Comment: EPCs are the tool for the job

By: ameer@trustedteam.com

Recent media coverage for EPCs (Energy Performance Certificates) has been far from flattering with headline grabbing claims about their perceived “lack of accuracy” and questioning whether they are fit for purpose.

Digging beneath the headlines, it is easy to demonstrate that the conclusions being drawn are wrong and the motivation behind the publicity may be more about saving private landlords money and inconvenience rather than helping the environment,

Most readers will know that since 2008 EPCs have been a requirement for anyone putting their home (or commercial building) on the market for sale or rent.

EPCs have been with us for over 15 years, and what some perceived as being “a piece of paper than nobody ever reads” is now the basis of numerous pieces of Government policy, being read by homeowners and occupiers and, most importantly, being acted upon.

So how is an EPC rating calculated? The EPC for existing homes is a legal document that uses RdSAP (a modified version of The Standard Assessment Procedure [SAP] that is used for new build properties) to predict the energy consumption of the home using sound building physics that was developed, and continually refined, by the Building Research Establishment since the 1970s.

RdSAP is a versatile tool that uses over 100 data points including the number of occupants, hours of occupation and lifestyles. However, because the home is soon to have a new occupant and to allow prospective occupants the ability to compare dissimilar homes on a like for like basis, the EPC standardises the number of people in the home based upon floor area and presents the rating as a cost metric per unit of floor area.

This is the right thing to do with regards the EPCs intended purpose, but does mean that the EPC is unlikely to reflect actual consumption. To be clear this is an issue with the EPC, not the methodology that calculates it. It is also only an issue if you expect the EPC to be bespoke to the building and a particular occupant (guess what; there are tools that can do that too).

Minimum Energy efficiency standards for domestic dwellings in England and Wales were established in 2015 and the trajectory was made clear that all privately rented properties would need to achieve an EPC band C by 2027.

Initially the legislation was applied to require buildings to achieve an E rating when there will be new tenants, but then moved on to new tenancy agreements even if the tenants are unchanged, and now to existing tenants. No timeline to increase the minimum standard from an E to a C has been announced, but the intention remains.

The coverage in the press is, we suspect, a response to this legislation rather than an issue with RdSAP or EPCs. Private landlords who have not acted earlier fear that their lives are going to get less convenient, and more costly but the reality is that the burden of cost is currently being shouldered by the tenant.

Homes that have an EPC of F or G are five or six times more expensive to heat than a typical new home rated at an EPC Band B. So, whilst this legislation maybe requires a landlord to spend money to make the home more energy efficient, the savings from the improvements will benefit their tenants who are currently either spending a large amount of money on heating or, even worse, not spending the money and living in a home that is cold and potentially unhealthy if there is a propensity for damp and mould.

For the avoidance of doubt, by the end of 2023, eight million households in the UK will be in fuel poverty – the definition of fuel poverty is if a household spends more than 10% of its income on fuel costs and if the remaining household income is insufficient to maintain an adequate standard of living.

Every home is different, and the EPC reflects construction by requiring energy assessors to understand not only the size and construction type of the building but another 100-120 relevant data points. The EPC offers up recommendations for improvement, and, for most F and G rated homes, the necessary improvement can be achieved at a realistic cost, especially when that cost is compared with the energy bill savings.

As a rule of thumb improve insulation, and as heat rises, start with the roof then the walls, and then consider how the energy is converted to heat by considering a modern fuel-efficient heating system.

Back to the headlines. The research to which a number of the articles referred was factually correct, but the comparisons it makes are not. As previously stated the EPC is a standard way of comparing houses and will never equate to actual consumption. Furthermore the analysis appears to compare the metered energy (electric and gas) supplied to a home and compares that with the total energy consumption estimates on the EPC;

  • Because of its relatively high cost many low performing homes are powered by LPG and oil , neither of which would be recorded by smart meter data feeds and will be omitted from the analysis.
  • A proportion of those homes will not be occupied (holiday lets, buildings under renovation etc.) and, obviously , homes that are vacated for part of the year will have very different consumption figures from a home that is fully occupied
  • With current fuel prices, many people in poor performing homes simply cannot afford to heat their homes to a level required for healthy living. Their energy consumption will also be lower than predicted.
  • Those in very efficient houses, tend to be those fortunate enough to be able pay for the necessary energy efficiency improvements, or can buy a newer house. They also have enough money to adequately heat their homes. These people fit the model far more accurately.

The Property Energy Professionals Association (Pepa) the trade that represents government appointed Accreditation Schemes works tirelessly with government and industry to improve the quality of EPCs.

Pepa’s chairman Andrew Parkin recently commented “I am convinced that the underlying methodology is fit for purpose and are proud of the quality of work done by the 10,000 plus energy assessors. But we also realise that if “experts” don’t understand the presentation of the data then something needs to be done”.

The good news is that change is on the way with major changes to the EPC promised in the EPC Action Plan which we are advised is ‘Imminent’;, changes to RdSAP methodology which is scheduled for early 2024 and a new energy bill which will give all parties greater freedom to develop EPCs as the catalyst for improvement that this country needs to achieve its net zero ambitions. Watch this space.

Martyn Reed is group managing director of Elmhurst Energy and executive board member of Pepa.

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