Consultation Position Paper
Review of the NABERS ruling:
‘Proportioning of Energy used by
Cogeneration or Trigeneration Systems’
1. EXECUTIVE SUMMARY
The purpose of this paper is to seek comments from industry on the review of the NABERS ruling
‘Proportioning of Energy used by Cogeneration or Trigeneration Systems’, issued on 7 July 2010 (July
Ruling). The July Ruling was placed under review to consider how externally supplied thermal energy
and electricity from co/trigeneration plants should be accounted for in NABERS Energy ratings for
offices, hotels and shopping centres.
NABERS is a rating system for individual buildings. NABERS is underpinned by a fundamental principle
which is to measure the externally supplied energy used to operate a building and then to rate this
against the market average.
The review considers a series of questions that were raised by industry and makes the following key
recommendations:
•
When a co/trigeneration system is located on-site and all the usable energy generated by this system
is consumed by either the base building or its tenants; then 100% of the externally supplied energy
(usually natural gas) can be proportionately allocated to the end users of the generated electricity.
•
When a co/trigeneration system is located on-site and it is exporting thermal energy or electricity offsite; then the proportion of externally supplied energy (usually natural gas) used by the
co/trigeneration plant to generate these exports can be excluded from the host buildings NABERS
Energy Base Building Rating.
•
When co/trigeneration thermal energy or electricity is externally supplied to a building then this
energy is to be accounted for within a NABERS Energy rating.
•
NABERS supports the creation of an industry/government accreditation standard to allocate an
emissions value to co/trigeneration thermal energy and electricity products externally supplied to
buildings (similar to GreenPower). Once an accreditation process is established, then these
externally supplied energy products can be included in a NABERS Energy rating. Until such a
standard is developed co/trigeneration electricity supplied via the grid/network will be allocated
standard grid emission values. Imported thermal energy will be considered by the NABERS National
Administrator on a case-by -case basis.
•
The amount of low emissions electricity will be identified in the NABERS Energy Rating Certificate
and accompanying Rating Report.
Comments will be received up-until 24 August 2012 and should be clearly marked ‘Submission – Review
of the NABERS ruling ‘Proportioning of Energy used by Cogeneration or Trigeneration Systems’ and can
be emailed to nabers.energy@environment.nsw.gov.au. All comments will be made public.
Office of Environment and Heritage
59-61 Goulburn Street Sydney
PO Box A290 Sydney South NSW 1232
Phone:
Email:
Web:
02 9995 5000
nabers@environment.nsw.gov.au
www.nabers.com.au
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Review of the NABERS ruling ‘Proportioning of Energy used by Cogeneration or Trigeneration
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2. PURPOSE
The purpose of this paper is to seek comments from industry on the review of the NABERS ruling
‘Proportioning of Energy used by Cogeneration or Trigeneration Systems’, issued on 7 July 2010.
3. BACKGROUND
NABERS is the industry standard for rating the environmental performance of Australian buildings.
NABERS is underpinned by a fundamental principle, which is to measure the externally supplied energy
used to operate a building and then rate this performance against the market average. The NABERS
star rating represents the level of performance achieved.
NABERS ratings are undertaken by Accredited Assessors. These Assessors apply the ‘NABERS Rules
for Collecting and Using Data’ (the Rules) to conduct a rating. The Rules are publicly available at
www.nabers.com.au. The Rules are a living document and as industry and technology changes, new or
unique situations arise which may not be covered in the Rules. In these circumstances an update or
revision to the Rules may be required; this process is known as a “Ruling”. For further information about
the Rulings process please refer to www.nabers.com.au.
The NABERS ruling ‘Proportioning of Energy used by Cogeneration or Trigeneration Systems’, (July
Ruling) issued on 7 July 2010, introduced a methodology by which externally supplied energy inputs to
cogeneration or trigeneration systems are apportioned to the parties using the electricity generated.
Co/trigeneration systems generate electricity through the burning of fuels (typically natural gas) that may
produce less greenhouse gas (GHG) emissions than burning coal. Therefore, the electricity generated
by cogeneration systems may have lower emissions than the typical grid supply. Co/trigeneration
systems also generate heat which can be used for heating and/or cooling.
