The Heat Pump Association (HPA) was among the many to respond to proposals for privately rented homes to meet a band C Energy Performance Certification (EPC), starting with new tenancies from 2025 and existing tenancies from 2028. Plans put forward to reach this target include an increased cost cap of £10,000 per property, and a requirement for landlords to install ‘fabric first’ measures. While these proposals would help to improve the energy efficiency of properties in a sector that has the highest concentration of fuel poor tenants, they are not ambitious enough to encourage the installation of low carbon heating in preparation for net zero.
At the heart of this concern is the headline rating on the Energy Performance Certification: The Energy Efficiency Rating (EER) – a metric that estimates the cost of energy but does not consider carbon. If this were to be used as the sole tool to improve the performance of private rented sector properties, we could therefore see homes moving up on the EPC scale while potentially incentivising the installation of fossil fuels and increasing carbon emissions. To put this into perspective, not one of the 831,000 EPC recommendations registered in Worcestershire recommended the installation of heat pumps.
To align the metric with the decarbonisation agenda, the HPA has instead advocated for the introduction of a target that also captures the benefits of low carbon heating technologies like heat pumps. This would utilise the Environmental Impact Rating (EIR) on the EPC, which is currently provided for information only. A combination of both the EER and EIR targets could help to balance the reduction of both carbon emissions and energy bills, alongside regular updates to SAP carbon factors to reflect the ongoing decarbonisation of the electricity grid. The shortfalls of EPCs were recently acknowledged within the Government’s own EPC Action Plan, which further strengthens the argument against basing policies on a metric that needs to be improved to align with UK carbon commitments.
A focus on EPC improvement alone could also be a mistake and perhaps too narrow an approach to prepare private rented homes for the efficient and cost effective installation of low carbon heating. The introduction of a maximum flow temperature of 55℃, for example, would ensure that all heating systems operate more efficiently, regardless of the technology in place. This would realise immediate carbon and bill savings to benefit tenants and the wider economy and would also establish the heating infrastructure needed for mass uptake of heat pumps. Making this a mandatory requirement would consequently help to reduce the cost of installing the technology at a later date and would support the Government’s deployment target of 600,000 heat pumps per year from 2028. Any spend on upgrading heat emitters so they are appropriately sized for low flow temperatures should be counted towards the cost cap so that landlords are encouraged to take swift and necessary action. This is something encouraged within the HPA’s recent report: Retrofitting Homes for Net Zero Heating.
Chair of the Heat Pump Association, Phil Hurley said:
“I look forward to the Government’s response to the Private Rented Sector Regulatory Consultation this spring in eager hope that amendments made are ambitious enough to prepare these homes for the future, in a way that drives down costs and carbon.”