Efforts to reform the EPC, including its requirements and the information it provides, have been a topic of ongoing discussion for years. As the energy crisis deepens and concerns about fuel poverty, environmental challenges, and energy security intensify, EPCs have come under increased scrutiny. Add into this the government’s desire to use the EPC to drive more energy policy (think MEES), it is an escapable fact that EPC’s are no longer just being used as part of a build, sale or rental transaction. This has led to growing calls for change, with organisations such as Elmhurst identifying key issues and proposing recommendations to enhance the effectiveness of EPCs.

Updating EPCs is vital to ensure they remain relevant and capable of supporting the country’s drive to decarbonise its building stock, a critical step toward achieving net zero targets. So, it was met with much relief when on December 4th the government (after years of hinting at movement in this space) finally released their consultation ‘Reforms to the Energy Performance of Buildings regime’.

The consultation highlights a key focus on the presentation of the EPC and the metrics it displays to consumers in England and Wales. Currently, the EPC is widely recognised for its colourful A to G rating scale (A+ to G for Non-Domestic EPCs). For Domestic EPCs, this scale reflects the energy cost of a property—indicating how affordable or expensive it is to run based on a standard occupancy model. In contrast, the Non-Domestic EPC uses the scale to represent an Environmental Impact Rating (EIR), which is based on carbon emissions.

While the consultation suggests maintaining the current format of the Non-Domestic EPC in the short term, significant changes are proposed for the design and metrics of the Domestic EPC, which (as a purely cost based metric) is a flawed tool to use:

“The government recognises the current metrics may not provide a sufficiently rounded picture of performance and could better support government priorities such as delivering net zero by 2050, tackling fuel poverty, and improving decency.”

As such the government is proposing to focus on the below metrics to give a more complete representation of building energy performance (with the first 4 metrics being given prominence above Carbon and Energy Use):

• Energy cost: helping individuals understand the financial implications of a building’s energy efficiency and make informed decisions about potential improvements
• Fabric performance: assessing the thermal performance of a building’s envelope
• Heating system: providing information on the efficiency and environmental impact of a building’s heating source
• Smart readiness: assessing a building’s potential to integrate smart technologies that can optimise energy consumption
• Carbon: an estimate of the carbon emissions arising from the energy used in the building
• Energy use: offering insights into overall energy consumption and identifying areas for energy efficiency improvements

While Elmhurst are broadly happy with the introduction of the proposed metrics, we have always advocated strongly for the 3 primary metrics being focused on the 3 C’s: Carbon, Cost and Consumption (otherwise called energy use). Based on the proposals, it seems that the government may have missed the mark with these metrics taking a back seat to Fabric, Heating System and Smart Readiness.

Given that so many policies focus on the need to decarbonise, to not give prominence to the Carbon metric seems to be a big missed opportunity. Elmhurst are also concerned that any desire to reform the EPC must not lose sight of the goal of making it an easier document for the average consumer to understand. We question whether primary metrics of Fabric Performance, Heating system and Smart Readiness will be intuitive to the general consumer and whether they should therefore appear as secondary metrics (present on the certificate but not confusing the key metrics).

There is also the question of what consumers are expected to do with this information; what is the action if they score badly on a Smart Readiness metric? and does this align with the move to net zero? This brings into question the glaring omission of Consumption (Energy Use) from the primary metrics. This metric, which Elmhurst believes may drive the desired behaviours from a building occupier of reducing their consumption, is in reality the singular metric which ties the others together. If you focused solely on reducing your energy consumption, then your carbon and cost would follow suit.

The consultation questions regarding metrics seek feedback on each metric individually. While Elmhurst supports all the proposed metrics, our response will focus on the positioning of Carbon, Cost, and Energy Consumption as the three primary metrics displayed on the EPC, with the remaining metrics presented as secondary. We believe this arrangement best supports the diverse purposes of the EPC, aligns with government policies, and offers the clearest understanding from a consumer perspective.