Higher Education Carbon Management Programme University of Central Lancashire. Carbon Management Strategy & Implementation Plan 2010 Update

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1 Higher Education Carbon Management Programme Carbon Management Strategy & Implementation Plan 2010 Update Date: September 2010 Version: 1.0 Approval Status: Approved by University Board, Nov 2010 Project Leader: Ruth Taylor Energy & Carbon Mgmt Officer Project Sponsor: Paul Morris Director of Facilities Management Original Carbon Plan Produced March 2007

2 Carbon Management Programme - update Project Plan Date: September 2010 Version number: 1.0 Owner: Ruth Taylor Energy & Carbon Management Officer Approval: Paul Morris Director of Facilities Management Foreword from Carbon Trust 4 Management Summary 5 1 Introduction 7 2 Carbon Management Strategy Context and drivers for Carbon Management Strategic themes Targets and objectives 10 3 Emissions Baseline and Projections Scope Baseline Projections and Value at Stake 12 4 Carbon Management Projects Existing projects Planned / funded projects Near term projects Medium to long term projects Projected achievement towards target 25 5 Carbon Management Plan Financing Assumptions Benefits / savings quantified and un-quantified 25 2

3 5.3 Additional resources Financial costs and sources of funding 26 6 Actions to Embed Carbon Management in Your Organisation Policy embedding CO 2 saving across your organisation Responsibility making it clear that saving CO 2 is everyone s job Data Management measuring the difference, measuring the benefit Communication and Training ensuring everyone is ready, willing and able Procurement engaging suppliers Monitoring and Evaluation keeping track of progress 31 7 Programme Management of the CM Programme Strategic ownership and oversight The Carbon Management Team delivering the projects Ongoing stakeholder management Annual progress review 34 Appendix A: Carbon Management Matrix - Embedding 35 3

4 Foreword from the Carbon Trust Cutting carbon emissions as part of the fight against climate change should be a key priority for the Higher Education sector - it's all about getting your own house in order and leading by example. The UK government has identified the HE sector as key to delivering carbon reduction across the UK in line the Climate Change Act targets, and the HE Carbon Management programme is designed in response to this. It assists participants in saving money on energy so that it can be put to good use elsewhere, whilst making a positive contribution to the environment by lowering carbon emissions. The partnered the Carbon Trust on this programme in order to realise substantial carbon and cost savings. This Carbon Management Plan commits the University to a target of reducing CO 2 by 48% by 2020/21 and underpins potential financial savings to the organisation of nearly 800,000 per year by 2013/14. There are those that can and those that do. Universities can contribute significantly to reducing CO 2 emissions and public expenditure. The Carbon Trust is very proud to support the University of Central Lancashire in their ongoing implementation of carbon management. Richard Rugg Head of Public Sector, Carbon Trust 4

5 working Management Summary The University s medium term strategy, A World-Class Modern University spanning the period states; We will be a model international University for sustainability. Our sustainability strategy will ensure that the University becomes a carbon-neutral institution in 20years We will also ensure that our students are educated for global citizenship by integrating sustainable development, health and well-being into our curricula Malcolm Mcvicar Vice Chancellor, 4th July 2007 The University produced its first Carbon Management Plan (CMP) in March 2007 in association the Carbon Trust as part of the second phase of working in partnership higher education institutions. This updated Carbon Management Plan (CMP) is a 5 year action plan which contributes significantly towards reducing the 's carbon dioxide emissions by 48% by 2020/21, based on our 2005/06 baseline. UCLan have also set an interim target of 25% by 2011/12 which has been incorporated into the University's strategic plan. The table below gives an overview of the scale of this CMP and what we are looking to achieve. Investment needed Annual cost saving Annual tco 2 saving 2009/ / / / /14 815, , , , ,792 35, , , , , In January 2010, HEFCE committed the Higher Education sector to a target reduction of 48% by 2020 against a 2005/06 baseline. HEFCE s target is likely to influence our carbon management strategy beyond the 5-year period of this plan The urgent need to reduce global emissions of greenhouse gases (principally carbon dioxide) in order to prevent an excessive increase in mean global temperature is almost universally accepted by those who study the scientific data and is the context in which this plan is based. The drivers which elevate context into action are: It is the right thing to do. As the pace of globalisation accelerates, Universities must be foremost in responding to the major challenges that threaten our fragile world. The UK Government s current target is a reduction in carbon emissions of 34% by 2020 and 80% by 2050 (against 1990 baseline values). The Higher Education Funding Council for England (HEFCE) has committed the HEI sector to achieving these same targets, the aspiration to achieve still greater reductions. It has 5

6 Carbon (kg) working chosen a 2005/06 as its baseline year. Against this baseline, the 2020 target becomes a 48% reduction in carbon emissions. Financial penalties for failure to reduce carbon emissions are already in place (e.g. CRC Energy Efficiency Scheme) or expected (HEFCE Capital Investment Framework), and will likely increase in severity. In addition, the cost of energy can be expected to increase significantly in the near future. The remit of the CMP is restricted largely to reducing scope 1 and scope 2 emissions, namely, those generated directly from sources controlled by the University, and those generated by purchased electricity, respectively. The Plan includes: academic, residential and student Union buildings, conference/business facilities and fleet vehicles. Scope 3 emissions, largely related to procurement, business and commuter travel, are being researched outside of the CMP. This plan is 5-years in duration as per the Carbon Trust requirements and reasonable timescale for project planning. In the baseline academic year 2005/06 UCLan emitted 15,559 tonnes of carbon dioxide of which 99% (15,401 tonnes) was related to the energy requirements of buildings and 1% to transport. As indicated in the graph below, over the 5-year period of the plan, successful completion of all projects described in the plan will reduce carbon emissions in line HEFCE s target. Further planning will be required to maintain the trajectory of reductions beyond 2015, taking into consideration the achievement of this plan and external factors such as the carbon content of electricity. Chart 1: Target projections 20,000,000 Summary of Carbon Emissions and Targets 15,000,000 10,000,000 5,000, Year Graph Legend: Carbon Emission to Date Planned Reduction to 2015 (CMP) Planned Reduction from 2015 to 2020 Construction Lines 6

