Objectives of the consultation
This consultation was dealing with a review of the operation of energy certification under the Energy Performance of Buildings Regulations. The consultation closed on 21 December 2010.
Prior to implementation of the ‘Green Deal' in 2012, DECC and DCLG deemed it appropriate to examine the operation of the energy performance of buildings regime which is currently in place in England and Wales. CIBSE was been invited to comment through the letter from Lord Marland and Andrew Stunell.
The existing Energy Certification regime was not designed with the Green Deal in mind, so the Ministers suggested that a thorough examination was required. CIBSE, amongst many others, were invited to examine its effectiveness and capability of supporting the future policy implementation.
Due to concerns expressed to the Government regarding EPCs, DECs and AC inspection reports, in particular relating to their quality, consistency, levels of consumer compliance and their enforcement, we were also asked to comment on how an effective roll-out of DECs to commercial premises could best be achieved.
The Government sought professional input as to how the EPBD could be improved prior to 2012 as they see this as intrinsically linked to broader policy on the energy efficiency of buildings, including the Green Deal. They aim to produce a set of recommendations to be implemented "from early 2011".
CIBSE welcomes the commitment in the government’s response to the consultation on “Making Better Use of Energy Performance Certificates and Data” to make information more widely available. Regulation 33 is already compromised in the case of DECs, which are required to be on public display in a prominent place by Regulation 16 but they need to become as fully accessible in digital format on the register as they are in physical form in buildings.
CIBSE believes that although the standard process and methodology for EPCs and DECs are adequate, energy assessors do not always follow them in detail because the price for doing an EPC or DEC is too low to enable them to follow the procedures in detail. EPCs are seen as a compliance task and sought on a lowest price basis. DECs are required of the public sector, who are generally expected to procure on price, not on quality and adherence to the DCLG requirements and guidelines.
The current QA arrangements could be improved in a number of ways. DCLG consulted on the arrangements for Competent Persons schemes in December 2009, and CIBSE responded in March 2010. We made the proposal then, in relation both to Competent Persons schemes and Energy Certification and Accreditation schemes, that UKAS accreditation should be used.
To read the full CIBSE response, please follow the link below.