The July Ruling was originally developed to address single buildings with multiple tenants or small scale
private district generation systems. Since the release of the July Ruling further innovation in the supply of
low/zero emissions energy has evolved or is proposed. The City of Sydney is proposing a precinct wide
trigeneration network that will include both an electricity and hot water district supply. Other major
projects are considering off-site zero emissions energy being supplied directly to buildings outside of the
GreenPower scheme.
Following a request for the July Ruling to be applied to these innovations, the Ruling was placed under
review to specifically examine how electricity and thermal energy generated by co/trigeneration systems
or other low/zero emissions technologies should be treated within a NABERS rating.
Further, this review also examines how NABERS could assist building owners in understanding both the
environmental performance and building energy efficiency impacts involved in utilising these new energy
supplies.
Due to the complexity and strategic importance of this review an extensive consultation process has
been undertaken to inform this paper, (refer to attachment A ‘Consultation Summary’). The NABERS
National Steering Committee, NABERS Stakeholder Advisory Committee, NABERS Auditors and
targeted industry and government stakeholders have been consulted to inform the development of this
consultation paper.
The consultation process identified the following key issues and questions that are addressed through
this review:
1. Potential double counting of emissions and corresponding double benefit under NABERS when the
co/trigenerated electricity is delivered via the grid.
2. How should on-site energy generation be treated within a NABERS rating?
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3. How should usable energy generated by co/trigeneration systems and exported off-site be treated
within a NABERS Energy rating?
4. How should low/zero emissions energy externally supplied to a building be treated in a NABERS
Energy rating?
5. How should NABERS communicate the use of low/zero emissions electricity in a rating to assist
industry in understanding both the environmental performance and energy efficiency of a building?
4. DEFINITIONS
Cogeneration
System
A cogeneration system is a system that uses fuel, usually gas, to generate
electricity and useful thermal energy in the form of hot water or steam. The system
includes the generator and pumps for the transport of heat from the system to the
internal building systems, but excludes any supplementary boilers used to boost
heat outputs.
Trigeneration
System
A trigeneration system is a cogeneration system that also uses some of the heat to
operate an absorption chiller, which produces chilled water. This system includes
the generator and pumps for the transport of heat from the system to the building
systems, the absorption chiller and associated pumps for the transport of chilled
water to the internal building systems, but excludes the supplementary boilers and
chillers used to boost the heat or chilled water outputs.
On-Site Energy
Generation
Energy generation is considered as being “on-site” if:
Auxiliary Energy
•
The process of energy conversion (e.g. solar-electricity, fuel-electricity)
occurs within the legal boundaries of the building and its grounds; and
•
The generated electricity is connected on the user side of the meter; and
•
No usable energy is exported beyond the building and its grounds (off-site).
Auxiliary energy is the energy required for control equipment and other devices
directly attached to cogeneration or trigeneration system components.
Energy inputs included within the auxiliary energy for cogeneration or trigeneration
systems include, but are not limited to:
•
Jacket heating to the generator.
•
Pumps used to reject heat from the generator and absorption chiller for both
utilised and rejected heat streams.
•
Pumps required to circulate/transport waste/heat or absorption chiller output
from the cogeneration or trigeneration plant to internal building users or to
export energy to another end user.
•
Electrical inputs to the absorption chiller.
•
On-board controls and variable speed drives (VSDs) for cogeneration or
trigeneration plant items.
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Auxiliary energy excludes:
Supplementary
Fuel
•
Energy consumption associated with the building management system.
•
Supplementary fuels used to boost the waste heat or absorption chiller
outputs.
Supplementary fuels used to boost the waste heat or absorption chiller outputs are
directly attributable to the end-users of the thermal energy. The supplementary fuel
consumption must be proportioned between the users on the basis of their
respective use of this thermal energy. This includes energy used to circulate and
boost thermal energy supplied through utility networks/systems to end users.
5. BASIC PRINCIPLES OF NABERS AND THE COMMERCIAL BUILDING DISCLOSURE
PROGRAM
NABERS is a rating system for individual buildings. NABERS is underpinned by a fundamental principle
which is to measure the externally supplied energy used to operate a building to service its functional
purpose, and then to rate this against the market average. NABERS uses the building’s actual energy
consumption data to rate a building, rather than considering modelled information or technological
solutions. The data used in a NABERS rating must be third party verifiable and typically is in the form of
utility bills. The NABERS star rating communicates how a building is performing against the market
average.