7 1 Introduction The (UCLan) has in excess of 32,000 students and 2725 staff. The city centre campus extends to 41 hectares and comprises of many buildings of varying age, some adapted for university use, others designed and built specifically for our use. As well as the main Preston campus, sites include UCLan Sports Arena, Burnley, Westlakes and Llangollen. As buildings account for 50% of the UK s total carbon emissions, it follows that our operations and buildings (totalling a gross floor area of circa 188,820m 2 do have a significant local, national and global environmental impact. If we add the effects of fleet vehicles and travel to and from the university it is easy to see that there is scope to reduce our carbon emissions significantly. The University accepts the overwhelming evidence that demands a significant reduction in greenhouse gas emissions and, by working the Carbon Trust, is seeking to define strategic and operational measures capable of reducing CO2 emissions by at least those agreed nationally and internationally. The Carbon Trust s Higher Education Carbon Management (HECM) Programme is based around a five-step process through which participating HEIs can create an organisation-wide carbon management strategy and action plan. The steps in the HECM process are as follows: The University has been steadily strengthening its focus on sustainability since 2007, and its key progress in areas related to carbon management is listed below: 2007: Original Carbon Management Plan published; Travel Co-ordinator appointed; Sustainable Development Strategy published; Travel Plan developed 2008: Energy & Carbon Management Officer appointed; Environmental and Sustainability Manager appointed; Energy Policy published; Internal carbon reduction budget provided; Environmental & Sustainable Development Steering Group formed; Pathfinder status achieved for the Carbon Trust Standard 2009: Highly Commended at Green Gown Awards for Carbon Reduction; Environmental web pages developed; Held first Carbon Awareness Week; 2010: Primary phase of ISO14001 audit completed; Developed a compulsory course on Environmental Management, which includes resource efficiency for contractors; Awarded Business Link North West Carbon Positive Footprint Award 7

8 working 2 Carbon Management Strategy The Vice-Chancellor has expressed his strong support for the HECM programme and for this Carbon Management Plan. The CMP will be published on the University intra- and internet websites. Future reviews of University strategy will consider including sustainability as one of the underpinning tenets of corporate strategy. This wider view will also include specific reference to reduction of CO 2 emissions. 2.1 Context and Drivers for Carbon Management The purpose of this updated Carbon Management Plan is to present a comprehensive plan to reduce carbon emissions across the entire University estate by 25% compared to the Business As Usual (BAS) scenario, against our baseline year of 2005/06 and to further reduce baseline emissions by 48% by 2020 in line HEFCE Carbon Reduction strategy. Available scientific evidence indicates that global average temperature is continuing to rise in a manner that is related to (and caused by) elevated atmospheric concentrations of greenhouse gases, most notably CO2. This threat to global climate posed by increasing CO2 emissions is already defining new policy, regulation and legislation locally, nationally and internationally. At the Copenhagen Climate summit in December 2009, big emitter nations agreed to continue negotiations on CO2 reduction policies. They will meet again in June and December 2010 where there is the intention to set binding targets. Whether this will be in the UNFCCC Kyoto framework is in question. There were also some limited commitments to funding for developing nations to adapt to change, reduce deforestation and adopt low carbon technologies. The Climate Change Act, which sets legally binding emissions reductions of 34% by 2020 and 80% by 2050 over a 1990 baseline. This Act has cross party support, and the public sector is expected to lead the way towards meeting the targets. Display Energy Certificates: As of 1 October 2008 there is a legal requirement for all public sector buildings a total useful floor area of over 1,000m 2, to show a Display Energy Certificate (DEC) in a prominent place, clearly visible to the public. Carbon Reduction Commitment (Energy Efficiency Scheme): The Carbon Reduction Commitment is a mandatory cap & trade emissions trading scheme for organisations whose total electricity consumption is greater than 6,000MWh or approximately 500k. If an organisation falls in the CRC scheme all electricity and fuel emissions are covered. From 2010 poorly performing Universities will be penalised depending on their position in a CRC league table. HEFCE Carbon Reduction Strategy: the Higher Education Funding Council for England developed a carbon reduction strategy for the HE sector, released in HEFCE committed Higher Education Institutions (HEIs) to the Government targets in respect of scope 1 and scope 2 emissions. An academic baseline year of 2005/06 has been set, against which to monitor carbon emissions. Using this baseline, HEFCE s target reduction is 48% by 2020, the aspiration to achieve still greater reductions. HEFCE also proposes that the HEI sector commits to making reductions in scope 3 emissions, the intention of setting targets for these emissions once protocols are more developed. HEFCE is also expected to link the distribution of future capital funding to institutional performance against carbon management plans. Scope definitions are as follows: scope 1: direct emissions that occur from sources that are owned or controlled by the organisation, for example emissions from combustion in owned or controlled boilers, furnaces, vehicles; scope 2: emissions from the generation of purchased electricity consumed by the organisation; 8

9 working scope 3: all other indirect emissions which are a consequence of the activities of the organisation, but occur from sources not owned or controlled by the organisation for example, commuting and procurement. The UK Government has placed an emphasis on the public sector setting a leading example on Climate Change. Public sector leadership will be critical to the achievement of the Government s climate change objectives, such as the long term goal to reduce CO2 emissions by 80% by 2050 in the Climate Change Bill. This has created a number of legislative drivers for public bodies to reduce carbon emissions. Finally, measures to increase energy efficiency will reduce energy costs, which is particularly important for the future given the predicted increases in energy prices. Energy and fuel costs have seen a dramatic rise in recent years, energy prices increasing by over 50% since This trend is not expected to change and we must accept that the price we pay for our energy will continue to increase in the coming years. 2.2 Strategic Themes The aim for UCLan is to increase energy efficiency, moderate energy demand and reduce carbon emissions. Ways in which we will achieve our aims are highlighted in the following sub-sections: Strategic Themes Policy review Responsibility Data Management Communication & Training Valuing sustainability in Procurement Monitoring & Evaluation Overview UCLan has a number of policies in place that are relevant to reducing our carbon footprint, including our Sustainable Development Environmental Policy. We will review our policies the intention of developing and implementing policies such as an Energy and Carbon Management Policy to support and sustain the reduction in CO2 emissions. The University s medium term strategy, A World-Class Modern University spanning the period states; We will be a model international University for sustainability. Our sustainability strategy will ensure that the University becomes a carbon-neutral institution in 20years We will also ensure that our students are educated for global citizenship by integrating sustainable development, health and well-being into our curricula Malcolm Mcvicar Vice Chancellor, 4th July 2007 UCLan will enhance its monitoring and targeting to allow a greater understanding, and therefore control of energy usage across the organisation. This includes sub-metering, automatic meter reading equipment (AMR) and the use of Team Sigma M&T software. Training is rolled out in various formats including induction of new staff, over 400 existing staff members have been trained in Environmental Management. Annual Carbon Awareness Week held for both staff and students. Use of sustainability requirements as selection criteria for contractor selection on all development work. Promotion of energy efficiency in procurement of products/services addressing issues of life cycle costing. Inclusion of sustainability requirements in all tendered contracts and key performance indicators. Key Performance Indicators are produced on a monthly, quarterly and annual basis. Information obtained from AMR data and Team Sigma M&T software. 9

