EPC madness: Are EPCRR judgements failing?

EPC madness: Are EPCRR judgements failing?

0:01 AM, 3rd October 2024, About 2 weeks ago 17

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I want to be environmentally conscious (who doesn’t?) and improve the legacy of both property and planet. I also want to be a good landlord (who doesn’t?) and enhance my tenants’ living conditions and cash flow.

But when the EPCRR (Recommendation Report) suggests that I should be spending £4,000 to £14,000 on “internal or external wall insulation” in order to afford my tenant a saving of £72 over 3 years(!), then something is not right in this process.

Put it another way, this renders the tenant a potential saving of 0.514% of their projected 3 year utility expenditure. How on earth can this be considered a justifiable expense to the landlord?

It is beyond bonkers or am I mistaken?

Surely the carbon footprint of £14k’s worth of construction materials, labour and transport through slow-moving London traffic is not sufficient to offset the measly saving on my tenant’s heating!?

This spurious item was Recommendation 2 (of 3 in total), made on one of my more recent EPCRRs.

Surveyed in early 2018, it is safe to say that there will now have been some significant changes in the estimated costings for installation particularly as the construction sector gets it’s inevitable ‘EPC-improvements! bandwagon on the road. Watch it happen!

The fallacy of EPCs and their shambolic guidance for property improvements in the PRS is only further exposed when Recommendation 3 on the same 2018 report [“Installation of Low Energy Light Bulbs”] can be achieved at an indicative cost of £15 yet creating a comparatively high(!) yield of saving for the tenant at a princely sum of £45 (again, across 3 years).

An easy win, which I’ll take – thank you very much – but will only expect it to last as long as the tenants remember to replace low-wattage bulbs for the same.

Don’t even get me started on Recommendation 1!

Suffice to say that, even if all 3 Recommendations for this property were met with bells on, the proposed £17,015 of initial expenditure would only save this particular tenant £366 across 3 years (or a 2.151% saving); and would help the property stagger from a mid-D to a very low-C rating, keeping the property at risk from future EPC hikes – and in no way really improving my tenant’s lifestyle.

Am I simply not seeing some grander vision of eco-credibility & tenant comfort?

I’d be interested to hear Property118’s readers’ thoughts.

PS: my other 4 properties – as well as my commercial property – all received equally spurious Recommendation Reports.

Thanks,

Alex


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Cider Drinker

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7:45 AM, 3rd October 2024, About 2 weeks ago

The grander vision that you seek is net migration.

Energy suppliers struggled to ‘keep the lights on’ last winter. Rather than tackle mass migration, Labour plan to build 1.5 million more homes. Each and every one will need power and Labour are not planning for more nuclear power stations over the next 5 years. There’ll be no additional gas powered power stations and GB Energy is unlikely to be delivering green energy in time.

Why is this? Why won’t they tackle net migration?

Firstly, politicians are scared of their own shadows. They fear being labelled a racists.

Secondly, governments worldwide are always striving for growth. Pretty much like a Ponzi Scheme depends on growth to keep the plates spinning. And, of course, more people means more customers for the media, retailers and bigger profits for their shareholders. Let’s just ignore increased crime and civil unrest, the housing crisis, the massive increase in the benefits bill and the wasted £billions on fighting legal challenges. The government just prints more money, right?

Peter Collard

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10:21 AM, 3rd October 2024, About 2 weeks ago

Adding to the power requirements are all those EVs. My basic Model 3 sucks up the entire capacity of 7 houses when I'm at the supercharger.

Geoff

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10:30 AM, 3rd October 2024, About 2 weeks ago

For balance -
1) the EPC provides “recommendations”. There is the potential for the recommendations to be implemented as part, other larger, improvements that might be considered in the years ahead.
2) Would you prefer the EPC to provide no recommendations?
3) The tenant is unlikely to replace an LED lightbulb with a tungsten filament bulb when the tungsten filament bulbs are no longer on sale,

Ectoplasm

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12:14 PM, 3rd October 2024, About 2 weeks ago

Agreed - the EPC report is an outdated, blunt instrument, poorly designed and totally lacking any allowance for common sense or surveyor discretion.

