Failed EPC Due to assumed no insulation?

Failed EPC Due to assumed no insulation?

15:23 PM, 3rd February 2020, About 2 years ago 24

Text Size

I am at a loss where to go to rectify my EPC rating. The engineer that came out to assess has rated my flat (converted Mill in 2007) a G3. He has given zero stars for Insulation walls & Ceiling. The stone walls are 2 foot thick which I believe are dry lined but my roof is pitched with no loft hatch.

What he has said is: “As there is no evidence on site of any insulation, we cannot say there is any even if someone says there is. There are 2 ways we are able to override the insulation –

The landlord can supply a building sign of document from when the properties were converted. This MUST include the building regulations date it was converted to(this isn’t always present on the documentation so if the LL doesn’t have it, it’s not that unusual).


A letter from the company who carried out the renovation. Within this letter it MUST have all of the following information
•Letterheaded paper
•Address of the property in question
•Insulation type and thickness as well as where the insulation is, ie exterior walls, roof etc
•Signed by a Director of the company who carried out the renovation.

That latter is impossible as the firm went bankrupt a couple of month after completion. I have no documents that refer to material used.

Can anyone guide me in the right direction?

Many thanks



by Julie Ford

16:44 PM, 3rd February 2020, About 2 years ago

Do you need the higher rated EPC so that you can rent it out?
A property with a G rating can still be used as a rental property it just needs to get an exemption.
There are a number of exemptions, if you go to the Gov website it will give you these and how to apply for the exemption, these usually last 5 yrs.

by James Barnes

16:56 PM, 3rd February 2020, About 2 years ago

Reply to the comment left by Julie Ford at 03/02/2020 - 16:44
Correct to a degree, if you can still make energy efficiency improvements to the property within a £3,500 price cap then you will be required to do that before you can register the "high cost" exemption.
Lack of a loft hatch to a pitch roof, doesn't prevent you from installing a hatch and installing insulation over the joists if it isn't already present. Finding out if/how the walls are shouldn't be too difficult either.

by John Dace

9:34 AM, 4th February 2020, About 2 years ago

Finally! People are waking up to the headache that is EPCs.
Another example of super standards / requirements / restrictions on rented houses. Private owners are not burdened with rules like this and all the other (licencing, gas, electric etc). I have had EPCs done on flats in an all electric area where internal wall insulation and solar panels were ignored. Then- if the suggested works were carried out - the saving would apparently be more than the actual real life bills are now! The whole thing is ridiculous. Plus its so ‘eco’ to have an army of inspectors attending courses all over the country, then driving round all day inspecting properties. Has anyone worked out how much Co2 and pollution this causes? Thats without all the people in heated offices dealing with the running, and training schemes.
Its going to get worse and together with all the long list of ‘over the top’ regulation will kill the sector - to the detriment of all.

by John

10:00 AM, 4th February 2020, About 2 years ago

Worst case scenario is to cut a 10cm square hole in wall or ceiling, or big enough to get a torch in and actually look. Maybe pay him to be there to record what he sees.

A patch repair to plaster board is very easy to fix. Check out the Utube vids on this.

by James Mann

10:11 AM, 4th February 2020, About 2 years ago

Put in a loft hatch and reinstate up to current requirements. It is really quite cheap.

by Helen (up North)

10:18 AM, 4th February 2020, About 2 years ago

You could try using an inspection camera. Mine cost £40 from Aldi but you can get them from lots of DIY stores. They have a built camera and torch on the end of a semi flexi cable. It would easily pass through a hole between 12-15mm did, so could easily be filled afterward. They are very efficient and clear. Good luck.

by brian gill

10:27 AM, 4th February 2020, About 2 years ago

If you have any electrical sockets on the walls, and it is dri-lined, there will be the plastic electric back boxes. Turn off the ring main and remove the face plate and you can usually remove the back box and you can see whats behind.

