Energy Performance Certificate reform: consultation analysis

Domestic Energy Performance Certificate Metric^[3] Reform Proposals

Key Findings

Across the questions asked in this section, many issues tended to emerge repeatedly. The main findings were as follows:

• Slightly greater numbers of respondents disagreed with the proposed set of ratings to display on the reformed EPC than agreed (Q1)
• Respondents requested more information on the costs and suitability of improvements as an addition to the ratings (Q2)
• A majority of respondents felt that the fabric rating should not include domestic hot water heat demand (Q3)
• General agreement with mapping the fabric rating against an ‘A-G’ scale (Q4)
• Majority agreement that more prominence should be given to the energy efficiency features of a home (Q5)

Key themes

• Supportive statements from organisations that the proposed set of ratings are sensible
• General agreement with the need to raise the profile of fabric efficiency, though difficult to quantify
• More disagreement than agreement with domestic hot water demand being included in the fabric rating. This was because of inconsistent data and the lack of a relationship to fabric heat losses
• Equal support for aligning the fabric rating A-G scale with the current energy efficiency rating (EER), and for setting the bands independently of the EER

Next most frequent themes

• General agreement with using a 0-100, A-G rating for the energy cost rating as monetary values will vary over time
• Requests for a rating to reflect the overall carbon emissions and embodied carbon
• Disagreements with including, or suggested amendments to, the heating system type, and requests for further detail regarding heating system classifications
• Concerns over the rating methodology and data accuracy, amid calls for real life fabric, energy consumption and heating system data
• Concerns over the accuracy of assessments (e.g. obtaining the correct information)

Other themes

• More consideration needed of the type of home in setting ratings, in particular regarding ‘hard to treat’ properties
• Calls to make the ratings and EPCs clear and easy to understand for non-experts in how they are presented and assessed, along with greater information provision and publicity
• Concerns mainly from individuals over the affordability of energy-related upgrades and improvements

Agreement with the set of metrics to be displayed on the reformed EPC

Q1: Do you agree with the set of metrics^[4] that we propose to display on the reformed EPC?

Views were relatively equally split, although slightly greater numbers of respondents did not agree.

Opinions between organisations and individuals were polarised. A majority of organisations agreed with the proposed ratings compared with only a significant minority of individuals. Among organisations, the highest levels of agreement came from local authorities, those involved in the EPC process and in the construction sector, and utility organisations.

A total of 252 respondents went on to give reasons for their answer or to make further comments at this question. In line with responses at the first part of the question, fairly similar numbers of respondents gave reasons for agreeing and disagreeing with the proposed ratings. Among individuals, a large minority of reasons given for disagreeing with the ratings were unrelated to the question.

General Comments in Support

Most of the support for the ratings (from a significant minority of mainly organisations) was expressed in broad terms, commenting that they seemed sensible. A small minority mentioned perceived benefits from better quality information and extra information being available.

Respondents also thought the new ratings would help demonstrate how home improvements have reduced emissions and provide support for reaching net zero emissions. In agreeing with the proposed set of ratings, a small minority perceived that the current EPC ratings were unfit for purpose and out of date, particularly regarding climate objectives.

A significant minority stated their approval of the ratings so long as they were easily understood, clear and easy to interpret. A need was foreseen to explain any explanations of changes in terminology.

General Comments in Opposition

A large minority of mostly individuals gave reasons for not agreeing with the proposed ratings. The main concern was over the accuracy of data and the methodology used to arrive at the ratings. Several different aspects to this were mentioned, as follows:

• Measurements being perceived to be insufficiently robust to support the reformed ratings
• Requests for measurements to be a ‘real world’ indication of performance
• Uncertainty as to how the new ratings will be calculated
• Criticisms of RdSAP methodology
• Perceived conflicts between cost rating and heating type

A small minority feared there would be extra costs arising from the surveying required to obtain the additional ratings. They noted a lack of information as to what the extra EPC costs to homeowners and house-sellers might be.

A small minority thought that the additional information on the EPC would be too complicated for the average homeowner or non-expert to understand.