10 2.3 Targets and Objectives At the start of the Programme the Sponsors have set an aspirational target, the practicality of which will be explored by identifying CO2 saving projects and assessing their implications. The final, substantiated target will be ratified in the Carbon management Plan (CMP). will reduce CO 2 emissions from its activities from the 2005/06 baseline, by 48% by We have set an intermediate milestone to reduce emissions by 25% by August Emissions Baseline and Projections 3.1 Scope The scope of the CMP includes all UCLan buildings reported to HEFCE via the Estates Management Statistics and include:- Owned building energy use Building energy use for outsourced functions Lighting energy consumption Owned fleet fuel use Additional areas excluded from the current scope of this CMP at present but to be included in future version Organisation owned business travel Business travel for staff Employee commuting Waste produced by buildings and operations Water used in buildings and operations Refrigerant & other gas losses ( e.g. N 2 0) Reduction in consumption of goods & services 3.2 Baseline 2005/06 Buildings Transport Total Baseline CO2 emissions (tonnes) 15, ,559 Baseline Cost ( ) 1,915,000 36,622 1,951,622 10

11 By implementing the Carbon Management Plan (CMP), the (UCLan) will reduce the CO2 emissions from its activities by 25% by August 2012, compared to the business as usual baseline from 2005/06. The baseline carbon footprint for the University was 15,559 tco2e in 2005/06 80% deriving from non-residential buildings; 19% from residential buildings and the remainder from University fleet vehicles. A number of activities such as business transport were excluded from the initial scope as they could not be quantified for the baseline year. These will be included as appropriate as the CMP develops. Sports facilities 3% Student union 4% Preston Campus other 2% Fleet 1% Baseline 2005/06 Residential 19% Teaching/research/ admin/support 71% Material emission sources The material emission sources accounted for in the baseline include: Electricity (procured 50% on a green energy tariff and 65% renewable from ). Calculations used fixed CO2 emissions factors for grid electricity based on the UK national fuel mix. Although the University procure renewable electricity; 100% of the consumption is included in baselines and targets. Gas (used for district heating, decentralised heating boilers, kitchens and laboratories) Fuel (diesel and petrol) for University fleet vehicles. The baseline year chosen for this Carbon Management Programme is 2005/06. The energy consumed was taken from utility invoices for the academic year (Aug July) 2005/06 and then compared the data submitted to HEFCE via the Estates Management Statistics. Gross internal floor areas have also been taken from the Estates Management Statistics. Factors used to calculate the greenhouse gas conversion GHG are listed below:- 11

12 2005/6 2006/7 2007/8 2008/9 2009/ / / / / /15 Carbon emissions (kgco2) working Estimate of emissions CO2 emissions, including equivalent gasses (eq) have been calculated by using Dept for Environment and Rural Affairs, updated September 2009, which have been reproduced here for convenience. Any amendment to the conversion factors or the carbon intensity of the electrical grid should be highlighted accordingly. Table 1. CO2eq factors for various fuel types (Source: Guidelines to Defra / DECC s Greenhouse Gas Conversion Factors for Company Reporting *Electricity factor used for 05/06 was Energy Type CO2eq Factors kgco2eq/kwh Electricity * Gas Gas Oil LPG Table 2. CO2 factors for transport fuels (Source: Guidelines to Defra / DECC s Greenhouse Gas Conversion Factors for Company Reporting) 3.3 Projections and Value at Stake Transport Fuel CO2 Factor Co2 Units Diesel kgco2/l Petrol kgco2/l LPG kgco2/l 18,000,000 16,000,000 14,000,000 12,000,000 10,000,000 Comparison of actual emissions BAU increases and reduction targets predicted 2014/15 Value at Stake 5,924tCO2 8,000,000 6,000,000 4,000,000 2,000,000 - Actual emissions BAU emissions Target Year 12

13 4 Carbon Management Projects Projects designed to reduce carbon emissions fall into four categories: existing funded projects; planned projects for which funding is approved; near-term projects for which funds need to be identified; and medium-to-long term projects not yet planned in detail for which funds also need to be identified. 4.1 Existing projects The following projects are already underway in UCLan. Project: Owner (person) Department Description Half-hourly metering gas & electricity in buildings Energy & Carbon Management Officer Development & Maintenance section Our buildings are currently metered manual, monthly-read meters. This project is converting them to AMR. Benefits Financial savings: 41k per year (based on a 2% saving on consumption in these buildings, from awareness raising where consumption is unjustifiably high Simple payback period: 4.8 years CO 2 Emissions reduction: 330 tco 2 (one off) Funding Initial cost of implementing the project: 200k first year, operational costs 5k/yr thereafter Funding from Utilities budget. Resources No additional resource needed Ensuring Success Measuring Success Requires good working relationship between and LIS (IT support) Success will be measured through reductions in energy consumption Audits of buildings will be undertaken by the Energy & Carbon Management Officer, prioritised by energy consumption noted from monitoring activities; highest exception consumers actioned first. Timing Milestones / key dates Installation Jan 10- Dec 10. Analysis weekly thereafter Monitoring Tools used will be exception reporting using Team Sigma M&T software, used for benchmarking and target setting. The effect of energy efficiency measures will be analysed by watching for changes in consumption before and after action. 13

