Energy Performance Certificates: An Alternative Approach

Policy Paper

Credits — Dr Keith Baker, Dr Ron Mould

Overview

Energy Performance Certificates (EPCs) are deeply flawed and do not present and accurate or useful picture of building energy efficiency to buyers and tenants.

This paper by Dr Keith Baker and Dr Ron Mould of the Common Weal Energy Working Group proposes an alternative framework based not on statistically modelling energy efficiency but by directly measuring the heat losses in buildings as they are used.

Energy Performance Certificates (EPCs) are the standard system of measuring the energy efficiency of homes and other buildings in Scotland but this system is fundamentally flawed and should be replaced. If EPCs continue to be used then the task of meeting climate goals will be critically undermined by the bad data produced them leading to colder, inefficient homes and more expensive, oversized heating systems overcompensating for those inefficiencies. A new system of measuring energy efficiency is presented here.

Key Points

1. The aims of the European Union’s Energy Performance of Buildings Directive (EPBD), which requires EPCs to be produced for all new buildings and those being sold or rented out, are fundamentally sound and should serve to drive improvements in energy performance. However, in Scotland and the UK, the method by which EPCs are produced are fundamentally flawed. In particular, this is due to the reliance on using modelled energy consumption data rather than actual (measured) data.

2. In light of the increasing reliance on using EPC ratings as a key driver for Scottish Government policies on energy efficiency and fuel poverty, including proposals to mandate home and building owners to upgrade their properties to achieve higher ratings, there is an urgent need to understand the highly significant uncertainties around both the ratings and the appropriateness of the improvements recommended by EPC assessments. Then if the Scottish Government seeks to persist in using EPCs as a policy driver it should develop an alternative method for producing them which both more accurately reflects actual energy consumption and includes a more realistic and appropriate list of recommended improvements. Doing so is entirely within its devolved powers, and such an alternative approach would be more aligned to the EPBD’s guidance for producing EPCs.

3. This policy paper sets out such an alternative approach, and how it would achieve greater alignment with the EPBD. The approach is based on the fundamental principle of maximising the use of real data in order to provide buyers and tenants with accurate, robust, relevant, and useful information. The approach is also designed to maximise the use of data already being collected by the Scottish Government and public bodies in order to be cost effective. We present this approach as an answer to the frequently asked question of ‘if not EPCs, then what?’, and would welcome comments from other experts and stakeholders as to how it could be refined further.