Surely I am not the only landlord worried about new EPC requirements?

Surely I am not the only landlord worried about new EPC requirements?

9:44 AM, 17th February 2021, About 8 months ago 154

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Hello, I was wondering if Property118 could shed some light on the new proposed changes to the EPC requirements – my understanding is that over the next few years 2025 onwards, properties in the PRS have to be rated a C as a minimum. Currently, has to be above an E.

My worry is that the government seems to be applying this rule to all properties regardless of age, although I think it may be different if it is listed. It is not difficult for a new property to meet the requirements of a C or about.

However, as the owner of several Victorian terraces, it is much more difficult if not impossible to get this rating. For example, we do not have cavity walls. I have done all the usual things like loft insulation, double glazing, energy-efficient boilers etc etc but other suggested improvements seem to be a lot of outlay for very little impact on the EPC.

For example, I think the only improvement that has been suggested is using solar panels, but the property is not suitable for solar panels.  I am concerned that I may not be able to meet the new requirements despite my best efforts.

Surely I am not the only landlord who is worried about this?

Is there a campaign to ask for property age to be taken into consideration?

Thank you



by John

12:12 PM, 25th February 2021, About 8 months ago

Reply to the comment left by Denise G at 25/02/2021 - 12:08
These are not facts yet, but they have been proposed and are being decided as we speak. For me i am planning for the worst case situation.

Bit of light reading for you:

If you google energy white paper you will find many summaries of what is to come, but focus on those relating to LL's

by Bob S

12:43 PM, 25th February 2021, About 8 months ago

Sorry – this is a long one!
Many LLs with older properties presently on E to low D with actions already undertaken may still face a knife edge of existence. The high-cost exemption may be my route for uprating my storage heaters (tenants are not on benefits and so the ECO grants (new gas fired central heating and replacement storage heaters) are not available and not covered by GHG). My Victorian early cavity walled villa style semi-detached converted flats will not suffer cavity fill insulation and an avenue for me here is to gain a RICS report to confirm so. Equally the roofs are not engineered to take PV.

John, I hear you and congratulate you on developing a relationship with a DEA but would suggest many landlords are not in the commercial position of encouraging their engagement. I’d also be mindful of the following that is taken from an internal Accredited Body’s bulletin in 2018.

“If a home owner or landlord is considering home improvements, they might contact the energy assessor and ask about the likely* uplift in SAP score if a specified item/measure was to be put in place.
Important notes
A DEA is not insured to give a written advice on what improvements should or should not be installed. The ‘pay per click’ insurance covers ‘verbal non-binding energy advice to building owners’. This is important in the light of MEES, with landlords wanting to know if they will reach a score of at least 39 if changes are made. If a DEA has arranged his/her own professional indemnity insurance, however, advice may be covered. We recommend DEAs consult the relevant policy document if private PPI is in place.
*Software is regularly updated, and the figures shown on the EPC always relate to the date of the original positive certificate was produced. The figures cannot be guaranteed if calculated on future versions of our RdSAP software, which take into account of changes in fuel prices and other software alterations.”

I now better understand why DEAs are reluctant to offer feedback when trying to understand what they might accept on the day of the assessment.

The following was in response to me pressing a DEA for clarity on what could be submitted by a property owner on the day of the assessment.

“Just so you know, all assessors use a software with the same question set from varying Accreditation Companies, so no matter who you are accredited with, the EPC rating will be the same. Our surveys are non-invasive, evidence based from what we see and record on the day of the survey. If no evidence of insulation is available, that element of the property will be recorded to be ‘as built’ and the software will default to the building regulations for the age band when the property was built for the amount of insulation that would have been installed.

Acceptable documentary evidence includes, but is not limited to, official letters from the applicable Registered Social Landlord, or certificates, warranties, guarantees, builders invoices and Completion Certificates from Building Control. The assessor must be confident and able to demonstrate, that any documentation relates to the actual property being assessed and that there is no physical evidence to the contrary. Evidence of intent to install does not quality as acceptable documentary evidence.”

