Elmhurst responds to Government's call for evidence on EPCs

Elmhurst has now reviewed and submitted its final response for the EPC in Buildings call for evidence. This call for evidence was extremely important to Elmhurst and our membership as it effectively covers everything that we do as a business.

We have spent a great deal of time developing a considered response, and we hope that all of our comments are constructive and add value to the work of our members. Our response generally aims to build upon the vital work that energy assessors do in terms of assessing the energy efficiency of the UK's building stock.

It is great to see Government acknowledging that EPCs are already "a key tool in promoting energy performance improvements in buildings." Now they are looking to use EPCs to deliver on the aims of the Clean Growth Strategy by identifying new trigger points for when an EPC will be required and how we can improve EPCs to ensure they contain "good quality data", that they are reliable, accurate and up to date.

We are delighted that Government realise EPCs are not just a legal obligation but an important tool that building owners should use as a catalyst for improvement. Previously, government policy has prevented departments from ‘gold plating’ EU directives which has unfortunately resulted in more pain, but less gain. Fortunately, this government wishes to explore options for other ‘trigger points’ when requiring an updated EPC.

Elmhurst consider this to be a fantastic opportunity for our industry, and a positive confirmation of the role that energy assessors fulfil in improving the energy efficiency of the buildings in which we live and work. To ensure that we gained a collective/representative feedback from our membership, we were delighted to welcome over 150 members and customers to our 25th Anniversary conference on 2nd October. The theme of the day was the Government's Call For Evidence on Energy Performance Certificates.

During the day members listened to experts from Elmhurst and the wider industry explain the context of the ‘Call For Evidence’ and draw attention to the challenges that exist with climate change and fuel poverty - and the opportunities that energy certificates present. Members were encouraged to give their opinions, which we promised to consider and, if possible, include them in Elmhurst's formal response.

Furthermore, last week we consolidated all these points and issued a draft response encouraging members to either respond themselves or provide feedback on Elmhurst's own response. We thank everyone who has contributed to our response.

Central to Elmhurst message inside the response was the following 9 points:

1. Energy Certificates always reflect the current state of the building and should be re-issued whenever there is a change  that impacts upon the energy performance of the building and, to reflect current fuel prices, an EPC should lapse after one year to ensure that estimates and recommendations are relevant.

2. The planning and building regulations process often require a prediction of buildings energy performance before construction starts. It is critical that the quality of such predictions is on par with the EPC and therefore they should only be undertaken by accredited energy assessors whose activities are overseen by an approved scheme.

3. Display Energy Assessments to be required for all buildings that are visited by members of the public including shops and offices, as well as buildings owned by government and local authorities.

4. Occupier engagement is restricted because the EPC is an asset rating for which the occupancy profile is not understood. Each EPC (asset rating) should be supplemented with an occupancy assessment that improves the energy consumption estimates and recommendations particular to the current occupier and their lifestyle. There is a need for independent advice and energy assessors are well positioned to provide this. 

5. As EPCs are now being used for setting minimum standards it is important that they are consistent over time. Elmhurst believe that an EPC rating should be based on a fixed standard, such as primary energy, rather than a variable such as cost or carbon.

6. EPC data should, with reasonable controls, be open for stakeholders to use to demonstrate possible improvement, and to improve enforcement authorities by linking to Land Registry and Trading Standard systems.

7. Investment is required in the SAP, RdSAP and SBEM methodologies to ensure that results of real world testing is fed back, in a closed loop model, to constantly improve accuracy.

8. The approach to assessing Houses of Multiple Occupancy (HMOs) should be simplified as most can be assessed using RdSAP as a single dwelling.

9. No building should be exempt from requiring an EPC. PRS/MEES, and other legalisation, can then be amended to allow exemption based upon the restrictions placed by planning and conservation restrictions.

We hope that we have made the message clear that Government need to build upon the excellent work of Energy Performance Certificates and energy assessors, and start encouraging more action. We trust that the feedback they receive is quickly analysed and new initiatives come through to ensure that buildings are warmer, cheaper to run and cleaner for the environment.

You can view Elmhursts final response in full here.

Remember the closing date for feedback is today: 11.45pm. Friday 19th October 2018.

Government Online Portal: https://www.gov.uk/government/consultations/energy-performance-certificates-in-buildings-call-for-evidence?utm_source=cda5179c-50e7-49fc-8486-7f3154a499ea&utm_medium=email&utm_campaign=govuk-notifications&utm_content=immediate

Article Published: 19th October 2018

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