14 working Transport Policy The University has an existing Travel Plan which aims to reduce solo car usage for commuting by 18% over a seven year period and promotes the use of public transport wherever practicable. The emphasis of the travel plan is on commuter travel to and from work, which is outside the scope of this Carbon Management Plan. - Travel Plan Project: Reference: Owner (person) Department Description University Sustainable Travel Plan. Commuter Travel Travel Plan Co-ordinator Facilities Management, Business Services The University s Sustainable Travel Plan , Supporting Sustainable & Active Travel aims to reduce the dependence on solo car usage in the University community and encourage modal shifts to more sustainable modes. Benefits Environmental benefits through a targeted reduction in solo car commuting Employee benefits through a greater choice of transport options available and associated improvements in health and well-being Contribute to the University implementing an Environmental Management System and achieving ISO14001 A target of 18% reduction in solo car commuting for both students and staff has been set to Measures and initiatives to promote and improve the choice of travel options and encourage sustainable commuter modes will continue to be implemented. Funding From 2010/11 the Travel Plan will be funded from the central Environment and Sustainable Development budget 30k/year allocated for Travel Plan activities (operational and infrastructure). In addition, funds for marketing and promotion are available from the central fund. Resources A dedicated Travel Plan Coordinator is employed and the Travel Plan is implemented in the current resources. Ensuring Success Measuring Success Initiatives to encourage modal shifts are implemented and promoted widely using different communication channels. Special events are organised throughout the year to promote initiatives to different audiences. The scheme is heavily promoted, for example, 50% reduction in bus travel, reduction in parking fees for those car sharing, restrictions on parking permits for students. The annual staff Travel to Work and student Travel to Study surveys are designed to monitor progress against modal target. The staff travel plan has been undertaken since 2007, whereas the student travel survey was incorporated into the annual UCLan Student Survey in Timing The Plan is in place and implementation is ongoing. 14

15 working A new Transport Policy will be developed to address business travel and operational vehicle use across the University. Key issues to be considered will include: measures to encourage travel avoidance, including greater use of web-based or video conferencing already in place; voluntary offsetting provisions whereby individuals or departments can offset their business travel carbon footprints by funding carbon saving projects across the University; actions to encourage the choice of vehicles lower fuel consumption by staff hiring cars; environmental criteria for new vehicle procurement; the cost/benefit comparison between typically fuelled vehicles, biofuel from waste cooking oil and electric University fleet vehicles. Project: Reference: Owner (person) Department Description University Sustainable Travel Plan. UK Business Travel Travel Plan Co-ordinator Facilities Management, Business Services Development of a consistent process to collect business mileage by travel mode. Set targets and introduce measures to reduce the carbon emission of business miles. Benefits Establish baseline statistics on business travel miles by mode and agree carbon reduction targets for business travel Reduce the carbon footprint of business travel Financial savings through reducing unnecessary travel through greater use of web-based and video conferencing facilities. Contribute to the University implementing an Environmental Management System and achieving ISO Funding No specific funding required Resources A dedicated Travel Plan Coordinator is employed and the Travel Plan is implemented in the current resources. Ensuring Success Measuring Success Ensure that all staff across the University who either travel on business or authorised business travel are aware of the University s travel hierarchy and the carbon reduction targets. Targets will be set following the establishment of base-line statistics. Timing A trial is currently underway (September 2010) to test the process for collecting business miles. Baseline figures will be established during 2010/11 annual targets set for 2011/12 onwards. 15

16 Project: Owner (person) Department Description Foster Refectory new Boilers & CHP Energy & Carbon Management Officer Development & Maintenance section To replace existing atmospheric boilers and plate heat exchanger which are under capacity for current requirements new condensing boilers, CHP and buffer vessel Benefits Financial savings: 32k per annum on utilities plus an estimated 1000 per annum maintenance savings Plant fit for purpose Simple payback period: 4 years CO 2 Emissions reduction: 237 tco 2 /year Funding Funding from Sustainability budget. Resources No additional resource needed Ensuring Success Measuring Success Requires communication Refectory staff Completion of works over summer, when facility is at its quietest Success will be measured through reductions in energy consumption Feedback from users Timing Milestones / key dates Installation July 2010 Monitoring Sub meter installed as part of the CHP installation 16

17 4.2 Planned/Funded Projects These projects are already planned in detail funding allocated or identified. This portion of our work will also be derived from outcomes of auditing, including: Fabric improvements such as insulation Controls improvements to BMS, air-conditioning etc. Service Improvements, such as lighting Project: Owner (person) Department Description Boiler Optimisation Energy & Carbon Management Officer Development & Maintenance section To install boiler optimisation technology on to boiler plant. Initial trial carried out winter 2009 in Darwin building. Roll out to continue year on year Benefits Financial savings: Simple payback period: 2 years (based on pilot) CO 2 Emissions reduction: 154 tco 2 /year (once rolled out across campus) Funding Funding from Sustainability budget. Optimisation costs 1850 per unit. Anticipate rolling our 27 units. Resources No additional resource needed Ensuring Success Measuring Success Installation to be carried out just prior to heating season when boilers are used Success will be measured through reductions in energy consumption Timing Milestones / key dates Trial winter Roll out 2010, 2011 etc. Monitoring Gas meter reads/amr 17

18 Project: Owner (person) Department Description Boiler replacements Energy & Maintenance Manager Development & Maintenance section There are a large number of boilers across the University that are very old; many are unreliable creating a large number of emergency/maintenance callouts. Some are also obsolete, so any failure of a part immediately puts that Building into an emergency situation where spares cannot be procured in order to provide heating and/or hot water. Buildings in which boilers to be replaced:- Harrington, Students Union, St Peters Art Centre, Maudland Road, Vernon Building, Hanover, Livesey, Flyde, Adelphi In addition, over the years, each system is becoming less and less efficient, requiring excessive energy to provide heat and circulate that heat. New boilers are required which will relieve time spent maintaining old and inefficient systems, providing a resilient reliable heating source for our staff and students, and reduce energy consumption in dated systems. Renewable and low energy heating and hot water provision technologies could provide even lower energy consumption. Benefits Financial savings: 60k per year on utilities, plus an estimated 20k maintenance savings Payback period: 8-15 years CO 2 Emissions reduction: 508 tco 2 /year Funding Cost 1m from Maintenance Improvement budget and Sustainability fund. Resources No additional resource needed Ensuring Success Requires commitment to maintenance improvement budget Measuring Success Success will be measured through reductions in gas consumption Timing Milestones / key dates Installation Aug 10 - July 13. Analysis thereafter 18

