Are EPCs fit for purpose?

The EPC was initially created to provide an approximate measure of the performance of housing stock in the EU. It does this, not by measuring the energy usage of a building, but by estimating the transmissivity of the external surfaces as a proxy for it.

To do this, approximate measures are taken of these surfaces and the changes in them, such as windows and doors. Guesses are made about the materials that make up the elements so a computer programme can estimate the heat that would be lost through them under typical conditions.

In real life, the performance of a particular property is also affected by altitude, exposure, prevailing winds, the direction the main windows face and the heat gained from them. Rooms are all at different temperatures, which cause different heat losses in different rooms. Air changes aren’t measured and they have a major effect on heat loss. Everything is treated as ‘Typical’.

The approach has some validity in being able to assess the energy performance of the house to a very approximate level. It has no validity in trying to predict the actual energy being used by a particular family in a particular property. Further, the methods used to determine the performance are open to too much guesswork on fabric and sizes and contain too many fudge factors to be regarded as an accurate assessment of performance.

Additionally, the whole process is hidden from view; the information fed into the computer, and the way the computer deals with it, is not laid out anywhere except as generalities. It is the antithesis of the ‘scientific method. Yet this determines if a house can be let or not.

Recording the facts

All the physical measurements and guesses are noted on site by the assessor and then fed into a computer. At this point, the guesses may be further tweaked to produce a value the assessor feels appropriate.

One hesitates to state the possibility that this tweaking would be open to financial modification. It is extremely unlikely, given the guesses and uncertainties that any two assessors would arrive at the same value on the same day. At no point does anyone get to validate the data used as input. To give it some credibility, the facts recorded and fed into the computer should form part of the EPC, possibly as an addendum. These facts could then be validated by anyone inspecting the property. This input information should be recorded on a standard data sheet and form part of the EPC.

The Magic

The computer then provides a precise number to classify the property. In my experience, with only two properties, the number can go down by 21 or up by 2 in successive assessments. In the former case, some improvements had been carried out; in the latter case no improvements had been made. To be considered accurate, the number would be exactly the same, no matter by whom or when the assessment was performed or which version of software they used.

An explanation of how the input information is mapped to the points in the rating should be available. For instance, one rating was reduced by 1 point because there was a decorative electric heater present in a room. How many more oddities are there?

At the moment, all this detail is left to the high priests who drive the computer. The system has much in common with the Post Office Horizon system in its opacity.

Energy estimations

The EPC also talks about the typical cost of energy used by the property. This applies to a typical set of occupiers using the property in a typical way. In other words, it is accurate for very few people. A bit like a stopped clock that is accurate twice a day. Perhaps a plot of energy usage based on actual energy used rather than the typical family would be of assistance here.

The recent consultation

In the recent consultation on the EPC, the accuracy and reliability of the rating system is not mentioned; it is assumed that this basic core of the system is perfect and fit for purpose. Clearly, it is not. The consultation is more concerned that the rules may have a bad effect on someone with ‘’protected characteristics”. There is talk of adding points for SMART readiness. Presumably, the landlord will have to provide the internet service to support it as part of his basic offering and probably provide the tenant with formal training.

Suggested changes

A number of suggestions for improvement are made in the EPC. These are unrealistically costed and often the changes are not related to the number of points to be accrued by their implementation. There is no suggestion that if the stated improvements were carried out that the improvement of points would be guaranteed.

To meet the requirements, it should be easily possible to try many different combinations of improvements without having to go back and ask and pay for another investigation by the assessor.

The EPC software should be generally available. After all, the assessors become experts after 3 days of an internet course, starting from no qualifications or experience and only needing the ability to switch on a computer. There must be very few landlords who couldn’t cope with this. No doubt it would make good deal of sense for any landlord to do the course in order to play the game.

There should be nothing magic or hidden about the EPC process.

Surely, only one can assume it is hidden because it wouldn’t stand up to the light of day?

What do others think?

Thanks,

Ian

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