NABERS communicates both the environmental performance and the energy efficiency of an operating
building.
NABERS currently allows a rating to include zero emissions energy purchased through the GreenPower
scheme. GreenPower is a regulated program ensuring that the electricity used is zero emissions.
Purchasing GreenPower improves the environmental performance of a building but not its energy
efficiency. The NABERS Energy Rating Certificate and accompanying Rating Report clearly state both
the percentage of GreenPower used by the building and the NABERS Energy rating without
GreenPower.
On 1 November 2011, the Commercial Building Disclosure (CBD) program, became mandatory. CBD is
a national program designed to improve the energy efficiency of Australia’s large office buildings. The
program is managed by the Commonwealth’s Department of Climate Change and Energy Efficiency
(DCCEE). Under CBD most sellers or lessors of office space of 2,000m2 or more are required to obtain
and disclose a current Building Energy Efficiency Certificate (BEEC). A BEEC is comprised of:
•
A NABERS Energy star rating without GreenPower for the building;
•
An assessment of tenancy lighting in the area of the building that is being sold or leased; and
•
General energy efficiency guidance material.
As the purpose of CBD is to drive improvements in the energy efficiency of buildings, CBD requires that
the NABERS Energy rating without GreenPower be disclosed.
DCCEE was engaged in this review due to the potential impact of the July Ruling on the NABERS
Energy rating without GreenPower, disclosed under CBD.
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6. REVIEW OF KEY ISSUES
Issue 1: Potential double counting of emissions and corresponding double benefit under
NABERS when the co/trigenerated electricity is delivered via the grid.
Some stakeholders were concerned that the low emissions energy produced by co/trigeneration systems
connected to the grid was already being taken into account in the grid electricity National Greenhouse
Accounts (NGA) Factors1. This could result in a possible double counting of emission savings under a
NABERS rating.
This issue has been investigated with the Department of Climate Change and Energy Efficiency
(DCCEE) who administer the NGA. They have advised that, at this stage, it is not possible to double
count the emissions benefit from co/trigeneration.
At present, emissions from fuel combustion by small generating units are allocated to the facility sector.
The emissions are not accounted in the electricity sector and are therefore not accounted in the scope 2
NGA factors for grid electricity.
DCCEE advised that as the number of minor sources of electricity increase they will continue to review
their current methods and investigate new data sources to ensure maximum coverage in the scope 2
calculations.
NABERS Position:
Currently, no double counting occurs when electricity generated by co/trigeneration systems (low
emissions electricity) is delivered to other buildings via the grid.
No change is required to the July Ruling in this regard.
Issue 2: How should on-site energy generation be treated within a NABERS rating?
On-site energy generation is defined as when:
•
The process of energy conversion (e.g. solar-electricity, fuel-electricity) occurs within the legal
boundaries of the building and its grounds; and
•
The generated electricity is connected on the user side of the meter; and
•
No usable energy is exported beyond the building and its grounds (off-site).
This simply means that all the usable energy generated by the plant is consumed by the base building
and/or its tenants.
Currently there are two main forms of useable energy being generated on-site: electricity and thermal
energy. Electricity is typically generated through either:
1
•
Renewable energy generation, such as photovoltaic cells or wind turbines, which generate zero
emissions; or
•
Fuel-based generation, such as diesel generators or onsite co/trigeneration systems which
typically produce lower emissions electricity than mains supplied electricity.
National Green House Accounts Factors, Department of Climate Change and Energy Efficiency.
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Efficient co/trigeneration systems can convert most of the gas burnt into electricity and useful heat, which
can then be used for heating or cooling. This may significantly reduce the GHG emissions generated by
a building during operation.
Section 6 of the ‘NABERS Rules for Collecting and Using Data version 2’ specifies that the Assessor
must ensure that the consumption of every external energy source supplied to the rated premises is
included in a rating.
Electricity generated by on-site renewable energy generation has no externally supplied electricity or
fuels associated with it and therefore it is not included in a NABERS rating. It also directly improves both
the energy efficiency and environmental performance of a building by reducing the demand for externally
supplied electricity and not producing GHG emission.
