Introduction
In a recent blog we highlighted Government’s proposed changes to the EPC regime:
Consultation on a new domestic and non-domestic EPC regime | SHIFT Environment
We have now submitted our formal response. Here is what we said:
Chapter 2: What EPCs measure
- To what extent do you agree or disagree that information using an energy cost metric should be displayed on EPCs? Please select one option for each building type
Agreement that using an energy cost metric should be displayed on EPCs. – Domestic buildings:
Strongly agree
Agreement that using an energy cost metric should be displayed on EPCs. – Non-domestic buildings:
Strongly agree
There are several reasons:
* A cost metric is something that building occupiers understand
* As the cost metric is based on kWh consumed, it means that that a lower cost represents lower kWh, which means lower CO2 emissions. This relationship does not always work the other way round e.g. some low CO2 buildings are high cost to run
* In our experience the cost metric has been a spur to improve energy efficiency. Here is one example:
https://shiftenvironment.co.uk/news/a-horror-story-poor-quality-in-new-builds/
We also believe this should remain the main, overarching metric on the EPC certificate. There are several reasons:
* We strongly suspect that multiple headline metrics will be very confusing for building occupiers
* by all means have other metrics on the EPC, but as sub-metrics – any relevant institution can then chose those that it wishes to focus on
* we acknowledge that costs do change but we believe this can easily be overcome – e.g. the £ on an issued EPC can be caveated to say they are the modelled costs based on current methodology – up to date running costs can be displayed on the online version of an EPC for reference purposes
- To what extent do you agree or disagree that information derived from a fabric performance metric should be displayed on EPCs? Q2: Agreement that information derived from a fabric performance metric displayed on EPCs – Domestic buildings:
Strongly agree
Agreement that information derived from a fabric performance metric displayed on EPCs – non-domestic buildings:
Strongly agree
It is useful to be able to identify what to improve – even on non-domestic buildings we have found buildings that would benefit from cavity wall insulation.
3. When evaluating the fabric performance of buildings, which methodology do you think should inform the basis of calculating a fabric metric? Please select one option for each building type.
Fabric performance of buildings methodology – Domestic buildings:
HLP/HTC
Fabric performance of buildings methodology – non-domestic buildings:
HLP/HTC
The HLP/HTC can be modelled from data captured on a non-invasive survey. Importantly though, it can also be measured using monitors and energy use data. This means that EPC’s can be upgraded with better data about the building should the owner wish. Better, more accurate data enables better building decisions. Deciding on wall and floor types on a non-invasive assessment is sometimes very difficult.
The impact of solar gains or potential cooling demand can be modelled elsewhere in the EPC methodologies.
- To what extent do you agree or disagree that information based on a heating system metric should be displayed on EPCs? Please select one option for each building type.
Agreement that information based on a heating system metric displayed on EPCs – Domestic buildings:
Strongly agree
Agreement that information based on a heating system metric displayed on EPCs – non-domestic buildings:
Strongly agree
- What are your views on the design principles and the scope for a Heating System metric?
The cost efficiency and the environmental impact should certainly feature in the design of the Heating System metric, but we do not believe it should be a headline metric as it may cause confusion.
The environmental impact may be a driver for some people to upgrade their buildings, but we suspect the vast majority of building occupiers will be motivated by costs savings. For that reason, this appears to be an attempt to nudge occupiers into getting a non-fossil fuel heating system in line with net zero pathways. We’d suggest that a more effective way to do this is to reduce the running cost of non-fossil fuel forms of heating. This will then feed into
the EPC calculations and result in a better rating for non-fossil fuel heated properties and come out as a standard recommendation.
Reduced cost of electricity versus gas has been called for many times and even the Government’s Heat and Buildings Strategy identified that it needs to be done. On top of all that, one of the priorities of this and other energy policies is to reduce costs for users.
- To what extent do you agree or disagree that information based on a smart readiness metric should be displayed on EPCs? Please select one option for each building type.
Agreement that information based on a smart readiness metric displayed on EPCs – Domestic buildings:
Strongly agree
Agreement that information based on a smart readiness metric displayed on EPCs – non-domestic buildings:
Strongly agree
- What are your views on the definition, design principles and the scope for a smart readiness metric?
The design principles outlined in the consultation look good except for inclusion of appliances. We envisage this could cause problems in tenant/landlord relationships.
Again, this should not be a headline metric, but a sub-metric.
