Landlords still ‘none the wiser’ about new EPC rating

Landlords still ‘none the wiser’ about new EPC rating

11:22 AM, 23rd January 2023, About A year ago 16

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Landlord association iHowz has called on the government to publish the new Energy Performance Certificate (EPC) and Minimum Energy Efficiency Standard (MEES) requirements for the private rented sector (PRS).

It says that landlords are still ‘none the wiser’ about what EPC rating will be required or when this will be published under the outstanding MEES legislation.

A target was initially proposed for 2025 for all new tenancies in the PRS to have an EPC of at least ‘C’.

And then the EPC target was to be extended to cover all tenancies by 2028.

Consultation on the EPC issue

A consultation on the EPC issue ended in January 2021 and the government has given no response to it, leading to widespread uncertainty in the PRS about what is expected from landlords.

Since August 2021, iHowz has been writing to ministers seeking clarification about the proposals.

And now the association has written to the All-Parliamentary Group on Climate Change asking them to put pressure on the government to publish the new energy obligations for landlords.

‘SAP is expected to favour a saving in carbon emissions’

The association’s Rod Townson said: “The new SAP is expected to favour a saving in carbon emissions, rather than cost.

“Thus, anyone installing a new gas boiler to meet current SAP requirements risks being penalised under the new rating; clear guidelines are required on transitioning to the new regime.”

He added: “Given the original proposals were for the first stage of implementation to take place in 2025, this now looks unreasonable at best and would result in a reduction in the supply of homes, due to time and labour constraints, in an already undersupplied rental market.”

Ensure a timetable for landlords

Before the requirements are published, iHowz wants the Department for Business Energy and Industrial Strategy (BEIS) and Department for Levelling Up, Housing and Communities (DLUHC) to work with the Treasury to ensure a timetable for landlords so they can organise materials and training for both fitters and assessors.

Rod added: “With the PRS representing 1 in 5 homes, it is reasonable for landlords to be supported by adequate long funding and incentives as they help bring some of the country’s oldest housing stock up to the required higher standards.”

The campaign for the release of the new MEES requirements can be found on the iHowz campaign website.

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Churchills Tax Advisers

11:48 AM, 23rd January 2023, About A year ago

In fact, why does it only apply to the private rented sector, why not ALL properties, or not at all??!


12:25 PM, 23rd January 2023, About A year ago

I'm not sure what SAP stands for in 'SAP is expected to favour a saving in carbon emissions'.

But it seems to me that if it's climate change you are interested in then you need to differentiate clearly between carbon from renewable and non-renewable sources. And you also need to look at the whole energy supply chain. This blog here:

which has figures from the US says that only 34% of primary energy actually reaches the consumer. Most of the energy is lost in generation and transmission.

UK figures are harder to come by in understandable form. You will all remember from your o-level physics that heat generated from electricity sent down a wire is proportional to the current multiplied by the square of the resistance.
So transmitting at low voltage over distance loses a lot of energy. You save some energy by moving to high voltage over distance but still lose some power. This blog here says that the losses are between 8 and 15%:

I don't know whether you lose as much energy transmitting gas over distance. If the pipe isn't leaking it can't take much energy to push gas down a pipe; polypropylene pipe lasts for years in the ground. But it's hard to find comparable figures. National Grid publish some figures for lost gas here for example:

But these figures are almost impenetrable and I can't imagine your average MP getting his or her head around these.

Last year (2021) the cost of turning off power from UK wind farms reached a record high:

So basically we can generate loads of electricity from wind. Within the last two weeks wind powered 50% of the UK's energy generation needs:,Big%20fans%3A%20Wind%20powers%20half%20of%20UK%27s%20energy,with%20new%20record%20generation%20day&text=Wind%20power%20generated%20record%20amounts,time%20ever%20on%20Tuesday%20evening.

The problem is that they are turning off the wind generators because they can't store the electricity. In reality rather than turn the electricity off they'd be better off using the surplus to generate hydrogen and either use that to generate more electricity at other times or pump it into a gas grid that can cope with it.

So if you were to add the electricity that could be stored as hydrogen centrally to whatever we could generate locally from photovoltaics I doubt we would have an energy crisis. But there is no incentive in the system for landlords or householders to do it.

northern landlord

13:35 PM, 23rd January 2023, About A year ago

SAP is Standard Assessment Procedure. It is used to produce a PEA (Predicted Energy Assessment) this is an energy efficiency calculation that must be provided as part of getting planning permission, it takes account of construction, type of heating etc. A PEA is a prediction of what the finished buildings EPC rating should be. Like EPC it is rated 0 to 100. A SAP of 69-80 would presumably indicate the new build should get a C rating EPC.


14:05 PM, 23rd January 2023, About A year ago

Reply to the comment left by northern landlord at 23/01/2023 - 13:35
I see. And what do you think about the EPC system and how it's being applied to landlords? In terms of doing something about climate change the implementation of the EPC system looks like nonsense to me.

