Objectives of the consultation
The Government has committed to upgrading as many private rented sector homes as possible to Energy Performance Certificate (EPC) Band C by 2030, where practical, cost-effective and affordable.
This consultation set out a suite of policy proposals towards achieving this. These proposals aim to bring significant benefits to landlords, tenants and our environment including:
- reducing energy bills and increased comfort for tenants and supporting delivery of our statutory fuel poverty target of EPC C by 2030
- potential property value improvements for landlords
- delivering carbon emission savings over Carbon Budgets 4 and 5, making progress towards our net zero target.
The consultation closed on 8 January 2021.
Download the consultation document and impact assessment below.
- Improving the energy performance of privately rented homes in England and Wales - Consultation document
- Consultation Impact Assessment
- BEIS Consultation page
CIBSE does not agree with the proposed new target of EPC (EER) C as a minimum energy performance standard in the PRS regulations under the current EPC approach, as evidence shows it will not reliably deliver either energy use savings or heat decarbonisation. As energy use is a crucial factor in fuel poverty, CIBSE does not think this is either the best strategy to reduce fuel poverty.
Firstly, improving EPC (EER) ratings is not strongly associated with reducing energy use and associated energy costs and carbon emissions. This has been noted by a number of studies, and the SAGE Housing paper referenced above points to the drawbacks with seeking to draw inferences about environmental performance, including energy use, from EPC data. A significant piece of evidence for this is a recent UCL project carried out for BEIS, covering over 400,000 dwellings.
Secondly, improving EPC (EER) ratings does not guarantee decarbonisation. Under current gas to electricity cost ratios, and because EER are cost ratings, a strategy driven by EERs can even go counter to heat decarbonisation, since it encourages continued gas-fuelled heating options. In the case of rural properties off the gas grid it can favour even higher carbon options, which is particularly problematic as, on an opportunity basis, these off-grid properties could form the first target of the transition away from fossil fuels. We are aware this perverse outcome has been noted as a concern by large rural landlords such as the National Trust, and we very much support their concern.
CIBSE strongly urge a revisit of the approach, as detailed in our response.
The best strategy allowing progress towards all objectives stated in this consultation, is to reduce energy use. This in turn helps reduce energy costs, fuel poverty and carbon emissions. Because fabric efficiency is a key part of reducing energy use, it is also likely to improve comfort.
CIBSE believes that the indicator should not be the current EPC rating, which is cost-based, but one based on energy use. This should be coupled with a heat decarbonisation requirement (whether through PRS regulations or separately) to complete the trajectory towards net zero (i.e. not only reduce emissions, but also move away from fossil fuels). It may also be coupled with an indicator focused on space heating and fabric efficiency, as detailed in our response.
To read the full CIBSE response follow the link below.