Improving the energy performance of privately rented homes: consultation response
Heat decarbonisation will require a combination of tighter energy efficiency standards, nationwide uptake of low-carbon technologies and a local planning strategy for buildings.
Energy Systems Catapult broadly supports the proposals to raise energy efficiency standards in privately rented homes as a way to prepare them for future low-carbon heat, help address fuel poverty and reduce energy bills.
We would urge Government to consider some important factors in assessing its proposed policy scenarios.
- The Energy Efficiency Rating of the Energy Performance Certificate (EPC) is primarily a cost metric, not a measure of actual energy use or a measure of carbon emissions. Our preferred long-term solution to driving decarbonisation in buildings would require substantial reforms to the way in which carbon emissions are measured, requiring the current EPC system to be reformed and replaced with a smarter, more accurate view of a building’s carbon and energy performance, which is fit for purpose.
- As suggested in the ‘Going Further’ chapter of this consultation we would encourage proposals targeting a dual metric, which would work towards measuring actual carbon emissions through the Environmental Impact Rating, an improvement on the single Energy Efficiency Rating metric of the EPC. As suggested, Government should be looking to reform this system, making it fit for the purpose of measuring actual carbon emissions, using digital technology and placing greater overall emphasis on emissions targets.
- Over time, carbon and energy performance could be evidenced by a Green Building Passport, with carbon emissions targets considered across all properties. Equally, opportunities and incentives should be distributed equally across all types of occupancy, including in privately rented homes. Our Six Steps to Zero Carbon Buildings policy work proposes a mix of new planning processes, standards, obligations, subsidies and market incentives to create an enduring framework for building decarbonisation.
- We broadly agrees with the proposals in Chapter 3 ‘Compliance and enforcement’ and recommend a stronger role for Local Authorities (LAs) in delivering net zero objectives. Not only should LAs be given more power to enforce standards, but associated resource should be readily available to them to carry out these duties.
- Any future reform of building standards must consider how proposals will integrate with existing schemes and policies. Landlords must be encouraged to take up schemes such as the Green Homes Grant to maximise the integration of these policies.
- A blanket ‘fabric first’ approach may not be appropriate for all buildings and cost-effective decarbonisation pathways should consider wider local dimensions, including existing building stock, network infrastructure and local energy resources. Private rented properties are disproportionately more likely to be older and therefore more expensive to retrofit than other property tenures, and costs and complexity are likely to be higher than for other tenure types. Our work on Local Area Energy Planning (LAEP) aims to address this by modelling the unique characteristics of a local area, and could be used to understand and evaluate cost-optimal solutions for local areas given a localities’ characteristics.
- Trying to achieve a multitude of policy goals with a single measure risks achieving sub-optimal outcomes. The outlined proposals act as an effective starting point which can lead to improvements in homes by lowering energy bills and getting homes zero-carbon ready, however these proposals need to be considered as part of a system wide approach to decarbonising the UK’s energy supply. Consideration should be given to complementary policy measures to avoid unintended consequences.