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Proposals for the minimum energy efficiency standard for non-domestic Private Rented Sector

Objectives of the consultation

In the Clean Growth Strategy, published in October 2017, the Government committed to support businesses to reduce their energy use by at least 20% by 2030.

This consultation sought views on how best to improve the energy performance of non-domestic private rented buildings through tighter minimum energy standards. Acting now to set a clear long-term trajectory to 2030 is designed to provide time and certainty to non-domestic landlords, businesses and the energy efficiency market in delivering the energy savings to support a zero-carbon future.

The Government’s preferred trajectory is that all non-domestic privately rented buildings achieve a minimum energy efficiency standard of EPC Band B by 1 April 2030, provided the measure or package of measures are cost effective. The preferred trajectory can be achieved by a mixture of low carbon heating systems in buildings such as heat pumps as well as low carbon heating infrastructure such as heat networks, biogas and hydrogen networks.  

This consultation closed on 7 January 2020.

Supporting papers

To download documents that supported this consultation, please follow the links below.

CIBSE response

CIBSE supports the introduction of a trajectory to give clarity to business and supply chains. 

We also support the desire for that trajectory and target to be ambitious, as ambition in scale and speed is what is required in order for the UK to meet its net zero carbon target. However, we have concerns around two aspects: (1) there is a need to refine the EPC methodlogy to better express potential asset performance, now and with future grid decarbonisation; (2) EPC ratings bear little relation to actual in-use performance: the porposed policy must be accompanied by regulations and incentives for actual in-use performance.

  • While 2030 may be a reasonable target date for the whole of the non-domestic building stock to be captured, there should be incentives for earlier action in order to save energy and carbon earlier, to help build expertise and supply chains and avoid long inaction and last minute calls for exemptions. 
  • In addition, there must be incentives for energy management, as the most cost effective way to reduce energy consumtion, bills, and carbon emissions, and to avoid investment into oversized or overly complex plant and equiment: the baseline must be right before works are carried out.
  • A review of the EPC methodology is needed as it does not sufficiently incentivise energy efficiency and carbon savings measures. While EPCs aim to indicate potential asset performance, and the main objection to their use is their poor link to actual performance, there is also a need to improve how they relate to potential asset performance. we strongly recomend to carry out the review of SBEM at the same time as the expected review of Part L for new and existing non-domestic buildings.
  • We acknowledge this consultation is on the private-rented sector, however we recommend the public sector leads by example and sets an accelerated trajectory for its own stock, both as landlord and tenant, in order to help develop supply chains and expertise, and to give confidence to industry about the government’s commitment. 
  • The lack of correlation between EPC ratings and actual in-use energy performance is well-documented. This means there is no guarantee the proposed policy would deliver the targeted energy and carbon savings. We strongly urge, alongside this policy, to introduce requirements for disclosure of actual in-use performance, and ultimately for compliance with minimum targets.

To read the full CIBSE response, please follow the link below.