EPC C: New calculations must be based on real-time data
Plans to transform the way Energy Performance Certificates (EPCs) are calculated need to be based on real data and must be realistic when it comes to reflecting different property types.
We have made the calls in our response to the Government consultation on its new Home Energy Model (HEM) plans, which will replace the existing system in 2030.
What is the Government proposing?
EPCs are, at present, calculated based on the energy costs for your home, but the Government believes the current methodology is flawed, and can often lead to inaccurate scoring.
Under the new Home Energy Model three metrics will be taken into consideration:
- Fabric performance
- Heating systems
- Smart readiness
Under the proposed new system, landlords will need to make the required ‘fabric first’ improvements, then pick either the heating systems or smart readiness metric to adhere to.
The ‘heating system’ metric will encourage landlords to install clean heating systems such as heat pumps.
Crucially – as the plans stand – homes with a gas boiler, even modern and efficient ones, will be unlikely to meet the C grade necessary to rent out your property post 2030, something we think needs to be revisited.
When it comes to smart readiness, the Government wants to encourage landlords to generate and store their own energy, so is proposing the introduction of solar panels.
Why does it think the new system will be better?
In its consultation the Government says the new methodology will rely less on assumptions and more on property specific data which will result in more accurate EPC assessments.
What do we want to happen?
In our response, we are asking the Government to take a pragmatic approach to the way different types of properties are assessed under the new rules and have stressed that any recommended improvements must be realistic and suitable for different property types.
In particular, we are asking the Government to take into account the whole picture when assessing a property, rather than relying on individual metrics in isolation.
Fabric metric
For the fabric metric, we have asked the Government to rely less on assumptions when assessing a property’s insulation, and instead make greater use of real data, such as Heat Transfer Coefficient (HTC) readings from smart meters.
Heating systems
For the heating system metric we have made clear that gas boilers should not automatically result in a lower rating. This is particularly important where a property is well insulated, has limited capacity for low-carbon technologies, and already has a cost-effective heating system.
Smart readiness
When it comes to smart readiness metric, we have welcomed the flexibility it offers – however we have stressed that many properties, particularly leasehold flats, will face barriers to installing technologies due to constraints around freeholder consent and structural limitations when it comes to installing solar panels on certain properties, for example, flats.
We have also flagged that, while exemptions may be available, we are concerned that the register may not be able to cope with the likely volume of cases. As a result we want clearer and more practical routes to compliance, especially where landlords are unable to make improvements due to factors outside their control.
More information
You can access the consultation documents here.
