EPC – contact your MP?

EPC – contact your MP?

10:57 AM, 3rd April 2023, About A year ago 36

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Hello, I’m a landlord with 4 flats that turnover less than £5k per annum each. They will never reach an EPC C. I can apply for exemptions once I have spent up to the £10k (more than 2 years turnover, not profit) on each flat.

I’m so annoyed with the stupidity of this legislation. It is based on an EPC that isn’t seen as fit for purpose by the climate change committee. The consultation that closed in January 2021 hasn’t been commented on.

There is a lot of really intelligent sensible stuff written on this site about this BUT who is listening?

Because I feel so powerless in this and want our voices heard I have been in touch with my local MP and I think any landlord in my situation should do the same.

Explain to them the situation about these regulations driving landlords from the PRS and ask them to speak on your behalf when these new regulations eventually get to be debated in Parliament.

Because of the housing crisis in the UK, every MP has a duty to protect the availability of cheap housing in their area or allow the increase of homelessness. Most of us in my situation have “substandard” homes that are warm, dry and affordable.

Say to him or her to highlight the detrimental effect a blanket £10k cap on spending (no matter what the income generated) could have on the PRS in in their constituency.

Ask him or her if they could suggest in such a debate that short notice to put in improvements when there is a shortage of skilled labour in the country is not enough time? The finalised regulations are 2 years off and yet there has still been no response to the January consultation.

If these regulations are not debated and finalised soon the wait for works will be enormous. At present, if I want a new window from a reputable firm the wait is 10 months and all the insulation contractors are doing lucrative grant paid for works and are not interested in small jobs like mine.

Ask your MP to point out that the EPC as it stands is not seen as fit for purpose by Lord Deben, the chair of the climate change committee, and as these measures are about making our housing stock more energy efficient then perhaps addressing the shortcomings of the EPC should come first? Perhaps it is possible to delay these new regulations and concentrate on that instead.

I actually think that last point about EPCs is really the most important … surely we should have a measure of energy efficiency that is fit for purpose?

So keep complaining on these pages but take your voice to where it might be heard please….and I know you’ll think what’s the point!

But if every MP in every constituency heard us maybe some sense could prevail …. You know, in the time you read this you could have rung your MP and made an appointment at their surgery.

Thank you,


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Richard Phillips

8:53 AM, 4th April 2023, About A year ago

Reply to the comment left by Jonathan Cocks at 03/04/2023 - 23:29
The EPC looks at how a property is conditioned and how much energy it consumes to meet a certain benchmark occupancy level. NOT how you actually occupy the space, but how the same benchmark person living in every residential property would live.
As such RdSAP (which is the methodology used for domestic EPCs, Commercial uses a different methodology) looks at the type of heating syetem, its efficiency and the carbon factors of the fuel feeding it. Gas appliances can exhibit their inefficiencies as waste gases and heat out of the flue, whereas Electric appliances can only exhibit their inefficiency as heat. Therefore inherently an electric heater is 100% efficient. There are differences in how the how is distributed, but any manufacturer claiming a more efficient electric heater than another is merely getting rid of the heat more effectively.
For SAP we have a database of products that the government have approved (it can be found here: https://www.ncm-pcdb.org.uk/sap/ ) which publishes efficiencies that can be used within SAP or SBEM (the commercial methodology) If a product is on that database, then it is the efficiency published that the software uses rather than a claim from a sales leaflet. I think I'm correct in saying that the only electric heaters on the database are what are referred to a high heat retention storage heaters. (E.g Dimplex Quantum)
IR Heaters work by heating the person in front of them rather than primarily the air. So in a warehouse, you'd like ave a few around workstations where people are packing etc, but the whole warehouse isn't being heated. SO they feel warm as the heat is radiating rather then convecting from say a panel heater. Night Storage heaters do better in the EPC than panel heater as they a) give off a continuos background heat all of the time, but also make use of the night storage tariff. So since the domestic EPC is cost related they do well using the cheaper overnight electricity. The old asbestos filled manual charged night storage units are less favourable as they don't have the same approved performance as the High heat retention units.
Regarding variations by different assessors. Firstly you can't see the workings of a previuosly issued EPC by another assessor so each subsequent EPC has to be redone from scratch unless its the same assessor. Whilst area has a bearing on the rating, I think and 8% would make very little difference to the EPC rating as the calculation is comparing differently constructed models within the software. So if EPC is 108 m2 the 2 models it's working with are both 108m2, i.e. the ratio is the same. So for a 49m2flat suppose one assessor measures low, and the other measures high. E.g Assessor one measures 7 x 7m, and the measures 7.34m. Suppose the absolute measurement is 7.17m square. The actual measurement inaccuracy is only 2.3%
As for Cob vs masonry well clearly one is wrong and there is a route to complain to the accreditation body whose details are on the foot of the EPC.
Just as a side note about the quality of assessors, and this is a general observation about perceived quality and what people pay. In an ideal world every assessor should produce the same rating as another. In an ideal world the EPC cost should also be fair an reflect the service provided. Look at the variation in the cost charged by differing assessors. You probably won't realise but in many cases there are large marketting bodies behind the big providers who are merely subcontracting the work out for pennies . I leave you to draw your own conclusions.