For the same property I have had two EPCs undertaken 10 years apart. During that time without any extensions or room changes it has according to the EPC produced by two separate DEAs grown by 20% in area.

One of my routes for gaining a C is to use the newer storage heaters. I asked two separate DEAs within 3 months of each other for a heads up as to what I could use to gain the EPC score benefit. From one I got a list of 16 heaters and the other 27. When I challenged the second DEA as to why the difference it was stated it was a good example of how the information changes and here’s a list of 32!. In reality it was a second page that had not previously been identified to me and the dates the latest heaters were included was 2019 so the first one should have been in a position to offer the complete list anyway! All I ask for is consistency to allow a thorough investment approach….

On pressing the DEA as to what ‘evidence of’, at the time of installing any particular measure, would be needed at the time of the assessment and whether a RICS survey to provided consistent dimensions would be of benefit I received the following.

“All evidence needs to be collected on the day and all DEA’s take their own measurements, on the day also. However, prior to a survey taking place, you can always advise the assessor of any retrofit improvements that have been installed and ask the assessor what documentary evidence will be required so that you can have it ready. (Ed. A bit late by then if the evidence isn’t good enough).
Other landlords need to speak directly with the DEA who did the survey of their property and raise any issues directly. Their contact details are displayed on every EPC along with their Accreditation company should the matter not be resolved at the bottom of the report.”

RdSAP has previously been noted as a dumbed down assessment tool with the emphasis to identify the cost of running a property. I am fully supportive of lowering our carbon emissions but this is not the tool to do so when it is potentially preventing LLs from continuing to trade and removing much needed stock from the PRS. I would be far happier to pay for a slightly more expensive assessment with an improved measurement tool that allowed qualified documentation that could be allowed to demonstrate what has been done in the preceding 10, or 5, years as it might become using real data rather than assumed or as built figures. This would allow property owners as well as LLs presently to work proactively towards improved properties, happier tenants and lower carbon emissions.

Presently RdSAP is not fit for purpose neither by the way the rating is calculated nor by the methodology of communicating the rules to property owners and therefore to the assessors. When I have a moment, I’ll be writing to the AB’s, Gov department responsible and my MP.

by Esat Karahasan

13:10 PM, 25th February 2021, About 8 months ago

Reply to the comment left by Bob S at 25/02/2021 - 12:43
Very well put. As far as the storage heaters are concerned we have found on a number of different properties that the Dimplex Quantum HHSRS range Q070RF and Q100RF seem to acheive the highest SAP point gains. We have taken a property with standard electric heaters from E to C and another from F to D the later we have now been served sufficient evidence of loft insulation which will tip that to a C also. They are quite expensive at around £6-700 each but do the job very well in terms of EPC gains and efficiency in use, they can also be used on single or dual supply again the later offering even higher savings.

by Bob S

9:33 AM, 26th February 2021, About 8 months ago

Good morning All,

Has anyone experience of the following which is taken from one of the Accreditation Body’s web site either as a landlord or an accredited DEA?

Retrofit Assessors

Retrofit Assessors are trained to undertake a retrofit assessment for dwellings in accordance with PAS 2035. The activities completed within the retrofit assessment include the production of an RdSAP assessment, a detailed floor plan, a condition report and an occupancy assessment.

The data collected from these sources is used by the Retrofit Coordinator to formulate a Medium-Term Improvement Plan. Accredited DEAs are well placed to become qualified Retrofit Assessors due to their extensive knowledge and experience with RdSAP methodology and assessment of existing dwellings.


Has any LL on here experience of including all of the costs of rehousing a tenant whilst improvement works are carried out, like underfloor insulation, within either Green Homes Grant funding or ECO funding?

