Top 50 Highest Energy Consuming Sites
Case reference EIR2025/02429
Received 11 December 2025
Published 9 January 2026
Request
Under the Freedom of Information Act 2000, I would like to request the following information relating to the Council’s operational estate and electricity usage. To ensure the request remains within the cost threshold, the primary request is limited to the Top 50 highest electricity-consuming council-managed buildings, with additional information requested specifically for sites with solar PV or battery systems.
________________________________
1. Top 50 Highest Electricity-Consuming Sites
For the most recent full financial year, please provide:
* Site name
* Full address
* Building type (school, office, depot, leisure centre, library, etc.)
* Annual grid electricity consumption (kWh)
* MPAN, if available
*
If a ranked list already exists, please provide the existing document.
________________________________
2. Half-Hourly Electricity Data
For the same Top 50 sites, please provide:
▪ 12 months of half-hourly electricity consumption data
▪ CSV format preferred (Excel acceptable if CSV is unavailable)
If a site does not have a half-hourly meter, please indicate which ones.
________________________________
3. Latest Electricity Bills
For each of the Top 50 sites, please provide:
* A PDF copy of the most recent electricity bill
(Redaction of personal information is fine. Only commercial/billing detail is required.)
________________________________
4. All Sites with Solar PV Installed (Regardless of Consumption Ranking)
To ensure renewable-equipped buildings are not excluded from analysis due to reduced grid consumption, please provide details for all council-managed sites that have solar PV installed, even if they do not fall within the Top 50 electricity-consuming category.
For each PV-equipped site, please provide:
* Site name and address
* Installed capacity (kWp)
* Commissioning date
* Annual generation (if recorded)
* Ownership model (Council-owned, leased, PPA, etc.)
* Whether the site also has battery storage installed
________________________________
5. All Sites with Battery Storage Installed (If Any Exist)
For any site with battery energy storage, please provide:
* Site name and address
* Capacity (kW / kWh)
* Installation date
* Ownership/financing model
(If this is already captured in section 4, no need to duplicate.)
________________________________
6. Energy Procurement Arrangements
Please confirm:
* The framework used for electricity purchasing (e.g., WME, Crown Commercial Services, LASER)
* Whether the Top 50 sites are on half-hourly meters
* Any existing PPAs or long-term renewable supply agreements affecting these sites
________________________________
Response
Under the Freedom of Information Act 2000, I would like to request the following information relating to the Council’s operational estate and electricity usage. To ensure the request remains within the cost threshold, the primary request is limited to the Top 50 highest electricity-consuming council-managed buildings, with additional information requested specifically for sites with solar PV or battery systems.
________________________________
1. Top 50 Highest Electricity-Consuming Sites
For the most recent full financial year, please provide:
* Site name
* Full address
* Building type (school, office, depot, leisure centre, library, etc.)
* Annual grid electricity consumption (kWh)
* MPAN, if available
*
If a ranked list already exists, please provide the existing document.
A: Please see attached detailing Site names, addresses, types and annual consumption. However MPANs have been withheld under Regulation 12 (5) (a) of the Environmental Information Regulations 2004 because disclosure would, on the balance of probabilities, adversely affect public safety.
This exception is subject to the public interest test, and accordingly I have weighed the reasons for and against disclosure as follows:
Factors in favour of disclosure:
• Providing MPAN numbers could demonstrate openness about energy supply arrangements.
• May assist in verifying energy sources or consumption for sustainability purposes.
Factors against disclosure:
• MPAN numbers are unique identifiers for electricity supply points. Disclosure under EIR is disclosure to the world at large, and therefore if the information should be discovered by someone with this intent it could enable fraudulent activity, such as impersonating the organisation to switch suppliers or access accounts.
• Fraudulent use could lead to financial loss, service disruption, and reputational damage.
• MPAN numbers themselves do not provide meaningful environmental insight beyond what can be shared through aggregated data.
Taking the above into consideration I have decided in favour of the public interest in non-disclosure.
________________________________
2. Half-Hourly Electricity Data
For the same Top 50 sites, please provide:
▪ 12 months of half-hourly electricity consumption data
▪ CSV format preferred (Excel acceptable if CSV is unavailable)
If a site does not have a half-hourly meter, please indicate which ones.
A: Information regarding half-hourly electricity consumption data is considered to be exempt under Regulation 12(5)(a) of the Environmental Information Regulations 2004, which allows withholding information where disclosure would adversely affect public safety. Providing detailed half-hourly electricity consumption data could reveal patterns of occupancy and vacancy within council buildings. This information could be used to identify times when buildings are unoccupied, creating a significant security risk and increasing the likelihood of theft or unlawful entry.
