should not reduce performance below 80% of the nominal for that device. Where such performance
reduction mechanisms are used a clear description of the operating parameters and performance impact should be
provided.
103
http://re.jrc.ec.europa.eu/energyefficiency/html/standby_initiative_data_centers.htm.
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As above
As above
4.2 Deployment of
New IT Services
4.3 Management of
Existing IT Eqt and
Services
As above
As above
4.1.6 Enable power
management
features
4.1.10 Control of
equipment energy
use
Formally change the deployment process to include the enabling of power management features on IT hardware as
it is deployed. This includes BIOS, operating system and driver settings.
4.2.1 Deploy using
Grid and
Virtualisation
technologies
4.3.2
Decommission
unused services
4.3.3 Virtualise and
archive legacy
services
4.3.4 Consolidation
of existing services
Processes should be put in place to require senior business approval for any new service that requires dedicated
hardware and will not run on a resource sharing platform. This applies to servers, storage and networking aspects
of the service.
5.1 Air Flow
Management and
Design
5.1.1 Design –
Contained hot or
cold air
5.3 Temperature and
5.3.3 Expanded IT
Select equipment which provides mechanisms to allow the external control of its energy use. An example of this
would be the ability to externally restrict a server‟s maximum energy use or trigger the shutdown of components,
entire systems or sub-systems
Completely decommission and remove the supporting hardware for unused services
Servers which cannot be decommissioned for compliance or other reasons but which are not used on a regular
basis should be virtualised and then the disk images archived to a low power media. These services can then be
brought online when actually required
Existing services that do not achieve high utilisation of their hardware should be consolidated through the use of
resource sharing technologies to improve the use of physical resources. This applies to servers, storage and
networking devices.
There are a number of design concepts whose basic intent is to contain and separate the cold air from the heated
return air on the data floor;
• Hot aisle containment
• Cold aisle containment
• Contained rack supply, room return
• Room supply, Contained rack return
• Contained rack supply, Contained rack return
This action is expected for air cooled facilities over 1kW per square meter power density.
Note that the in rack cooling options are only considered to be containment where the entire data floor area is
cooled in rack, not in mixed environments where they return cooled air for remix with other air flow.
Where appropriate and effective, Data Centres can be designed and operated within the air inlet temperature and
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Humidity Settings
5.4.1 Free and
Economised Cooling
As above
eqt inlet
environmental
conditions (temp
and humidity)
5.4.1.1 Direct Air
Free Cooling
5.4.1.2 Indirect Air
Free Cooling
relative humidity ranges of 5 to 40°C and 5 to 80% RH, non-condensing respectively, and under exceptional
conditions up to +45°C as described in ETSI EN 300 019, Class 3.1.
External air is used to cool the facility. Chiller systems are present to deal with humidity and high external
temperatures if necessary. Exhaust air is re-circulated and mixed with intake air to avoid unnecessary humidification
/ dehumidification loads.
Re circulated air within the facility is primarily passed through a heat exchanger against external air to remove heat
to the atmosphere.
Table 2: Practices Planned to Become Minimum Expected Practices in Future Updates of the EU Code of Conduct on Data Centres
No
Name
Description
4.1.9
Energy &
temperature
reporting hardware
5.1.10
Equipment
segregation
5.1.12
Separate
environmental
zones
Select equipment with power and inlet temperature reporting capabilities, preferably reporting energy used as a counter in addition
to power as a gauge. Where applicable, industry standard reporting approaches should be used such as IPMI, DCMI and SMASH.
To assist in the implementation of temperature and energy monitoring across a broad range of data centres all devices with an IP
interface should support SNMP polling of inlet temperature and power draw. Note that event based SNMP traps and SNMP
configuration are not required.
The intent of this practice is to provide energy and environmental monitoring of the data centre through normal equipment churn.
Deploy groups of equipment with substantially different environmental requirements and / or equipment airflow direction in a
separate area. Where the equipment has different environmental requirements it is preferable to provide separate environmental
controls.
This objective of this practice is to avoid the need to set the data centre cooling plant for the IT equipment with the most
restrictive environmental range or poor air flow control as this compromises the efficiency of the entire data centre .
Where a data centre houses both IT equipment compliant with the extended range of practice 4.1.3 and other IT equipment which
requires more restrictive temperature or humidity control separate areas should be provided. These areas should have separate
environmental controls and may use separate cooling systems to facilitate optimisation of the cooling efficiency of each zone.
Examples are equipment which;
 Requires tighter environmental controls to meet archival criteria such as tape
 Requires tighter environmental controls to meet long warranty durations (10+ year)
The objective of this practice is to avoid the need to set the data centre cooling plant for the equipment with the most restrictive
environmental range and therefore compromising the efficiency of the entire data centre.
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50 