Updating post from Reddit.
Was just reading through this thread:
https://www.reddit.com/r/uklandlords/comments/1lf6pi4/the_epc_system_is_entirely_rigged_and_the_uk/
There are a lot of inaccuracies; I was going to reply to all the points but I thought it would be easier to do it this way. I'll answer as fully as I can.
edit: I thought I would add a few points first to give clarity:
DEAs do not rate the property. This is done automatically by the software we use. All we do is enter the data.
The basic rule we must stick to is: If it is to be included in the data, we must be able to provide photographic evidence. If it can't be photographed (and measured if measurable), it can't be included.
We are subject to audits by our accreditation. If we fail an audit, the penalty is anything from having to amend the EPC and re-lodge it (at our own expense) to being shut down permanently.
The required C rating is only proposed: it is not cut and dried. Nobody knows what is going to happen, so at this stage it is best not to make adjustments in preparation.
As an EPC assessor..how money pound signs did you see when you 1st heard of the government's plans to overhaul EPC ratings and the need for everyone to get assessed again lol
where did you see this? the new rating system coming in place will be overlapping with the existing one until expiration of current EPC ratings
Did you not read the mees consultation? Compliance would only be to the new EPC metrics so properties would need to be reassessed.
can you point me at exactly where it says this? all sources I can find state the opposite.
I just operate under the current regulations. Experience tells my that there is a large difference between proposals and reality.
How are homeowners supposed to prove that insulation is there if it is not easily visible? I had to cut a hole into the eaves of my house and send a photo demonstrating the insulation after the assessor had just assumed that there was none…
An assessor never assumes there is no insulation - the assumption is that the fabric is as it should have been at the time of construction or that it's been subsequently improved. The 'as-built' assumption is based on the expected building regulations requirement for that building part.
The best documentary evidence a homeowner can provide would be a signed schedule of works from a building doing works, dates before and after photos showing measured thicknesses of insulation over the whole area being improved, planning permission (where applicable).
So in my specific situation, a previous owner did the work and this was included in a previous EPC. When I had it redone, that then wasn’t included - why is there allowed to be that discrepancy?
The insulation could not be measured and photographed.
It could if you climbed in the loft with a tape measure
We always do that. The poster stated it was not easily visible.
It was possible he could have done it, there was some exposed insulation. He chose not to and I challenged it when the report came through
OK well I can't comment on that because I wasn't there, and the DEA is not here to present his side of the story. All I can tell you is, if the insulation is there, we are supposed to measure it, photograph it, and include it in the assessment.
In the case of wall insulation, exposing the insulation by removing an electricity outlet is acceptable, but I think most DEAs would need to see more than one in order to input a large area.
You might also have to then cut it again every renewal because a new assessor won’t accept old proof. The system as far as I’m aware won’t accept that once the insulation is in, people generally don’t then take it out. Madness.
What would you suggest in order for it not to be madness?
I would suggest that surveying a property and providing photos of what/how the building is constructed then that is logged for future assessments. Provided the construction hasn’t been altered. Ripping a hole in the ceiling to prove it has insulation every 10 years seems dumb. Putting in access panels just to prove it is still there (what I was recommended to do) also seems stupid.
The problem is photos. They prove nothing: they could be photos of a different property, or they could be edited. If you could use photos, there would be no need for an assessor - and the EPC itself would be valueless.
You don't have to rip a hole in the ceiling; you can install an inspection hatch. Most properties have them.
I meant more to have it evidenced via photo. If it is clearly photographed and is accepted for one epc, then why is that then not logged going forward. It’s not like I will remove my plastered ceiling, walls, floors etc, to take out the Celotex (or whatever insulation).
EPCs are valid for 10 years. When an EPC is renewed, anything could have happened in those 10 years. Essentially it is a snapshot of the property on the day of the assessment. If we take into consideration something that was installed 10 years prior, then it would not be an assessment, i.e. it would not be a snapshot of the current state of the property.
You say it's not like you will remove your "plastered ceiling, walls, floors etc, to take out the Celotex", but many people do just that: renovations, alterations, conversions, refurbishments - they happen all the time, especially within a 10-year period.
What about where you have a loft room and the roof insulation is between the vaulted plasterboarded ceiling and the underside of the roof??
The rules do not vary. In order to include insulation, there must be evidence of it. If we can't see it, photograph it and measure it, then it won't be included - although documentary evidence of professional installation is acceptable.
That’s bonkers. Could have been done 20 years ago under previous ownership, pre-dating the legislation. So actually you DO have to rip a hole in the ceiling.
If you want the insulation to be included, it must be exposed. You could install a couple of inspection panels.
Still crazy
If it's not easily accessible the simple is answer you can't. DEAs cannot accept photos as evidence. If we can't photograph it ourselves and measure it, it doesn't get included.
I didn't know it was that bad, crazy.
If you've had the insulation installed professionally and you have documentary evidence, a DEA will accept that.
I had that issue. Self installed insulation over 500mm, fully accessible but the assessor classed it as "no insulation" and gave me a D !
Can you explain exactly what happened? We don't care who fitted it; if we can photograph it and measure it, it is included.
BTW the assessor did not 'give you a D'. The rating is calculated automatically.
