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Through their new ‘be seen’ policy, the GLA are seeking to address a performance gap apparent between design estimates and actual in-use energy demands.

Whilst the guidance for the policy is still under consultation, the GLA are looking for the following, amongst other items:

  • Installation of gas, heat & electricity meters that enable central collation of data;
  • Submission of design stage data for regulated energy as well as unregulated cooking & appliances;
  • A transfer of reporting responsibilities to building owners;
  • Submission of in-use data for 5 years post-completion;
  • Where in-use data does not align with design estimates, the causes are to be investigated along with potential remedial measures.

Whilst the intent of the be seen policy is admirable, there remain a number of unresolved questions, including:

  • The guidance seems to be based on the unstated assumption that differences between design & operational performance are due to poor construction. The reality is that the way people use their home is equally as important and its very difficult to separate the issues without extensive investigations into a building and the people living in it;
  • How will data be collected for freehold houses where there is no management company?;
  • Is there any obligation to rectify the higher actual energy usage compared to the as built estimates, and if so, how will this be enforced?