Failed EPC Due to assumed no insulation?

by Readers Question

15:23 PM, 3rd February 2020
About 8 months ago

Failed EPC Due to assumed no insulation?

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Failed EPC Due to assumed no insulation?

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


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Mike W

17:58 PM, 8th February 2020
About 8 months ago

Rachel, you have my sympathy.
As another commentator has said it is worse in Scotland.
In 2015 I had internal wall insulation work done on two properties as part of a kitchen and bathroom refurbishment. Then I had EPCs done on both properties by a well known UK firm of surveyors/valuers. The result was C and D, the D because less wall work had been done in that property. Late last year I agreed to subsidised work to insulate the underfloor area and add loft insulation. As part of the deal an EPC would be taken before and after the work.
The EPCs before the work were D and E - the properties had dropped from C and D!! The surveyor was clearly inexperienced but basically said if I can't see it, it is not there! He did not notice the triple glazing either. The new work has been done but I have not yet had the new EPCs and will not deal with that assessor.
So how did this happen? Well the regulator (BRE) changed the goalposts (RdSAP 2012 v9.94) in September 2019 :
But the assessor was very inexperienced and he did not recognise that modern extensions (2010) had been made in the roof in both houses, something which of course the local 2015 surveyor/valuer knew about - its a row of similar houses and only these two had the extension. As he is local he would have looked up the building warrant online to establish the work age. The 2015 'inspection' took on board the wall insulation.
Thus the drop in EPC figures was due to the inexperienced assessor not identifying the extension as modern and refusing to recognise the wall insulation. Now the wall insulation does not require building warrant approval so it can be done by the homeowner, but if so, where is the proof? Do we have to disassemble the house to prove it is there? Other commentators have talked about drilling holes etc but that only 'proves' that the insulation is in that locality in that room. And anyway what about the cost? Interestingly would an inexperienced assessor even look under the floor for underfloor insulation if the access hatch is covered by carpet?
Now there are serious implications arising from this experience. Later this year minimum levels of EPC become a legal requirement.
I have over recent months have had a number of conversations with the Scottish Landlords Assoc., local authority building inspectors and assessors so it is clear to me that this mess has not been thought through. Who is going to provide an exemption because the assessor cannot see what is there?
And the inexperienced assessor also loaded up his incorrect assessment onto the national database despite my objection.

Rachel, I suggest you get a trustworthy experienced assessor to properly evaluate your property.

Jireh Homes

0:39 AM, 9th February 2020
About 8 months ago

As Mike W has suggested, best to engage with a DEA who understands the issues and is willing to work with you to achieve a realistic rating working within the guidelines. Any decent assessor should be willing to share the results of the assessment before lodging on the database and be open to challenge on their assumptions.
As the implementation in Scotland of min Band E has been delayed till Oct 2020 we have yet to see the route to exemption, but suspect the lack of "evidence" is not one of the justifications. Given the style and age of many of the properties in Scotland foresee a turbulent period ahead, both within the PRS and owner-occupied where Band C is proposed to kick-in in 2024!


9:08 AM, 9th February 2020
About 8 months ago

My assessor carries out a 'what if' exercise by inputting data on the computer system. That way we know the outcome and the process builds into it the anomalies the software contains.


16:58 PM, 15th September 2020
About 2 weeks ago

Thank you all. I am still no closer. The council have come back to me and confirmed The specification in relation to your request supplied by the contractor was the following:

Metal stud walling to be installed internal to the existing outer walls with 50mm PIR between them looking to achieve 0.35 W/sq mC
250mm Rockwool to be installed to the roof 0.16 W/sq mC
100mm Rockwool to be installed between the dividing walls of flats

They are saying it is not specific to my flat but the whole conversion. My assessor won’t accept the email as proof and is not giving me much more to work off!

There is by the sound of things no need for expensive work but I guess it will have to be holes in my walls & ceiling to prove it.

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