EPC for Solar PV

1. EPC for Solar PV Helping to achieve D rating Chris Grant, Director EPC Choice

2. Introduction • Qualified as a domestic energy assessor in 2008 • Personally undertaken over 3,000 EPCs • EPC Choice undertake ~400 EPCs per week for a diverse range of clients including: • Housing Associations • Property companies • Retailers • Property Agents • Private Clients The main reason for me being here today is that the EPC and Solar PV industries are about to become inextricably entwined

3. Government Response to Consultation on Comprehensive Review Phase 1 – Tariffs for Solar PV You will be aware that on the 9 February the Government published . . . Government Response to Consultation on Comprehensive Review Phase 1 – Tariffs for Solar PV

4. Government Response to Consultation on Comprehensive Review Phase 1 – Tariffs for Solar PV “ We have decided to proceed with an energy efficiency requirement for new Solar PV installations with an eligibility date on or after 1 April 2012, as a pre-requisite of eligibility for the standard Solar PV tariff rates. This will mean that new FITs applications for Solar PV will need to demonstrate that the building to which the Solar PV installation is attached or wired to provide electricity has an Energy Performance Certificate rating of Level D or above. “

5. Government Response to Consultation on Comprehensive Review Phase 1 – Tariffs for Solar PV “ This specific requirement is a change from the original two options considered, taking into account consultation responses, but with the same general intent. The review went on to say . . . “ The original options wereeither: • (1) Bringing the building up to an Energy Performance Certificate (EPC) rating of level C or above; or • (2) Undertaking all the measures that are identified on an EPC as potentially eligible for Green Deal finance The view was that the Level C requirement was in fact too stringent and that the Green Deal link was not feasible as the Green Deal had not been launched

6. So what is an EPC? It stands for Energy Performance Certificate

7. Background of the EPC The EPC was borne out of a European piece of legislation known as the Energy Performance of Buildings Directive (EPBD). This was introduced in the UK in January 2006 Objective To improve energy efficiency and reduce carbon emissions as part of the government’s strategy to achieve a sustainable environment and meet climate change targets agreed under the Kyoto Protocol Initial purpose To provide prospective purchasers with an assessment of the property's energy consumption, together with a list of practical measures that can be taken to cut their fuel bills and carbon emissions

8. Background of the EPC EPCs were first seen as part of the much maligned Home Information Packs which were phased in from August 2007 and promptly scrapped by the incoming coalition government in May 2010 The EPC however remained a requirement for all properties sold or rented and this included commercial properties also in many circumstances

9. EPCs EPCs . . . • . . . are produced using a piece of software known as RdSAP(Reduce data Standard Assessment Procedure) and is a scaled down version of SAP which did not rely on the provision of U values but more on general assumptions relating to the building age and applicable building regulations • . . . are valid for 10 years and there are no immediate plans to reduce this period, but this may conflict with Green Deal legislation • . . . can only be produced by qualified and accredited energy assessors and will always require a physical inspection (unless sampling or using multiple certification) The EPC Survey is designed to be a non intrusive survey with no lifting of floorboards or knocking holes in walls. The assessors will require access to the loft where possible. “Essentially, the EPC is assessing the ways in which a property uses and losses heat or energy”

10. The EPC Survey Energy assessors are typically working through a checklist of data required by RdSAP which will include: • The address • The age of the property • The built form – whether detached, terraced, etc. • The volume of the property • The length of the walls from which the property looses heat • Wall construction type • Floor construction type • Insulation measurements both to walls and loft • The number of extensions – if any • Rating • Conservatory • Loft conversions • The proportion of windows DG • The proportion of LE bulbs • The presence of solar water heating • Wind turbine • Solar PV • Air conditioning • The heating system including the fuel and the way in which it is controlled This list is not comprehensive but covers the main factors which will affect the rating

