EPB and EPC Reform Consultation
09 December 2024
Status
DESNZ has published a consultation on Reforms to the Energy Performance of Buildings regime. The consultation closes on 26 February. You can find the full consultation documents by clicking here. You can download our draft response and comment form below. Please use the form to send any comments to [email protected].
BEAMA draft response to Energy Performance of Buildings consultation
Impact
The consultation includes a suggested new approach to EPCs which presents lots of opportunities but falls short on detail regarding how to fully accommodate a new energy paradigm based on time of use and reduced costs, carbon and primary energy. Whilst the issue is well covered, we believe there is a long way to go to ensure EPCs reflect modern methods of heating homes. The key here for the supply chain is that whilst the Smart and Secure Electricity System approach is a driver for product development and a potential market opportunity, a strong commercial driver for action is falling short on promise.
We are seeking member views on key questions highlighted below.
New EPCs will be introduced second half of 2026 and EPC wrapper consultation due in 2025.
Disappointingly, the consultation refers to occupancy health but very much kicks the can down the road which is a missed opportunity unless addressed now, particularly with MEES for Private Rented Sector around the corner and Warm Homes. We will use our IAQ EPC report to address this in our response and discuss with officials.
We have not addressed quality assurance or assessor requirements in this summary paper but would welcome any views.
The details
This consultation seeks views on the reform of the Energy Performance of Buildings (EPB) framework. It covers the following areas:
- clarifying and consolidating regulations, and focusing on improving the applicability, quality, and data usage of energy certificates in domestic and non-domestic buildings
- updating EPC metrics
- refining requirements for Energy Performance Certificates (EPCs) and Display Energy Certificates (DECs)
- improving data management protocols and strengthening quality control
- revising air conditioning inspection reports (ACIRs)
Geographical reach - England and Wales
- Updating EPC metrics is the main thrust of the document
- Refining requirements for EPC and Display Energy Certificates (DEC)
- Improving data management protocols
- Strengthening quality control
- Revising Air Conditioning Inspection Reports (AICRs)
MHCLG upcoming research on user needs and preferences to align with climate objectives and consumer expectations
Benefits of EPCs
- Compare properties for energy performance
- Recommend improvements and signposting advice
- Policy information source
Use:
- The above plus MEES platform, grant gateway, target setting to effect change
- EPC will be underpin Warm Homes Plan
EPB vision
- Provide accurate info for purchase decisions
- Provide accurate info for grant eligibility
- Provide information for a range of actions (reduced carbon, fuel poverty alleviation, improving decency and Warm Homes
- Support other stakeholders including supply chains and lenders
The Environmental Impact Rating (EIR) does not reflect what is happening upstream (grid)
The Energy Efficiency Rating (EER) does not reflect changing fuel cost landscape
Revised metrics in place by H2 2026 with HEM… consultation on EPC HEM due later in 2025
Range of metrics to be introduced:
Energy cost – financial implications of a building and proposed to not be the only metric (Q.1)
Carbon – emissions from energy use
Energy Use – consumption based on predicted energy needs for heat, hot water, lighting pumps and fans. Includes primary energy use. We need to look at this carefully as to whether primary energy is relevant for consumers and maybe challenge the theory that is a static number in relation to smart readiness. (Q.8 and 9)
Fabric Performance – thermal efficiency with FEES proposed over HLP or HTC (Q.2 and 3)
Heating System – efficiency and EIR and one members need to look closely at as it will be a ranking table with heat pumps as best and the remainder in descending order. Tech efficiency is mentioned over DSR capability which could have poor consequences on cost and performance assessment. Direct electric would sit above fossil fuels though. (Q.4 and 5)
Smart readiness – potential for optimised consumption and access to cheaper tariffs, onboard generation. The Government is seeking views on how to define this metric, whether it should be building based or cover smart appliances and how might it be tiered. Work was done on this in Europe some years ago so maybe one to reference for members. (Q.6 and 7)
Italic = headline metrics
Proposed retention of carbon metric for non-domestic but seeking views on expanding to other metrics (Q.10 asks for views on downgrading carbon as a metric)
Government will research how to present metrics and there is no detail on how EPCs will be applied against various policies, leaving those decisions to policy design. (Q.12 seeks views on transition).
Government is also seeking views on how long an EPC should be valid for, potentially moving from 10 years to a shorter time frame. Existing EPCs would remain valid. (Q.13 covers various time frames from less than 2 years through to retaining 10 years and Q.14 covers whether this should be for new EPCs only). There are follow up questions relating to multiple occupancy and private rented tenancy plus extending scope to heritage buildings.
SMETER methods
Smart Meter Thermal Efficiency Ratings are being piloted in domestic dwellings but are considering applications in commercial too. (Q.11 seeks views on this as a method to calculate heat transfer coefficient or standardised heating demand)
Action
The consultation closes on 26 February. You can download our drat response and comment form below. Please use the form to send any comments to [email protected].
BEAMA draft response to Energy Performance of Buildings consultation