Co/trigeneration systems use an external energy supply, such as natural gas to produce electricity and
heat. As the NABERS rating measures a building’s use of externally supplied energy, it is appropriate to
include the gas supplied to the building in the NABERS Energy rating.. If the electricity generated by the
co/trigeneration system is distributed to multiple end users within the building (remains on-site) then the
gas supplied to generate the electricity can be proportionately allocated to the parties within the building
that use the generated electricity.
An on-site co/trigeneration system forms part of the building’s plant, delivering the building’s electricity
and thermal energy needs. This affects both the building’s energy efficiency and environmental
performance. The system may also provide electricity to the tenancies and this low emissions electricity
should be recognised in a NABERS Energy tenancy rating.
For on-site generation, the current July Ruling allows for all the externally supplied energy to be
allocated solely to the electricity generated, regardless of whether the thermal energy generated is
utilised within the building. This approach is well accepted by industry.
NABERS Position:
Retain the current July Ruling position that allows for all the energy supplied to an onsite co/trigeneration
system to be allocated to the electricity generated for the building/and its tenants (where applicable).
No externally supplied energy is required to be allocated to the internally used thermal energy or the non
usable thermal energy.
The on-site generation of electricity and thermal energy for use by the base building is considered to
affect both the energy efficiency and environmental performance of the building. Therefore this energy
will be included in the NABERS rating disclosed through the Commercial Building Disclosure program
(CBD).
The NABERS Tenancy Energy Rating Certificate and accompanying Rating Report will identify the
amount of low emissions electricity that has been used by a tenancy.
The July Ruling is to be amended to include a definition of ‘on-site’ energy generation, as follows:
Definition: Energy generation is considered as being “on-site” if:
1. All of the process of energy conversion (e.g. solar-electricity, fuel-electricity) occurs within the
legal boundaries of the building and its grounds; and
2. The generated electricity is connected on the user side of the meter; and
3. No usable energy is exported beyond the building and its grounds (off-site).
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More complex situations may arise where electricity or thermal energy is being provided to a non-office
use within the building, which can be excluded under the NABERS Rules, if appropriately sub-metered.
Metering and record keeping required for the apportioning of on-site generation are detailed in the July
Ruling and are to be retained. In this situation the non-office use will be treated as receiving a proportion
of the energy input and this can be excluded from the rating.
Example: On-site energy generation
Base
Building
Tenants
10MWh
90MWh
Gas Bill
Key
Electricity
Gas supply
Building boundary
Co/trigen
plant
1,000 GJ
Base building
rating report
Star rating:
4.5 stars
Tenancy
rating report
Star rating:
4 stars
Electricity use: 0 MWh
Electricity use: 10 MWh
Gas use:
CogenPower:
100%
Gas use:
0 GJ
900 GJ
Issue 3: How should usable energy generated by co/trigeneration systems and exported off-site
be treated within a NABERS Energy rating?
Increasingly co/trigeneration systems within buildings are being designed to enable the electricity and/or
thermal energy to be exported off-site to external end users. These generators may form part of a district
or regional network, or simply be a private connection servicing a couple of buildings. Fundamentally, a
transaction is occurring where one building is generating usable energy that is then purchased by an offsite end user. These systems may be referred to as embedded generators when they export to the grid.
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Strategies such as the City of Sydney’s “Decentralised Energy Master Plan – Trigeneration 2010-2030”
are creating the planning and infrastructure frameworks to support district scale energy generation.
NABERS is a single building rating tool and all externally supplied energy used by a building is to be
included in a NABERS Energy rating. Where a building generates energy beyond its operational needs
and exports this surplus energy off-site, this export should be allocated with the emissions of the
generator.
NABERS has established rules that govern the data that is considered acceptable for use in a rating.
The standard for Acceptable Data is explained in Section 2 of the ‘NABERS Rules for Collecting and
Using Data version 2”. The key principle is that the data must be derived from measurements or records
which have been independently verified and are of a known degree of accuracy. The primary form of
acceptable data of energy consumption is utility bill records and verified non utility meters.