11. EPC data • This data is then fed into the RdSAP software by the assessor either on-site using a PDA or once they are back at their PC • The resulting EPC simply reflects the data that is inputted and in many ways it is not the Energy assessor producing the EPC but RdSAP software • The only area of control the assessor has over the EPC will be in the recommendations section • The EPC provides recommendations for ways of improving the Energy Efficiency and in certain circumstances these will not be appropriate to the property in question and the assessor can remove them Example If a property had visible signs of condensation in the loft we would suppress the Loft Insulation recommendation

12. Landmark In order for an EPC to be validated it needs to be lodged on the National Database which is run by Landmark – once entered they are given a unique 20-digit reference number

13. Landmark At this stage the EPC is not fully in the public domain as you are required to have an interest in the property to obtain a copy of the EPC The Landmark database contains this rather stark warning: • If you are not the owner or a tenant of the building (or acting on behalf of the owner or tenant), it is a criminal offence to show or allow someone else to show any EPC or recommendation report, or any information taken from it (including a reference number) to anyone, unless: • You are giving the information in line with the Energy Performance of Buildings Regulations (or any regulations related to them) • You are giving it in line with your (or someone else's) decision to buy or rent the building the EPC relates to • You are giving it to an accreditation scheme that assesses the professional standards of energy assessors • You are giving to a local authority so they can enforce trading standards or buildings regulations • You are giving it to: • Detect or prevent crime • Arrest or prosecute offenders • Work out, use or defend someone's legal rights • Keep to a court order

14. Green Deal However, this is about to change in relation to the Green Deal as the EPC database will be opened up to: • Green Deal Providers • Organisations which provide energy efficiency advice • Government departments • Local authorities • Researchers . . . but still subject to strict Data Protection guidelines in order to protect the public

15. Green Deal map

16. Has the EPC served its purpose? This is in response to a report produced by consumer focus

17. Consumer Focus document Conclusion of the report This research highlights two common concerns regularly raised by the energy efficiency industry: • Failure of estate agents and other property professionals to comply with regulations that require energy performance certificates to be provided to prospective buyers or tenants • That EPCs have little impact

18. Changes to the Energy Performance Certificate As a result of these findings the Cabinet Office along with DECC and the DCLG undertook comprehensive revision of the EPC And on the 1 April all future EPCs will look like this . . .

19. Energy Assessor retraining In order to produce the new style EPC – Energy Assessors have needed to undertake additional training and pass a new qualification – any assessor who has not completed this prior to the 1 April will not be able to produce EPCs from then So lets take some time to examine the new EPC . . .

20. Energy Performance Certificate

21. Energy Performance Certificate

22. Energy Performance Certificate

23. Energy Performance Certificate

24. Solar PV industry So how is this going to work for the Solar PV industry? This does represent a huge change for the EPC as for the first time it effectively has . . . . . . a pass . . . or fail . . . a minimum requirement in order for it to have a maximum value

25. Industry concerns I have spoken with many installers since February in order to identify the way in which we can adapt our working methods to ensuring we are meeting the requirements of the solar industry. What we know for certain: • An EPC is now required with all FiT applications in order to qualify for the full FiT • The rating on the EPC will need to be a minimum of D • Solar PV can be included towards D rating The concerns raised by the solar industry have been: When should the EPC survey be undertaken? • We believe that the EPC should be undertaken only once the client is committed – agreement signed deposit taken. Your salesman or surveyor should proceed on the basis obtaining the D rating will not be an issue. ( I will come on the reasoning behind that). The ideal window to undertake the EPC survey is during the 7-day cooling off period, as this is showing the customer that the wheels are in motion, its building commitment Who should pay for the EPC? • This will depend on your own business model, some companies are taking payment for the EPC when the contract is signed, and refunding this once the installation is completed • Others are absorbing the cost completely Will there need to be two EPCs undertaken? • No, there should be no need for more than one survey. The four pieces of data collected for Solar PV collected Roof Orientation, Roof Slope, Shading Issues and the kWp. Provided you are able to provide an anticipated output for the Solar PV we can issue a draft EPC to confirm whether D can be achieved. The final version EPC can be issued without a second survey once the MCS certificate is produced What if the EPC fails to make D? • Some properties will simply not be able to achieve a D or the cost to do so will be prohibitive, in those situations there is a strong likelihood that the installation will not proceed. If the client has paid for the EPC they should still be entitled to receive it as it may serve other purposes in the future – valid for 10 years, they could use if they sell the property

