The Impact of COVID-19 on NABERS Ratings

Frequently Asked Questions

The rapid and unprecedented spread of COVID-19 and subsequent containment measures taken by government have altered the way we work.  A vast majority of building occupiers have been working from home, which has disrupted operations of commercial buildings many of which were never designed to operate at such low occupancies.  This in turn has encouraged building owners, portfolio and asset managers, sustainability consultants, energy managers and other stakeholders to better understand:

• Different ways to optimise building operation and remove non-essential expenses without impacting occupier health and wellbeing
• The impact of factors such as low occupancy, estimated meter readings and compliance on sustainability ratings including GRESB, NABERS, GreenStar, TLA, WELL and others.

Our team of NABERS experts have been closely following the advancements and updates in this space and have compiled this document to provide information and insight regarding the effects of COVID-19 on NABERS Ratings for commercial office buildings.  All the information below is current as of the date of release, and in accordance with the latest ruling by NSW Department of Planning, Industry and Environment (Managing Impacts of COVID-19 on NABERS Ratings v2, issued on 5^th May 2020).  This is a live document and provisions in this ruling are valid until 30^th June 2020.  Further, these are subject to change prior to and/or after 30^th June, as NABERS continue to assess what remains a dynamic situation.

1. My building’s occupancy has significantly reduced, will it still be eligible for a NABERS Rating?

Yes, buildings remain eligible for a NABERS rating with the data that is available.  Buildings continue to be certified across Australia.

NABERS are continuously working on updating specific rulings due to the COVID-19 situation to help mitigate the issues surrounding delivery and comparability of ratings.  As of the date of this document, they have determined that the affected period is currently the 23rd of March 2020 – 30th of June 2020.

Buildings will still be rated as long as the data required (as stated in the rules NABERS Energy and Water for Offices v4) is available.

2. If my building is operating on low or zero occupancy, how will this affect my NABERS Rating?

Low occupancy in the building will likely have the most impact on computer count and Tenant Occupancy Survey (TOS) for Whole Building and Tenancy ratings.

For Computer Counts, the assessor can use a combination of the number of computers from a previous rating, photos, video and/or virtual tours and confirmation from tenants regarding the number of computers in use.  For TOS, NABERS will allow the rating to be lodged in lieu of the survey providing supporting evidence and use of a lower priority method.  This is discussed in more detail in Q-10 and Q-11 below.

3. Do I need to provide an evidence that the building has been impacted by COVID-19?

In addition to the evidence requirements as per NABERS rules v4.0, the ruling Managing Impacts of COVID-19 on NABERS Ratings v2 permits evidence including photos and video recordings from virtual site visits, previous site visit notes, written correspondence between site management and tenants advising of reduced HVAC services and spreadsheets containing necessary information (e.g. BMS data).

4. Can I turn off the HVAC in unoccupied areas or make changes to the schedules?

As per the latest ruling Managing impacts of COVID-19 on NABERS Ratings v2, for the period during which this Ruling is valid, NABERS will place a moratorium on the use of the following data collected during the COVID-19 affected period (23^rd March 2020 – 30^th June 2020):

1. Energy and water consumption data;
2. Temperature data used for annual monitoring.

This means that assessors must not use data from the affected period as part of a rating application.  Hence, the site team can take such measures (e.g. turning off the HVAC in unoccupied areas as energy management measures), unless otherwise agreed with the tenants.

5. If the rating is due to be performed in Jun’20, can I use my building’s energy and water coverage till May’20 as this would uplift my rating due to the reduced usage in the government mandated lockdown period?

As per the latest ruling Managing impacts of COVID-19 on NABERS Ratings v2, energy and water usage between 23^rd March 2020 and 30^th June 2020 cannot be used for the rating.  This is because using this data will not provide a fair comparison for buildings which were rated prior to the affected period.  Assessors must still provide 12 months of continuous data as part of their rating applications.  To achieve 12 months of data, it is permissible to reuse data from the previous rating period (example below).

Example:               
Rating period for the previous rating: 2^nd April 2018 to 1^st April 2019Rating period for the current application: 23^rd March 2019 to 22^nd March 2020 Period of reused data: 23rd March 2019 to 1st April 2019

For the period during which this ruling is valid, NABERS will grant an extension of the rating lodgement period from 120 days to 180 days to ensure that the assessor and building managers get enough time to perform the rating in accordance with new guidelines.

6. Can I adjust the setpoints for unoccupied and/or minimally occupied areas in the building?

Yes, the site team can adjust the setpoints unless otherwise agreed or advised by tenants. NABERS ratings will not be impacted by this as energy consumption for the period from 23^rd March 2020 to 30^th June 2020 will not be used in the ratings.

