For Rent: glass house with good boiler: E rated?

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Last week, it was announced that up to 1 million tenants renting from a private landlord can look forward to warmer homes that cost less to heat.  From April 2018, landlords will be required by law to get their leakiest properties to an energy efficiency rating of at least a Band “E” energy rating.

The new regulations will mean that:

  • From April 2016, residential private landlords will not be able to unreasonably refuse consent to a tenant’s request for energy efficiency improvements where Green Deal finance or subsidies are available to pay for them.
  • From April 2018, private domestic and non-domestic landlords will need to ensure that their properties reach at least an E EPC rating, or have installed those improvements that could be funded using available Green Deal finance or subsidies available to pay for them, before granting a tenancy to new or existing tenants. These requirements will apply to all private rented properties – including occupied properties – from April 2020 in the domestic sector (and from April 2023 in the non-domestic sector).

The new requirements are of course to be welcomed, as any minimum standard is better than no standards at all, but this does seem to be a bit of a wasted opportunity. The new standards could have been set so as to improve the rental housing stock further, reducing heat demand and thus helping to lift more people out of fuel poverty.  A Band ‘E’ property at the bottom of the scale is still going to be expensive to heat and pretty energy inefficient.

(An EPC for an existing dwelling, can be a fairly rough yardstick to use for a comparison, but it is what we have for now, EPC’s seem to often be produced at the lowest possible cost, by an assessor trying to get as many done as he or she can in a day and the assessment itself is based on standardised assumptions of heating patterns and occupancy that may not match what actually occurs; Air tightness isn’t captured and there are a lot of assumptions made).

As I noted in a blog post last year, whilst upgrading the existing building stock is very much the right idea and setting minimum standards of energy efficiency for rental properties is one of the better approaches to helping reduce fuel poverty, a band ‘E’ target can represent a wrong turn, or cul-de-sac, that may add cost and lengthen the journey towards truely energy efficient properties.

In common with many students,  I once rented an extremely energy inefficient house shared between five of us. The house was a two up, two down, solid brick walled, victorian mid-terrace. It was built around the 1900’s and still had no insulation in the walls, floors or roof; heating and hot water came from a gas fire in the living room (with a card operated gas meter) and an immersion heater in the bathroom. Overall, it was similar to many other unimproved victorian terraced houses across the land.

I’ve looked at the properties around where I used to live and they now seem to mostly have ‘E’ ratings; maybe they’ve been improved a lot since I was at college (or perhaps their heating and hot water is somewhat better than it was when I lived there). I just remember that it was always cold and we had to scrape mould off of the walls in the bedroom every week through the winter and spring, because we simply couldn’t afford to heat the place.

That was a while back now, before EPC ratings were implemented; I’d like to think that nowadays, we would have carefully examined an EPC rating before taking on a property and then thought long and hard about it; but the reality is that energy performance sadly isn’t high on the list of what people look for when renting a property and many of the other houses we looked at back then were far worse, with high rental demand and low supply meaning you couldn’t spend too long considering.

According to the DECC press release:

“These new regulations will drive bills down in some of the worst-insulated homes where up to 1 million tenants are paying too much to keep warm. It’s also good news for landlords, who can benefit from improved properties with the financial support of the Green Deal and other schemes, and a real boost to the industry.”

As I noted during the consultation, If the targets required that improving the building fabric was necessary from the outset, houses could achieve a band ‘D’ rating fairly easily, probably even a ‘C’ rating, especially if the heating and hot water were addressed alongside the fabric (rather than instead of).

If the improvement target is only to get to an ‘E’, landlords may be more inclined to just get the cheaper things done to get there and then may baulk at anything further. Getting out of a poor band ‘F’ or ‘G’ can sometimes be achieved by installation of a better heating system and controls, without addressing much of a reduction in heating demand. Whilst the resultant rating might look better on paper, the reality could be somewhat different for those living in it.

Looking back at the house that I once rented with my friends, assuming that it is now an ‘E rated’ property, with a new boiler, and better controls, but that it is otherwise still uninsulated, with a poor building fabric, it is likely that it will still be cold, draughty and costly to live in.  A house that costs a fortune to heat, simply won’t get heated if the occupants can’t afford to keep up with the high heat demand – even if the heating system is more efficient.

A house that addresses high heat demand, through insulation and reducing leakiness whilst at the same time, ensuring adequate heating and ventilation will easily achieve and surpass the new minimum standards and at the same time result in a property that gives a higher standard of health and comfort to its occupants.

Don’t get me wrong, the new minimum standards are a good first step towards better housing, it just seems a real shame that a bolder step isn’t being taken. Maybe in 2020 when the first review takes place, a bolder step might be considered – unfortunately the measures that will be undertaken now to get to an ‘E rating’, might then prove to be barriers to going beyond that.


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Jon Ducker is a qualified energy assessor working for Kingspan Insulation Ltd. He has an extensive knowledge of energy efficiency, renewable energy systems and sustainability in buildings with an expert knowledge of the relevant sections of buildings regulations and standards and their interactions with SAP. He provides authoritative advice regarding energy assessments for a wide range of public and private sector clients.

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