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EPC Reform - an energy assessor writes…

All landlords need to have an Energy Performance Certificate (EPC), with few exemptions. As a property writer, landlord and Domestic Energy Assessor, I like to think that I can understand all sides. But many landlords are confused by the process itself, by the recommendations for improving their property’s score, and there are mixed messages going out about planned EPC changes.

Let’s start with those changes. I keep reading that having a Grade C by 2025 is the law. It isn’t! It is a proposed change, it’s only for new tenancies and looks like it will be pushed back to 2028 if not longer, which may be the time that existing tenancies will also require a C. But basically, no-one knows what the Government may decide.

Then there’s the role of technology in deciding an EPC score. The Domestic Energy Assessor (DEA) visits a property and collects data, feeds it into the algorithm, and a result comes out. They don’t calculate the score themselves, to avoid any bias.

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But that data input needs to be correct. In my experience – both as a landlord and a qualified DEA – it sometimes isn’t.

I look at the previous EPC for a property before I visit, and occasionally see big discrepancies – for instance a flat has been entered as top floor when it’s actually a mid floor, and this inaccuracy would downgrade the score.

This suggests that whoever commissioned the EPC has not looked carefully enough at the completed certificate. If they did, they could contact the assessor, whose details are always on the report, and get them to put it right, so it’s important to study the information properly.

Another problem is that the system does not take into account the way the home is used. It makes some assumptions based on the size of the property and how many bedrooms there are, but not on occupancy numbers, and it assumes most of the space is heated for most of the day.

The EPC industry is well aware of these limitations. Elmhurst Energy, a leading training and accreditation body, is calling for a redesign. Currently EPCs are based almost entirely on the cost of energy, meaning gas central heating often scores much higher than all-electric because it’s cheaper.

Elmhurst want EPCs to show energy consumption as well as cost and the amount of carbon emissions.

Some of the recommended measures are often hard to achieve without spending a lot of money, and perhaps having to evict tenants while the work is done. External wall insulation may not be possible for leasehold properties, and internal has problems too, possibly making a room too small to meet minimum space standards.

But DEAs can advise on other ways to lift a rating – just ask us! Landlords complain that the scoring system is hard to understand, but we can give recommendations and run a “dummy” EPC, adding or subtracting improvement measures, though we will charge an additional fee for the extra work

There’s also a new animal called a Retrofit Assessor. I’m not one of them, but I have seen the training, which involves a lot of building physics. They cost more than using a DEA, but they can give excellent, detailed individual recommendations and can arrange installations.

What’s also badly needed from the Government is extra grants for landlords, and the training of many more installers, as there are currently not enough.

Let’s end with some brief top tips to get a good score – don’t fit heat pumps unless the building is very well insulated first; don’t change from a gas to an electric boiler; if replacing a boiler, consider a hydrogen-ready model; if you’re all electric, try modern High Heat Retention storage heaters, a vast improvement on older models.

And if you’re having insulation fitted, take photographs during the process along with depth measurements, because once it’s covered up we can’t see it, and also we can’t get to the roof space without a ladder – we may be many things, but sadly we’re not psychic and we can’t float upwards!

* This article first appeared on Estate Agent Today *

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    Would have thought a ladder was basic kit for an energy assessor, how else can you assess attic insulation. There are plenty of fold up or telescopic versions a available

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    I always supply my own ladder placed in the open loft hatch, no excuse not to view the attic space then

     
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    I would have thought the comment about not having a ladder was a wind up, but I've had it happen.
    Unfortunately I wasn't present at the time of inspection.

    When I queried it. He said he was unable to access the loft so looking at other EPC's of houses on the street that had 50mm he assumed that was what I had as he couldn't see the other 270mm that I had just fitted.

    Surely a DEA who assesses a normal house should carry a 6ft step ladder as standard?

    I guess it wasn't mentioned in the 3 day training course or it wouldn't fit in the Ferrari.

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    I know many properties don’t have a hatch or had it sealed up with FB plaster board so you can’t even find where it was.
    A couple of factors here with Combination Boilers no water storage tanks required in the lofts or legionnaires testing.
    With the introduction of HMO’s in places like Harrow the hatch fire proofing specifications is so onerous people obliterate them and they are gone. I have their specification and had to do it, purchase a full fire door cut it to size glue and hardwood lip it all around, remove hatch lining and replace with fire frame.
    I kid you not its over the top in more ways than one, not any one up there.
    Another silly thing I was required to do remove the notice board with all the required documents from the prominent position it had in their living room and put it in their entrance hallway, Tenants those days always seem to have a bag on their back and rubbing off the notice board knocking off the documents, now I see they have disappeared it altogether.
    Another thing I was minded to add an extra Shower & Toilet to the very large bedroom again I way told I would need an amendment and planning
    permission for the work, no thanks leave it how it is too much nonsense. I could have it done in a week but involve red tape then not viable and hassle just leave it.

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    I assume Esatte Agent today is a typo and so is EPG ! GB news has being going on about what is effectively brainwashing by the governments nudge unit and the army disinformation group 77. (Landlord monsterng In this instance).

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    I had aluminium loft ladders installed in all my properties as standard but have since removed some, it was too convenient for the Tenants for storage and unwanted items then when they leave anything they don’t want is let behind.
    NHBC had a requirement that you had to have a certain sq footage boarded out, probably not relevant any more, it was too handy for them.
    Of Course there’s so much insulation up there now you wouldn’t know where the floor is.

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    We don't need grants for LLs, we need the new EPC algorithm! We have been told it is going for over a year & until it is in use, no sensible LL will spend money because we don't know what we need to do!

