Regulatory oversight: Include sustainability within CQC/NHS England governance assessments." 

 Mary Aladegbola, Senior Net Zero Technical Energy Lead, NHS England

"NHS England published its Delivering and Net Zero NHS strategy in 2020 that set out the ambition and strategy for achieving net zero carbon by 2040 (for the NHS Footprint emissions). This takes a wide approach and covers emissions linked to a range of activities across the NHS, such as the delivery of clinical services, operation of buildings, operation of fleet vehicles, supply chain and others. 

Each NHS Trust needs to develop a Green Plan that sets out the actions and targets that Trust will work towards over the period of the Green Plan – usually 3 years. 

In NHS Property Services, we produced our second Green Plan in 2025, which sets out what we will be doing over the period to the end of the 2027/28 year. 

The NHS Property Services Net Zero Strategy sets out the activities that we will be working through as we aim to reach net Zero carbon by 2040 (for NHS Footprint emissions)."

Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services

"Grid capacity is becoming a central issue in NHS decarbonisation because electrifying heat and phasing out gas will significantly increase peak power demand across large hospital estates. In practice, the response needs to be a mix of approaches rather than reliance on grid reinforcement alone. 

Trusts are increasingly assessing onsite generation such as solar, battery storage, demand-side management, and smarter energy controls to reduce import demand and improve resilience. In practice, our strategy is coordinated with wider energy policy, network investment, and planning reform."

Mary Aladegbola, Senior Net Zero Technical Energy Lead, NHS England

"Within NHS Property Services, we're working with a range of stakeholders to understand, assess, report and highlight the local grid capacities across the estate. Available power has the potential to be a limiting factor to decarbonisation. However, working to plan at the earliest possible stage and working with DNO’s, iDNOs, suppliers, and other stakeholders enables effective mitigation. There is a lot to do to improve the grid capacity to make the transition away from fossil fuels an easier prospect, but it is not yet a limiting factor for us."

Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services

"The increasing demand on power is absolutely a challenge. Strategic planning and collaborative working with the energy networks are critical, especially when rolling out solutions at scale.

Local generation should always be considered as part of any feasibility study – whether new build or retrofit. The challenge with that is often to map generation to demand so that power can be used as generated / or stored and used within a short (24hr) window. For larger-scale projects where feed-in is anticipated, wider engagement is critical.

Perhaps a point best addressed by others, but long-term strategic planning can really support integration with other local assets such that changes support rather than challenge the network."

Dave Percy, Operations Director, Urban Design & Consult

"Improving the asset rating may be a useful prerequisite for enhancing ‘readiness’ for Net Zero. However, it is important to be mindful of the performance gap and the fact that EPC ratings are not necessarily reliable indicators of in-use performance. We therefore recommend adopting key performance indicators (KPIs) based on ‘actual’ energy and carbon performance, alongside asset ratings."

Dr Esfand Burman, Associate Professor, UCL Institute for Environmental Design and Engineering

"The EPC has been around as a regulatory instrument for some time, with limited success due to the ambiguous calculation methodology and lack of control over the assessment procedure, leading to accurate assessments of buildings. However, with the introduction of MEES the EPC holds some weight with landlords being able to let poor performing property.  

Any landlord needs to consider MEES as a strategic driver for rental value, cash flow and sustainability. If you are not complying with MEES you can’t continue to let properties. 

However, the current lack of direction and clear guidance means there is currently a vacuum in terms of what is coming down the line, and what needs to be done to comply. 

In the non-domestic side the original guidance was to be the MEES improving to a B rating by 2030. However, with 2030 now fast approaching and with no formal regulation being published this seems unlikely to be the case. In some cases, the work required to achieve a B rating is significant, both in terms of cost and disruption, which in a busy healthcare facility needs careful and long term planning. 

We welcome the improvement of the minimum standards for EPC compliance, but also need clarity and long-term guidance to enable the changes to be made in an efficient and effective way."

Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services

"Joined-up thinking and a systematic approach to decarbonisation are essential. For example, adopting a portfolio-level approach to assess the estate, identify, and prioritise building clusters that are most in need of intervention and that could deliver the greatest energy and carbon savings can be highly effective."
Dr Esfand Burman, Associate Professor, UCL Institute for Environmental Design and Engineering 

"There is strong operational data available, but the main barriers are data quality, fragmented systems, limited analytical capability, and weak linkage between technical metrics and board priorities. DECs, ERIC, and BMS often sit in separate silos, with inconsistent accuracy and no single view of asset performance or investment need. At board level, decisions are usually driven by risk, finance, compliance, and service impact, so raw energy data rarely translates into compelling capital cases. To shift decarbonisation from grant-led to needs-based investment, data must be converted into clear decision metrics such as cost avoidance, backlog risk, resilience, carbon impact, and return on capital. In short, the challenge is less about lack of data and more about turning data into investable insight."

Mary Aladegbola, Senior Net Zero Technical Energy Lead, NHS England

 "As has been pointed out by both Esfand and Mary, there is often a lack of joined-up and systematic operations across different business functions. This means even if the data is available, is it available to the right people at the right time who can use this to effect change? 