19 4.3 Short/Near Term Project These are projects being planned for which funding is being actively sought. Project: Owner (person) Department Description Wind Turbine at UCLan Sports Arena Len Lewis Development & Maintenance section To install wind turbines at our Sports Arena Benefits Financial savings: 7,000/annum based on utility savings Good publicity CO 2 Emissions reduction: 49 tco 2 /year Funding Being sought externally Qualification for feed in tariffs (FIT s) Resources External feasibility study required Ensuring Success Accurate wind speed data Measuring Success Detailed feasibility study Success will be measured through generation meter Reduced electricity consumption Timing Milestones / key dates Feasibility to be carried out summer If feasible completion by July Medium and Long Term Projects These are potential project areas that are yet to be fully defined/detailed The following tables show the rationale and planned programme for energy conservation measures over the period until Only the period until 2012/3 is planned in detail, as there will no doubt be other, currently unsuspected, opportunities arising toward the end of that period. Funding for these measures will be via an internal financing commitment and the Maintenance Improvement Programme budget. 19

20 Investment Type Cooling BMS Cavity/Roof Insulation Timers Heating Insulation Lighting Motors/Inverters Fume Cupboards Refrigeration Voltage Reduction Water Rationale The focus of 2010/11 will be the installation of additional controls to reduce simultaneous heating and cooling, overcooling, overheating and out-of-hours use. Spend will decrease in future years as the A/C stock becomes better controlled. Products currently being trialed in 2010 include humidified water treatments and natural ventilation. In line the Energy Performance of Buildings Directive all air conditioning needs inspecting. As part of this work we have requested that a detail advisory report also be carried out advising of potential efficiency gains. This year we are conducting a full review of the existing BMS system and its settings. It is anticipated that 2010/11 will see investment in response to this such as additional sensors, outstations, etc. As we proceed the CMP, it will be necessary to consider investment projects longer paybacks such as Cavity Wall and Roof insulation. These projects will require considerable investigation, dependant on the results of a thermal image survey due to be carried out 2010/11. There are a growing number of leased vending machines across campus for hot beverages, cold drinks and snacks. Investigation needs to be made in which appliances we can put onto an integrated timers. We also use cold water chillers and hot water boilers in staff kitchenettes, which we are looking to install timers to, again to reduce out of hours consumption. A rolling programme for boiler replacement is on-going together the boiler optimisation controls. Thermostatic radiators valves should be fitted to every radiator. Controls are to be trialed in Halls of Residence in 2010 which automatically adjusts the temperature set point, unless manually overridden, which will adjust the temperature for one hour before returning to the original set point. Estimated cost of equipment per flat excluding installation is 500. We are looking at carrying out thermal imaging of our building stock to highlight any areas of concern. A budgetary cost for this has been included in 2010/11. We have conducted a trial of LED lamps in corridor areas and are keen to roll out LED both internally and externally. The cost is quite prohibitive at the moment, however we are anticipating large reductions in CO2, given that our main electrical load can be attributed to lighting. We are to investigate replacing existing belt motors centrifugal motors. Where possible motors will be fitted inverters. There is an ongoing project to install inverters across campus Fume cupboards are linked to the BMS, however are on constantly due to lack of control management. Local controls are required and are not currently available to users. We have approximately 48 fume cupboards on campus. Investigation needs to be made into refrigeration used in our catering outlets and in our science laboratories. Voltage reduction has been considered and may be appropriate in some buildings. However a project to modify our voltage from on-site substations is planned for 2010/11. AMR equipment is being installed to highlight out of hours consumption. Potential projects to include infrared operated wash basin taps, urinal controls and grey water harvesting. Investigation into bore holes is to be carried out for our Sports Arena. 20

21 Cost Annual Saving Ref Project Lead 1 Inverters - Harrington Capital Operational Financial CO 2 Main 4,413 2,070 Pay back % of Target Year 12.5 tco % Replace boilers - Kirkham Dev 24,800 8, tco % Boiler Optimisation - Darwin Main 5,550 4, tco % Boiler Optimisation - South Campus Main 7,400 18, tco % Wind Turbine - Westlakes Dev 16,370 1, tco % CHP & Boilers installed - Victoria Dev 200,000 16, tco % Solar Trackers - Harrington Dev 75,282 1, tco % Ground Source Heat Pump - Westlakes Dev 22,646 1, tco % LED Corridor lighting - Greenbank Main 1, tco % CHP & Boilers installed - Foster refectory Dev 130,000 50, tco % Vernon boilers from oil to gas Dev 150,000 7, tco % Boiler Optimisation - Greenbank Main 7,400 3, tco % Boiler Optimisation - Brook Main 5,550 3, tco % Solar Thermal - Adelphi 15 Transformer - North Ring 16 Boilers - Library Dev 35,000 1,330 Main 7, ,503 Dev 30,000 19, tco % tco % tco % EcoCoolling - Maudland Dev 4, tco2 new 0.00% Removal of personal printers LIS 0 8, tco % Inverters & pumps - Greenbank (x16) Main 39,000 22, tco % Boiler Optimisation - Fylde Main 3,700 1, tco % Boiler Optimisation - C&T 22 Insulation - Foster Main 9, Dev 20,000 1, tco % tco % External Street Lighting - Sports Arena Main 35, tco %

22 24 Boilers 15/16 Maudland 25 Boilers - Adelphi phase 2 Dev 3, Dev 35,000 7, tco % tco % Supply fan upgrade BMS - Leighton Main 10, tco % CHP & boilers - Student Union Dev 50,000 5, tco % LED Corridor lighting - Greenbank (9 corridors x 4 floors) Main 70,128 2, tco % LED Corridor lighting - Harrington Main 70,128 1, tco % Insulation - Flyde 31 Insulation - Greenbank 32 Insulation - Harrington 33 Insulation - Harris 34 Boiler - St Peters 35 CHP & Boiler - Harrington Dev 20,000 3,439 Dev 20,000 3,600 Dev 20,000 3,240 Dev 20,000 3,240 Dev 8, Dev 40,000 6, tco % tco % tco % tco % tco % tco % Heat Recovery - Harrington Dev 30,000 1, tco % Inverters & pumps - Harrington (x18) Main 43,875 29, tco % Insulation - Livesey 39 Insulation - Victoria 40 Vending Timers - campus Dev 20,000 2,760 Dev 20,000 3,000 Main 6,000 8, tco % tco % tco % Internal Corridor Lighting - 24hr bldings Main 200,000 27, tco % Internal Corridor Lighting - Roeburn Main 22,000 8, tco % External Lighting - Car Parks/Halls Main 35,000 30, tco % Boiler - Hanover Main 20, tco % Pipework insulation - Fylde, Harris, Livesey, Leighton, Victoria Main 10,000 4, tco % Wind Turbine USA 120,000 8, t % TRV's - Leighton, Adelphi, Main 4,000 1, tco %