Regarding the public interest in disclosing the information weighed against the public interest in maintaining the exception, I have taken the following factors into consideration:
The public interest in disclosing the information:
• Providing energy consumption data could help demonstrate how the council manages energy efficiency and sustainability.
• Disclosure may support research or initiatives aimed at reducing carbon emissions and improving energy use.
• Sharing data could increase public awareness of council operations and energy performance.
The public interest in not disclosing the information:
• Detailed half-hourly electricity data could reveal occupancy patterns. Disclosure under EIR is disclosure to the world at large, and therefore identifying times when buildings are vacant could create a real and substantial risk of theft, vandalism, or unlawful entry if the information should be discovered by someone with this intent.
• Disclosure could compromise the safety of staff and visitors by exposing vulnerabilities in building usage.
• Increased security risk could lead to additional costs for security measures or losses from theft/damage.
I have decided on balance that the public interest in not releasing the information outweighs the public interest in disclosure.
________________________________
3. Latest Electricity Bills
For each of the Top 50 sites, please provide:
* A PDF copy of the most recent electricity bill
(Redaction of personal information is fine. Only commercial/billing detail is required.)
A: This is considered to be excepted under Regulation 12 (5) (e) of the Environmental Information Regulations 2004 because disclosure is likely to prejudice the commercial interests of our energy provider West Mercia Energy (WME).
In reaching this decision I have taken into account relevant guidance provided by the Information Commissioner's Office including whether the information in question is commercial or industrial.
Disclosure of the withheld information would adversely affect WME. The withheld information contains detailed unit costs and charges.
The council accepts the legitimate economic interests of the company would be likely to be prejudiced by disclosure of the information.
The council is also able to consider its own economic interests in addition to those of West Mercia Energy. Herefordshire, as a partcial owner of WME would also be effected by the release of the information.
In coming to this decision, I have weighed up the public interest for disclosure against the public interest in not disclosing the information and the commercial interests of West Mercia Energy as follows:
The public interest in disclosure:
• Disclosure could demonstrate how public funds are spent and ensure value for money in energy procurement.
• Providing cost data may help public understand the financial implications of energy efficiency measures.
• Enhances public confidence that contracts are fair and competitive.
The public interest in not disclosing the information and the commercial interests of West Mercia Energy
• Detailed unit costs are commercially sensitive and could prejudice the energy supplier’s competitive position in future tenders.
• Disclosure could undermine fair competition by giving competitors insight into pricing strategies.
• Revealing this information could weaken the authority’s bargaining position for future contracts, leading to higher costs for taxpayers.
Taking the above into consideration, I have found the public interest in disclosing the information in this case is outweighed by the public interest in not disclosing the information.
________________________________
4. All Sites with Solar PV Installed (Regardless of Consumption Ranking)
To ensure renewable-equipped buildings are not excluded from analysis due to reduced grid consumption, please provide details for all council-managed sites that have solar PV installed, even if they do not fall within the Top 50 electricity-consuming category.
For each PV-equipped site, please provide:
* Site name and address
* Installed capacity (kWp)
* Commissioning date
* Annual generation (if recorded)
* Ownership model (Council-owned, leased, PPA, etc.)
* Whether the site also has battery storage installed
A: Please find spreadsheet attached.
________________________________
5. All Sites with Battery Storage Installed (If Any Exist)
For any site with battery energy storage, please provide:
* Site name and address
* Capacity (kW / kWh)
* Installation date
* Ownership/financing model
(If this is already captured in section 4, no need to duplicate.)
A: see above answer for Q4
________________________________
6. Energy Procurement Arrangements
Please confirm:
* The framework used for electricity purchasing (e.g., WME, Crown Commercial Services, LASER)
* Whether the Top 50 sites are on half-hourly meters
* Any existing PPAs or long-term renewable supply agreements affecting these sites
________________________________
A: Electricity is supplied by West Mercia Energy WME. WME is established as a Joint Committee, jointly owned by four local authorities; Shropshire Council, Telford & Wrekin Council, Herefordshire Council and Worcestershire Council.
Regarding whether the Top 50 sites are on half-hourly meters, please see this information provided in the spreadsheet provided in Q1.
Documents
This is Herefordshire Council's response to a freedom of information (FOI) or environmental information regulations (EIR) request.
You can browse our other responses or make a new FOI request.