Any metric design should consider how it will be assessed, particularly if suggested improvements are going to be made based on the assessment. For instance, it would not be practical for an energy assessor to decide whether or not there is space for a battery.
- To what extent do you agree or disagree that information from an energy use metric should be displayed on EPCs? Please select one option for each building type.
Agreement that information from an energy use metric displayed on EPC – Domestic buildings:
Agree
Agreement that information from an energy use metric displayed on EPC – Non-domestic buildings:
Agree
Again, modelled energy use would provide useful information, it should not be a headline metric, but a sub-metric.
In any case we strongly believe that the primary energy information should NOT be on the EPC. It serves no purpose to the occupier and has, in our experience, been misinterpreted.
It may be a piece of hidden data on a government database if it is useful for government statistics.
- If an energy use metric is to be displayed on Energy Performance Certificates (EPCs), which type of energy use measurement should be used to calculate this metric? Please select one option for each building type.
If an energy use metric is to be displayed on Energy Performance Certificates (EPCs), which type of energy use measurement should be used to calculate this metric – Domestic buildings:
Delivered energy
If an energy use metric is to be displayed on Energy Performance Certificates (EPCs), which type of energy use measurement should be used to calculate this metric – Non-domestic buildings:
Delivered energy
We strongly believe that the primary energy information should NOT be on the EPC. It serves no purpose to the occupier and has, in our experience, been misinterpreted.
It may be a piece of hidden data on a Government database if it is useful for Government statistics.
- To what extent do you agree or disagree that information from a carbon-based metric should be displayed on EPCs? Please select one option for each building type.
Agreement that information from a carbon-based metric should be displayed on EPCs – Domestic buildings:
Strongly agree
Agreement that information from a carbon-based metric should be displayed on EPCs – non-domestic buildings:
Strongly agree
If you wish, please explain your reasoning and provide any evidence to support your view. Please do not include personal data in your response:
Again, modelled CO2 emissions would provide useful information, but should not be a headline metric, but a sub-metric.
Assuming the UK continues to transition away from fossil fuels, we recognise that the carbon intensity of different fuels will change between when the EPC assessment was done and the current situation. But we believe this can easily be overcome – e.g. the CO2 on an issued EPC can be caveated to say they are the modelled emissions based on current methodology – up to date emissions can be displayed on the online version of an EPC for reference purposes. For completeness, an estimate should also be made for non-regulated emissions from appliances.
- To what extent do you agree or disagree with incorporating smart metering technologies, like SMETERS, into the energy performance assessment framework for buildings? Please select one option for each building type.
Agreement with incorporating smart metering technologies, like SMETERS, into the energy performance assessment framework for buildings – Domestic buildings:
Neither agree nor disagree
Agreement with incorporating smart metering technologies, like SMETERS, into the energy performance assessment framework for buildings – non-domestic buildings:
Neither agree nor disagree
We believe that more research should be carried out to demonstrate one way or another, that SMETERS reduce energy costs. Some meter displays are better than others.
It would be an extra burden for assessors to identify the technologies and, unless it is proven to reduce energy costs, this extra burden would serve no purpose to the building occupier.
- Do you have any views on key transition issues?
It is a really confusing landscape for rdSAP for domestic buildings. rdSAP 10 has been anticipated for years and the current indications are that it will be introduced “soon”. Introducing a new regime in 2026 will cause 2 changes in quick succession.
For owner occupied buildings this may not be also much of a problem, but for tenant/landlord relationships this could really impair improvement plans.
Chapter 3: When EPCs and DECs are required
- What should be the validity period for Energy Performance Certificate (EPC) ratings?
10 years
- To what extent do you agree or disagree with the approach for any changes to validity periods to only apply to new EPCs?
Strongly disagree
The requirement to reduce the validity of EPCs to 5 years seems redundant. In addition, it will increase costs for organisations such as housing associations for no real benefit. We’d suggest that enforcement and other drivers should increase the frequency of EPC renewals:
* Proper and fuller MEES enforcement
* Investor requirements – EPCs can get updated when it comes to reporting to investors
* Funding requirements – if grant funding is given to upgrade properties, then part of the funding requirement is to have an updated EPC
* Property sellers – we suggest they would be motivated to have an up-to-date EPC to show to prospective buyers anyway. Perhaps this motivation can be increased by a government campaign about what EPCs are and how useful they are.
- To what extent do you agree or disagree that a new EPC should be required when an existing one expires for private rented buildings?
