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News & Events: A Curate’s Egg of a Consultation

At the start of March CLG published a consultation document “Making better use of Energy Performance Certificates and data”.

The consultation got rather overshadowed by the “Warm Homes, Greener Homes” strategy document which was published with DECC at the same time.

But the outcome of the EPC consultation could have a more immediate impact on our industry. It also highlights one of the critical issues we face in trying to get building owners – particularly homeowners – to act on the recommendations provided in the EPC.

We think the proposals in the consultation are welcome. But we are concerned that they don’t go anything like far enough in some areas. You can read our draft response and we are hoping that you will take the time to let us have your thoughts before we submit our final response.

How to send us comments on the draft response

Simply write your comments in a Word document or in the body of an email and send it to us. Please ensure that it is clear which chapter and question your comments relate to.

We would also encourage you to respond to the consultation directly. Details of how to do so are given at the start of the consultation document and you are welcome to incorporate any elements of our draft response you consider helpful should you wish to do so. The more responses CLG receives expressing a particular view, the more likely they are to act.

So what is proposed?

In our view the most significant proposals in the short term are:

  • Requiring EPC ratings in property advertisements;
  • Providing greater access to the data on the Central Register, particularly to Local Authorities to support the development of Local Carbon Frameworks;
  • Requiring EPC for Houses in Multiple Occupation and those rented out on short-term holiday lets;
  • Clarifying the regulations to make it clear that the EPC is required at the start of marketing; and
  • Requiring the lodgement of Air Conditioning Reports.

All of these proposals are in response to feedback from the market and reflect a growing awareness that the current regulatory framework is preventing the EPC having the positive impact we all want it to have.

The proposal to require EPC ratings in all property advertisements is particularly welcome. It should help to improve compliance rates in the commercial building EPC and dwellings rental sectors (private and social). It will also provide a useful safety net to ensure that EPC are produced for homes marketed for sale if the HIP is suspended or scrapped.

There is also a proposal to extend the requirement for DEC to commercial buildings that aren’t occupied by organisations delivering public services. This is something we have supported for a long time and it is great that it is now being seriously proposed, but such a change will require primary legislation and it is going to be a challenge to get this onto the legislative agenda.

An Oliver moment

The positive nature of the proposals means that it is rather churlish to be asking for more. But the truth is that the proposals, whilst good in parts, don’t go anything like far enough given the goals that have been set and the barriers that exist.

The targets for reducing energy waste and carbon emissions over the next decade are hugely ambitious. And as anyone who hasn’t been living somewhere outside the solar system for the past year or so knows, we’re also facing “challenging” financial times. This means there isn’t going to much money around for incentives and the public sector is going to be shrinking rather than looking for new responsibilities.

The only way that this circle is going to be squared is if the private sector is much more actively engaged than it currently is.

We need to free up the energy, imagination and sales skills of the companies and individuals in our industry so that they have the option – and the incentive – to get more directly involved in ensuring that the recommendations in EPC are acted on.

That almost certainly means we have to recognise the basic information in an EPC as public data rather than hiding it away in databases with hugely restrictive access and the threat of criminal prosecution hanging over anyone using it.

It probably also means rethinking the role of the energy companies and CERT funding, which dominate the energy efficiency industry – but that’s another issue.

For the moment I’d settle for a more logical approach to handling EPC data. The only way a homeowner can currently retrieve an EPC from the central register is if they have the 20-digit report reference number. If they’ve lost the EPC they had when the purchased the property, they can’t get a copy of the EPC.

The proposals in the consultation do nothing to change this. That seems crazy to me, but I’d love to know what you think.