Churchills Tax Advisers

14:09 PM, 23rd January 2023, About A year ago

Reply to the comment left by northern landlord at 23/01/2023 - 13:35
Sorry, I thought PEA was the average size of the brain of an MP and SAP was what most MPs were.

northern landlord

14:22 PM, 23rd January 2023, About A year ago

Reply to the comment left by Gone Fishing at 23/01/2023 - 14:09I think you are most likely right about the initials. As a landlord I am against regulations that are imposed on us but not on owner occupiers. Some regs are intrinsically good like gas and electrical certs, but imagine the outcry if they were imposed on every property..Social housing is exempt from electrical certs because the bill to bring a lot of social property up to standard would be astronomical but as landlords we can afford it apparently. last time I looked the Local Council had more money than me.


14:26 PM, 23rd January 2023, About A year ago

Reply to the comment left by Gone Fishing at 23/01/2023 - 14:09
Certainly I suspect that their understanding of the issue may be limited. This article:,%22%20and%2027%25%20during%20production.

Says that "...The major source of natural gas losses from local distribution systems is cast iron distribution pipes....In 1990 the Earth Resources Research, an environmental consulting firm based in the United Kingdom, released a report funded by Greenpeace which indicated that natural gas pipes in the country leaked so much methane that the leaking alone contributed more to the greenhouse effect than the burning of the fossil fuel."

So it looks to me as though the EPC system is just a bit of b******s that some politician came up with whilst grandstanding at Kyoto. Bashing landlords in an attempt to appear to be doing something about climate change to appease the electorate (because they really just want to be seen to be bashing landlords for short-term political gain rather than solving real problems) is a red herring.

You can't really make a sensible decision about whether it's good or bad to replace your gas boiler without knowing whether your gas is coming to you via a polypropylene gas pipe that doesn't leak or maybe only leaks 2% of the energy, or whether it's coming to you from a system that leaks 30% of the energy. The figures produced by National Grid are almost impenetrable and look to me to be way beyond the understanding of most MPs.

And when it comes to generating energy, we now generate so much energy from wind that we have to turn the generators off. But if you have a surplus of electricity and you want to store it then you need water (which we have a fair bit of in the UK) and a means of storing the hydrogen. If you put your hydrogen down a polypropylene pipe that doesn't lose more than a few % the cost of transmitting that energy shouldn't be high. Some can be generated and stored locally. Even a domestic house with photovoltaics can generate and store hydrogen.

So isn't this EPC system in its current form just a bit of nonsense? A bit of window-dressing that won't solve anything and is just there to make some politician look good in a sound-bite somewhere?
Surely there are bigger problems elsewhere and trying to foist that problem off on landlords when you probably aren't going to do anything about social housing or owner occupiers is just b******t.

Andrew Martin Harrington

20:43 PM, 23rd January 2023, About A year ago

As an energy assessor for EPC in Domestic and commercial property- I find that all landlords are energy experts and try to answer questions before they are asked. The EPC assessment has to be input to a calculation tool- that assesses what you have and what will make it better- simple as that. No need for off the map questions and telling the assessor they have seen an article on super quilt - it’s the best thing ever - I do not think so. Just let those who known give you direction - you must ask questions to get the answer you need


8:29 AM, 24th January 2023, About A year ago

Reply to the comment left by Martin Harrington at 23/01/2023 - 20:43
Many landlords who have EPCs and have seen the output of that calculation tool have no faith in it.

Luke P

10:04 AM, 24th January 2023, About A year ago

Reply to the comment left by Martin Harrington at 23/01/2023 - 20:43
Are you responding to the OP? The article is about the expected band-C minimum but having had absolutely no movement on this, despite the consultation having been finished and it potentially costing landlords tens of thousands/leaving the industry entirely.

Of course we're going to ask, and rightly so, questions.

You just do the assessment. Until band-E minimum came in, you nor anyone else really cared what the end result was. Even then, it's not hard to get to an E. Perhaps you don't understand the gravity of the matter and it's because there's no consequence/understanding by the assessors (who just want to get in & out as fast as possible to make their race-to-the-bottom fee) they rarely do their job properly. Just because there's an option to 'assume zero' or 'could not access', does not mean that's nearly good enough for us landlords with an incredible amount at stake for an arbitrary EPC band that an assessor could scarcely be bothered to thoroughly, and I mean absolutely 100% perfect, get it right. I will shadow my assessor, treat him like the lazy idiot he is and point out all the things he's missed because the loft hatch was a bit too high and/or he didn't realise I have the certificates with the U-values for certain building materials he'd otherwise have overlooked.

Some of us have hundreds of properties, so it's a bloody big deal, though I expect that to go over your head being nought but a 'loft-checker'.

It's not limited to my assessor either...I've used over half a dozen and they're all the same because of the culture of being cheap to compete with the others and the necessity to do five assessments per day.

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