If we understand that the principle justifications for the EPC assessment are:
a) to encourage homeowners and landlords to reduce the carbon footprint of their property(ies); and
b) to protect buyers and tenants from excessive energy bills...
... then the report surely must:
a) take account of the actually annual energy consumption - for example, for the previous year, or an average of the previous 2 or 3 years;
b) give credit points for the proportion of green energy consumption. Some properties may run entirely on supplied green electricity from renewable sources.
c) (controversial suggestion:) encourage both tenants and landlords to improve efficiency. I suggest an option to split all energy bills between them (80/20, 60/40, 50/50, or whatever), so that both are incentivised to make efficiency improvements.

Alex

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14:10 PM, 3rd October 2024, About 2 weeks ago

Reply to the comment left by Geoff at 03/10/2024 - 10:30
True enough - though there really is no arguing that the current EPC model is outdated & lacks any kind of precision.

But, more importantly, there is no allowance for renter autonomy or surveyor discretion...

We have been hearing for some time now that, if the property is from old 'housing stock', then there is a pre-determined ceiling of sorts - beyond which the EPC rating can never really manage to go...

Algorithmically, the surveyor's report will churn out a higher rating for a new build than for an older property - even with comparable u-values & eco-installations in both...simply because it has a build date of [in the example's case] 1908. This auto-bias was confirmed by another surveyor I discussed the EPCs with, a few years ago.

Furthermore, the first example for recommended works that was given in the original post [£14k expenditure for a £72 saving on bills over 3 years] should surely have been quashed - or, at the very least, heavily annotated - by the surveyor: condemned as a computer-based error in logic and clearly an inappropriate use of resources...rather than it then going on to constitute part of an official, publicly available document. I'm sorry, but no matter which way one rubs them up, there simply is no defending those figures.

The proposed system vilifies older properties within the sector - allowing no 'buyer discretion' (surely if one wants to live in an older property then that should be up to the individual!?) & allows politicians et al to continue lambasting landlords - simply for owning/renting out these properties.

Is the idea to remove all older property from the PRS - representing an enormous portion of the UK's housing stock? Given the national mandate to supply more houses - this seems an unlikely & unrealistic goal...

Or [foil cap alert] is this a nepotistic opportunity for the government to promote rampant (cheap) mass construction & EPC-based upgrade projects, with favoured national/overnight-starter firms? ["PPE, anyone?"]..!

Alex

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14:14 PM, 3rd October 2024, About 2 weeks ago

True enough - though there really is no arguing that the current EPC model is outdated & lacks any kind of precision.

But, more importantly, there is no allowance for renter autonomy or surveyor discretion...

We have been hearing for some time now that, if the property is from old 'housing stock', then there is a pre-determined ceiling of sorts - beyond which the EPC rating can never really manage to go...

Algorithmically, the surveyor's report will churn out a higher rating for a new build than for an older property - even with comparable u-values & eco-installations in both...simply because it has a build date of [in the example's case] 1908. This auto-bias was confirmed by another surveyor I discussed the EPCs with, a few years ago.

Furthermore, the first example for recommended works that was given in the original post [£14k expenditure for a £72 saving on bills over 3 years] should surely have been quashed - or, at the very least, heavily annotated - by the surveyor: condemned as a computer-based error in logic and clearly an inappropriate use of resources...rather than it then going on to constitute part of an official, publicly available document. I'm sorry, but no matter which way one rubs them up, there simply is no defending those figures.

The proposed system vilifies older properties within the sector - allowing no 'buyer discretion' (surely if one wants to live in an older property then that should be up to the individual!?) & allows politicians et al to continue lambasting landlords - simply for owning/renting out these properties.