Strongly disagree
If you wish, please explain your reasoning and provide any evidence to support your view. Please do not include personal data in your response.
This requirement seems redundant. In addition, it will increase costs for organisations such as housing associations for no real benefit. We’d suggest that enforcement and other drivers should increase the frequency of EPC renewals:
* Proper and fuller MEES enforcement
* Investor requirements – EPCs can get updated when it comes to reporting to investors
* Funding requirements – if grant funding is given to upgrade properties, then part of the funding requirement is to have an updated EPC
* Property sellers – we suggest they would be motivated to have an up-to-date EPC to show to prospective buyers anyway. Perhaps this motivation can be increased by a Government campaign about what EPCs are and how useful they are
* Property renters may be motivated to update the EPC to increase chances of gaining a tenant, but this seems a small motivation for domestic properties as there is a housing shortage and EPC rating may not be at the forefront of the minds of people looking for somewhere to live.
- To what extent do you agree or disagree that the regulations should be amended so that a property must have a valid EPC before it is marketed for sale or rent?
Strongly disagree
As per q 14
- To what extent do you agree or disagree that houses in multiple occupation (HMOs) which don’t already fall under the (Minimum Energy Efficiency Standards) MEES should do so when a room is rented out?
Strongly agree
If you wish, please explain your reasoning and provide any evidence to support your view. Please do not include personal data in your response:
This seems a sensible approach and brings HMOs more firmly into the EPC regime.
- To what extent do you agree or disagree that there should be a transitional period of 24 months to allow HMO landlords to obtain a valid EPC and comply with MEES regulations?
Neither agree nor disagree
24 months seems sufficient time for a HMO landlord to make necessary improvements, but clearly a shorter time would be beneficial to help reduce CO2 emissions quicker.
- To what extent do you agree or disagree with requiring short-term rental properties to have a valid EPC at the point of being let?
Strongly agree
If you wish, please explain your reasoning and provide any evidence to support your view.
- To what extent do you agree or disagree with requiring short-term rental properties to have a valid EPC irrespective of who is responsible for meeting the energy costs?
Strongly agree
If you wish, please explain your reasoning and provide any evidence to support your view.
Perhaps this requirement will drive better and clearer agreements over who is responsible for paying bills and who is responsible for making improvements.
- To what extent do you agree or disagree that we should remove the exemption for landlords from obtaining an EPC for buildings officially protected as part of a designated environment or because of their architectural or historical merit?
Strongly agree
Energy efficiency of all buildings should be known so that potential occupiers can make clear choices. Exempting heritage buildings will do nothing to reduce CO2 emissions. There is a growing knowledge base of improving heritage buildings whilst preserving their heritage value.
The heritage value of buildings should be better codified. It appears that the heritage laws are applied very differently between different local authorities.
- How useful do you find Display Energy Certificates (DECs) for understanding and improving a building’s energy performance?
Neither not useful nor useful
- Are there any limitations or challenges with the current DEC approach that reduce its effectiveness?
We’d suggest that buildings required to have DECs should instead have valid EPCs AND have some kind of energy management system akin to ISO50001.
- What alternative approaches, if any, could drive energy performance improvements more effectively than DECs for public sector buildings?
We’d suggest that buildings required to have DECs should instead have valid EPCs AND have some kind of energy management system akin to ISO50001.
There are now many energy monitoring software options that identify energy use and, using machine learning, identify energy use anomalies that can be fed back to the occupier and save public money in the process.
The ISO50001 approach could require an annual “walk through” to identify energy saving opportunities instead of an annual DEC.
- To what extent do you agree or disagree with the proposed changes to the validity periods for DECs and DEC recommendation reports?
Neither agree nor disagree
- What would be an appropriate validity period in years for these DEC and DEC recommendation reports? Please select a validity period for each option.
An appropriate validity period in years for these DEC and DEC recommendation reports – DEC 1000m² and under:
Don’t know
An appropriate validity period in years for these DEC and DEC recommendation reports – DEC recommendation report 1000m² and under:
Don’t know
An appropriate validity period in years for these DEC and DEC recommendation reports – DEC recommendation report over 1000m²:
Don’t know
We’d suggest that buildings required to have DECs should instead have valid EPCs AND have some kind of energy management system akin to ISO50001.
There are now many energy monitoring software options that identify energy use and, using machine learning, identify energy use anomalies that can be fed back to the occupier and save public money in the process.
The ISO50001 approach could require an annual “walk through” to identify energy saving opportunities instead of an annual DEC.
