Disappointing EPC on new build residential

Disappointing EPC on new build residential

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PurpleFox

Original Poster:

447 posts

92 months

Saturday 25th February 2023
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I didn't want to de-rail the other EPC thread that has recently been started but wondered if there were any EPC assessors or experts that can advise....

Recently created some small studio flats. The EPC's were received last week and I am pretty gutted to be honest......the ratings were all 'C' and 'D'. I have gone all out on insulation (75mm celotex on all walls), all new double glazing, 95% efficient mechanical heat recovery units, A-rated Stiebel Eltron instantaneous water heaters, A-rated Herschel heater panels etc etc.

The insulation was way over the architects spec and the SAP calcs were all done early on to check that they would pass etc.




I seem to have been penalised for using electric heating and electric water heaters. There was little alternative, the units are too small for gas boilers and rads. Everything else scores good.


The chap who did the work on the SAP calcs and EPC's says that had I installed an oil boiler (or gas), I would have got a far better score. Even a new heat pump can score worse than some boilers! It just seems like a load of BS when electric is 100% efficient and can be fully renewable.


Question is - if the property is at it's maximum potential (according to the chart on the EPC) how could I get this to a C and would it still be rentable when / if the rules change or would there be an exemption because it's already at it's maximum potential?

Thanks.




AlexC1981

5,056 posts

224 months

Saturday 25th February 2023
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That's interesting. I had my 1989 flat tested in May last year and it scored 70-C, however I thought that later in the year the test criteria was going to be adjusted to make electric more favourable.



It looks like my heating and hot water coming from off-peak electric helped a lot with the score as everything else is worse than yours apart from lighting which scores the same.

Edited by AlexC1981 on Saturday 25th February 18:19

PurpleFox

Original Poster:

447 posts

92 months

Saturday 25th February 2023
quotequote all
It just doesn't make sense. Your elec storage heaters might save money by using off peak electricity but I thought it was about 'Energy Performance' not cost!

I have victoriana terraces with a 'C' and really all they have is loft insulation, double glazing and a decent boiler. Still cold and drafty as hell.


PurpleFox

Original Poster:

447 posts

92 months

Saturday 25th February 2023
quotequote all
AlexC1981 said:
That's interesting. I had my 1989 flat tested in May last year and it scored 70-C, however I thought that later in the year the test criteria was going to be adjusted to make electric more favourable.



It looks like my heating and hot water coming from off-peak electric helped a lot with the score as everything else is worse than yours apart from lighting which scores the same.

Edited by AlexC1981 on Saturday 25th February 18:19
Crazy that an electric immersion heater gets 'average' because its off peak yet instantaneous heater with zero losses gets poor. Its nuts.

Equus

16,980 posts

108 months

Saturday 25th February 2023
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Gas would have given you a better score on the energy efficiency rating (ie. running costs), because 'raw' electricity - as opposed to feeding it into a heat pump which then sts out heat - is bloody expensive. As you say, even with a heat pump can be as expensive to run as a modern gas boiler.

There is a separate score on environmental impact (carbon footprint) where electricity performs rather better (and where a heat pump will beat a fossil fuel boiler hands down), so you may be doing less harm to teh planet even if you're bancrupting your tenants.

If it's any consolation, new houses built to current Building Regulations energy efficientcy standards (which are massively better than we were building even 20 years ago) and with heat pump heating systems will still typically only score a B on energy efficiency. The system has to be able to rate anything from a 19th century house with solid brick walls, through to a zero-carbon PassivHaus, and it's only when you're getting close to the latter that you'll score an A. A D-rating isn't that bad on an older property.

You would get an exemption if the rules ever changed to require a C rating on rental properties.

If the units are genuinely too small for gas boilers and rads (bearing in mind you can run a CH system off a combi boiler without a cylinder), then I'd be worried about being prosecuted under the Housing Act (which stipulates minimum room sizes and occupancy levels for rental housing) long before I'd worry about the EPC.


smokey mow

1,117 posts

207 months

Saturday 25th February 2023
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It’s difficult to comment without seeing the full SAP calculation that produced the EPC but at a guess I would assume that thermal bridges were all default rather than calculated. You could have done better with the roof insulation speciation and the lack of any renewables (solar PV or thermal) will hurt you hard when using electric heating.