7. What if the tenant requests to maintain the base building HVAC Services on vacant floors?

Depending upon the lease obligations, OTA and other agreements between building owners and tenants, the building manager may be required to provide base building HVAC to such areas.  However, due to significantly reduced occupancy and heat loads (with the onset of Autumn) in the Southern Hemisphere, control parameters should be adjusted to optimise energy consumption. Contact your MARS Engineer or Technical Services Manager at EP&T if you require expert guidance or assistance in identifying target areas for energy reduction.  NABERS Ratings will not be impacted by this as the energy usage for the period of 23^rd March 2020 – 30^th June 2020 will not be used in the rating.

8. I have agreed lease (core business) hours with tenants to provide HVAC services, if I turn off the plant early considering the area is only occupied till certain time, will it negatively impact my rated hours?

As per NABERS Energy and Water for Offices Rules v4, although the building owner is obligated to provide services during core hours, in some cases the owner knows that all the tenants have gone home by the end of the agreed hours and so will turn the air conditioning off early – until the tenant complains. This is an efficient and effective strategy that NABERS recognises, so the hours must remain as those stated in the OTA.  Hence, trimming of the plant schedule will not negatively impact the rated hours in your NABERS rating.

9. Due to the COVID-19 travel restrictions, if the assessor is unable to perform NABERS site assessment, will the rating still proceed?

The Ruling ‘Managing Impacts of COVID-19 on NABERS ratings v2’ provides certain provisions for the assessor if he/she is not able to visit the site due to COVID-19 restrictions.  The provisions include having another accredited assessor do the site visit, using the prior site visit evidences, using the non-assessor information for the rating and using conservative inputs when the building or tenancy is in access lockdown.  The assessor must accumulate written evidence regarding the site visit methods and prior approval from NABERS is required depending upon the method used.

10. In case of the vacant tenancy, how would the computer counts take place?

In order to use the computer count method specified in the ruling ‘Managing Impacts of COVID-19 on NABERS ratings v2’, the assessor must provide the following evidence:

1. Evidence of very low occupancy in the building and that this is directly related to COVID19.
2. Evidence that the computer counts or Tenant Occupancy Survey has or would have occurred between 1^st March 2020 and 30^th June 2020.

Alternative evidence of number of computers could include a combination of:

1. Computer count from the previous rating;
2. Photos or video from a virtual site tour;
3. Confirmation from the tenant that the figures for this rated period are similar, and/or;
4. Office floor plans or recent furniture audits.

The use of this Ruling is at the discretion of NABERS and will depend on the robustness of the alternative method proposed by the assessor. NABERS will assess whether the alternative evidence for computer count provides a fair representation of the number of computers in the rated period.

11. In case of vacant tenancies, how would the Tenant Occupancy Survey (TOS) be filled?

Assessors can use OTA hours minus 5 as rated hours, if the Assessor can provide following evidence:

1. Evidence that a valid OTA is available; and
2. Evidence that shows:
3. Current occupancy patterns are not representative of the rated hours; or
4. A valid TOS could not be sourced due to occupancy failing to meet the required minimum 20 % occupancy threshold.

12. How is the provision of BEEC and TLA affected by COVID-19?

Building owners are still required to comply with the disclosure requirements of the CBD program as it is legislated under the Building Energy Efficient Disclosure Act 2010.  If a NABERS rating was not completed due to technical reasons, building owners can apply for an exemption.  For example, if there is insufficient data due to vacancies over an extended period, it may not be possible to rate the building in accordance with the NABERS rules.  Applications for exemptions must be accompanied by a supporting statement made by a CBD Accredited Assessor detailing the reasons why a rating cannot be assigned. Further information can be obtained by visiting http://www.cbd.gov.au/does-this-apply-to-me/covid-19 or contacting info@cbd.gov.au directly.

13. Would a building with skeleton staff on all floors be considered fully occupied?

For rating purposes, the building occupancy will not change as long as the current lease is in place and the building is ready for occupation.

14. Some utility providers may not have access to their meters and hence, there coiuld be some estimated utility bills.  How would these be accounted for?

When one or more consecutive meter readings are missing or estimated by the utility, and valid meter readings are available for the period immediately before and immediately after these missing or estimated readings, the total consumption for the period can be accurately determined using the method described in the section 9.6.5 of NABERS Energy and Water for Offices Rules v3.2.

15. What is the period for moratorium/end date for the rating?

For the period during which this ruling is valid, NABERS will grant an extension of the rating lodgement period from 120 days to 180 days.  This ruling will not be applied retrospectively to ratings which have been created and lodged with NABERS prior to the publication of this version (v2.0) of the ruling.

For any further queries, please contact our team of experts at nabers@eptglobal.com.