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Graham Awards


Who Has The Energy To Reform EPCs?

There is much debate about energy efficiency right now and about expected changes to minimum EPCs for private rental properties and ultimately the wider housing stock.

But isn’t this the ideal opportunity not to talk about tinkering with EPC targets - but look at whether EPCs are fit for purpose at all? 

And asking whether they need reform? Or if they are even capable of being reformed? Or should they really be replaced?


The pro-EPC lobby is a conservative one that in my experience does not take kindly to proposals for change. 

But the case for reform, at the very least, seems strong.

It’s over six months now since the Sunday Times revealed genuinely shocking research showing that Energy Performance Certificates were inaccurate at best, useless at worst, and easily rigged.

Sophisticated and highly detailed research by a firm called CarbonLaces found that EPCs overestimated energy use by up to 344 per cent.

CarbonLaces compared the EPCs of more than 17,000 homes with their actual use, as logged by smart meters every half hour for at least 300 days, to calculate energy bills. 

The Sunday Times reported: “The average metered gas and electricity use for all the properties studied was 125kWh per square metre a year — 91 per cent lower than what their EPCs claim (239kWh/m2/yr).

“The lower the EPC rating, the bigger the overestimation. For properties with the worst rating of G, EPCs estimate they use 656kWh/m2/yr. Yet their smart meters show they use only 151kWh/m2/yr — a 344 per cent gap.”

CarbonLaces also found that EPCs overestimated not only energy use but also carbon emissions, by between 20 per cent (for EPCs rated C) and 308 per cent (for EPCs rated G). 

And having gone on to reveal the tricks that developers and contractors use to get a good EPC rating, the Sunday Times quoted one expert who analysed new build EPCs .

He said: “All they do is make the plaster wall box airtight, while the building itself is very leaky. Give me a garden shed and enough mastic, foam and plaster board and I can make it airtight . . . It’s nothing to do with making sure that they’re energy efficient. It’s to do with ticking a box.”

One newspaper investigation is not conclusive proof that the whole EPC system is of limited use but there was almost no industry refutation of the article: the silence was deafening, and pointed to an acceptance of the problem.

And many peoples’ experiences of EPCs being conducted in their own homes (certainly in my case) may add weight to the growing scepticism that surrounds the certificates.

Finding a suitable replacement is easier said than done, of course.

I am certainly not qualified to suggest an alternative but I was struck some years ago when experts suggested measuring the thermal losses of a building in operation, both at the time of construction (if possible) and the time of sale. 

More recently RICS called for major refinements to the way EPCs were calculated and used to inform consumers.

This included emphasising a property’s final energy use; carbon emissions; and energy cost. These three metrics were selected to dovetail with the objectives of the government - at least until recent U turns.

Other players (some, perhaps, with vested commercial interests) say any reform of an EPC must involve more frequent assessments, too. Once every 10 years seems too long given today’s accelerating technology.

There will, no doubt, be a debate in our industry and in the wider world on this issue given the growing passions surrounding energy efficiency.

Let’s hope the debate is not hijacked by short term expediency. 

We’ve surely had enough of politicians and outspoken pressure groups wanting to be seen to be ‘doing something’ and so demanding stricter EPC targets without stopping to see if these certificates were actually fit for purpose.

Instead, let’s take the time to work out what EPCs are for and how they can best achieve those objectives. 

This will take time, which won’t fit in with the schedules for the political party autumn conferences nor for the next Generation Rent press release. 

Does anyone have the energy to take on such a comprehensive and thoughtful review? Let’s hope so.

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    I'm a chartered surveyor, commercial property landlord and domestic property landlord. EPCs are MOST CERTAINLY 'fit for purpose', it's the energy wasteful housing stock (mostly PRS) that is not fit for purpose. It's now widely reported that more than 25% of families in the PRS live in sub-human fuel poverty because their landlords have chosen not to insulate the walls, loft and roof of these units. The Carbonlaces 'research' has been comprehensively picked apart by the professional surveying community. Anyone with any critical intelligence realises that an ACTUAL tenant in an EPC Grade G flat would be using 344% LESS energy than the EPC assumes because an EPC is an ASSET RATING - it has been for 15 years and this is the correct methodology. An ASSET rating assumes that the tenant heats every room to 20 degrees all winter. Of course if you are in a shockingly energy wasteful Grade G flat only a millionaire could afford to heat the whole flat correctly. So what happens? These tenants UNDER HEAT their families by 344% every winter. At most they heat one room and normally they cannot afford to heat even that because the property has NO insulation. The energy assessors I use for my properties are highly professional, attend regular training up-dates, and are routinely & thoroughly audited by the Government. As with any measurement its more accurate if the building owner provides data on their building to the energy assessor. Just like a check-up with a Doctor is more accurate if you talk to the Doctor and provide him with some information.
    The robust EPC system for commercial rental buildings has been tried and tested for years. That's why there are more then 1 million commercial EPCs on the public database. That's why they are used and relied on by every UK bank for loan security purpose. That's why they are used by RICS Registered Valuers for valuation reports. It's a national system that's working and is the envy of the rest of the world.
    The 21 million domestic EPCs and the Tory's super simple and effective Minimum Energy Efficiency Standard (MEES) means that not a single energy wasteful EPC Grade F or G house, flat or commercial unit has been let to a new tenant since 2018. EPCs and MEES are working, the numbers don't lie. That's why good, forward thinking landlords have been installing LED, electric heat pumps and insulation for YEARS. It's the moaning landlords who have failed to invest in making their product fit-for-purpose that are now getting all upset.
    We now need to change the main EPC Grade on domestic EPCs to report the CO2 pollution figures as the main coloured graph. This data is already reported half way down the EPC certificate so it just needs to be bought to the top of the EPC. Very simple. This is how's it's been for commercial EPCs for the last 15 years. This would then encourage landlords to install intelligent, efficient electric heating systems in conjunction with insulation to walls, loft and roof. That's what our UK housing stock desperately needs. EPCs are an excellent national measurement system and folk need to focus on making their buildings better rather than trying to find a scapegoat.

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    Hi Martin,
    I too am a Chartered Surveyor Landlord and also a Managing Agent for a small medium size portfolio (1500 units) for about 30 years . Whilst I agree with a lot of your response I must take issue about EPC being fit for purpose. In my experience, EPC's ARE NOT FIT FOR PURPOSE , the main problem lies in the tick box way they are reported, I often see EPC's which are simply wrong. As An example on one of my own properties the Assessor failed to notice my flat was fitted with fairly new Double glazing and then recommended it, she also assumed the loft insulation to be 100mm but did not look in the loft to see it was over 300mm! when challenged the answer was "oh its on the drop down menu" the qualification process is so basic and simple it allows anyone with only the very basic knowledge to complete it .
    I carry out RICS homebuyer reports and on three/four times out of ten there's something I disagree with .
    its true about tenants failing to properly heat their properties but thats not the point.
    I note you contend "The energy assessors I use for my properties are highly professional, attend regular training up-dates, and are routinely & thoroughly audited by the Government." - you are very lucky . I feel the estate agents putting forward EPC assessors don't care about these things, only the bottom line . I tackled another EPC assessor who complained they only received £40 per assessment. There are some properties especially older ones in London that cannot be raised up to a C unless tens of thousands are spent which no landlord will do. Is demolition a better prospect ?


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