A need to highlight information in specified areas was pinpointed by a small minority of mainly organisations. These included actual running costs, the effectiveness of thermostatic radiator valves, and options for retrofitting and other measures to improve home performance.

A variety of recommendations for alternative ratings or adjustments to the proposed metrics^[5] were offered, each by single respondents or very small numbers of mainly organisations. These included:

• The total cost of annual energy use of a property under standard conditions
• Total primary energy demand under standard conditions per m²
• Ratings based on operational carbon, embodied carbon or CO₂ emissions
• Alternative EPC methodology approaches

Comments about Fabric Rating

A significant minority (all organisations) commended the separating, or heightened profile of, fabric efficiency. It was felt this helps with identifying the correct remedial actions for construction types. There were a few comments that the new rating should be designed to be sufficiently robust to provide evidence of compliance with a regulatory fabric standard. Existing Homes Alliance Scotland advocated that this:

“should be set in terms of kWh/m2/year number for space heating demand that could be considered “zero emissions heating ready’”.

A small minority of organisations supported the exclusion of domestic hot water demand from the fabric rating, saying it should cover space heating or fabric performance only.

Conversely similar numbers advocated against having fabric rating as a main metric. Firstly, it was argued that affordability of energy or measurement of total energy use should be the main aim. Secondly, the presence of fabric rating will prejudice decision-making in favour of fabric-heavy retrofit approaches, regarded as expensive and disruptive.

Similarly to comments for the proposed ratings overall, a small minority however had concerns over the accuracy of, and the calculation methodology used for, the fabric rating. The main problem was felt to be the number of factors needing to be taken into account.

There was also a perception from a small minority that many homes will be unable to meet fabric standards or would have adverse unintended impacts if they attempted to do so.

Comments about Energy Cost Rating

A small minority of respondents voiced support for retaining the 0-100 rating index. The £/m²/yr indicator was seen as too technical for householders to understand as well as being too volatile due to being subject to changes in inflation and energy costs.

However, smaller numbers of respondents expressed concerns about the 0-100 index, reasoning that it cannot convey how good a property is for energy costs. They perceived a need for values to be presented in cost terms for proper comparability between properties. Alternative measures in the forms of kWh/m² and £/m²/yr were suggested, being seen by several local authorities as useful measures for themselves and for registered social landlords (RSLs).

Challenges were envisaged in assessing this rating because of the variety of different impacts on it. These included the property’s energy tariff (e.g. fixed, variable, peak / off peak) and whether green taxes and standing charges are included.

A small minority had doubts over the rating’s usefulness, citing energy price volatility, a lack of cohesion with ‘real world’ costs, and potential confusion over what remedial actions to take. A consultancy noted that:

“While a highly insulated property will achieve a high Fabric Rating, it may well achieve a lower Cost Rating if electrically heated via low carbon heating systems e.g. ASHPs. Currently, a cost rating would favour mains gas resultant from the cost per kWh of the SAP model.”

Comments about Heating System Type

Almost all comments about heating system type were critical in nature. A significant minority of mainly individuals cited specific concerns about heat pumps and encouraging moves towards these^[6]. These concerns included the following:

• Practical challenges and expense of purchase and installation
• Perceived inefficiency
• ‘Optimism bias’, i.e. real world performance failing to match laboratory based performance
• Unsuitability for many houses

A small minority of mainly organisations noted a lack of mention or urged inclusion of specific heating systems in the classification.

A significant minority (again mainly organisations) expressed a variety of other concerns over the proposed heating system classification, as follows:

• The placing of hydrogen under ‘zero direct emissions’, amid perceptions that this is an impractical domestic heating solution
• Prioritisation should be based on carbon intensity plus the efficiency of the system (not ‘responsiveness’ or access to an off-peak fuel tariff)
• Consideration needed of homes with no primary heating source (e.g. Passivhaus), and homes with more than one heating type
• The classification of biomass and biofuels
• A need for real usage data for classification purposes
• A need to reclassify hybrid heating systems

Small minorities maintained that a rating for heating system type was not required. It was argued that this was not relevant in assessing the energy performance of buildings or that many buildings cannot get efficient or appropriate heating solutions.

