Ready or not, here it comes! The legislation has not yet passed The Parliament, so we cannot talk with certainty. But what if it does happen? A good landlord should always be prepared. The phantom of Banc C has been looming over the landlords’ heads for some time already, and all the chatter has generated a lot of concern. True, those who are caught unawares will most likely have to act quickly. Having to act in a hurry often means extra expenses you might not be prepared for… But knowing what’s coming allows you to brace yourself against the changes and welcome them instead of trying to ignore or avoid them for as long as possible. When it comes to Band C, you still have time to prepare, and we are here to help ?
To make the changes more manageable, let’s review the current situation.
According to the official government website,[1] “Since 1 April 2020, landlords can no longer let or continue to let properties covered by the MEES Regulations if they have an EPC rating below E, unless they have a valid exemption in place.” In other words, you cannot star renting a property or, if you already have tenants, cannot renew a lease if your Energy Performance Certificate is classified as lower than ‘E’. As it stands, if a property does not achieve the minimum EPC standard and is not covered by a valid exemption then the landlord can be fined up to £5,000.
The government introduced the EPC in 2008 and they became a benchmark for property comparison and improvement. As the Government policies focus more on properties being “greener”, it is reasonable to say that we can expect the changes to be going in that direction in the future, as the government will want to be seen as actively promoting eco policies on all fronts. With the increase in fuel prices and general cost of living, energy efficiency is to be put high on agenda.
For some time, there have been rumours that this is about to change, and we have been observing an influx of enquiries from confused landlords regarding MEES and the prospective jump to band C. We can see how it’s causing a lot of worry for the landlords as they cannot find a definitive answer. There is a lot of legislation out there and keeping tabs on it all, not to mention making heads and tails out of it all is a full-time job – we know because we’re doing it!
We are in constant contact with a specialist energy certificate provider, and here’s what we know so far.
The consultation in 2020 proposed properties would need to reach a minimum of Band C for new tenancies by 2025 and then Band C for all private rented tenancies by 2028. The government are yet to announce the outcome of the consultation.
The idea of Band C becoming a standard remains an idea so far. As our consultant highlights, ‘In fact this hasn’t even been debated in Parliament yet. We have no detail on the caveats and exemptions in the final legislation when/if/or not the legislation is approved.’
This update is not as accurate as we would have liked, as we still do not know precisely WHEN Band C is coming. The signals are that it IS coming.
So, what can you do about it today?
There are many ways to improve energy efficiency of properties, but the key thing is that the works undertaken improve the EPC as well. There have been many situations where a well-intentioned Landlord has followed advice from tradespeople to improve the property, but the measure has either not improved the property or even been detrimental to the EPC rating.
The recommendations on the EPC are cumulative and should not be indicative of the total improvement outcome, without the other measures preceding being done first.
It is recommended that an EPC assessor is first consulted to model the property and see what rating the proposed improvement makes.
The measures that always have the largest impact on the property are:
- Loft Insulation/ Roof Insulation
- Wall insulation (Cavity, Internal or External)
- Heating system and heating system controls
There is a point of no return where further improvement to a measure will achieve negligible improvement to the EPC. For example, increasing insulation in a loft beyond 250 mm.
Properties not on mains gas have a much higher chance of not passing for MEES and/or being difficult to get to the required standard.
Electricity is not an efficient fuel source, so properties can struggle to pass for MEES.
Regardless of age, type, manufacturer claimed efficiency, smart controls, trades person advice – ALL wall mounted Panel Radiators are regarded as direct acting and as such get a very poor rating in the EPC. This type of heating can be extremely detrimental to the EPC result. The use of Economy 7 or dual rate electric could improve the rating a little.
Electricity storage radiators are rated as more efficient than panel radiators because they possess a storage element in their operation. Because through using Economy 7/ dual tariff the system is designed to heat up at off peak times.
The mechanics of heat storage within the unit means that there is a continual release of heat energy even after the unit has ceased to be powered.
It is this storage of heat and release that makes these units more efficient. Despite manufacturer claims oil and gel filled electric radiators are not classed as storage radiators. It should be noted that there are now improved High Heat Retention Storage radiators, such as Quantum Dimplex. Their proven efficiency offers a marked improvement on the standard model.
Other points:
Electric hot water systems can have a massive impact on the EPC. Ensure that your cylinder is well insulated. Electric instant hot water is regarded as preferable as it does not require storage and continual heating of water.
Be careful of products like electric boilers that do wet central heating as these are not regarded as an energy efficient way to heat a dwelling. These also do not benefit from different electricity tariffs. Heat Pumps are extremely energy efficient, despite combining electricity and wet central heating.
However, these benefits only apply when the system is one that is approved on the PCDF database and fitted by an MCS accredited installer.
Oil boilers are rated as less energy efficient than their mains gas counterparts, so it is likely EPC ratings on oil properties will be lower, causing potential MEES failures.
In comparison to other off grid fuel sources, the impact of a new oil boiler, heating controls, and property insulation can have a large impact on improving an EPC.
Other points:
- LPG is a very poor efficiency fuel system. All LPG systems will have lower ratings than their mains gas equivalent.
- Bottled LPG is regarded as the least efficient fuel system, even worse than bulk LPG.
- Properties on LPG will nearly always struggle on an EPC.
- Where LPG is the only fuel source, all other aspects of insulation and improvements should be considered.
Other improvement notes on some common misconceptions.
- Double glazing does not greatly improve the EPC rating.
- Low Energy Lighting does not greatly improve the EPC rating.
- Water meters do not improve energy efficiency.
- How the occupant uses the heating system has no impact on the EPC
- Assessors cannot accept verbal confirmation of an improvement measure. They can only accept visual evidence on site or supporting documentation – such as building controls completion certificates.
- Planning permission outlines are not evidence of an improvement measure having been installed.
Bigger fixes may involve planning permission and can be time-consuming. Improving a property is a long game. The best strategy to achieve a favorable outcome is to start playing now, while you can still get ahead and stay in control. Then, whenever changes arrive, you will be ready.
Not sure where to start? Keep reading our blog and get in touch if you have questions about a specific property.
Written in consultation with Symon Silvester, Director of SAS EPC
[1] Domestic private rented property: minimum energy efficiency standard – landlord guidance – GOV.UK (www.gov.uk)
