Government's call for evidence on EPCs - Elmhurst's draft response

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.

With one week to go we have now completed the first draft of our response (click here) and in the hope that it stimulates members to respond to government though their online portal . If you don't have time we would also welcome feedback from members which we will consider and, where possible, include in our final submission, which we will publish.

Government acknowledge 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.

Elmhurst's Managing Director Martyn Reed was delighted that government now 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. Unfortunately this can mean we get the pain, but less of the gain. Fortunately this government wishes to explore options for other ‘trigger points’ for 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."

The essence of our response can be covered in nine key 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.

Remember the closing date for feedback is Friday 19th October 2018.

You can view our draft response in full here.

Article Published: 12th October 2018

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