26. So what will the minimum D requirement mean in reality? The government has said . . . “Currently, around 51% of all dwellings are rated at EPC level D or above, and 47% of all dwellings except flats (this compares to 13% of dwellings at EPC level C or above). The proportion is larger amongst local authority and housing association dwellings (72% and 77% respectively). There is less data available for non-domestic buildings, where EPC ratings vary greatly among different building types and usages. However, the data that is available based on the limited sample of existing non-domestic EPCs shows that 65% of non-domestic buildings with EPCs are currently at level D or above.” On the face of things this is quite encouraging particularly as if the government had stuck with the C requirement that would have been just 13% of UK dwellings. I will provide some further examples of the benefits of Solar PV on EPC ratings later.

27. Energy Efficiency Rating Bands, 1996 and 2010, performance by tenure • However what this 51% does not incorporate is the percentage of property that is currently E rated that would become D rated by virtue of having Solar PV installed • As an example a 4-bedroomed detached property with double glazing but no loft insulation currently rated at 46 Middle E rating with the addition of a 2 kWpSolar PV would have an improved rating of 57 two SAP points into D rating

28. A further consideration • A further important consideration is that the government figure of 51% of qualifying properties is based on data for properties that have had an EPC undertaken • This currently stands at just under 7m and comprises almost exclusively of properties which have been bought and sold or rented in the past 5 years • However there are an estimated 26.7m properties in the UK of which approximately 15m are Owner Occupied

29. Properties So what of those properties that are without an EPC? English Housing Survey Headline Report 2010–11 The English Housing Survey provides us with valuable data as the energy efficiency of these properties and provides very specific figures on the factors that allow us to identify whether properties are likely to have the potential for D rating

30. Boiler types, 1996–2010 Source: English House Condition Survey, 1996–2007; English Housing Survey 2008 onwards, dwelling sample

31. Insulation measures, 1996–2010 Source: English House Condition Survey, 1996–2007; English Housing Survey 2008 onwards, dwelling sample

32. Statistical Release: Experimental Statistics

33. Levels of cavity wall and loft insulation Home in the UK with cavity wall insulation and lost insulation: April 2001 to January 2012 (000) • The number of properties with cavity wall insulation increased by 6% between the start of January 2011 and January 2012 • The number of properties with loft insulation of 125mm or more increased by 9% between the start of January 2011 and January 2012 What these figures identify is that the housing stock in the UK is at an advance stage of being improved and that if EPCs were to be undertaken on every single property a significant majority would have D rating as a minimum

34. For discussion I believe that the typical customer who is considering a Solar PV install, even aside from the statistics or if you are considering Solar PV , is very likely to have already had: • Double glazing installed • Had their loft insulated • Had their cavity walls filled • Have a condensing boiler with the latest control requirements Even with two out of these four measures present there is a very good likelihood that the property is question will either be currently D rated or close enough to D for the installation of Solar PV to make D a certainty

35. How will this work in practice? – Example 1 • Property built very early 1900s • Virtually detached – losing heat from all four walls • Solid Walls – no insulation • No Loft Insulation • Just 40% of the windows double glazed • 50% low energy light bulbs • A non-condensing boiler with TRVs but no Room Stat

36. How will this work in practice? – Example 1 This property is clearly well below D rating but what will the effect of installing Solar PV have? 2kW Solar PV would take rating to . . . 2.5kW . . . 4kW . . . 3kW . . .