23 48 Optimisation - Kirkham/Hanover Main 11,100 1, tco % LED Lighting - Harrington Reception Main 10,000 1, tco % External Lighting LED - Library Main 7,000 1, tco % Whitendale Halls Honeywell heating controls Dev 40,000 11, tco % Removal of electric heaters 1,000 17, tco % Timers on zip water boilers Main 1, tco % Inverters - Greenbank 55 AMR electric 56 Inverters - Brook AHU (8) Main 2,438 22,916 Main 100,000 2,500 40,294 Main 27,504 11, tco % tco % tco % External Court lighting - Sports Arena Main 96,000 18, tco % Remote power down AV equip LIS 5,000 18, tco % Upgrade Zone valves & Ctrols - Leighton Main 10,000 1, tco % AMR gas Main 100,000 2,500 13, tco % Automatic PC switch off LIS 5,000 1, tco % Full virtualisation of test environ. LIS 10,000 18, tco % Switch off old servers LIS 0 5, Servers to blades LIS 0 1, tco % tco % Replace IT switches more efficient ones LIS tco % Exemplar building 67 Exemplar building Dev 570,000 8,505 Dev 100,000 2, tco % tco % Solar PV - SU 250, tco % South Campus Boilers 70 BMS Upgrades campus Dev 350,000 11,079 Main 50, tco % tco % Solar PV - Media Dev 250, tco %

24 72 Boilers - Fylde Dev 35,000 12, tco % Reduction in Estate size 0 37, Reduction in Estate size 0 51, tco % tco % EcoCooling - server room 76 EcoCooling - server room 77 Fume Cupboard controls 78 Vernon Lighting LED's 79 Flyde LED lighting 80 Kirkham LED lighting 81 Inverters - Adelphi (6) 82 Inverters - Darwin AHU (8) 83 Inverters - SU (2) 84 Double Glazing - Victoria 85 Lighting controls Dev 21,000 73,440 Dev 21,000 73,440 Dev 20,000 12,204 Main 250,000 19,800 Main 300,000 13,584 Main 85,000 7,963 Main 14,628 2,700 Main 27,504 11,457 Main 4,876 1,080 Main 400,000 2,009 Main 250,000 31, tco % tco % tco % tco % tco % tco % tco % tco % tco % tco % tco % 2011 Projects a 10+ year payback form part of the plan to replace redundant and end of life equipment. The whole replacement cost has been included rather than just the cost difference between like for like replacement and highly efficient replacement to ensure project costs are fully accounted for. 24

25 working 4.5 Projected Achievement towards Target 18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 - Carbon progress against target Year Predicted Business as Usual Emissions Target Emissions Emissions in chosen plan 5.0 Carbon Management Plan Financing UCLan is committed to investing in new technology to achieve reductions in greenhouse gasses (GHG). This investment will encompass CHP, energy efficiency, better design and renewable technologies. 5.1 Assumptions The key assumptions made in calculating the benefits and savings are: Electricity 9p/kWh Gas 4p/kWh Business as usual (BAU): 11.6% cost increase per annum and a demand increase of 0.7% per annum Conversion factors used are Defra s GHG updated Sept Gas conversion factor is based on the Gross Calorific Value 5.2 Benefits/Savings Quantified and Un-quantified The quantified benefits of this approach will be to: contribute to HEFCE carbon reduction targets for the sector; generate new ideas and opportunities for collaboration industry partners; lead the sector during the inevitable move towards a low carbon economy; encourage students to study at UCLan; and save substantial expenditure for the University that can be reinvested in core activities Carbon Plan Savings Annual saving energy costs Annual CO 2 saving 2009/ / / / /14 35, , , , ,

26 working Un-quantified benefits: There are a number of un-quantified benefits identified against which it is hard to place a monetary value, these are as follows: Staff and student health University reputation Staff and student recruitment and retention Decreased risk from volatile energy markets Effect on climate change from the impact on the behaviour of staff, students and the community 5.3 Additional Resources UCLan have used grant funding for its renewable projects from BRE Low Carbon Buildings Programme. This funding stream has now ceased, however we research available grant funding and have contacted external organisations regarding the potential funding of the turbine project at UCLan Sports Arena. We have fully investigated the Salix funding, but have reached the conclusion that an internal budget, whilst available, was less of an administrative burden, given our current staff resource. 5.4 Financial Costs and Sources of Funding Anticipated 2009/ / / / /14 Total annual capital cost 815, , , , ,028 Total annual operational cost 0 0 4,856 4,810 4,763 Total costs 815, , , , ,792 Committed Funding Committed Annual Funding Grant Funding Grant Funding Received 300, ,000 1,000,000 1,000,000 1,000, ,204 Figures in red are projected costs/funding 26

27 working 6 Actions to Embed Carbon Management in Your Organisation 6.1 Policy alignment Environmental Policy Governance and implementation of the University Sustainable Development Strategy is through the Environment and Sustainable Development Structure. The structure consists of a number of working groups the aim of improving coordination and cooperation in the pursuit of sustainability across the University. Membership consists of service, academic staff as well as student representation. There are six working groups, which include Travel, Biodiversity, Sustainable Procurement and Carbon Management. All Chairpersons for these working groups report to senior management via the Environmental Management and Sustainable Development Steering Group meetings (3 per year). Sustainable Development Strategy.pdf Energy and Carbon Management Policy (ECMP) The Energy and Carbon Management Policy is already available on UCLan s website and addresses key issues relating to energy conservation across the University. The ECMP supports the CMP by providing a statement of UCLan s commitment and provides a general overview as to how we anticipate to meet our targets and embed carbon management across the organisation. Key sections include: To create and maintain high profile for carbon management & reduction To reduce the amount of pollution, particularly CO2 emissions by 25% by the year To undertake an Energy Benchmarking Programme to highlight poor performing buildings based on energy consumption against appropriate criteria. To invest in a continuous programme of energy saving measures to reduce utility consumptions. To safeguard the achieved reductions by continually monitoring the Performance Indicators. To raise the awareness of staff and students on energy conservation matters and the environmental impact of the University's travel demands the co-operation of all stakeholders. To promote and improve sustainable methods of transport such as public transport, walking, cycling and car sharing the University can reduce its carbon footprint. To adopt good housekeeping practices To fully utilise our Building Management System to effectively and efficiently manage fossil fuel consumption in our buildings. Sustainable buildings The Energy & Carbon Management Plan also sets standards for all new buildings and major refurbishment projects. The Policy sets an environmental benchmark for buildings that will set Local Government planning requirements and HEFCE capital spend guidelines as a minimum. It is anticipated that the Sustainable Buildings Policy will require that all projects covered by the policy will aim to achieve an Excellent rating in the new BREEAM for Universities certification scheme. 6.2 Responsibility UCLan s approach, links in its Sustainable Development Strategy and related implementation plan spanning the entire institution. Our 7 key objectives each have a Working Group of experts from the University s academics, support staff, students, and Student and Trade Union representatives. 27