AlexC1981

5,056 posts

224 months

Saturday 25th February 2023
quotequote all
PurpleFox said:
Crazy that an electric immersion heater gets 'average' because its off peak yet instantaneous heater with zero losses gets poor. Its nuts.
I guess it is scored better as it helps even out peaks and troughs in the national grid and so saves electricity by reducing the overall maximum generation capacity needed.

Raj28

135 posts

138 months

Saturday 25th February 2023
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With the talk of banning gas boilers though, surely the EPC calcs need to be adjusted to take this into account?

PurpleFox

Original Poster:

447 posts

92 months

Saturday 25th February 2023
quotequote all
smokey mow said:
It’s difficult to comment without seeing the full SAP calculation that produced the EPC but at a guess I would assume that thermal bridges were all default rather than calculated. You could have done better with the roof insulation speciation and the lack of any renewables (solar PV or thermal) will hurt you hard when using electric heating.
Perhaps they did take the defaults / way option. Example, the EPC above was from a unit on the 1st floor, there is a heated space below, and a heated flat above. With a suspended ceiling filled with insulation (that wasn't even needed but was added mainly for sound insulation as it was easy to do at the time), 12 inches of concrete, then a parquet floor overlayed with acoustic flooring and a floor covering.

So no idea how 'roof' is 'good' when the actual roof is several floors above having no bearing on that particular flat.

PurpleFox

Original Poster:

447 posts

92 months

Saturday 25th February 2023
quotequote all
Equus said:
Gas would have given you a better score on the energy efficiency rating (ie. running costs), because 'raw' electricity - as opposed to feeding it into a heat pump which then sts out heat - is bloody expensive. As you say, even with a heat pump can be as expensive to run as a modern gas boiler.

There is a separate score on environmental impact (carbon footprint) where electricity performs rather better (and where a heat pump will beat a fossil fuel boiler hands down), so you may be doing less harm to teh planet even if you're bancrupting your tenants.

If it's any consolation, new houses built to current Building Regulations energy efficientcy standards (which are massively better than we were building even 20 years ago) and with heat pump heating systems will still typically only score a B on energy efficiency. The system has to be able to rate anything from a 19th century house with solid brick walls, through to a zero-carbon PassivHaus, and it's only when you're getting close to the latter that you'll score an A. A D-rating isn't that bad on an older property.

You would get an exemption if the rules ever changed to require a C rating on rental properties.

If the units are genuinely too small for gas boilers and rads (bearing in mind you can run a CH system off a combi boiler without a cylinder), then I'd be worried about being prosecuted under the Housing Act (which stipulates minimum room sizes and occupancy levels for rental housing) long before I'd worry about the EPC.
That is some consolation, I wrongly assumed all new builds would be aiming for an A.

How come I would get an exemption then? Is it because its already reached its potential?


The studios are approx 30m2 which is small obviously and smaller than I would have liked but had to work with the existing building. AFAIK space standards will not be an issue. If ever there was an ideal setting for electric, then it is a small, well insulated studio flat. I am mindful that I may end up renting some as all bills inclusive so they have been built accordingly, they should not bankrupt the tenant.

Gas heating isn't just about having the space to hang a boiler, it needs a flue on an outside wall, a condensate connection, blow off, carbon monoxide detector, rads on walls, pipes to the rads, an annual safety check, a gas meter, a significant amount of gas pipework to get the gas to the studios, gas pipe supplying a flat cannot go through another flat etc etc.


The scheme seems crackers when modern equipment which is energy efficient is being penalised in favour of older fossil fuel burning appliances. On the one hand they want to phase out gas boilers yet on the other, fit an air source heat pump and you might not be able to rent your property out when it gets a D rating. If you don't have gas, fit an ancient storage heater!

Perhaps a lot comes down to who does the EPC.....

r3g

3,750 posts

31 months

Sunday 26th February 2023
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The positioning of the pointers on the EPC chart are decided based on the thickness of the brown envelope you hand to the EPC assessor. Clearly your envelope was not thick enough, so now you pay in other ways.

smokey mow

1,117 posts

207 months

Sunday 26th February 2023
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PurpleFox said:
smokey mow said:
So no idea how 'roof' is 'good' when the actual roof is several floors above having no bearing on that particular flat.
Because they probably calculated block average for compliance rather than by individual flats.

