ARU supports a Net Zero Carbon policy which aligns with its own Zero Carbon targets. ARU also agree that requirements should be ambitious but also need to be realistic/deliverable. It is though considered that requirements such as these are best set at a national level, with consistent methodologies (and expertise). Any policy also needs to differentiate between new buildings and refurbished buildings, recognising the difficulty in refurbishments meeting the same standards as new buildings.

Notwithstanding these comments, the policy needs to clarify that m2 refers to GIA and clarify that Total Energy Use Intensity (EUI) targets exclude renewable energy contribution. Higher education teaching facilities EUI targets also need amending and disaggregating as follows:
a. General HE teaching space – 65 kWh per m2 per year
b. HE science/lab/medical teaching/research space – 150 kWh per m2 per year
c. HE office space – 55 kWh per m2 per year