Government consultation to increase minimum EPC rating to band C for PRS

by Property118.com News Team

10:46 AM, 1st October 2020
About 5 months ago

Government consultation to increase minimum EPC rating to band C for PRS

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Government consultation to increase minimum EPC rating to band C for PRS

The Government has just released a new consultation proposing to amend the energy efficiency regulations for the PRS in England and Whales and raise the minimum EPC rating for rented property to band C.

To download the consultation document click here

The consultation proposal would also allow Councils to impose a fine on landlords of up to £30,000 for non-compliance.

This consultation seeks views on the government’s proposal to amend the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 (from now on referred to as “the PRS Regulations”). The proposed amendments would significantly improve the energy performance of private rented sector homes in the 2020s, in order to:

Deliver significant emission reductions, which will contribute to Carbon Budgets 4 and 5 and support a decarbonisation pathway consistent with our Net Zero 2050 target;

– Decrease bills for low income and vulnerable tenants, in support of the government’s statutory fuel poverty target;

– Increase the quality, value and desirability of landlords’ assets;

– Reduce energy bills for tenants and ensure warmer homes;

– Support investment in high-quality jobs and skills in the domestic retrofit supply chain across England and Wales;

– Provide greater energy security through lower energy demand on the grid and reduced fuel imports.

The detailed proposals for amending the PRS Regulations are set out in Chapter 1 below outlines the preferred policy scenario for improving the energy performance of privately rented homes, comprising four elements:

– Raising the energy performance standard to Energy Performance Certificate (EPC) energy efficiency rating (EER) Band C;

– A phased trajectory for achieving the improvements for new tenancies from 2025 and all tenancies from 2028;

– Increasing the maximum investment amount, resulting in an average per-property spend of £4,700 under a £10,000 cap

– Introducing a ‘fabric first’ approach to energy performance improvements.

The government strongly encourages responses by the 30th December to be submitted online using the Citizen Space link below as this supports timely and efficient analysis of responses.

Respond online at: beisgovuk.citizenspace.com/energy-efficiency/improving-energy-performance-privately-rented-home

Or Email to: PRStrajectoryConsultation@beis.gov.uk

When responding, please state whether you are responding as an individual or representing the views of an organisation. Your response will be most useful if it is framed in direct response to the questions posed, though further comments and evidence are also welcome.

Comments

David

11:42 AM, 7th October 2020
About 5 months ago

Just a joke. So the only option is external insulation equals claddings equals Grenfell or internal insulation and damp rot. Of course you should not fill cavity walls I have even been told that by a CW contractor. or you risk damp. All the Victorian property botch ups with lime mortar replaced with Portland etc .But you must apply every few years if you live in a conservation area. This government is really jerking our chain, but don't forget its to save the planet !

Beaver

13:42 PM, 7th October 2020
About 5 months ago

Reply to the comment left by David at 07/10/2020 - 11:42
I agree it would be a joke if it weren't such a pain in the backside.

At the same time though this is a consultation and the purpose of a consultation is to go "...did we get this right? Are there unintended consequences? Or should we adjust this proposal?" And probably the chances of getting them to adjust this proposal would be better if the response that went back was constructive, so I would suggest:

- any proposals must apply not just to the PRS but also the social housing sector [if they don't it is probably because they are unreasonable and in any case there is a public benefit in doing it]
- insulating walls should not be a pre-condition for accessing benefits for your PPR *or* for whatever incentives there are for private landlords in the PRS
- there should be incentives for private landlords such as favourable tax treatment, being able to deduct all your finance costs for example
- there should be incentives for your PPR if you are an owner occupier e.g. lower council tax costs
- every residential property should have an incentive to improve so the objective should be that every holder of an EPC should have some way forward

I also think there should be some kind of appeals process enabling you to challenge your EPC rating with objective measurements if it appears to have been allocated in a subjective manner. My own house (PPR) has double glazed plastic windows, cavity walls, loft insulation but a double-glazed wooden conservatory. I would have guessed that the conservatory would have been the major source of heat loss and I had the Energy Saving Trust people come in and point a thermal camera at the house. Surprisingly the conservatory wasn't a problem at all. The major areas of heat loss were around the edges of some of the double-glazed plastic windows.

So under the present grant rules because I already have loft insulation and double glazing I would be unable to access any kind of grant to do anything unless I put cavity wall insulation in. And it would be stupid of me to do that.

My point being that if we want to do something about climate emissions, every EPC should have a possible route forward. What that route forward should be will depend upon the property; and you ought to be able to take measurements and challenge the EPC if you can get measurements showing that you are addressing the principle source of heat loss for your property.

Marie

15:08 PM, 29th October 2020
About 4 months ago

Reply to the comment left by David at 01/10/2020 - 11:21
You cannot achieve A rating unless it is a Passiv House.

Marie

15:13 PM, 29th October 2020
About 4 months ago

Reply to the comment left by Dylan Morris at 01/10/2020 - 13:14
The discrimination between the social sector and the private sector is everywhere. I have a property in a development with lots of council properties. They pay less towards the service charges, they can get their own insurance and are not forced to have terrorism cover, whereas we have to accept insurance arranged for us by the managing agent with is not competitive,

Shining Wit

16:45 PM, 16th December 2020
About 3 months ago

Hey Folks,

This ‘consultation’ finishes in a couple of weeks. It is our chance to submit some reasoned arguments – which hopefully might balance the views expressed by others who, perhaps, don’t see the PRS the same way that we do.

Filling in the consultation response is a painful process – and took me quite a while to complete. The consultation is, as others have already noted, a little biased in its presentation. ‘They’ have reached a view on the proposed solution – and do not necessarily make it easy to argue why the proposed changes could have significant unintended consequences.

When you read the consultation paper, I expect that you, like me, will be shocked by the proposals.

Please take a little time to submit your thoughts on how the proposals could be improved. Many others, with ‘less-enlightened views’ may have already responded to show how even more draconian measures should be considered/implemented. If those views are accepted, it won’t be good for Landlords or (in the longer term) helpful for tenants.

Many thanks to those of you that have already made time to respond to the consultation. If you haven't responded yet, please do. Thank-you.

Seasons Greetings to you all
SW

Beaver

17:36 PM, 16th December 2020
About 3 months ago

Reply to the comment left by Shining Wit at 16/12/2020 - 16:45
I have already contributed to this thread and pointed out that there are unintended consequences. Just as there are unintended consequences for the recently introduced electrical regulations requiring every PRS landlord to have a EICR every 5 years.

Does this consultation require a full regulatory impact assessment?

Denise G

17:38 PM, 16th December 2020
About 3 months ago

Reply to the comment left by Beaver at 16/12/2020 - 17:36
is there a link anywhere to the consultation?

Beaver

17:47 PM, 16th December 2020
About 3 months ago

Reply to the comment left by Denise G at 16/12/2020 - 17:38
It was in the first post to this thread... 🙂 but here it is again.

https://beisgovuk.citizenspace.com/energy-efficiency/improving-energy-performance-privately-rented-home/

I think it needs a full regulatory impact assessment. Otherwise I think every house with solid walls is stuffed as a rental property.

Seething Landlord

19:54 PM, 16th December 2020
About 3 months ago

Reply to the comment left by Beaver at 16/12/2020 - 17:36
I think you will find that if an impact assessment is required it will be published with the draft Bill, which will not be until Government have "considered" the results of the consultation and decided what they want to do, so don't hold your breath. Similarly, if they find reasons for not carrying out an assessment, they will be explained at that time, as happened with the EICR regulations.

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