It’s a method used to gain compliance for the entire block when some flats might have a good pass whilst others may fail.

smokey mow

1,117 posts

207 months

Sunday 26th February 2023
quotequote all
r3g said:
The positioning of the pointers on the EPC chart are decided based on the thickness of the brown envelope you hand to the EPC assessor. Clearly your envelope was not thick enough, so now you pay in other ways.
One in ten calculations I do is audited at random. If I’m more than 2points different to their calculation then I have to do it again at my cost. So on blocks of housing and flats there’s a very high chance of being audited on more than one of them.

It’s really not worth the hassle for a few £££ and the risk of loosing my registration.

Equus

16,980 posts

108 months

Sunday 26th February 2023
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PurpleFox said:
That is some consolation, I wrongly assumed all new builds would be aiming for an A.

How come I would get an exemption then? Is it because its already reached its potential?
Yes.

You will never, in a month of Sundays, obtain an A (or even a B) rating on that sort of existing property.

PurpleFox said:
The studios are approx 30m2 which is small obviously and smaller than I would have liked but had to work with the existing building. AFAIK space standards will not be an issue.
As a landlord you should be aware of the space/room standards embodied in the Housing Act 1985 and it is your responsibility to ensure that overcrowding does not occur. It also stipulates a minimum of 70ft2 (6.5m2) for the room in which they sleep.

There is a document called the Nationally Described Space Standard, which is optional upon new-builds/conversions at the moment (it's down to whether individual LPA's choose to adopt it), but there have been noises made about making it mandatory for rented accommodation, in which case you're fked: the minimum size for a 1 bed, 1 person studio is 37m2.


Edited by Equus on Sunday 26th February 09:05

NDNDNDND

2,201 posts

190 months

Sunday 26th February 2023
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The EPC cares more about cost to run than absolute efficiency. We encountered a similar problem when installing a heating system into an off-grid rented property. We initially wanted to use modern electric radiators but were quickly told they would be heavily penalised the EPC. We were dismayed to be told we had to install storage heaters, but the Dimplex Quantum HHR (High Heat Retention) came recommended, are favoured by the EPC calculation and our tenants are happy with them.

One thing that is puzzling about your EPC is why it says there's no room for improvement - there should be a list of (often slightly improbable) recommendations for how to improve your rating appended to the certificate.

ETA: out of interest, what instantaneous hot water appliances have you used? That particular house above used a hot water tank with an immersion in it, which took up a lot of space in a small house and didn't work that well - we were looking at instant hot water taps for the kitchen and bathroom sinks but couldn't find a product we had faith in.

Edited by NDNDNDND on Sunday 26th February 08:47

Equus

16,980 posts

108 months

Sunday 26th February 2023
quotequote all
Raj28 said:
With the talk of banning gas boilers though, surely the EPC calcs need to be adjusted to take this into account?
They already have been - a revised SAP calculation process came into force last year.

As noted above, a full SAP calculation/EPC on a new build house gives two separate ratings, one for running cost, the other for environmental impact.

Electricity now scores much better than it did on environmental impact, to reflect the fact that more electricity is being generated by low-carbon/renewable means. But the fact remains that raw electricity, particularly when you are consuming it at peak periods, is bloody expensive for equivalent heat output compared to gas.

One obvious thing that the OP could look at is installing storage heaters, so that the electricity for space heating is off peak. I'm assuming that there isn't space to fit a storage cylinder to allow off-peak immersion heating of the water, otherwise this would be another no-brainer... instantaneous, direct heating of anything by electrical means is murderously expensive.

Another slightly less practicable option might be to do an air leakage test on the properties: at the moment the calculations will be assuming a default maximum figure for this.

Edited by Equus on Sunday 26th February 11:05

springfan62

855 posts

83 months

Sunday 26th February 2023
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The other option is to install a small heat network using a central heat source (gas or ASHP) and meter heat to each flat for billing purposes.

This also reduces the maintenance cost as well, one heat source to maintain and if you are using gas then you only pay one standing charge.