Put in a loft hatch, or at the very least an inspection hatch that you can get your head through. They can be fitted between the joists and glued onto the ceiling. Inspection hatch will cost £10-15 and will be there for when/if you need to get another EPC done, or check for any roof issues.

by Laura Delow

10:27 AM, 4th February 2020, About 2 years ago

Planning permission is not normally required for fitting insulation (where there is no change in external appearance) but if there was any change to the external appearance or at the time the property was listed or in a conservation area, then insulation may have been required as part of the planning application, copies of which are available online from your local planning office if you know the year it was converted & are of public record.
Building Regulations where a solid wall has been upgraded by the installation of insulation, today must meet the minimum energy efficiency values set out in Approved Documents (these may have been different minimum standards in 2007 when converted) but if such an upgrade in insulation was / is not technically or functionally feasible, the element should be upgraded to the best standard which can be achieved within a simple payback of no greater than 15 years i.e. comparison of the installation cost against the energy savings made by the proposed specification over the 15 years.
Where 25 per cent or more of an external wall was renovated, building regulations would normally apply and the thermal insulation of the wall would have to have met the standards required (at the time) by building regulations Approved Documents. Unfortunately the Building Regulators records are not normally kept for more than 4-5 weeks. You can however pay a fee to your local authority to carry out a search of their archives if the building control work was carried out by the local authority. You should nevertheless contact them to obtain a copy of a Completion Certificate or Full Plans approval notice (the Building Regulations 2000 provide for the issue, by local authorities, of completion certificates where work has been carried out and completed under the building regulations, and the local authority are satisfied after taking all reasonable steps, that the relevant requirements of the building regulations have been complied with).

by Billy

12:26 PM, 4th February 2020, About 2 years ago

Firstly, the Assessor has carried out the correct course of action, at times this is not understood by the client and he seems to have advised correctly.
Secondly, It is good to see assessors not cutting corners.

Yes this is a problem and as an assessor I have had similar issues. The assessor will have to age the building in accordance to the year it was built in, if there is a completion certificate then he can change the year of age in accordance to when the conversion was completed. Once this is inputted into the software it will take into consideration the building controls for that year and in your case 'assume' there is insulation which will have a difference to the score. As there is no evidence for this he would have to set the age of 1900's if its a mill and the building controls for that would assume there is no insulation (as an assessor I don't agree with this but unfortunately it is the rules. I have spoken to the auditors about this).

I have gone above and beyond at times and contacted the council and managed to obtain a completion certificate even though the landlord does not have one.
If this is a mill then I would assume others would have been converted also, its worth checking if these have passed recently and contacting the assessor (details are provided on the certificate) to see if they managed to obtain the necessary paperwork or getting the assessor to do this (not technically within his remit but it's something I do above and beyond for my clients).

As next actions:
- Contact your local council to see if they have a copy / some councils may state they can only give this to the landlords.

Not sure what area you are in in the UK but if it is in and around the Manchester area I don't mind assisting if I can.. feel free to message me.

by Jo Westlake

13:18 PM, 4th February 2020, About 2 years ago

The whole EPC assessment is flawed and results are largely down to the opinion of individual assessors.
I have just bought a renovation project that had an EPC done in November 2018 for sales purposes. It scored F25. I asked my regular EPC assessor to have a look at it and advise me how to target the renovation to best improve it's EPC. His starting point was to assess it in its current state (exactly the same as it was in 2018) and has rated it as G14. That's an 11 point difference of opinion.
The flat in question is ground floor with part uninsulated concrete floor, part uninsulated suspended timber floor, uninsulated cavity walls, single glazed sash windows, no heating or hot water but it does have low energy light bulbs.

On other houses I have had EPC scores lowered after doing roof insulation work because the roofing invoice only stated Celotex, not the thickness used. The Building Control certificate just said it complied, not what materials were used. The EPC assessor decided that as I couldn't absolutely prove what was there he would assume nothing.

If we can't have consistency in the system what is the point of having the system at all?

1 2 3

Leave Comments

Please Log-In OR Become a member to reply to comments or subscribe to new comment notifications.

Forgotten your password?


Landlord Tax Planning Book Now