Comments on Proposed Secondary Metrics

Relatively small numbers of respondents (almost all were organisations) commented on the emissions rating and total energy use ratings.

A small minority thought the emissions rating should be a primary rating. This would give an indication of a property’s impact on the environment, that it would help address fuel poverty, and that this would align more closely with the Heat in Buildings Strategy. Additionally, it would facilitate the right environmental changes to help drive progress to net zero emissions.

There were a small minority of concerns over the accuracy of this rating. This was due to data becoming outdated because of shifting emissions factors and geographical factors affecting the carbon intensity of energy generation.

Similarly, there were requests to make the total energy use rating a primary rating. It was perceived that it could be used to calculate expected running costs. This was seen as a priority for consumers and would encourage homeowners to move towards more efficient systems.

There were again a small minority of concerns about the modelling of this rating being unrealistic as it relies on standardised rather than actual energy usage.

Other remarks

A significant minority (mostly individuals) expressed concerns about upgrades and improvements to property being unaffordable. A small number highlighted concerns about the effects on the most vulnerable in particular.

A small minority of respondents, all individuals, were critical of the policy in general.

A small minority (almost all being individuals) highlighted worries about the policy leading to negative impacts on house prices and the ability to sell homes.

Q2: Are there additional metrics^[7] that you think should be included on the EPC, or metrics that you do not think should be included?

A total of 198 respondents commented at this question. A significant minority of these noted their approval of the proposed ratings or did not see the need for additional ones. Conversely, small minorities wished to retain the current ratings, or voiced their opposition to any EPC scheme whatsoever.

Additional or Enhanced Metrics

The most frequently mentioned rating – by a significant minority of respondents – was an enhanced rating to reflect overall carbon emissions or carbon footprint. It was felt that this would help incentivise the switch to low carbon heating systems and reflect embodied carbon and net CO₂ emissions. Various breakdowns of this were suggested. These included by fabric, heating, hot water and / or lighting, and a whole life measure recommended in terms of kgCO₂.

There were a similar number of calls for enhancements to the total energy use rating, mainly by giving total actual consumption in kWh/yr rather than per m². It was also suggested that proportions of heating and hot water use should be added to the total energy use calculations. This would give households a clear indication of where they are likely to use energy.

Alterations and additions were also suggested for the energy cost rating, again by a significant minority. It was considered that account should be taken of heating controls, heating system efficiency and access to flexible time of use tariffs. A small minority wanted to see a separate rating to capture the annual running costs of heating the home. This should be in either £/yr or an A-G scale based on £/yr.

Slightly smaller minorities advocated alterations and additions to the fabric rating. This included consideration of fabric state of repair, external shading levels, presence of shutters, information on where heat loss occurs and the U-value of the dwelling.

Slightly larger minorities (including several manufacturers and installers) wanted to see enhanced recognition for various elements of insulation. Factors to include were measures for air tightness, a draught indicator and amount of window glazing. It was thought this would be useful in assessing how suitable heat pumps might be as they were perceived to require a well-insulated building envelope. There were also requests to ensure the risks of mould and damp would be flagged.

Other suggestions concerning building fabric included the following:

• A rating for, or inclusion of, hot water provision or hot water demand
• Ventilation measures taken and ventilation performance
• A rating for, or added information about, heat loss

There were also a small minority of suggestions for alterations and additions to the heating system type. Factors specified for inclusion were age of system, maintenance and lifecycle schedules. Optionality for partial or seasonal clean heating systems was also recommended, as were classifications for LPG gas, oil or solid fuel burning in rural areas.

A small minority of respondents urged that onsite or microgeneration of energy (in cases where these are installed) should be included. An average annual generation figure was suggested as well as information on lifecycle schedule, age and maintenance.