28 Influence Reduction potential working Each group is responsible for the achievement of their objectives, including the design of campaigns and the prioritisation of actions for future versions of the plan in the University s developing Environmental Management System, which we anticipate to be operational by autumn In addition to the Working Groups, the University also has 4 forums whose aim is to increase the effectiveness of its work on Biodiversity, Community, ICT and general staff concerns. The Working Groups feedback into the Environmental & Sustainable Development Steering Group. The Steering Group is chaired by the Executive Director of Operations, who reports to the Board on Sustainable progress in the organisation. Individual or Group Their interest or issues Means of Communication Students Staff Facilities Management Senior Management Team (SMT) Environmental & SD Steering Group Environment Staff Forum External Community M M Environment in which they live and study. M M Working environment. Global climate change H H Influence design of new build, refurbishments, maintenance. H H Setting of strategies. Internal funding opportunities. Image of organisation H H Responsible for Sustainable Development for the organisation. Reports into Board M M Suggestions for efficiencies. Highlighting issues L L Working in partnership. County carbon emissions Student Union officer. AU Lookout. Plasma screens. Lectures. Helpdesk. Internet. National league tables. Internet and Intranet. Footprints newsletter. Helpdesk. Development, Maintenance & Estates (DME) monthly meeting SMT meetings. Update from Env. & SD Steering Group. Bi-annual updates from Director of. Working Groups reporting back into Steering Group. Reports to Board. Regular meetings, ideas fed back by Environment Manager Press releases. Close working relationship Local and County Councils. Building Managers M H Assistance in implementing initiatives across campus. Management Team meetings. s. Helpdesk Teaching Support Technicians M M Suggestions for efficiencies. Technical support. Responsible for AV equipment. Monthly LEG meetings. Carbon Management Team meetings. Influence: the level of influence on the successful outcome of the Programme - High (H), Medium (M) or Low (L) Reduction potential: to what extent can they directly or indirectly reduce carbon through their actions or decisions- High (H), Medium (M) or Low (L) 28

29 6.3 Data management UCLan currently records its energy consumption & expenditure using monitoring and targeting software directly from invoicing information. In addition all gas and electricity meters and sub meters are read on a monthly basis. Other fuels (oil & LPG) are monitored through delivery notes. The building data included in the HECM baseline calculations is taken from current and historical energy records. UCLan are currently rolling out automatic meter reading technologies across gas, electric and water meters to allow a better understanding of energy and water consumption in individual buildings and over time. The data is taken every half hour and will be transmitted to the server on a daily basis. The Energy & Carbon Management Officer will take responsibility for analysing and interpreting the data in order to: establish accurate baseline consumption, building by building monitor the success or otherwise of carbon saving projects; identify new opportunities; provide clear feedback on energy performance to the Sustainable Development Steering Group and to the wider University. The data from these monitoring programmes will be available on the internet. These will have the greatest impact if the data is available at a range of temporal resolutions to allow them to be compared on hourly, daily, monthly and annual timescales. All buildings over 1000m 2 legally have to display an Energy Certificate, identifying how much energy the building has utilised in the previous 12 months. A Display Energy Certificate analysis will be used as a tool to identify areas of improvement to building performance; the results of which will be internally and externally reported on an annual basis. Transport The usage and vehicle description data for fleet and academic transport is obtained from vehicle fuel logs. The emissions calculations are based on fuel consumption and therefore forecasts are extrapolations of average consumption rates based on the estimated growth of the University. Plans are currently being developed to include all University business travel in the carbon footprint. It is intended to capture most data through new web-based travel and subsistence forms together greater information requirements on invoices for air travel. 6.4 Communication and Training UCLan s has seven Working Groups of cross functional experts including; academics, support staff, students, and Student and Trade Union representatives. Each group is responsible for the achievement of their objectives, including the design of campaigns and the prioritisation of actions. The University also has 4 forums whose aim is to increase the effectiveness of its work on Biodiversity, Community, ICT and general staff concerns. There is an informal Sustainable University Group (SUG) who meets to share and discuss ideas. The group are also at the moment developing their own voluntary Environmental Champion roles. UCLan hold an annual Carbon Awareness Week identifying ways in which staff and students can reduce their carbon footprint. Awareness areas include buildings, transport and at home. 29

30 working Over 400 staff members have completed environmental training, by either attending a training session or carrying out our on-line training programme during The University s staff induction programme includes a course on Environmental Management at UCLan. It explains to staff that the use of energy, fuel and water is a significant environmental aspect of University operations. The course highlights the responsibility all staff hold in reducing this aspect of operations by using examples of operational controls, such as, training, checklists and key messages like: We turn off our computers and monitors when we leave at night. We report building, energy and utilities faults promptly to the Helpdesk. Toolbox talks have also been developed for support staff, such as cleaners and security. Environmental web pages have been developed covering a wide range of aspects, including; Guidance & Procedures, Sustainable travel, Waste & Recycling, Awards & achievements Procurement As a large consumer of goods and services, the University has a key role to play in protecting the environment. Purchasing decisions have enormous potential to promote environmental protection. Therefore the Purchasing Office will seek to: meet and, where appropriate exceed the requirements of all relevant legislation - where no regulation exists, we will set our own standards informed by relevant codes of practical and guidelines. seek to reduce our consumption of material, re-use where possible and promote recycling and the use of recycled materials; seek to dispose of materials in an environmentally sensitive manner; promote and manage energy efficiency in all our operations and incorporate effective energy measures wherever possible; influence our major suppliers to minimise the negative impact of their operations on the environment. In conjunction the North Western Universities Purchasing Consortium and the other Member Institutions, the University will endeavour to:- consider goods and services which can be manufactured, used and disposed of in an environmentally aware way; give preference, where items are of a similar standard and cost, to those that are manufactured a high recycled content; wherever possible, specify items that can be recycled or reused; consider the energy usage/cost of operating equipment prior to purchase; favour suppliers that are committed to environmental improvement; consider whole life costs of and impacts when assessing equipment for purchase; ensure that suppliers hold or are actively working towards certification for its environmental The Head of Procurement chairs the Procurement Working Group and as such also sits on the Environmental & Sustainable Development Steering Group. 30

