Planning, building and the environment

Frequently asked questions on Energy Performance Certificates (EPCs) and commercial buildings

As the guidance states that EPCs must be produced by an Accredited Energy Assessor, does this mean that a team can gather the data for the EPC, and if so, would all the team need to be Accredited Energy Assessors?

A team of people can work on gathering the information for an energy assessment as long as they are working under the direction of an Accredited Energy Assessor. The Accredited Energy Assessor must ensure that anyone visiting a property or gathering information on their behalf is both 'fit and proper' (for domestic properties this will include a CRB check) and suitably qualified to gather the information. Only Accredited Energy Assessors can produce and lodge an EPC. 

Certification for apartments or units in blocks can be based on the assessment of another unit in the same block. Existing data may be used that was gathered at an earlier date and/or by another person. 

An Accredited Energy Assessor may use data previously collected about a building. They must , however, be satisfied that any data about a property has been properly collected and accurately reflects the property as they will be responsible for any data used to produce an EPC. 

For existing domestic properties, the Accredited Energy Assessor must base the assessment on a visit. Where an assessment is based on the assessment of another representative apartment or unit, the Accredited Energy Assessor will need to visit a sample of the apartments or units to verify that they are indeed representative. In other cases the assessor must visit the property if they have any concerns about the data and should expect to do so unless they have good reason not to.

The guidance talks about similar representative units. What does this mean?

An apartment or unit is a part of a building that is designed or altered to be used separately. This implies that for a part of a building to be defined as an apartment or unit it should be capable of separate occupation. An apartment is a dwelling and a unit is a non-dwelling.

Representative units should all be in the same building or block. In terms of what makes one unit representative of another it will be down to the judgement of the assessor as to whether the data used for one building would accurately reflect another. Material facts may include age and construction of property, orientation, position within the block, type of heating, insulation and glazing.

If I am assessing similar and representative units, can I re-use the data?

If one unit in a block was surveyed in detail the assessor can copy the data model to prepare an EPC for another. The assessor needs to be satisfied that they are the same (or make any adjustments as required) and then submit the data to produce an EPC for the second unit.

Shell and Core units. If I let out a shell and core unit without services (or connections or meters) do I need an EPC and if so, what is it based on?

If there is the expectation that the unit will have conditioned space, then an EPC is required. The EPC for the shell and core work is based on the maximum design fit out spec that is used for compliance under Part L of the Building Regulations. Part L ensures building work conforms to energy performance standards and the default maximum design spec will apply the 'worst' energy rating for the building under the energy performance targets in Part L. This will ensure the recipient of an EPC is aware of the energy performance implications of installing the full suite of services. Any subsequent fit out work, including installed services, will need to comply with Part L (as in or equal to ADL2B) and the associated energy performance targets. 

What happens though, if a tenant installs their own services later on? Is the same EPC still valid?

Any services installed will still need to comply with Building Regulations. To comply with Building Regulations any services installed must meet energy efficiency requirements. The original EPC is still valid.

What happens if my shell and core unit is divided into two parts (that are altered to be used separately - eg two shops instead of one) with services to each?

If you create more or fewer parts and provide or extend fixed services (e.g. heating, hot water, air conditioning or mechanical ventilation) then you will need to provide an EPC for the building. Simply creating a new part without changing the fixed services at all or changing the fixed services without creating a new part will not trigger the need for an EPC.

If the new parts you create have separate fixed services then each new part will require an EPC. If you are creating a new part in a building with a common heating system where the existing fixed services serve that part then if there is an EPC for the whole building you can provide that EPC for any buyers or tenants.

For a shell and core unit without any services installed, any EPC will be based on the maximum design spec (as described in section 4). As the unit does not have any services installed, a modification that creates a new part but still does not provide services, will not trigger the need for an EPC.

In guidance reference is made to the treatment of shared or communal areas that accompany units with independent heating systems. How can these areas be assessed?

In the guidance (section 4.2.2 scenario B1 - a centre with conditioned central space and independent heating systems) - note was made of including a proportion of the energy consumption of the conditioned central space in the EPC for a unit. The following advice below should replace 4.2.2 scenario B1 in the guidance:

In practice, where a centre has units and a common space all with independent heating systems, 1 EPC can be provided by a seller or landlord for the whole building only if it is being sold or let as a whole.  Otherwise a seller or landlord should provide an EPC for the part (or unit) being sold or let plus an EPC for the common space. The prospective buyer or tenant can then make their decision on the basis of the energy rating for the unit and the energy rating for the common space that serves the unit.

Does a care home need an EPC?

A care home will need an EPC only on construction, sale or rental as a whole building. There will normally be no EPC duties towards residents, for reasons explained in the question below. The whole building EPC would be based on SBEM, the method for assessing non-dwellings.

Should an EPC be provided to every new resident of a care home?

Accommodation provided with attendant services and without a right of exclusive possession of any part of the premises would not usually constitute a letting in respect of which an EPC should be made available. Residency of care homes, student accommodation block, hotel rooms, prisons are likely to fall into this category.

Sheltered housing, by contrast, frequently contains self-contained apartments, either let or owned, with common rooms also provided for social and recreational purposes, with use of them also governed by the terms of the lease of the individual accommodation. In this circumstance an EPC would be required for each dwelling when rented or sold.

If I rent office space or rooms on an occasional basis (ie for a meeting or conference), should I be provided with an EPC?

Renting rooms or office space on a purely occasional basis will usually not constitute a rental in respect of which an EPC should be made available.

Would student accommodation blocks require an EPC?

An EPC would be required when the whole building is built, sold or rented for which SBEM (the method for non-dwellings) should be used.

Whether an EPC should be given to persons who take up residence would depend on the arrangements in the accommodation in question. No EPC is likely to be needed in a hostel or hall of residence open only to students of a particular institution and for the duration of their studies and subject to institutional discipline.

If I am offered work on a farm and that employment comes with a tied building, should I expect to see an EPC? If so, for which part of the building?

If the accommodation is tied to an employment contract, this would not usually constitute a rental in respect of which an EPC should be made available.

I am assessing a building that is made up of more than one dwelling.  Do I use SAP?

Each dwelling should have an EPC. If a building has a mixture of self contained dwellings plus residential rooms (i.e. rooms plus shared kitchen/bathroom facilities), then the self contained dwellings should be assessed separately using RdSAP or SAP, but the remainder of the building should be assessed used SBEM.

Were there enough energy assessors to support 1st October 2008 EPC roll-out to all commercial properties?

Yes. Our analysis suggested we needed in a range of 300 and 550 assessors and we had 471 assessors accredited on 1 October which was well within this range.

Does this mean you have enough energy assessors?

We base our figures on current market conditions which are subject to change.

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