REVEALED: Why not all EPCs are created equally

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Getting a good EPC rating is important for rentals to meet the MEES regulations, and in future even higher ratings will be demanded, but this can be a challenge for some landlords…

Since October 2008, rental properties in England and Wales have been required to have an Energy Performance Certificate (EPC).  On April 1^st 2018, the Minimum Energy Efficiency Standards (MEES) came into force. This required all rental properties of new tenancies and renewals to have a minimum EPC rating of ‘E’ or above. In the future this requirement is likely to may move to a “C”.

But for various reasons rental properties in particular may fail to meet these standards.

Ask any Domestic Energy Assessor dealing with rental properties and they will tell you that in most cases when doing an assessment, they find the property empty.

Because the owner (landlord) is usually not available to answer any queries the assessor must make certain assumptions and these will always assume the worst-case scenario.

For example, it is usually not possible to determine major structural features such as if cavity wall insulation is installed. If rendering or external cladding is insulated, if insulation has been installed through removing bricks as opposed to drilled holes. If under floor insulations exists etc.

Where the assessor cannot be sure that insulation techniques have been applied, either from the build time, which assigns the insulation and standards set out in the building regs at the time the property was built, or retrospectively. Any rating applied will be assigned “As built”. This same approach will be taken on several other aspects of a building.

Whatever work has been done to improve the property’s rating can easily be negated simply because there was no one there to explain to the assessor exactly what has been done. Providing photographic evidence and invoices to so show what has been done is advisable when it is impossible to see improvements, or exactly what work was carried out.

Cooking on gas

Another vital piece of information, and this problem occurs most in rural situations, is when non-standard fuel such as LPG is used for heating and cooking etc.

By some quirk of the standard assessment protocol used by the energy assessment computer algorithm, mains gas gets a high score, whereas oil will be marked down and LPG even more so.

LPG (Liquefied Petroleum Gas) which is used in many rural locations where mains gas is not available is a hydrocarbon gas that exists in a liquefied form. LPG is a colourless, low carbon and an efficient fuel, but it is more expensive and fuel cost is a factor taken into consideration by the energy assessment.  

Supplied in two main forms, propane (C3H8) and butane (C₄H₁₀), LPG has a range of uses – from providing fuel for leisure parks, crop-drying, BBQs, heating homes and much more.

If in doubt about the detail of assumptions made during an EPC assessment, take a look and the “summary of this homes energy performance related features” table on page 2 of the EPC. This will indicate a star rating given to the main energy features.  In general LPG will automatically be rated as “poor”.

Longstanding concerns

UKLPG, the trade association for the Liquefied Petroleum Gas (LPG) industry has raised longstanding concerns about the EPC calculation methodology used to measure energy efficiency, as it argues this places disproportionate focus on the cost of the input fuel rather than the building fabric.

The association showed to a BEIS Select Committee as part of their recent inquiry into Energy Efficiency that this policy directly impacts off-grid homeowners and the effective implementation of decarbonisation policy, with an unintended consequence being that homeowners are moving away from low carbon fuels such as LPG to higher carbon alternatives simply in order to gain a higher EPC rating on their property.

The EPC rating is supposed to be a measure of the energy efficiency of a building, but in reality argues UKLPG , the rating is actually a measure of energy cost per m2. This method is particularly distorting when comparing various fuel types between similar properties and creates a particular problem for off-gas grid properties where all fuel options (heating oil, electricity, solid fuel or LPG) are more expensive than natural gas, UKLPG says.

Off-grid properties are instantly disadvantaged as their location dictates their fuel options, which automatically results in lower EPC ratings than their mains gas counterparts. For example, an identical property built to the exact same standards will receive a much lower rating if it happens to be situated outside the coverage area of mains gas.

So no matter what efforts are made on the insulation from, heating fuels can bring down the rating and often there’s not a lot can be done about that.

Find out more about EPCs.

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