EPCs – call for evidence

CIBSE wants better enforcement and detailed recommendation reports, says Sara Kassam

The Clean Growth Strategy set out the government’s ambitions to improve the energy performance of buildings in the domestic and non-domestic sectors. In particular, it set out an aim for properties in the private-rented sector – and all fuel-poor homes – to be upgraded to Energy Performance Certificate (EPC) band C by 2030, and an aspiration for as many homes as possible to be upgraded to band C by 2035. It also wants energy efficiency in businesses and industry to be improved by at least 20% by 2030.

In this context, a call for evidence was made seeking views on introducing additional points when EPCs might be required and ways in which they could be improved.

EPCs are widely used as a measure of the energy performance of buildings, but – in the CIBSE response to the call for evidence – we question how robust this is. You cannot manage what is not measured. For all uses of EPCs in the domestic and non-domestic sectors, the attributes of quality, encouraging action and data availability are essential.

Powerful tool

Policy cannot assume that, just because an EPC has been produced, better energy performance will automatically follow. A whole range of other factors affect whether energy-related improvements are made to a building.

If comprehensive recommendation reports were provided, with realistic estimates of savings and costs, EPCs could become a powerful tool to improve energy performance. Enhancing the quality and overcoming the low-fee culture among those producing EPCs should be a priority.

A significant factor influencing the reliability of EPCs is the time to produce the certificate. EPCs done with insufficient time to obtain the required information related to buildings, will lead to an inaccurate energy report. Those procured in a hurry to facilitate the sale of a property are at increased risk of using default values, which are intended as a tool of last resort. Also, an EPC is a standardised form of energy labelling, but does not include operational energy use. CIBSE has long advocated the wider adoption of Display Energy Certificates (DECs) in the non-domestic sector. Operational ratings based on measured energy consumption serve a different purpose from EPCs, but can be seen as complementary and there is a good case for reporting both metrics.

There is great concern about the lack of enforcement and low levels of compliance with all certification aspects of the Energy Performance in Buildings Directive. As always, we are keen to see more rigorous enforcement of EPCs and DECs. 

CIBSE’s response to this call for evidence was made possible by detailed input from enthusiastic members. Next time you see a request for contributions to a consultation, please get involved and make your views heard. CIBSE’s full response is available here.

Sara Kassam is head of sustainability at CIBSE.