Following a call for evidence in 2018, BEIS and MHCLG have released Energy Performance Certificates for Buildings – Action Plan. Since their introduction in 2007, EPCs have been used across the UK to measure the energy performance of buildings. Aside from being a legal requirement during any sale/lease transaction, the certificates provide building owners and landlords with an understanding of a building’s energy efficiency. As building stock accounts for over 30% of the UK’s greenhouse gas emissions, understanding and improving its energy efficiency is crucial as the nation strives towards its 2050 net zero goals.
The Action Plan
The way EPCs work is that a model of a new or existing building is created to predict its expected performance. It looks at factors like the fabric standards of the building, the glazing, HVAC, controls, and any renewable energy. This is then translated into a rating of A-G (A being the highest). There has been criticism that the correlation between rating and actual performance is not as strong as it should be (see A Tale of Two Buildings – Are EPCs a true indicator of Energy Efficiency?, Better Buildings Partnership.)
2018’s call for evidence on EPCs outlined the government’s view of what EPCs are currently used for, what they are likely to be used for in the future, and what important characteristics are required for these uses. From the 229 responses received from a variety of stakeholders, the key points were:
- Following the introduction of Minimum Energy Efficiency Standards for the private rented sector in 2015, which prohibit the leasing of properties with an EPC rating of F/G, and the current trajectory of achieving EPC ratings of C or better by 2030/2035, EPCs are gaining increasing financial value, driving the need for them to be more accurate, reliable and trusted.
- If EPCs are to be used as more than a tick box exercise for sale/lease transactions, and to provide a framework for improving the energy performance of buildings, they need to better engage consumers, providing clear information to drive action.
- The data infrastructure for EPCs needs to be fit for future changes, including the capacity to incorporate real-time data into the software used for building energy modelling, and assist consumers in understanding how to improve their buildings in a cost-effective way that ensures the long-term sustainability of their assets.
Some of these changes will take years to implement, while others will be much simpler and easier to make, but this action plan provides a much-needed starting point from which to shape future policies and legislation, particularly as the UK will no longer be bound by EU Directives post-Brexit.
One of the main changes will be a shift away from EPCs being created using a theoretical model based on features of a building (fabric, heating/cooling and ventilation systems) towards a true measure of “in-use” performance, while remaining a measure of building performance and not occupant behaviour. The Committee on Climate Change (2018 and 2019) specifically highlighted the need for EPCs to reflect real-time performance of buildings, and this is likely to be achieved through more sophisticated building modelling methodologies.
EPC consultation
Alongside the release of the action plan, came the release of a government consultation on how the MEES Regulations can be progressed to ensure a consistent improvement in the energy efficiency of our building stock, moving towards net zero targets. The consultation – Improving the Energy Performance of Privately Rented Homes in England and Wales – focuses and seeks views on proposed changes to MEES to significantly improve the energy performance of private rented sector homes in the 2020s. The proposed changes include:
- raising the MEES standard to rating C, by way of a phased trajectory, with new domestic tenancies required to achieve EPC rating C from April 2025 and all domestic tenancies required to achieve EPC rating C from 2028;
- an increase in the sum that landlords will be required to invest in improving the EPC rating of a sub-standard building from the current “costs cap” of £3,500 to £10,000;
- the introduction of a “fabric first” approach to energy performance improvements, that is, improving the fabric efficiency of a domestic building before heat and energy generation;
- enhanced enforcement aimed at encouraging compliance, including a new exemptions database, increased inspection rights, an increase in the maximum fine per property per breach to £30,000 and new restrictions requiring an EPC to be in place before a property is marketed and prohibiting properties from being advertised for let unless compliant with MEES; and
- the introduction of new provisions including giving domestic tenants the ability to require that energy improvements are made, a requirement that a new EPC is obtained on expiry of an existing EPC and on completion of improvements so as to provide that an EPC is in place at all times while a property is let and a requirement that listed buildings and buildings in conservation areas obtain an EPC and therefore fall within the scope of MEES.
The consultation closes 30 December and the government plans to publish a summary of responses in spring 2021 with revised regulations to follow in autumn 2021. The proposed changes, particularly in the domestic rented sector, are significant and the incremental improvement pathway is going to be crucial when considering that 80% of the buildings we will see in 2050 have already been built today. There will be a lot of work to be undertaken by landlords of all types in the next decade. So, while current and future building regulations may point towards net zero carbon buildings, ensuring EPCs can be relied on to predict better the energy/carbon performance of a building and guiding appropriate retrofit measures will be vital.
Lucy Davies is a sustainability consultant at WSP and Kate Symons is a senior associate at Boodle Hatfield LLP
