Citizens Advice response to DESNZ’s consultation on the Home Energy Model: Energy Performance Certificates
Citizens Advice welcomes the opportunity to respond to DESNZ’s consultation on the Home Energy Model: Energy Performance Certificates.
In principle, we support the aims of the modular approach to assessment - where assessors use dwelling-specific information where they can, and defaults where they can’t - as EPCs should be as accurate, and specific to a home, as possible. But, before we agree with this approach, we need more clarity on the standards for collecting and verifying this data, how the Government will avoid a two-tier system of assessment, and whether this will add more costs for consumers when getting an EPC.
On the fabric performance metric, we support the Fabric Energy Efficiency (FEE) methodology’s focus on both heat loss and overheating risk. And we think that the priority when setting C/D boundaries under the fabric performance metric should be ensuring that EPC C represents a decent standard for future decades.
We agree with the general principles of the heating system metric, particularly making sure that the efficiency of the system is taken into account as well as the carbon emissions. But we have concerns about the potential for electric storage heating technologies to score C on the heating system metric. When trying to meet Minimum Energy Efficiency Standards (MEES), this could incentivise landlords to install systems that are cheaper to install but more expensive for tenants to run.
On the smart readiness metric, there should be detailed and clear definitions provided for exactly which types of technologies would and would not be in scope. We prefer Option 2 (microgeneration and storage) as the threshold for reaching EPC C, as research shows that combining solar PV with battery storage can lead to significantly increased savings compared with just solar PV.
We believe that the energy cost metric should be prioritised within the EPC, as information on their energy costs is what consumers would find most useful. The presentation of the energy cost metric must be robustly tested with consumers through user research, to ensure that it effectively helps people to understand the energy costs of their home and how they could lower their costs by making improvements.