Review of the Operational Efficiency of the Commercial Building Disclosure
Program
Response to Recommendations
Department of Industry
Introduction
Grosvenor Management Consulting (Grosvenor) was engaged by the Department of Climate
Change and Energy Efficiency, the manager of the Commercial Building Disclosure (CBD)
Program, in early 2013 to conduct a review of the Program. The purpose of the review was
to provide feedback to the Program’s manager, now the Department of Industry, to inform
improvements to the operation of the Program. Funding for the review was provided by the
Council of Australian Governments through the Select Council on Climate Change Energy
Efficiency Working Group. The focus of the review was the operational efficiency of the CBD
Program and it examined the service delivery systems and the interaction between these
systems and stakeholders, including CBD Accredited Assessors and building owners, with
the aim of improving the efficiency of Program arrangements. The review also examined the
usefulness of information provided in the Building Energy Efficiency Certificate (BEEC) and
the impact this has on the decision making of users. The review comprised both a survey
and targeted interviews with a cross section of stakeholders. Full details on the structure of
the review can be found in the full report prepared by Grosvenor.
Review Findings
Grosvenor reported that the CBD Program is operating well. Key indicators from the survey
of CBD Accredited Assessors and interviews with stakeholders, to support this finding are:
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80% of respondents were satisfied with the current processing time for a BEEC and
nearly 70% of respondents were satisfied with current processing times for Tenancy
Lighting Assessments (TLA).
Over 90% of respondents rated the service provided by the CBD team in issuing
BEECs and TLAs as excellent or good.
The majority of stakeholders who had contact with the CBD team indicated that the
team was responsive to their requests and they were satisfied with the interaction.
Grosvenor also identified a range of opportunities to further promote the Program aims and
to improve the operational efficiency of the Program. These were summarised into eight
recommendations. The Department has taken on board all of the recommendations and has
already begun implementing some of the proposed improvements. A response to each of the
eight recommendations is provided below.
Recommendations and Response
1. Develop and implement a stakeholder communication and engagement plan to promote
broader awareness and understanding of the program across all stakeholder groups and
in particular, amongst tenants and their agents/representatives.
Response – 1
The Department will continue looking for opportunities to improve on stakeholder
communications and engagement with a particular focus on tenants, so as to create a
more effective market signal for building energy efficiency. While there is a high level of
awareness of the CBD Program among owners and agents, an area of future focus will
be raising awareness and understanding amongst tenants, building upon work already in
train.
Recent activities include the launch of the refreshed website including searchable
building energy efficiency register on 2 May 2013 and supporting the development of the
LEASA mobile application, which is designed to assist users in selecting office space
with energy efficient lighting a key criteria. LEASA is targeted at small to medium
enterprises and will help them to, amongst other things:
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calculate and compare tenancy lighting costs of space for lease;
search the BEEC database; and
understand simply how choosing different space and/or changing other tenancy
variables (for example, lighting efficiency) effects the energy efficiency and/or
cost of that space.
The LEASA app was launched on 12 August 2013 and relies on CBD data. The LEASA
app was developed by the Royal Institute of Charted Surveyors (RICS) with a grant from
the Department’s Energy Efficiency Information Grants Program.
The CBD Team has also now developed a ‘downloadable data set’ as part of a recent IT
system upgrade. This will make both historical and current CBD data available to
researches, analysts and application developers in a format that can be easily utilised in
applications like LEASA. The data set was launched on 16 September 2013.
2. Review and update the TLA rating system and presentation to improve comprehension
amongst stakeholders. This could potentially be achieved by:
a. presenting the information more visually, and with less technocratic language
b. including a relevant benchmark or other frame of reference
c. indicating the cost impacts and more importantly the potential savings to better
achieve behavioural change.
Response – 2
The Department continues to monitor the results of the Tenancy Lighting Assessments
to ensure that performance comparison bands are appropriate and relate to the real
world. The CBD team has recently completed a revision of the TLA Rules, in
consultation with stakeholders which included the addition of an additional comparison
band – Very Poor. This improves the quality of information provided to users of the
BEEC and we will continue to liaise with stakeholders on this and the benefits of other
enhances that improve use of the TLA information.
Department of Industry - Response to Recommendations
Review of the Operational Efficiency of the Commercial Building Disclosure Program
The Department will continue to review guidance material explaining the TLA component
of the BEEC and work towards improving comprehension, both through better
presentation and use of frames of reference.