9:09 AM, 4th April 2023, About A year ago

Reply to the comment left by Richard Phillips at 04/04/2023 - 08:53
Richard P. Thank you very much for your detailed explanation/reply.
as i did not request the EPC in 2017, i might wait until I have my next EPC ,yes i believe you are correct re how IR heat people rather than space. but this is actually what my elderly tenants want, which is why it would be great if they are recognised.
may i ask you a question (and if you are noy allowed to reply i will understand, do you think changes need to be made to the SAP database?
before we have new energy targets (EPC in principal make sense to me, to help save this world we live in)but only if these targets have been fully accepted by all the energy experts.

thank you

Richard Phillips

9:19 AM, 4th April 2023, About A year ago

Reply to the comment left by Jonathan Cocks at 04/04/2023 - 09:09
Can I ask why the EPC was issued in 2017?
The database is merely a tool for people to use, one of those uses is for an EPC. I think there are some gaps and oddities in the calculation method and the conventions.

Susan Darke

14:39 PM, 5th April 2023, About A year ago

Reply to the comment left by andy adewale at 03/04/2023 - 13:42
Great idea

Brian Strickland

8:18 AM, 8th April 2023, About A year ago

Reply to the comment left by Richard Phillips at 03/04/2023 - 13:20Housing associations are exempt from the current proposed EPC legislation.


9:29 AM, 8th April 2023, About A year ago

I put some of these issues to my MP about a year ago who put it to the then housing minister…the response was a general ‘we are looking at how EPCs are calculated’. Indeed, there seem to be several EPC related discussion papers/bills/consultations but no more clarity on what proposals will actually become law. The only thing I’ve heard is that the C requirement has been pushed back to 2028 (from the proposed 2025) but haven’t found confirmation of that on the Gov site. As such, yes we need to push MPs but it’s unclear what we need to push against!

Jireh Homes

9:34 AM, 8th April 2023, About A year ago

Reply to the comment left by Ian Brand at 03/04/2023 - 12:00
In response to roof insulation which is evident in eaves and may be below boarding over joists, then any reasonable assessor will check if visible at edges and thus reasonable assumption to conclude covers whole loft floor. However some may argue only "allowed" head & shoulder view through hatch and to access and have proper examination takes time and effort so be careful who you engage. Alternatively if fully boarded you could drill a few "inspection" holes which will then allow spot checks.


9:43 AM, 8th April 2023, About A year ago

I think EPC ‘C’ has been put back to 2028! ?

Jireh Homes

9:46 AM, 8th April 2023, About A year ago

Reply to the comment left by Jonathan Cocks at 04/04/2023 - 09:09
The software and conventions behind RdSAP are reviewed periodically, which is why some EPCs now have different ratings to those conducted 10 years ago. This software is due to be renewed, predicted later this year which "might" treat electric heating more favourably, My advice is to have an EPC conducted with current version of RdSAP and if "low rating" address the low cost improvements (in consultation with your DEA, not the report recommendations) and then rework the assessment with future version of RdSAP, but only lodge if an improvement in SAP Rating.

Jireh Homes

9:51 AM, 8th April 2023, About A year ago

Reply to the comment left by LaLo at 08/04/2023 - 09:43
The original implementation plan was for minimum Band C to apply to new tenancies from 2025 and all existing tenancies from 2028. So no change in "direction of travel" just creating a tsunami a few tears down the road with applications for exemptions

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