At NHS Property Services, we are working with our Capital Projects Teams to integrate the data and risks, especially from EPCs and benchmark data, into Capital plans and decision-making. Upskilling and awareness go alongside this, as a key enabler to change. "

Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services

"In our view, this is essential to reducing energy use in existing buildings and ensuring that the environmental targets set for new buildings and refurbishments are achieved in practice. UCL is currently collaborating with CIBSE to further develop and update the CIBSE Online Benchmarking Tool, which offers a high level of granularity for healthcare buildings. "

Dr Esfand Burman, Associate Professor, UCL Institute for Environmental Design and Engineering

"Taking a different look at this question, we are increasingly using technology to monitor occupancy utilisation (motion sensor technology) that provides weekly/daily/hourly insight into how our buildings are used, trends and opportunities – we are considering how this data can be linked to BMS systems to more dynamically adjust heating and cooling provision by zones."

Simon Taylor, Director Estates Policy, Strategy & Capital Projects, NHS Property Services

"Suppliers can materially accelerate net zero by making projects easier to approve, fund, and replicate across the estate. 

In practice, that means taking responsibility for whole-system performance rather than just installing assets. If suppliers can standardise their offerings, aggregate across multiple NHS sites, and contract on verified performance (with clear measurement and verification), it significantly reduces delivery friction and enables faster deployment. "

Mary Aladegbola, Senior Net Zero Technical Energy Lead, NHS England

"At NHS Property Services, we have a structured approach to the asset-level review referred to here with quinquennial asset condition surveys that enable a Forward Maintenance Register to be maintained and integrated with Property, CAFM and Finance systems."

Simon Taylor, Director Estates Policy, Strategy & Capital Projects, NHS Property Services

"We are currently reviewing the actions required to comply with the updated regulations for heat networks, so that we can register in 2027, as required. 

There is a lot of work needed to be done to pull the information required together. I am sure we, or the wider NHS, are not alone in considering this a huge task that will require new systems and processes to enable effective compliance and ongoing management"

Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services

"We recommend following a robust environmental design hierarchy:

• prioritising passive measures,
• implementing highly efficient building systems 
• exploring opportunities for on-site micro-generation and decarbonisation. 

Existing buildings offer more limited opportunities for passive and fabric-first interventions. However, it remains essential to assess and implement all feasible measures before introducing active building systems. Natural ventilation may still be a viable design strategy; however, it must be carefully designed to mitigate both current and future overheating risks. 

We also recommend going beyond minimum regulatory requirements by undertaking detailed assessments of overheating risk and associated mitigation measures under future climate scenarios (e.g. using CIBSE Future Weather Files). "

Dr Esfand Burman, Associate Professor, UCL Institute for Environmental Design and Engineering

"Taking newbuild to begin with, I’d strongly argue that this is an opportunity rather than a challenge. As a business, we find it a huge benefit that current drivers support and challenge us all as designers to truly make the most of ‘place’ and ‘setting’. Good design looks very different now, and it’s great to see that clients are really seeing the value of designing for efficiency as well as aesthetics. Technology is really supporting us to deliver on the opportunities presented by what might previously have been considered challenging sites. Personally, I welcome the challenge, and I hope to see other designers following suit.

Retrofit can prove more challenging in this regard, but I’d strongly urge everyone not to dismiss it. We have some great real-life examples of success in this regard, which I’d be very happy to share. Whilst we are ‘stuck’ with the constraints of site and orientation, let’s not disregard opportunities to re-structure the internal space and to harness the great products available to harness natural resources. This can and has proven particularly effective on community assets where ventilation strategies are more relaxed than in an acute setting. Finally, I’d encourage taking a holistic approach and ensuring that any new technologies are integrated to ensure optimum efficiency."

Dave Percy, Operations Director, Urban Design & Consult

"As part of the Delivering a Net Zero NHS programme, there is a requirement for NHS Trusts and bodies to engage with their supply chain on Footprint Plus emissions. The aim of this is to reduce the scope 3 emissions across the NHS where we don’t have direct control, but have the ability to influence change. 

Once of the requirements is for NHS bodies to require suppliers to assess their carbon emissions and produce Carbon Reduction Plans that set out what they are doing to reduce their own emissions. The intention being that this will translate to a reduction in the large Scope 3 emissions seen across many NHS bodies. 

In practice, there are a huge number of suppliers to the NHS, some of which are large national or multi-national organisations that are already well on the way with their own net zero plans. Other suppliers are smaller companies that are just starting to look at their own emissions and lack the expertise in this area. 

While we want to make sure our suppliers are engaging on this topic and looking at reducing their own emissions performance, we don’t want to turn away the smaller, local companies that provide a key service to the local communities they serve and us, because they don’t have the expertise in this area.

We are working with as many suppliers the NHS Property Services as possible to ensure Carbon Reduction Plans are in place and providing support where this is needed."
Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services

"Individuals understand their daily energy use best when buildings make it visible in simple, real-time terms. The system uses tools including PowerBi, the energy dashboards and BMS systems." 

 Mary Aladegbola, Senior Net Zero Technical Energy Lead, NHS England

"This is a challenge that exists across all large property portfolio owners and operators. The use of metered data and BMS outputs can allow building users to see how the building is operating. However, this depends on the effectiveness of the metering and the BMS in the building, which will vary from building to building, and how this data is then displayed. 

In the Public Sector, the easiest way for building users to gain an understanding of the operation of the building is to view the Display Energy Certificate that is required for most public buildings.  

The DEC provides a rating of performance for the last 12 months and how that compares to previous years to track the performance trend. The DEC converts the energy consumption into the carbon benchmark in the form of an A-G rating, which most people are now familiar with."

Nick Macdonald-Smith, Net Zero Carbon Lead, NHS Property Services