Energy Performance Certificate reform: consultation analysis

Non-Domestic Energy Performance Certificate Metric Reform Proposals

Key Findings

Across the questions asked in this chapter, the same issues tended to emerge repeatedly.

• Around one in three respondents agreed with the set of metrics^[8] proposed to display on non-domestic EPCs (Q6)

Key themes

• Advantages outlined for these ratings included the provision of a clear understanding of the ratings and how they feed into the EPC score. They are a good range of measures to improve building performance. It was also felt these would provide a good foundation for other workstreams and should help incentivise stakeholders to make buildings more energy efficient
• The current ratings are sufficient and no change is needed
• Views were positive on having a relative Energy Rating that would align with the rating system used in other parts of the UK
• There were some calls for consistency between domestic and non-domestic EPCs to help reduce complexity
• There were concerns over the potential costs of retrofit changes, with some requests for additional grant funding to be made available

Next most frequent themes

• The new non-domestic EPC ratings should help to counteract some of the perceived poor quality of data provided under the current ratings
• Some respondents preferred the use of real data rather than modelled data and felt this would provide a more accurate reflection of a building’s performance. There were also some requests for the actual energy costs to be provided rather than being based on standard modelling
• There were some comments that it can be difficult to set ratings for non-domestic buildings because of the variety of building types and uses across the country
• A number of additional ratings for display were suggested by respondents
• There was some criticism over a ‘one-size-fits-all approach, as usage of buildings varies considerably. Additionally, it was felt that some listed buildings and older properties would need to be assessed on an individual basis

Agreement with the proposed set of metrics

Q6: Do you agree with the set of metrics that we propose to display on non-domestic EPCs?

Around one in three respondents overall agreed with the set of ratings proposed to display on non-domestic EPCs. In terms of sub-groups, higher proportions of organisations agreed with this proposed set of ratings than did individuals. In terms of organisation type specifically, highest levels of agreement came from organisations involved in the EPC process, local authorities, those in the construction sector and housing providers.

A total of 132 respondents, across all sub-groups, provided commentary in support of their initial response to this question. In general, less comments were provided in respect of non-domestic EPCs than for domestic EPCs, presumably reflecting that some respondents have a lack of experience of them. Some individuals participating in the face-to-face discussions noted this is not an area of concern for them.

Support for the proposed Non-Domestic EPC

To a large extent, many of the comments made by respondents echoed the reasoning provided in the consultation paper. Of those who supported these ratings, it was felt they would provide a clear understanding of the ratings and how they feed into the EPC score.

Also, that they are a good range of measures to improve building performance. It was also suggested they would provide a good foundation for other workstreams and they should help incentivise stakeholders to make buildings more energy efficient.

A significant number of organisations saw the introduction of a relative Energy Rating that would align with the rating system used in other parts of the UK as a useful element. This was particularly useful given that many buildings are owned or managed by UK-wide organisations.

A need to align domestic and non-domestic EPCs

A number of respondents across most sub-groups suggested that consistent EPCs for domestic and non-domestic buildings would be preferable. This would help to reduce complexity in that different measures can cause confusion. For example, the use of direct emissions for non-domestic properties but overall emissions for domestic properties could be confusing. As EDF commented:

“We support alignment of non-domestic EPC metrics with broader UK policy. This will give businesses a more reliable comparator to assess the energy efficiency of their properties in relation to others. While absolute emissions of a property are important, they do not tell the whole story as the nature of business itself is likely to impact energy requirements i.e. some businesses will naturally require more (or less energy) to run their business.”

However, a few respondents felt the non-domestic EPC needs to be separate from domestic EPC. This was because of the wide variety of non-domestic buildings and their differing uses, even within the same property type.

Views on the suggested metrics

There were some criticisms of the poor quality of data provided by the current ratings. There was a view that non-domestic EPCs need more data to obtain a full breakdown to understand buildings better. For example, there is a need for more comprehensive modelling that includes heating, schedules, occupancy, controls and so on.

In terms of the suggested ratings, there was a small amount of criticism of the use of modelled energy. Respondents commented the use of real rather than modelled data would provide a more accurate reflection of a building’s performance. This was particularly in the context of direct emissions. A representative body suggested if the non-domestic EPC is based on modelled energy, any reforms will limit the usefulness and accuracy of the data available. Attendees at workshops pointed out the need to highlight that any ratings provided are only indicative.

Some representative bodies and organisations within the construction sector asked for clarity over which rating will be used as the target when designing and assessing retrofit options. For example, while a cost rating may be convenient for consumers, it is more problematic for designers. In comparison, a fabric rating based on kWh/m²/yr provides a clearer performance target for design. Furthermore, the heating / fuel type might be problematic given that the availability of some fuels may be limited in some areas. Also, heating systems can be changed and improved, while fabric measures are more permanent and difficult to change.

There were also a few suggestions that the ratings should include total emissions as per domestic EPCs rather than direct emissions. This would provide an overall carbon footprint of non-domestic buildings. There were also some requests for the actual costs to be provided, rather than being based on standard modelling.

Concerns

There were some comments that it can be difficult to set ratings for non-domestic buildings in Scotland. This is because of the variety of building types and their uses across the country.

Q7: Are there any additional metrics that you think should be displayed, or any in the proposed set that should not be included?

A total of 120 respondents commented on this question, most of which commented on additional metrics that should be displayed, rather than those which should not.

Additional metrics that should be displayed

A number of additional ratings, or additional information, were suggested by respondents. These included:

• The fabric rating should provide more detail
• Heating system type and efficiency
• Total annual carbon emissions: direct and indirect
• Actual running costs and energy consumption
• Peak heating load
• Hot water demand
• Embodied carbon (kgCO₂/m²), although this would mean an embodied carbon calculation would need to be added to SAP calculations
• Whole life carbon (embodied and operational)

There were a number of comments that a ‘one-size-fits-all’ approach is not suitable for the varied uses of non-domestic buildings. As such, there were some requests for different buildings to be assessed on an individual basis. There were also a few comments on the need for any ratings to be clear and easy to understand for everyone likely to use an EPC. There were also concerns about the costs of any improvements made and the need for funding and grants to be made available.

Ratings that should not be included

Comments made in response to this question tended to be generic and some focused on domestic EPCs rather than non-domestic EPCs. They included comments that heat pumps are not suitable for some types of property or that the present system is adequate. Also, there was some disagreement with the proposals within the consultation.