Why does my EPC not recommend a heat pump?

With government’s saying that gas boilers are to be phased out in order for the UK to achieve its carbon targets why does an EPC rarely recommend one?

What is energy efficiency?

The first point to consider is “What is energy efficiency?” When EPCs were first devised, the thought was that consumers would perceive energy efficiency as the amount of money they spent on fuel, and demonstrating savings would motivate home owners to make improvements. That is why the EPC is based on a cost-based metric, the cost of fuel (for heat, light and water) for each square metre of floor area of the home.

The problem with this assumption is twofold:

  1. Research has shown that for many people saving money, either because they don’t have the money to invest or because the payback periods are not attractive, is not enough on its own.
  2. A cost metric will not help reduce carbon emissions when the cheaper fuels have higher carbon emissions.

Elmhurst proposes that EPCs are restructured to give equal prominence to the property's carbon emissions (CO2), energy consumption (kWh) and energy cost (£s) and that the methodology is updated at least every three years to reflect improvements in technology and changes in the way in which energy is produced.

EPCs favour gas

The second anomaly is that RdSAP recommendations will not normally recommended a move away from gas as main heating fuel. When RdSAP was last subject to significant update, gas was not only cheaper than electricity , but it produced less carbon emissions, as consequence a block was set in the methodology which prevented recommendations that required a fuel switch for main heating, ironically unless it is towards gas!    

Elmhurst proposes that this block is removed at the earliest opportunity and that the logic behind recommendations are reviewed.

The methodology is out of date

Putting cost and the EPC recommendations to one side, the EPC doesn’t accurately represent the performance of heat pumps either because the carbon intensity figures used for electricity are out of date and do not take account of the significant decarbonisation achieved through investment in renewable sources such as windfarms, solar photovoltaics and hydro.

Elmhurst proposes that the methodology is updated at the earliest opportunity and reviewed and updated at least every three years thereafter

In summary

In summary because the methodology has not been kept up to date, the EPC is actually dissuading consumers away from the solution that government believes is the right one. The good news is that the assessment process is effective and well established and that that the physics on which the methodology is based has proved the test of time. Government realises that some of the variables (such as carbon intensity), and the logic in how the recommendations are presented, are now out of date assumptions and that is why they are working on a update. We expect SAP to be revised and reissued later this year and also anticipate a major revision to RdSAP to follow in 2022 which we believe will address all of these anomalies.

We recommend

As part of that review Elmhurst, through numerous articles, lobbying and our annual Manifesto for Change, are asking for government to: 

  1. Restructure the EPC to give equal prominence to the property's carbon emissions, energy consumption and energy cost
  2. Update the SAP/RdSAP methodology as soon as possible and then at least every three years thereafter
  3. At the earliest opportunity remove the current block of fuel switch recommendations for primary heating
  4. Reduce the validity of EPCs to three years and require a new one whenever there is a change to the property that is likely to impact its rating  and the recommendations it contains
  5. Focus legislation on the metric that it relates to;  Climate change legislation should focus on carbon emission, fuel poverty legislation on cost.
  6. With our new central register of EPCs in England and Wales allow for the recommendations to be switchable between those that will have the best impact on carbon emissions and those that will save most money letting the consumer decide, influenced by legislation, taxation and incentives, what is most important to them.

    Article Published: 28/06/21

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