General Factors to include or take account of in the metrics

A significant minority of respondents wanted to highlight other general factors, without specifically recommending a rating for these. The largest numbers– a significant minority – wanted information on the suitability of improvements. Indications of cost effectiveness and affordability, as well as influencing factors such as size and space limitations and weather conditions in the area. It was urged that these recommendations should be doable in practice, for instance not recommending double glazing on a listed building. Costs of upgrading were also requested.

It was also thought by a significant minority that account should be taken of the type of home or building. There was a perceived need to group construction types in terms of their suitability for types of improvements.

The other main theme expressed by respondents referred to a need to focus on better explanations to the public about the ratings and the EPC scheme. Explanations should be clear and easy to read, while providing as much useful information as possible.

Metrics that should not be included

This question was answered by 115 respondents. A significant minority reiterated that they did not want an EPC scheme at all. Smaller numbers simply reiterated their preference for retaining the current ratings, while a small minority cited approval of the proposed rating set as it is presented. There were also calls to slim down the number of ratings in general terms amid concerns that the ratings will become too complex.

The largest numbers of reservations (from a significant minority of mainly individuals) concerned either removing or altering the heating system rating. This was because it is seen to penalise non zero-direct emission systems.

A significant minority also saw issues with the energy cost rating, though generally without referring to its removal. These included problems with quantification in terms of monetary sums due to variability over time, location, type of tariff, and energy prices.

Only a few concerns were raised over the fabric rating. Most urged that cavity wall insulation should not be displayed as a feature, citing a lack of visibility to assessors and lack of suitability in some situations. Other worries centred on a lack of affordable options for improvements and that it made an understanding of home performance too complicated.

Fabric Rating

Q3: Considering our proposal to include a Fabric Rating on EPCs, do you think this metric should include domestic hot water heat demand?

A majority of the respondents thought the fabric rating should not include domestic hot water heat demand. This compared to only a significant minority who thought this should be included. More organisations felt this rating should not include hot water heat demand than supported its inclusion. This was more marked in the case of individual respondents. The types of organisation with the highest levels of disagreement included those involved in the EPC process, housing providers, local authorities and third sector organisations.

Reasons for including domestic hot water (DHW) heat demand in the Fabric Rating

The question then went on to ask respondents to give their reasons as to why the metric should include DHW heat demand. There were 105 responses.

The main theme, from a large minority of these respondents, was that domestic hot water demand is part of the overall energy use. As such, all heating should be included in this. It was pointed out that its inclusion would provide a truer picture as hot water is a significant proportion of some households’ overall consumption. Additionally, a significant minority foresaw that this would be a growing proportion of all heating demand.

A significant minority supported inclusion on the basis that the more information available, the better to support decision-making about insulation and other fabric improvements. It was thought that inclusion would provide valuable information as to what would happen if a property changed to a zero-carbon system. It was also thought this would lead to less waste, better thermal storage, more water tank insulation and greater amounts of waste water heat recovery. Conversely, there was a perception that exclusion would deprioritise efficiency measures by limiting consumers’ abilities to make informed choices.

Caveats and provisos

A significant minority of respondents cited caveats to supporting the inclusion of DHW heat demand in the fabric rating, as follows:

• As long as DHW heat demand is quoted separately from space heating demand
• As long as it is viable to estimate this accurately. Concerns were expressed over the accuracy and complexity of DHW heat demand ratings
• As long as savings in demand from microgeneration and energy storage solutions are allowed for

Reasons for not including DHW heat demand in the Fabric Rating

Respondents were also asked for their reasons for not including DHW heat demand in the fabric rating. Reflecting the greater numbers who answered ‘no’ in the first part of the question, 147 gave their views. Some of the reasons given reflected those stated in the consultation document. Most domestic workshop participants’ comments agreed that the fabric rating should cover heating demand only, though opinions were split among the business interviewees. Two themes dominated the responses.

Firstly, a large minority voiced concerns about the complexity, confusion around and accuracy of DHW heat demand ratings. They felt these would not be based on actual operational usage and would be subject to consumer activity and number of property occupants.