by DSR

9:46 AM, 26th February 2021, About 8 months ago

Reply to the comment left by Bob S at 26/02/2021 - 09:33
Bob - you read my mind! I am wondering the same. If a LL does all the things they can do to reach the C rating, yet the only thing left is really invasive works like internal wall insulation, does it mean it HAS to be done? What if the tenant does not want the upset? Can they state they don't want it? Tenant rights are so hot at the moment, surely a LL cannot be forced to undertake such work if it is not wanted by the actual tenant? It begs the question - are the measures to be taken to achieve a C classed as mandatory no matter what, necessary, viable, to the best possible level with full consent only? The devil is in the detail.
I'm wondering if costly things like getting planning permission/drawings done to even an agreement to have such measures, like external wall insulation for example on a property in a conservation area, can be taken out of the 10k max spend that they are expecting LL's to pay out to get these improvements done? Imagine the situation where it takes the LL takes £2k alone just to get permission denied for the only measures it can take anyway! The same for moving a tenant out while internal insulation is put in....

by Jireh Homes

4:29 AM, 3rd March 2021, About 8 months ago

Agree there is a logic that ALL costs associated with upgrading energy performance should be included in the application for exemption, the challenge is the understanding that spending up to the cost limit is a pre-requisite before an exemption is granted, which itself is time limited. Perhaps LL experience on applying for exemptions should be a new thread?


12:01 PM, 5th March 2021, About 8 months ago

Reply to the comment left by Tom Pope at 17/02/2021 - 10:42
Good morning Tom.
Is there such a thing as an eco-friendly night storage heater.
I have 4 storage heaters in my flat and I intend to replace them with infrared heating panels made by Heissen. What do you think. How will this replacement impact on the EPC?..
Further the Government is committed to provide the electricity utlity generated by 'zero' CO2 emission sources by 2030 in some case. Is there any reason for worrying about 'energy efficiency' and 'environmental impact? part of the EPC?
Regardless when will there be a requirement to hit the EPC band 'A' for properties.
Thank you

by DSR

13:17 PM, 5th March 2021, About 8 months ago

Reply to the comment left by Jireh Homes at 03/03/2021 - 04:29
sooo...coming off this thread then, there is no real benefit with me paying now to try and do what I can to get permission to even carry out measures to up the EPC, if such evidence will only be (time limited )accepted, say 6 months before the C rating comes into effect??

by Stuart

18:45 PM, 10th March 2021, About 7 months ago

Your correspondents have hi-lighted the major flaw in the current domestic dwelling Energy Performance algorithm (the software program calculating EP scores).
The EP algorithm was born as a part of the ill-fated Home Information Pack in 2004, in the days when we weren’t so concerned about global warming. The algorithm/methodology has changed little since then.
At the time, energy units (kWh) supplied by gas and by Economy-7 night-time electricity were much cheaper than a regular (all-day) units – and they still are – which meant that a consumer who heated a home by these means could afford (literally afford) to be more wasteful of energy. So the EP algorithm was deliberately fiddled to award far more points for gas heaters and night-time storage heaters than was justified, yielding higher EP Classifications in those cases than they actually merited.
Of course this built-in fiddle in the algorithm made a complete nonsense of an EP rating supposedly making an objective assessment of the intrinsic energy performance of a domestic dwelling.
The number of all-electric homes will increase vastly as domestic use of natural gas is phased out – let’s remember that after 2024/5 there will be NO methane gas supplied to new-builds and unrepairable combi-condenser boilers will have to be replaced by electric boilers – and the long-overdue revision of the EP algorithm will have to happen before then. (In my professional opinion, replacing piped methane with piped hydrogen is a completely uneconomic non-starter – forget it.)
The climate in 2021 onwards will continue to warm. It doesn’t distinguish between a kWh energy unit from heating with gas and one from heating with electricity!! All kWh energy units are equal to climate warming, regardless of the source, and should be treated as such for EP calculation purposes. Some are NOT “more equal than others”, and never have been, even if the EP algorithm then – and still – believes that they are.
David Stuart Emmerson
former Professor of Physics (rtd)
[Comments cc to:]

by Rennie

11:52 AM, 12th March 2021, About 7 months ago

Reply to the comment left by Stuart at 10/03/2021 - 18:45
Thank you so much for all your information. This is just what we need in this day and age when everyone and it's mother-in-law is lying to us. Not intending to be contentious but if there is no climate warming (as in I don't believe it to be the case) would you still think hydrogen to be uneconomic and would methane or electricity be best in that case?

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