The Department will and continue to promote the LEASA application, which gives users
the ability to calculate the costs associated with lighting.
3. Improve the clarity regarding program applicability, including exemptions and exceptions,
and revisit the applicability of the program to unsolicited offers.
The following changes have been suggested to improve the clarity of exceptions and
exemptions:
a. change the name of exceptions; it is too similar to exemption
b. review and enhance the guidance available, including providing clarity for
situations in which the exception and exemption provisions interact
c. provide a tool or template to assist stakeholders in determining if an exception
applies.
It is also recommended that the CBD team consider amending the exception provisions
to include unsolicited offers as a transaction type excepted from the disclosure
obligation.
Response - 3
The Department launched a refreshed website on 2 May 2013, just prior to the
consultation period of the review. The refreshed site included updated information about
exceptions and exemptions to the CBD disclosure obligations. The Department will
assess feedback on the enhanced information and will continue to further refine
guidance material. The Department will also consider an alternative title for exception,
such as unrestricted, unobligated or not disclosure affected building or area.
In relation to exception provisions for unsolicited offers, this has been identified for future
legislation change.
4. Implement refresher training as a quality control mechanism and determine if, and what,
additional continuous improvement and quality control mechanisms are required, on the
basis of:
a. the first tranche of audit results
b. a commissioned study of the repeatability and consistency of TLA assessments.
Response – 4
The Department has recently completed the first round of level 2 audits. A report is being
prepared summarising the audit results and the Department, if required, will review
training materials and the need for refresher training to address any systematic errors
identified. The revision of the TLA rules was initiated following feedback form assessors
and the revised rules introduce additional methods of assessment and worked examples
making the assessment process easier for assessors to undertake. The Department will
Department of Industry - Response to Recommendations
Review of the Operational Efficiency of the Commercial Building Disclosure Program
continue to assess feedback from assessors about the revised rules and once they have
been in place for 12months will conduct a repeatability study if required.
5. Where possible, adopt the following opportunities to reduce, and improve consistency of,
processing timeframes:
a. further devolve issuing authority responsibilities to reduce delays in obtaining
approval for the TLA and BEEC
b. change data sharing arrangements of the NABERS Energy rating to an opt-out
system, rather than opt-in to reduce instances of unintentional non-provision
c. combine the TLA and BEEC application processes to reduce the total elapsed
time to obtain a BEEC.
Response - 5
The Department implemented a major upgrade for the IT systems for TLAs and BEECs
processing in May 2013 including introduction of a new CBD Assessor Portal and daily
instead of weekly updates of NABERS data. The new IT system has streamlined the
process which has led to an improvement of the processing times for TLAs and BEECs.
This improvement can be seen in the graphs below that show the actual processing days
for TLAs and BEECs, noting that the Department has undertaken to ensure processing
times are within 21 and 28 calendar days respectively. The Department will continue to
closely monitor processing times to ensure they remain consistent. The Department will
also work with NABERS National Administrator to change the data sharing arrangements
to an opt-out system. In relation to devolution of issuing authority responsibilities, this
has been identified for future legislative change.
6. Investigate the adoption of business rules which would allow the BEEC’s full 12 month
validity period to be granted.
Response - 6
The Department already works with portfolio agents to streamline processes and
maximise possible validity periods in tandem with NABERS National Administrator. The
Department will investigate further opportunities, noting this is legally complex and in part
dependant on constraints in legislation and the NABERS rules.
7. Adopt the following suggested improvements to the assessor register and monitor the
success of recent improvements to the BEEC register.
a. Potential assessor register improvements are the inclusion of a method of
identifying both whether an assessor actively undertakes assessments and which
locations the assessor (or company) operates in.
Response - 7
The refreshed website released on 2 May 2013 included a user-friendly Assessor
Register with search capability. The Department will investigate further enhancements
to the CBD Assessor register and IT system that will give assessors the ability to selfinput and manage information about their availability to conduct assessments for third
parties and which locations the assessor operates in.
Department of Industry - Response to Recommendations
Review of the Operational Efficiency of the Commercial Building Disclosure Program
8. Seek a more detailed assessment of the cost impacts of the program in the effectiveness
evaluation due to be undertaken in 2015.
Response - 8
The Department will include an assessment of cost impacts in the proposed
effectiveness evaluation, scheduled to be undertaken in 2015.
Department of Industry - Response to Recommendations
Review of the Operational Efficiency of the Commercial Building Disclosure Program