Where a building is exporting usable energy off-site to a third party, whether that is thermal energy or
electricity, all the outputs from the co/trigeneratation system will require accurate metering, including onsite-use thermal energy. The amount exported can then be assigned an emissions value derived from
the energy used to generate and supply this export. Consideration also needs to be given to the
efficiency of the generation technology and the networks.
Noting that under no circumstances is waste heat (non-usable energy) to be allocated generation energy
inputs.
The July Ruling currently only allocates an emission value to the electricity generated. The Thermal
usable energy, which may also be exported off-site for use by an end users, is currently treated as waste
heat and not allocated an emissions value. This has the potential to distort NABERS building ratings, as
not all the externally supplied energy is able to be included in a building’s rating. Further, the building
exporting the thermal energy should be able to exclude the proportion of the energy inputs associated
with generating this export, as it is additional to the building’s operational needs.
For the NABERS Energy rating to accurately include all the externally supplied energy sources used to
operate a building, it is necessary for exported thermal energy to also be attributed with an emissions
value derived from the fuel used to generate and supply this energy. This will also include the energy
used to boost and circulate this thermal energy through the supply network.
For example: How to rate a building with a co/trigeneration system that is exporting offsite thermal energy and electricity is treated as follows:
In this scenario the externally supplied energy (natural gas) used to generate the thermal energy
and electricity needs to be accurately apportioned to the internal and export streams. Metering
will be required to measure the:
•
Cogeneration electricity used on-site
•
Cogeneration thermal energy used on-site
•
exported electricity, and
•
exported thermal energy.
No allocation is made to any waste energy exhausted from the building.
Once measured, the gas can be apportioned to the streams. The gas used to generate the
exported electricity and exported thermal energy can be excluded from the NABERS Energy
Base Building rating. Any on-site supplementary fuel used to boost or circulate these exports can
also be excluded.
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NABERS Position:
NABERS is a single building rating tool, to measure the operational performance of existing buildings.
Under NABERS, treatment of exported energy from building co/trigeneration systems, whether this is
electricity or thermal energy, is to be accounted for in the NABERS rating, irrespective of whether it is
exported via public or private networks. Therefore, all useful energy exported off-site from a building,
(including electricity, hot water or chilled water), for the purposes of supplying energy to a third party end
user, will be proportionately allocated a generation emissions value.
When a building exports thermal energy off-site, it will need to meter both its exported and internal
thermal energy use to enable the accurate apportioning of energy generation inputs.
The externally supplied energy used by on-site co/trigeneration systems to produce export electricity or
export useable thermal energy can be excluded from a NABERS Energy Base Building Rating.
It is recommended that the July Ruling be amended to account for the allocation of generation energy
inputs to usable thermal energy exported off-site. This will require working with industry and government
to determine an appropriate apportioning calculation methodology.
Example: off-site energy exports.
Rated
premises
Off-site
user
Gas Bill
Key
Electricity
Co/trigen
plant
1,000 GJ
Grid
Thermal energy
Gas supply
Building boundary
Note:
Gas consumption associated with electricity and thermal energy exports off-site can be excluded from
the premises NABERS Energy Base Building rating.
Issue 4: How should low/zero emissions energy externally supplied to a building be treated in a
NABERS Energy rating?
NABERS currently allows a rating to include zero emissions electricity purchased through the
GreenPower scheme. GreenPower is a regulated program that ensures that the electricity used is zero
emissions. The amount of GreenPower used is clearly identified on the utility bill and can be easily and
reliably determined by an NABERS Accredited Assessor. Using GreenPower improves the
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environmental performance of a building but it doesn’t improve its energy efficiency. Therefore the CBD
program requires that the NABERS rating exclusive of GreenPower be disclosed.
NABERS seeks to recognise other supply-side low/zero emissions energies such as electricity
generated through on-site cogeneration systems in a manner that does not diminish the value of
NABERS as a measure of a building’s performance. It recognises that low emissions electricity
improves the environmental performance of a building but doesn’t improve the building’s energy
efficiency, whilst the use of low emissions thermal energy affects both the energy efficiency and the
environmental performance of a building. This is achieved by recovering the heat produced by the
co/trigeneration system and utilising this to operate the building, reducing the need for grid electricity.
