Housing sector

Scott Restrick: For a housing sector heading towards net zero, the EPC is a brutal tool

Scott Restrick, Liaison group responsible for energy and sustainability, is then featured in Scottish Housing News’ #COP26SHN showcase of the social housing sector’s efforts to help tackle the climate crisis with his views on how the housing sector housing urgently needs access to a more sophisticated toolkit to meet the needs of both our tenants and our nation’s net zero challenge.

The housing sector is planning and making decisions now to achieve EESSH2 in 2032 – which inevitably must be changed to reflect the Net Zero Emissions agenda. We urgently need to make long-term investment decisions that are fair and equitable for all tenants and for the contribution the residential sector will make to national emissions.

Since 2015, social housing providers have been striving to achieve the Energy Efficiency Standard for Social Housing (EESSH), the successor standard to SHQS. The EESSH was entirely based on the Energy Performance Certificate (EPC), which for successive Scottish Government building energy policies has become the de facto measure of energy performance since its introduction in 2009.

The EPC’s policy journey is almost 20 years old and, despite an overhaul in 2012-2013, it remains insufficient in many areas as a policy tool to inform energy efficiency, zero emissions ambitions and fuel poverty.

Moreover, the current review of the EPC in Scotland is for many in the sector a simple matter of semantics and presentation. It does not seek to address some of the fundamental issues facing housing providers in balancing investment decisions, tenant energy needs and contributing to national emissions performance in the residential sector. However, some would argue that the main purpose of the EPC was not to support these policies, and was simply an energy label in the same way we have similar labels on washing machines and fridge-freezers.

EPC (RdSAP version 9.94) now allows new and emerging technologies to be included in a Evaluation. If we were to redesign an EPC further for today’s needs, what would it look like?

  • Actual energy costs would be a factor: these are actual costs that tenants have to pay and would therefore give a new EPC utility beyond a nominal rating for an average home.
  • All energy would be regulated: currently only lighting, space heating and water energy are counted in the EPC, not appliances such as a washing machine or fridge-freezer.
  • Occupancy would matter: How we use our homes has a huge impact on the cost of the energy-supplied amenities we buy, from making decisions like lowering the temperature of washing machines to regulating the time spent and the temperature of the water in our showers.
  • The risk of fuel poverty would be an outcome of the EPC: with occupancy factors, actual energy costs and all energy consumption included, the risk of fuel poverty for a range of households could be determined directly from the EPC. See Recommendation 6 of the recent Zero Emission Social Housing Task Force Reporting.
  • The timing of energy delivery to our homes would be important: overall this is an issue for grid-supplied electricity, but we can all take steps to reduce our related carbon footprint. to energy consumption by being smart about when we use electricity because at certain times of the day it can be very low in carbon. The impact of time on costs has yet to be fully realized for the domestic market, but we can already see tariffs such as Octopus Energy Agile to be able to provide real savings to those who wish to control their energy consumption.
  • Environmental emissions would be reviewed annually: the current underlying methodology for EPCs is SAP2012, baseline values ​​for emissions and energy costs were determined over a three-year period from 2009 to 2011. Associated emissions to grid-supplied electricity are approx. 60% less today than they are under SAP2012. Currently the estimate of running costs (£) on the EPC is revised every six months, emissions are only revised if there is a change in methodology. Essentially, electric heating today performs as well as town gas systems in terms of emissions, but this is not reflected in the EPC.
  • The improvements recommended on the EPC would focus on the targeted users: currently, the methodology of the recommendations follows a strict predetermined logic. For planning purposes, this should basically follow a structure-first principle and allow measurement sets to reach defined EPC band thresholds.
  • The analysis of the risk of condensation would be included: the ventilation factors are too generalized in CPE and the results of air pressure tests on existing buildings cannot be considered in the assessment. With EnerPhit and EnergySprong systems are gaining popularity in the UK retrofit market, the EPC needs to better reflect ventilation heat losses and the risk of condensation.

In light of the above, the current EPC has not kept pace with the rapid evolution of technologies and the decarbonization of the energy sector. He pegs sustainability and the sector’s asset managers with renewable energy generation technology as the main option for short-term gain, while investing in real estate fabric should always be the first option on the table, a position taken up in recommendation 2 of the Zero Emissions Social Report of the working group on housing – Achieving net zero in social housing. There are alternative and more practical approaches to the current EPC, which will take a much more holistic approach, and it is essential that they are explored as we move forward in our journey to net zero.