Yes they can
So what are the newer assessment changes, why when the recommended actions are addressed do scores go down, and what are the top 5 aspects to address for flats to get some quick win score increases?
Would be a starting point. Thanks for offering 👍
RdSAP 10 was introduced on June 15. For DEAs, it requires a lot more time on site because more data is required - not least thefact that we have to measure every window and state its type of construction and compass orientation.
That is a problem for DEAs; the only way it will affect you is that most DEAs are raising their prices because of the time spent on site.
There aren't really any top aspects - either for flats or houses. The biggest aspect I have noticed for flats is the actual size: even with electric heating and little-or-no insulation, a very small flat can achieve a C.
Should i plan to upgrade to EPC C now or wait untill new changes come?
Don't do it. The changes are only planned: they are not set in stone, so any changes you make could be money down the drain. Put it this way: my properties are not C rated and I'm not doing anything about it.
On the other hand, if they become a mandate, suddenly the cost of getting this upgrade skyrockets because of shortage of labour.
I'd say do such things when demand is low (others aren't doing).
That's a big 'if' in my opinion.
If a flat is EPC D, and the actions to get to C are a freehold responsibility. What can a landlord do? Is there an exception.
There's a third-party consent exemption
Thankfully all my properties are C and the EPCs have a long life left on them. So I’m viewing all this as somewhat of an outsider but may one day get roped in.
From my perspective this is clearly nothing but a scam.
‘Can’t verify it if we can’t see it’ what fools!
Thankfully from the EPC guys I’ve met and the system to qualifying I wager it wouldn’t take much effort to find an EPC guy who will give you any grade you’re willing to pay for.
It’s just a shame as scams like this effect the rule of law; no ones taking all this new regulations seriously anymore.
I think the government is barking up the wrong tree with this EPC rubbish. It's a huge amount of money, a lot of effort and maintenance.....for very little green savings.
It'll probably be cheaper and better long term keeping the money in the economy and building an additional nuclear reactor if they're that concerned about green energy. All this money wasted when it could have been used on something with an actual proven track record of working.
" 'Can’t verify it if we can’t see it’ what fools!"
What criteria would you suggest are acceptable for inclusion?
"Thankfully from the EPC guys I’ve met and the system to qualifying I wager it wouldn’t take much effort to find an EPC guy who will give you any grade you’re willing to pay for."
I find that a strange attitude to encounter from someone who is clearly against scams. Regardless, EPC assessments are frequently audited by the accreditation. Any DEA who is entering fraudulent data will be found out and penalised accordingly.
And to clarify: DEAs do not 'give grades': they only enter data. Grades are generated automatically by the RdSAP software.
With all due respect to becoming an assessor, any tom, dick and Harry can do it. It's assumption based which means that the error margins are unconstrained. I lived in a D rated property but following the most chilling of winters I decided to do my own assessment. I worked at an engineering consultancy and surveyed the property with pointcloud scans and ran a full heat loss simulation on a model which had full material lists and U/K values. The results were staggering. The D rating was complete rubbish. The heatless calcs based on survey and materials would've have actually put the house as a G rating. Upon further investigation, I discovered that the assessor was the landlords friend, so I played the same game. My friends at said consultancy were both chartered architect and Engineers, both were Passivhaus certified which came in handy when we took him to court.
Are you expecting every domestic dwelling in the UK to have a full set of U-values calculated? Drilling every exposed element to determine all the construction materials to confirm whether that U-value matches the prevailing Building Regulations of the time of construction?
No, but when there is a clearly evident physical disparity you should be concerned and do your own investigations instead of relying on a guesstimate
"No, but when there is a clearly evident physical disparity you should be concerned and do your own investigations instead of relying on a guesstimate"
The purpose of the thread is to ask a DEA questions - especially relating to landlord issues. You clearly have your opinions about the way assessments should be done; I'm here to answer questions about how they actually are done.
There are finite construction and insulation options that assessors can select, and together, these pick an underlying U-value from the methodology. Assessors cannot deviate from the methodology, apart from inputting U-values calculated by a suitably qualified person. You have had this done in your scenario, but RdSAP is a non-invasive inspection methodology and assessors simply aren't insured to be drilling into people's houses.
So you're effectively saying it's all guesswork. Some scheme that is.
No, your own preconceptions are saying it's guesswork
You stated "non-invasive" which means a guess
Ok, in all your investigations, did you take the boiler off the wall and send it for testing?
Why send it for testing when you can commission test on site and use AFUE and SCOP analysis alongside thermographic method?
So you did that then, right? Wouldn't just assume a value
So what question would you like to ask?
Not sure what point you are making. You are describing an exceptional circumstance in which a DEA allegedly acted fraudulently, which seems to me to be an exception that proves the rule.
Based on the experience of that tenancy and landlord he knew no bounds.
But it's an exception. This is an AMA on EPCs.
I still stand by my comment that it is assumption based and therefore highly inaccurate and open to manipulation
I'm not here to discuss the merits of the process (or lack of them); that is a discussion for another thread. I started the thread to clarify inaccuracies and misconceptions, so that my fellow landlords can be fully prepared for assessments and present their properties in a manner that will achieve the optimum rating.