37. How will this work in practice? – Example 1 But what if the maximum install on this roof was 2 kWp, its not a huge roof or maybe the customer can only afford a 2 kW system? We are now back to this scenario We need to achieve 7 SAP points to reach 55 D rating

38. How will this work in practice? – Example 1 This particular property didn’t have a Room Stat – this would generally be quite easy to fit using a wireless model but this again only adds a single SAP point – taking us to 50 We could grab one of those points by upping the level of LE bulbs from 50% to 100% but this still leaves us short

39. How will this work in practice? – Example 1 However the most obvious and certainly the most cost effective measure to achieve a real uplift in the SAP rating is loft insulation; the addition of 270–300mm of insulation would have the following effect • The loft insulation alone has added 8 SAP points • D has been achieved and the install can proceed • That type of uplift from Loft Insulation is fairly typical but the increase tends to be greater on larger properties

40. How will this work in practice? – Example 2 • Property built late 1960s early 1970s • Semi-detached still losing heat from 3 walls • Cavity walls – unfilled • 150mm loft insulation • Fully double glazed but installed before 2002 • 16% low energy light bulbs • Gas-fired back boiler

41. How will this work in practice? – Example 2 This property is clearly well below D rating but what will the effect of installing Solar PV have? 2kW Solar PV would take rating to . . . 4kW . . .

42. How will this work in practice? – Example 3 • Built late 1800s • Mid-terraced losing heat from front and rear walls only • Solid brick – no insulation • 300mm loft insulation • Fully double glazed but installed after 2002 • 88% low energy light bulbs • Older type combination boiler with Room Stat

43. Examples – conclusions • The examples further reinforce that where a relatively high proportion of properties currently have a D rating and even in cases where it is below D – it can be relatively straightforward to achieve D based largely on insulation or other low cost measures • Loft insulation can be relied upon to add 6–10 SAP points with cavity wall insulation adding similar amounts

44. Table of SAP improvements

45. Benefits of Solar PV on an EPC

46. Danger signs Clearly some properties will have significantly lower rating and may well have limited opportunities for improvement So what are the danger signs in a property? • Solid Brick properties can pose a problem as solid wall insulation is not a viable option • Larger properties 200 sq m+ and detached will be at a disadvantage as they are losing heat from larger areas of wall • The obvious absence of double glazing or loft insulation • Properties with a high number of open fires • Properties with no gas supply – if the property is using oil, LPG, coal , logs or wood pellets and, too a lesser degree, electricity

47. Obtaining an EPC – how will this work? From our base in Bromley, Kent, we operate nationally utilising our own panel of assessors which currently stands at 750. This is a relatively small number in terms of the total number of registered assessors but the panel has grown organically and each panel members has: • Completed 2,000+ EPCs • Completed an in depth application form • Undertaken a telephone interview with us • Signed our Code of Conduct • Signed a Non-Disclosure Agreement to protect both you and your customers If you decide to use us as your EPC provider we would require you to register for our online CRM system this will allow you to immediately start placing EPC orders

48. Account Registration You can have more than one registered user for a particular account so your order can be placed by different staff members, different offices or could also be placed directly by your surveyors or salespeople

49. Orders • The order needs the customer’s address and contact details and also your figure for the anticipated kW output of the proposed install (this can be added later if needed) • The customer’s preferred appointment date and time is also required to ensure that the panel members that accept the job can meet this requirement • We confirm receipt of the order and contact the customer within 2hours to arrange an appointment • In the absence of a preferred appointment time we will aim for a next day appointment wherever possible

50. EPC Survey • The EPC survey is undertaken and on the same day two draft EPCs are produced – one without Solar PV and one with – based on your figures. These are available to download in order for you to advise your client if any additional works are required • The Solar PV installation proceeds and upon completion of the works you simply upload a copy of the MCS certificate onto the system – this will trigger the issue of the final EPC to download and submit with the FiTapplication