Secondly, similar numbers saw hot water demand as having nothing to do with fabric or fabric losses. There were calls for DHW heat demand to be included under annual energy cost calculations or overall energy demand. Significant numbers saw a need to focus the fabric rating on improving energy efficiency related to wall, roof and floor insulation and draught-proofing. This would ensure fabric improvements without the complications of hot water usage, seen as reducing the incentives of fabric first measures.

A small minority of respondents reflected on the differing lifecycles between hot water systems and building fabric making comparability difficult if not impossible.

A significant minority, however, advocated that DHW heat demand should be stated, but separately from space heating demand. There was some support for DHW heat demand having its own category. This was seen as useful for households to understand how the hot water system relates to overall energy demand. Alternatively, participants at a break-out group in the domestic workshop agreed that hot water should be in the heating rating.

Other Comments

There were a significant number of concerns reiterated over the costs involved in complying with the fabric rating and the EPCs. Concerns were again raised over upgrades resulting in worse EPC scores than previously. Similar numbers restated their opposition to having a fabric rating at all.

Proposed Approach to Scaling Fabric Metric

Q4: Do you have a view on the way that the Fabric Rating mapped against a scale, for example, how ‘A’ or ‘G’ rated performance is determined?

A total of 198 respondents commented at this question. A significant minority of these noted their agreement with the suggested A-G scale, stating this was sensible, familiar and well established. Respondents also noted that this would allow for continuity and comparability. It was also regarded as simple, straightforward and easily understood.

Alignment of the Scale with the current EER

There was significant support for the fabric rating to map consistently with the current EER. In particular there were calls to link the cut off for band C in the fabric rating to the cut off for band C in the EER. There were also views to align the bands as best as possible with the existing SAP bands. This would help to facilitate current policy as targets are based on this, and also not to penalise those already in band C for EER.

However, slightly greater numbers preferred the fabric bands to be set independently of the EER and EER band C. It was felt that this would give greater freedom and flexibility to set appropriate bands against the distribution of fabric values. It would also give greater emphasis to higher rated properties. It was also felt the two A-G scales would lack like-for-like correlation, with the labelling confusing the public.

Comments about the suggested bands

A small minority of respondents supported the suggestion that the highest rating should equate to Passivhaus standards. That said, there were some suggestions this should be given an ‘A+’ rating rather than an ‘A’. A small minority agreed with the band B anchor on typical new build fabric performance.

Other alternative suggestions for band anchors and grading included the following:

• Anchoring bands B or C on new build Technical Compliance
• Making the lower bands correspond to less demanding fabric standards already in existence
• Aligning target bands with zero emission heating readiness or achieving net zero buildings

Additionally, there were a small minority of queries about how the scale will be determined, what the grades mean and what improvements would be needed to move up the grades.

Other comments about Fabric Rating Scales

A small minority supported displaying actual units of heat demand (kWh/m²/yr). This was regarded as being useful for professionals, local authorities and social landlords, and would help people visualise or understand the running of large properties. Furthermore, it was perceived that the units can equate to A-G ratings or be used to determine the fabric rating. However, there were also concerns that this type of display may be difficult to understand for most.

There were also a small minority of positive comments about retaining or having a 0-100 rating scale. The advantages were that comparisons to averages across Scotland would be straightforward, and that this would be simple while informative. It would also make it easier to see the steps required to achieve the next band.

There were also calls for a consistent scale or approach with that of the UK or with international standards.

A small minority thought the fabric rating should incorporate other specified factors. These included the energy usage of Mechanical Ventilation with Heat Recovery (MVHR) systems, charging capability, and the presence of solar generation. Further recommendations were to use suitable U-values or to use the Heat Transfer Coefficient ratio to gauge fabric performance.

Concerns about Fabric Rating Scales

Without specifying any in particular, a significant minority were concerned that the scales and measures in general were too complicated for non-experts. Slightly fewer respondents revealed that they were not bothered about what scale was used, as long as it was easily understood. They also felt a need for clarity about what rating properties should try to achieve. To help with understanding, a significant minority sought clear explanations for interpreting each point on the scale and how they relate to occupants’ homes.