31 6.6 Monitoring and Evaluation UCLans carbon emissions baseline is not yet regulated through commitment to any external scheme such as the EU ETS, however we do qualify for the Carbon Reduction Commitment (Energy Efficiency scheme). UCLan was awarded the Carbon Trust Standard in 2008, which is seen as a credible, independent scheme which enables the organisation to demonstrate a commitment to and achievement of carbon footprint reduction. Key Performance Indicators (KPI s) are produced on a monthly, quarterly and annual basis detailing consumption in kwh, CO 2 absolute emissions and CO 2 normalised against gross internal floor area (GIA). Performance of utility metrics are reported to HEFCE on an annual basis, via the Estates Management Statistics. Carbon Management Plan will be reviewed internally on an annual basis KPI s reported to the University Resource Committee. Implementation of projects in the CMP is also reviewed by the Carbon Trust annually. Progress in the Carbon Management Team is reported back to the Environmental & Sustainable Development Steering Group meeting which is held three times per year. 7. Programme Management of the CM Programme In order to be successful, the University recognises the need for good Programme Governance, which will encourage: senior, strategic ownership of the carbon reduction target; bringing together, in one place, the diverse set of projects across the University; oversight of the Programme to encourage delivery by the identification and removal of blockages; project owners coming together to ensure coherence and coordination of carbon reduction activity 31

32 7.1 Strategic Ownership & Oversight The (Deputy) Project Lead will chair quarterly meetings of the CM Team to review progress on activities and projects, identifying any blockages that need to be raised the Environment & Sustainable Development Steering Group. University Board University Resources Committee Vice Chancellor Executive Director Operations University Safety,Health & Environment Committee Environmental & Sustainable Development Steering Group Carbon Management Team 32

33 7.2 The Carbon Management Team Delivering the Projects Role Name and position in HEI Contact details Project Leader Deputy Project Leader Carbon Management Team members Ruth Taylor Energy & Carbon Management Officer Mick Errington Energy & Maintenance Manager Pete Hill SHE Adviser Andy Coverdale Business Services Manager Roberta Foster Finance Supervisor Dr Andrei Chamchine Lecturer Keith Parkinson Senior Room Technician Student Union Campaigns Officer Student Representative Clair Challen Travel Plan Coordinator Sarah Buckland Environment & Sustainability Manager Jane Anthony Head of Development & Business Enhancement Paul Morris Director Facilities Management George Hall Academic Co-ordinator

34 7.3 Ongoing stakeholder management Bodies that will be kept informed of our progress are: New Staff through the induction process New students, through welcome literature, Carbon Awareness Week and Freshers Fair Technical Staff in charge of high energy users, through monthly consumption reports Commuters, through the bi-monthly Travel to Work Implementation Group Environmental & Sustainable Development Steering Group through quarterly meetings and intervening ad-hoc reports Other Universities via the Environmental Association for Universities and Colleges. 7.4 Annual Progress review We will formally review progress to Board members annually. The review will include: consumption kwh CO2 savings against target normalised by gross internal floor area Absolute CO2 emissions year on year Progress made towards target Cost savings achieved 34

35 ECM Alumni Self Assessment; Management and Technology Progress in embedding of Carbon Management Date of Assessment: 02/09/10 TARGET & EVALUATION RESPONSIBILITY DATA MANAGEMENT INTERNAL COMMUNICATION FINANCE & INVESTMENT PROCUREMENT 5 BEST SMART carbon targets in Action Plan signed off Target & Strategy launched internally & externally Progress against Targets regularly reviewed & published internally & externally Visible SMT level review CM is full-time responsibility of a few people CM integrated in responsibilities of senior managers VC / Principal support Part of all job descriptions Quarterly collation of CO 2 emissions for all sources Data externally verified M&T in place for: o Buildings o Transport o Waste All staff & students given formalised CM: o Induction o Training Plan o Communications CM matters regularly communicated to the SMT Specific engagement of academic staff Granular & effective financing mechanisms for CM projects Finance representation on CM Team Robust task management mechanism Ring-fenced fund for carbon reduction initiatives Whole life costing is routine Senior purchasers consult & adhere to procurement best practice (e.g. Forum for the Future or OGC guidance) Sustainability comprehensively integrated in tendering criteria Renewables and sustainable new build under consideration if cost effective 4 SMART targets developed but not signed off Strategy launched internally only Core team & SMT regularly review all operational progress CM is full-time responsibility of an individual CM integrated in to responsibilities of department managers, not all staff Annual collation of CO 2 emissions for: o o o Buildings Transport waste Data internally reviewed All staff & students given CM: o o Induction Communications - CM communicated to the SMT - Regular awareness campaigns Regular financing for CM projects Some external financing Sufficient task management mechanism Environmental demands incorporated in tendering Familiarity best practice guidance Joint procuring between HEIs or LAs. 3 Strategy awaiting sign-off Incomplete targets (i.e. tco 2, but not cost) Core team regularly review priority actions & outstanding objectives CM is part-time responsibility of a few people CM responsibility of department champions Collation of CO 2 emissions for limited scope i.e. buildings only Environmental / energy group(s) give ad hoc: o o Training Communications Ad hoc financing for CM projects Limited task management No allocated resource Whole life costing occasionally employed Some pooling of environmental expertise 2 Uncoordinated & disjointed policy aspiration Ad hoc review of CM actions & progress CM is part-time responsibility of an individual No departmental champions No CO 2 emissions data compiled Energy data compiled on a regular basis Some poster/awareness campaigns Staff & students given ad hoc Carbon Management communications Ad hoc financing for CM related projects Limited task coordination resources Green criteria occasionally considered Products considered in isolation 1 Worst No policy No Climate Change reference or monitoring No CM responsibility designation No CO 2 emissions data - Estimated billing only No communication or training No internal financing or funding for CM related projects No Green consideration No life cycle costing Page 35

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