The government has issued a call for evidence to learn how energy performance certificates (EPCs) are performing and whether they can be made more effective.
The consultation asks how EPCs are currently performing, whether they are suitable for the purposes for which they are used, and how they can contribute to reducing buildings' energy use. It applies to both commercial and residential buildings and the closing date is 19 October 2018.
EPCs are a widely used measure of the energy performance of buildings in the residential, commercial and public sectors, and are a key tool in promoting buildings' energy efficiency. They were originally introduced in 2007 when the UK transposed the requirements of the EU Directive on the Energy Performance of Buildings into domestic legislation, and there are now over 18 million EPCs recorded on the central register.
Although EPCs were originally an EU concept, they are now governed by domestic law and will continue to be relevant after Brexit.
The purpose of EPCs has changed over time. An EPC is needed before a building, or part of a building, is sold or rented out. EPCs were originally intended to provide information for building users, particularly home-buyers, by providing an indication of energy efficiency from A (best) to G (worst), and by making recommendations for how a building could be made more energy-efficient.
However, EPCs are now used for other purposes, including assessing energy efficiency for the purpose of the Minimum Energy Efficiency Standard (MEES). MEES has applied to new lettings of both residential and commercial buildings from 1 April this year, and it will apply to all let residential buildings from 2020 and all let commercial buildings from 2023. It is therefore vital that EPCs are reliable and effective.
Some of the specific issues raised in the call for evidence are:
How reliable are EPCs and how can their reliability be improved? It seems that there is considerable variability in EPC results: apparently a test carried out in 2014 arranged for EPC assessments to be carried out five times on 29 houses. In two-thirds of cases, the EPC ratings spanned at least two bands. The call for evidence paper says there have been improvements to the EPC software, auditing process and assessor training since then.
How likely is it that EPCs are out of date because works are carried out that might affect the EPC rating? It is possible that there are many properties with EPC ratings that are no longer accurate after improvements have been carried out, such as new boiler installations or houses being extended. Should EPCs be required on new trigger points?;
What evidence is there that EPC recommendation reports are helpful? Could they be improved to make them more helpful?
What evidence is there that EPC ratings are helpful to consumers when buying or renting a property? Are consumers using information in the EPC to negotiate property prices or rents;
Do consumers understand the energy rating system?
What evidence is there about levels of compliance with the requirement to provide an EPC when buying or letting a property? What evidence might there be about reasons for lack of compliance? How could levels of compliance be improved?
The call for evidence concludes with a request for any other relevant information that consultees wish to provide. This will be a good opportunity to mention some of the uncertainties with which practitioners have to contend, because the EPC regulations are not well drafted. For example, it is unclear whether an EPC is needed for a listed building.
An additional concern is that, in places, the government's guidance seems to differ from what the EPC regulations actually state, such as whether an EPC is needed on a lease renewal. This is an opportunity for us to draw these and other problems to the attention of the civil servants responsible for the EPC regulations.