Policy submission

Consultation on Energy Performance of Buildings - Which? response

Which?'s response to the government consultation on the reform of Energy Performance Certificates (EPCS) calls for changes to help consumers understand and improve the energy efficiency of their homes.
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Summary
We welcome the UK government’s consultation on energy performance of buildings including the proposed reforms to Energy Performance Certificates (EPCs). EPCs could be an important tool supporting consumers that are looking to buy or rent a home, and those looking to make improvements to their property. However Which? research shows that too often EPCs are not working for consumers. Too often the information and recommendations are inaccurate or out of date, difficult to understand, or lack relevance. As a result many consumers have very limited engagement with their EPC.

In order to make EPCs work for consumers the government should introduce reforms in the following areas.

  • Metrics:  We recommend that EPCs have four primary metrics relating to energy cost, environmental impact, fabric efficiency and the heating system. It should be clear that the energy cost metric refers to energy cost, and not energy efficiency as is currently the case. The new heating metric should incorporate an efficiency rating and be used in conjunction with the energy cost metric to ensure that households and landlords are aware of the cost implications of different systems, and landlords are not incentivised to install low carbon heating systems that may have higher running costs for their tenants.
  • How EPC metrics will be used: We are concerned that there are no proposals in the consultation for how these metrics will be used in house sales and lettings, or how metrics will be used to demonstrate compliance with regulations or eligibility for grants and financing. These are critical issues that may influence the design of the EPC.and will impact on how much consumers use their EPC.
  • Improving the design and content of EPCs: Our research showed that improvements to the design and language of the EPC can significantly improve engagement. The government should ensure the design of the reformed EPC is tested with consumers before its introduction. 
  • Use of data in EPCs: We support data from previous EPCs and EPC assessments being used to improve accuracy. However this information should not be used to ‘prefill’ assessments as this may encourage tickbox assessments. We recommend the government also considers the use of data from other reputable sources, such as Gas Safe, or the MCS and TrustMark databases, to improve the information available or to verify the information that is presented in the EPC.
  • Links to further information and advice: The government should include links from the EPC to other government or third party tools that give consumers access to more up to date prices or tailored information based on information they have provided about their household size and energy use. This was not part of the consultation.
  • Validity period of EPCs: The government should reduce the validity period to 5 years as our research showed that consumers are sceptical as to whether older EPCs are an accurate representation of the property. On balance we agree that existing EPCs should remain valid until their term has expired. Property owners with older EPCs that have made significant changes to their properties will have an incentive to update their EPC without a regulatory requirement. 
  • Accuracy of EPCs: Our mystery shopping exercise highlighted concerns around accuracy and our review of EPC audit data identified gaps in the information available. The government should improve their oversight of the auditing process,  set clear targets for the proportion of audits that pass each year and require schemes to publish more information about the results of audits. Allowing the use of performance data from SMETERs will also improve accuracy and deliver other benefits for consumers.