The government’s new consultation – Reforms to the Energy Performance of Buildings regime – acknowledges flaws in the headline metrics of both domestic and non-domestic EPCs and aims to provide better and more accessible building performance data.

It proposes using different metrics on domestic EPCs to provide a more complete representation of building energy performance, including energy cost, an estimate of the carbon emissions, energy use, fabric performance, details about the heating system and a building’s smart readiness. Non-domestic EPCs will likely maintain the single headline carbon metric in the short term, although other metrics could be added.

Heating system metric

I’m pleased that it’s acknowledged these amendments and have sent off my response. For starters, I believe it would be incredibly useful to display information based on a heating system metric as this is one of the simplest and quickest identifiers of whether the building has changed since the EPC assessment, or whether there are opportunities to improve low carbon heating systems. An indication of the system’s efficiency would also be helpful, although admittedly, in the context of non-domestic buildings where there could be several space heating systems contributing to the overall EPC rating, it might make the EPC rather cumbersome.

Smart readiness metric

Including information based on a smart readiness metric would mean the EPC becomes a thorough document that records more building characteristics, with the caveat that by quickly installing a smart meter, solar PV, battery storage or EV charging point, an EPC can become out of date very quickly. Perhaps the installer could update the EPC Register rather than prompting a survey, which would protect the consumer from subsequent extra costs.

Energy use metric

I believe primary energy use should be given more prominence on EPCs to promote comparison between assumed and actual consumption, while making it clear that the values are based on a standard occupancy pattern for the activity class. This should help educate consumers about how data is used to calculate the EPC and would reduce the number of related complaints and queries. Although they might not be primarily driven by, or focused on, carbon emissions, because an EPC is meant to contribute to decisions about reducing carbon emissions, carbon should certainly be displayed as a metric.

Smart metering technologies

It would make sense if incorporating the data gathered from smart metering technologies such as SMETERS to inform or influence the EPC rating was either included in all assessments or limited to those embarking on an improvement or retrofit project. Not all buildings have the technology to present the data and consumers might not even want the technology, creating a disparity in the basis of the assessment methodology between EPCs.

Validity period

While the government is focusing on amending the validity period for EPC ratings, I think it would be more appropriate to consider the validity of an EPC based on a reflection of the building as constructed. When a material change occurs, the EPC ceases to reflect the building and hence ceases to be valid. The challenge would then be what constitutes a material change.

Validity throughout tenancy

While lease/tenancy renewals are expressly excluded from requiring an EPC under the EPB Regulations, they are within the scope of MEES, which has caused confusion. Discerning tenants, particularly in the non-domestic sector, are more likely to use the EPC in negotiations. Similarly, with the growing trend for leases to incorporate green clauses, it makes sense to ensure the EPC is current, reflecting the building as constructed at the point the lease is renewed.

Data sharing

I believe the general prohibition on sharing data gathered under the EPB Regulations should be removed as it has caused confusion and prevents collaboration. Accreditation schemes have made a complete mess of the interpretation of the principles of the data-sharing rules when re-writing their scheme operating requirements, to the extent that Assessors are not able to share a photo of a meter reading with their client without first making a formal request to their accreditation scheme.

EPCs are increasingly being used in Environmental, Social and Governance reporting and investing, with many companies wanting to ensure their investments are environmentally responsible. Improving EPCs will allow them to have more confidence in their potential investments, while improving consumer trust.

Improving the overall reliability of energy certificates should increase the number of energy efficiency recommendations carried out, helping to build demand and supply chains. However, under the current system, there are far too many errors being made and incorrect surveys being submitted – which isn’t great for clients who are then making investment decisions based on specious results. Energy Assessors might believe they’re doing everything right but could be ignorant (perhaps unconsciously) of making errors, while the QA audits aren’t frequent enough to capture all the potentially defective EPCs. There’s definitely room for improvement and I’ll be sharing my thoughts on the consultation’s recommendations around training in my next blog.