Call for clarity on new EPC plans

With Renters’ Rights dominating the headlines at present its easy to forget other reforms on the horizon which could have significant consequences for landlords. Here NRLA Chief Innovation Officer and founder of Safe2 explains more about plans to change the way EPCs are calculated and what that means for you and your portfolio. 

The Government launched its consultation on future minimum energy efficiency standards (MEES) for the private rented sector earlier this month, but a more technical consultation was launched late last year that proposes changes to the way the energy efficiency of our homes is worked out. 

Both will have a significant impact on PRS landlords and could mean costly works to bring homes up to standard, as part of the Government’s plans to get all private rented property to a minimum EPC rating of C by 2030.  

We have now submitted our response to the first consultation, which closed this week, flagging a series of key concerns that we believe need to be resolved before plans can progress.   

What is the Government proposing?   

Essentially the Government wants to change the way Energy Performance Certificate ratings are calculated using more comprehensive home assessments and more frequent inspections, taking into account:  

• carbon emissions   

• the fabric of the building   

• the heating systems used    

• the cost of bills   

When it comes to what is measured, it wants to replace the existing Standard Assessment Procedure (SAP) with the Home Energy Model (HEM) something it believes will give a more accurate rating.  

The changes are likely to mean extra expense for landlords, with the new, more in-depth inspections expected to take longer, and, as such, come with a heftier price tag, something we have flagged in our response.  

Key concerns  

In our consultation response, we have raised a number of other key concerns with the proposals, including:   

1. The issue of thermal comfort  

The first of the concerns we have flagged is ‘thermal comfort’, essentially how happy people are with the temperature of their home environment  

This – and the price of energy bills – are arguably the two most important things to tenants when it comes to energy efficiency, yet we feel they are being put on the back burner due to the Government’s myopic focus on low carbon heating.   

We want to make sure these two elements are front and centre when it comes to measuring properties’ EPCs, not least as the Government has stated its primary mission is to ‘cut bills for families and slash fuel poverty’.   

1. The concept of fair ranking   

As it stands, the proposed ‘heating systems’ metric will create a ranking system that places all low-carbon heating systems over all non-renewable heating systems.   

This could result in, for example, an inefficient heat pump or electric heater being ranked above a cheap and efficient gas boiler, leading to higher costs for tenants in some cases, which we believe is wrong. We are therefore suggesting that the issue of efficiency to be included when making decisions on ranking.  

1. Smart readiness  

We are also seeking clarity on the need for a property to be ‘smart ready’, as outlined in the consultation report. We are arguing that properties, particularly older ones, should not be ‘marked down’ because they do not have reasonable access to low-carbon heating or other low-carbon tech such as EV charging points.    

1. Changes to validity periods  

Our final concern centres on discussions around proposed validity periods for EPCs, both new and existing. The Government is consulting on a range of options, from phasing in new rules – applying them to new EPCs only at first –  to invalidating them all in one fell swoop. We want to know more about the favoured option, and how changes could be introduced in a way that would cause least disruption to landlords and their tenants.  

The consultation closed earlier this week, and it’s likely to be several months before a government response is published. The second consultation, on Minimum Energy Efficiency Standards, is open until 2 May and we urge all landlords to respond.  

Please keep an eye on our news centre and social media channels for all the latest on the progress of both and to find out more about our calls.  

More information  

• For more information on the NRLA’s ongoing energy efficiency campaign click here.     

• Part of the NRLA family, Safe2 is a digital platform providing of all forms of property safety certification. A one-stop-shop for all things compliance, it sends alerts when documents are due to expire, organises inspections and repairs and issues certificates. All NRLA members are entitled to exclusive discounts when using any of Safe2’s services.     

• The NRLA’s award-winning Training Academy also runs a course on energy efficiency for landlords and a new retrofit course.