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    Tricia. EPC’s is a sore point with me it makes no different how good your property is when your EPC can get marked down.
    I had one recently which was a ‘C’ on renewal Accessor emailed me with a ‘D’ despite many improvements over the years including more insulation, New Vaillant Boiler that didn’t count for much because I didn’t have a room stat to photograph, I can’t see the point we are supposed to have thermostatic rad valves to control individual rooms which
    can’t work if blocked by room stat. My perfect 20mm double glazed PVC windows through out marked as average, yet we have Martin on here saying he didn’t even need to replace windows but put one piece of plastic over full window.
    My poly beads cavity walls insulation not counted Certificate not available but counted last time time in 2013 my house is full of documents how much do we have and anyway he could have checked with CIGA he so smart with his computer. No insulation assumed in loft extension I done it myself to Building Regulation’s compliance in 1988 a extra good roof decked double battened insulated and Asphalt roof. The loft extension is warmest room in the house, this guy is graduate out of Uni’ they are brain conditioned and can’t help it, took scores or photos in and out of every
    room several time. I
    had to hold back on the edge of telling him to go, just pay him to get rid so sorry I didn’t.
    Its a Mid-Terraced house for Christ sake.

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    You could challenge the latest EPC rating you received Michael. According to an internet website, you should contact the assessor and explain what is wrong with the EPC and ask them to redact it. The assessors details will be listed on the EPC in the ‘Contacting the assessor and accreditation scheme’ section of your EPC.

    Alternatively, perhaps you could carry out a small recommendation on the latest one and engage somebody else to do another one.

     
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    This is a free template on how to challenge the EPC from the "Energy Saving Genie":

    Free template: Email to assessor about incorrect EPC
    Dear Sir/Madam,

    I email in regarding to the EPC for [insert property address].

    The EPC can be found at [insert EPC link]

    The EPC is incorrect and the errors on the certificate are:

    1) [insert details of the error]

    2) [insert details of the error]

    3) [insert details of the error]

    etc.

    The relevant part of the guidance states ‘for complaints regarding the energy assessor or the energy assessment contact the energy assessor in the first instance. If the matter cannot be resolved, contact the accreditation body of the energy assessor who produced the EPC. Contact details of both the assessor and accreditation scheme can be found on the EPC.’

    I am contacting you as the energy assessor, and ask that the appropriate redress is made to correct or redact the EPC.

    Please take action by [insert date 14 days ahead]


    There was a link in the template but I couldn't post it on this website

     
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    Thanks Ellie, I can’t see me appealing I had a half dozen communications back and forth with assessor to no avail he said he put it to the Board and that’s result. It’s too much stress and unpaid time wasting not enough hours in a day or days in a week with the amount of additional crap they have dreamt up for us in recent years to make money for themselves and damage PRS, no wonder Landlords sell up.
    They keep on about Rogue Landlords but I think the Rogues are in Local Authorities and Government Departments, Ministers forced to resign, Prime Ministers forced to resign or under investigation, even Presidents the same, who is the Rogues. Sorry for the rant.

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    You sound as though you have done all you can with that assessor, Michael.

    According to the Energy Saving Genie website the next stage is to the accreditation scheme. They suggest the template below (I had to remove the link part in their template)

    Dear Sir/Madam,

    I email in regarding to the EPC for [insert property address].

    The EPC can be found at [insert EPC link]

    The EPC is incorrect and the errors on the certificate are:

    1) [insert details of the error]

    2) [insert details of the error]

    3) [insert details of the error]

    etc.

    I have contacted the assessor responsible for the property and the issues with the EPC have not been resolved.

    The relevant part of the guidance states ‘for complaints regarding the energy assessor or the energy assessment contact the energy assessor in the first instance. If the matter cannot be resolved, contact the accreditation body of the energy assessor who produced the EPC. Contact details of both the assessor and accreditation scheme can be found on the EPC.’

    I am contacting you as the accreditation scheme and ask that the appropriate redress is made to correct or redact the EPC. I ask you to investigate the complaint and, where necessary, provide the appropriate redress. Where it is found that the information is incorrect, a new EPC must be issued and the information on the register amended. This procedure should be followed at no cost to the complainant. In the event that the complaint cannot be satisfactorily resolved, I ask that as the accreditation scheme you refer the matter to an independent third party for adjudication.

    Please take action by [insert date 14 days ahead]

    Can you please invoke the process above and report back regarding your investigations, or referral to the independent third party for adjudication if your investigation is complete already.



    However, if you think it would be a waste of time to try to dispute the latest EPC, then perhaps carry out a small cheap energy improvement (if that is possible) and instruct another company to do a new EPC.

    I know exactly how you feel about the current system; and they are creating a new regime in which it will not be possible to operate any more. I am considering selling everything before Labour increases the capital gains tax rate. They might not increase the rate, but it is a risk.

    However, like me, you were involved in letting property before Section 21, and we may find a way to carry on after its gone. EPC is another issue though now.




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    Ellie. Many thanks

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    I have a block of 6 self contained flats - I completely refurbished the whole building over the last 3 years including new front & rear brickwork with 150mm filled cavities - both side elevations had 50mm external insulation fitted & 97mm PIR insulation backed plasterboard fitted internally - new roof fully insulated to current building regulations - fire proofed & insulated suspended ceilings between flats. the 2 ground floor flats had all floors replaced with insulated concrete floors, all flat had new combi boilers the TRV's & room stat - all flats had new double glazed windows.
    After all of this attention to detail & expense all flats were assessed as 'C's - appeals to the assessors were a waste of time.
    How can this be right????????
    All flats insulation exceeded current building regulations

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