There was scepticism voiced (by a significant minority) as to whether realistic and accurate ratings could be set. It was perceived this might be too complex as there are many different types of property with differing ages, conditions and variability of fabric.

There were also concerns that a change would mean some properties would no longer meet the required ratings, despite having done so previously.

A significant minority of respondents felt that the fabric rating was disadvantageous for older, rural and listed properties. Changes such as cavity wall and glass wool insulation were claimed not to be feasible and furthermore that thick walls retain heat well. It was also felt that it would be unrealistic for these properties to reach a C rating, and that EPCs should apply only to new builds. Participants at the domestic workshop suggested mapping the A-G scale specifically for older-type properties to help level the playing field.

Energy Efficiency Features

Q5: Do you agree with our proposal to give more prominence to the energy efficiency features of the home (such as the depth of loft insulation)?

A large minority of the respondents overall agreed with giving more prominence to the energy efficiency features of the home, while a smaller number, but still a large minority, disagreed. Almost all organisations who expressed an opinion agreed with this, but more individuals disagreed than agreed. Among organisations, those with the highest levels of agreement were EPC process, housing providers and local authorities’ respondents.

Respondents were then asked to provide further details and 221 did so. The numbers of expressions of support and non-support roughly reflected the numbers of opinions given at the first part of the question.

Reasons for agreement

A significant minority of respondents were keen to see more information and detail on energy efficiency features. It was felt it is easier to see where the home may be lacking in energy efficiency and where there are opportunities to improve. Respondents wanted to see information on heating technologies, a list of the main fabric elements with their energy rating, and the input data generating the EPC. Slightly smaller numbers of respondents supported this view but held the proviso that the information provided should be accurate and reflect the thermal characteristics of all materials. Proper investigation of these was advocated with assessor skills being deemed important. It was also recommended that all information should be updated regularly and should reflect occupant numbers and lifestyles.

A significant minority cited their general approval of giving more prominence to the energy efficiency features of the home. They felt this was sensible and in keeping with a fabric first approach, while fabric improvements were the highest priority in increasing energy efficiency.

In particular, a significant minority wanted a focus on insulation. It was felt that the better the insulation, the lower the energy requirements. It was perceived this can also be installed relatively easily for most types of housing. It was thought more recognition of external and internal wall insulation might lead to better insulation opportunities.

In addition to insulation, similar numbers of respondents wanted more prominence to be given to other features regarded as important for action on energy efficiency.

There were requests for clear and easy to understand descriptions of information to be provided.

A significant minority again saw a need for information on energy efficiency features to be promoted and publicised properly to aid consumer engagement.

Reasons for Opposing Greater Prominence to Energy Efficiency Features

The most quoted reason for not supporting the measure was doubt over the accuracy of assessments. A variety of issues with accurate assessment were identified. It was felt that these can lead to misleading surveys and wrong recommendations. Related to this, a small minority of respondents thought there was no point in enhancing the prominence of energy efficiency features unless more detailed information and other factors are considered.

Similar numbers of respondents – a significant minority – viewed energy efficiency alterations and improvements as impossible or very difficult in many cases.

A small minority voiced specific issues over a perceived focus on lofts and depths of loft insulation. It was pointed out that many people do not have lofts and that this is only one source of heat loss. There were also comments that depth does not reflect the efficiency of materials used. Furthermore, loft insulation depth has a ‘ceiling’ limit in terms of performance benefit vs materials used. Additionally, loft insulation is the only insulation value that can be reasonably measured.

Other reasons for disagreeing with giving greater prominence to energy efficiency features were provided by a small minority, as follows:

• It would make no difference to householders’ choices as they will focus on other information such as energy costs
• A desire to keep information and ratings simple for ease of understanding
• Concerns over specified extra expenses for homeowners
• The relevant information is already available

Other comments

A significant minority of respondents (mainly individuals) noted potential difficulties in relation to energy efficiency regarding older, rural and listed properties.