We have carried out many ESOS assessments and typically identify savings opportunities 3-4 times our audit fee. The energy audit element of ESOS could be the “walk through” item described above.
EPC and DEC Data
Would you like to respond to questions on ‘EPC and DEC data’?
Yes
Chapter 4: EPC and DEC Data
- There is a proposal to provide an exception in the regulations for certificates that have been marked as cancelled or not for issue to be removed from the Energy Performance of Buildings (EPB) Register after 2 years. To what extent do you agree or disagree with the proposal?
Neither agree nor disagree
No strong opinion, but, if pushed, would lean for more data rather than no data.
- To what extent do you agree or disagree with the approach to remove the option to opt-out EPCs from the EPB Register public address search?
Agree
- To what extent do you agree or disagree with retaining the option to opt-out EPC address level content from the Open Data?
Disagree
More data is useful for everyone and there doesn’t appear to be a legitimate reason to opt-out of this data being publicly available. However, we recognise there is a” big brother” element to this approach. On balance we would lean to more data availability.
- There is a proposal to remove the general prohibition on sharing data gathered under the EPB Regulations and replace it with a Secretary of State discretion about when, how and with whom to share the data. To what extent do you agree or disagree with the proposal?
Neither agree nor disagree
More data is useful for everyone and there doesn’t appear to be a legitimate reason to opt-out of this data being publicly available. However, we recognise there is a” big brother” element to this approach. On balance we would lean to more data availability.
- To what extent do you agree or disagree that data gathered in previous EPC assessments should be available for use in future EPC calculations for a dwelling?
Agree
- What are your views on the approach to using existing data, while balancing accuracy and practicality?
On the surface this seems a good idea and would, potentially save an assessor time in measuring spaces and deciding on difficult to decide things.
However, it must be clear who is liable for this data. E.g. if an assessor sees that a previous assessment identified the wall as filled cavity, and they take that as read, if it is subsequently found that the cavity is unfilled, who is liable for that assessment – the previous assessor or the current assessor?
If this is to be implemented, then we would suggest that it is made clear whether or not the assessor has made a new decision, and that the new assessment should not be liable for previous assessor’s interpretations.
Better enforcement would encourage building owners to direct assessors to upgrades they have made, and the assessor can take these into account.
Chapter 5: Managing EPC Quality
- To what extent do you agree or disagree that Accreditation Schemes should be given more responsibility for overseeing the training of energy assessors?
Neither agree nor disagree
This proposal sounds good, but we have sent people on one very popular scheme training course, and it was clear that the trainers were heavily incentivised to pass delegates quickly – e.g. the test sites visited had pre-filled data in i.e. not giving delegates a chance to learn the skills. There is a suspicion that the trainers were being “paid by results” – as we understand it, they weren’t necessarily the scheme direct employees, but we booked the course through the scheme.
- Do you have suggestions for other actions which could be taken to improve the accuracy and quality of energy assessments, or to help identify fraud in EPC assessments?
There seems to be an attitude that EPCs are a tick-box exercise and as such people who pay for it are searching for the lowest price with no regard for quality. It seems a good first step would be for an information campaign to let building occupiers know the value of the EPC and the work involved in generating one. That way, prices can really reflect the work involved.
- To what extent do you agree or disagree with these proposals to improve compliance?
Strongly agree
In addition, work with the various institutions and grant-givers that are looking at EPCs so that they themselves do some kind of spot check.
- To what extent do you agree or disagree that penalties should be increased?
Strongly agree
- If penalties were to increase, how much should current penalties increase by?
Maybe something more aligned to the costs of upgrading a property e.g. average £/m2. That way it would cheaper to upgrade than to pay the fine.
- When should penalties be imposed for non-compliance with Energy Performance of Buildings Regulations (EPBR) requirements?
Don’t know
- What are your views on changing the current allocation of responsibilities for enforcing Energy Performance of Buildings Regulations (EPBR)?
Whichever authority is chosen to enforce the regulations, they must be sufficiently resourced and demonstrate good enforcement. The overall definition of the authority’s success will be how many upgrades have resulted from their enforcement work. They should also report on their enforcement activities, fines levied and received.
Maybe there could be some whistleblowing arrangement such that any group or individual can report suspected buildings to the enforcing authority.
Upgrading the MEES compliance threshold from EPC F and G to EPC E, F & G would send a strong signal that the regime is changing and, at the same time, capture more buildings for upgrading.
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