For this energy to be considered in a NABERS rating third party verifiable data is required which reliably
and accurately accounts for the amount of zero/low emissions energy supplied to a building from a
network, regardless of the scale of the network. This energy is required to be attributed with an
emissions value that includes all energy required to reticulate, boost and supply this energy.
The outcomes of the review indicate that the source of any low/zero emissions energy externally
supplied will need to be rigorously verified to be considered. At present, when a cogeneration system
supplies energy to supply networks, the reconciliation is managed by the utility itself. There is no audit or
third party accreditation in place like GreenPower.
NABERS Position
NABERS supports the creation of an industry/government accreditation standard to account for the
apportioning of generation and network supply emission values to thermal energy products and
electricity. Once third party verifiable invoices/bills are available that clearly show the energy purchased
and its emission value, this low emissions externally supplied energy can be included within a NABERS
Energy rating. The amount of low emissions electricity will be identified in the NABERS Energy Rating
Certificate and accompanying Rating Report (similar to GreenPower).
Until such a standard is developed co/trigeneration electricity supplied via the grid/network will be
allocated standard grid emission values. Imported thermal energy will be considered by the NABERS
National Administrator on a case-by-case basis.
Issue 5: How should NABERS communicate the use of low/zero emissions electricity in a rating
to assist industry in understanding both the environmental performance and energy efficiency of
a building?
NABERS should remain transparent, consistent and continue to provide a clear message to building
owners and tenants.
The rating should provide information to enable the market to understand both the environmental
performance and energy efficiency of the building.
Currently NABERS recognises the purchase of GreenPower and clearly identifies the percentage of
GreenPower purchased by displaying the rating with and without GreenPower on the NABERS website,
Rating Certificate and accompanying Rating Report. The percentage of co/trigeneration low emission
electricity purchased should be displayed in a similar manner as GreenPower.
Unlike the purchase of low emissions electricity the use of thermal energy is considered an energy
efficiency measure as well as an environmental performance measure and it will be included in the
NABERS Energy rating disclosed under the CBD program.
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NABERS Position:
NABERS will continue to communicate both the environmental performance and the energy efficiency of
a building through its website, star Rating Certificate and accompanying Rating Report. Once an
acceptable audit and verification system is in place to account for low emissions electricity externally
supplied, these purchases can be considered in a NABERS Energy rating.
Consistent with the treatment of GreenPower, the percentage of low/zero emissions electricity used by a
building will be displayed on the Rating Certificate and Rating Report.
Example: Externally supplied co-generation electricity to a base building.
Power bill
Rated
premises
1,000 MWh
50% CogenPower
NABERS rating
certificate
Star rating:
4 stars
Electricity use:
1000 MWh
CogenPower:
50%
Rating w/o CogenPower: 3 stars
7. COMMENTS
The NABERS National Steering Committee is seeking comments from industry on the positions
presented in this paper.
Submissions should be in writing, and clearly marked “Submission - Review of the NABERS ruling
‘Proportioning of Energy used by Cogeneration or Trigeneration Systems’ and can either be addressed
to:
NABERS Energy
Built Environment Section
Office of Environment and Heritage
PO Box A290
SOUTH SYDNEY 1232
Or emailed to: nabers.energy@environment.nsw.gov.au
All submissions will be made publicly available through the NABERS website.
Anonymous submissions will not be considered in this review.
Comments will be received up until close of business 24 August 2012
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Attachment A Organisations consulted to inform the preparation of the
Consultation Position Paper:
Organisation
Lend Lease Australia
Green Building Council of Australia
PCA Forum
on Cogeneration
INVESTA
City of Sydney
NSW Department of Premier and Cabinet
COGENT ENERGY
NABERS Stakeholder Advisory Committee and Co/Trigeneration Working Group
NABERS National Steering Committee
Refer to the NABERS website www.NABERS.com.au for a list of NSC and SAC members
Department of Climate Change and Energy Efficiency
NGA and NGERS team
Commercial Building Disclosure (CBD) Team
Conference Energy Efficiency Council
Melbourne
Dalkia Energy Services Pty Ltd
Energy Efficiency Council
Clean Energy Council
Places Victoria and Melbourne City Council
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