Energy Systems Catapult welcomes the opportunity to this consultation on changes to Energy Performance Certificates, Display Energy Certificates, and air conditioning inspection reports (ACIRs).

Key points:

• The Catapult’s view is that the EPC headline metrics should be: energy use, energy cost, carbon emissions (“climate impact”), and smart readiness. Our view is that this combination of metrics would enable an outcome-focused, technology agnostic approach to improving the energy performance of buildings.
• We do not agree with the introduction of fabric performance and heating system metrics as part of the headline metrics, although this information should be included in the EPC.
• Real-world measurement of building performance should be used wherever possible. This should include measurement of fabric performance through SMETERs technology and monitoring of the efficiency of heating systems, which is particularly important for heat pumps.
• The validity period of EPCs should be reduced and we should move towards a ‘live’ EPC, updated regularly when changes are made to a property. This would be enabled by digital building passports/logbooks which bring together a wide range of data about properties and trigger updates to the EPC.
• We support the proposals to require a valid EPC throughout a tenancy and to require an EPC when a single room is rented out in a house of multiple occupancy.
• Improving the quality and accuracy of EPC assessment should be a priority. The proposals set out in this consultation should help with this but should be combined with measurement of the actual performance of buildings and improved access to reliable data about buildings and their energy performance.