Is the idea to completely remove all older property from the PRS - representing an enormous portion of the UK's housing stock? Given the national mandate to supply more houses - this seems an unlikely & unrealistic goal...

Or [foil cap alert] is this a nepotistic opportunity for the government to promote rampant (cheap) mass construction & EPC-based upgrade projects, with favoured national/overnight-starter firms? ["PPE, anyone?"]..! ...Perish the thought.

Northernpleb

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15:10 PM, 3rd October 2024, About 2 weeks ago

They are never going to build 1.5 million Houses. Major Builders are not going to be Building anything unless the figures stack up.
Unlike Private Landlords Builders are well represented

Reluctant Landlord

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16:39 PM, 3rd October 2024, About 2 weeks ago

I keep hold of a box of low energy lightbulbs.

If a new EPC is needed I go into the property earlier and put in all these bulbs where there are no eco ones already in place. Once done, remove and replace with existing bulbs that the tenant has fitted themselves.

Positive points confirmed on the EPC. Box ticked.

NB all properties are routinely fitted with low energy bulbs pre-tenancy. Tenants either do not replace like for like when then blow or actually don't replace at all.

Reluctant Landlord

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17:01 PM, 3rd October 2024, About 2 weeks ago

Reply to the comment left by Northernpleb at 03/10/2024 - 15:10
agree. No profit, no build. Any 'plan' that says anything different is simply bull.

The construction sector HAS and will continue to lay people off as there is no sign of any change in the status quo. The longer this goes on the more costly any build will be as labour will inevitably have to be imported.

LA's are throwing cash at managing the current accommodation crisis and they actively don't want to be social landlords themselves. Here is a couple of snippets from the latest Housing Plan 2024 - 2029 for one council I have rentals in the area of....

* Where homes acquired are purchased for social rent, they can be part-funded by Homes England grant. With typical grant rates currently in excess of £100,000 per home, this means that the net cost to the council is considerably lower than purchasing homes for TA, which is not eligible for grant funding.
The recommendation would be to acquire up to 10 newbuild homes per annum (based on latent/emerging need), substantially funded by Homes England grant. Such acquisitions would be limited to newbuild homes, with 10-year structural warranties and purchased on a turnkey basis (with almost no commercial risk). If funded by grant, Stamp Duty Land Tax relief can also be applied. This would be for specialist needs and is not intended to be for general social housing purposes.

* With current TA costs averaging £420-£700 per week for a single person (significantly more for families), but with an ability to only claim back 90% of the LHA rate (equalling £90 per week), it will be straightforward to demonstrate that this capital investment will make a substantial improvement to the Council’s revenue outturn position and reduce the financial risk to the Authority

Housing Management
The Council’s position is currently that it does not want to become a long-term social landlord.

The proposal instead is that the Council should make capital interventions to stimulate growth; get new schemes built and seek a partner(s) to take on the ownership and management at appropriate points. It is unlikely that the Council will be able to sell individual sites as/when construction complete, as this is not an attractive proposition for an incoming RP. It is more likely that the Council will be able to sell batches of homes to an RP over time. As a result, there is a likelihood that the Council will need to take interim or medium-term management responsibility after construction completion. For financial modelling purposes, officers will ensure schemes are viable for the Council’s investment on both a notional 5-year deferred disposal, and a long-term development finance model, in the event that it’s not possible to find an RP purchaser. Where long-term ownership is inevitable, officers will also consider opportunities to externalise management responsibility, paid for through rental income, to reduce the obligations on XXXXX Council.

Reluctant Landlord

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17:15 PM, 3rd October 2024, About 2 weeks ago

Reply to the comment left by Northernpleb at 03/10/2024 - 15:10
perhaps not just about being represented. Just awareness from government that if builders say no we are not investing - things just won't get built and nothing happens!

With the PRS the investment by the LL has already been carried out so in that sense it's not so visually obvious.

Time will show though, that as with construction, there is no appetite for the PRS LL to expand - and perhaps moreover (due to impending legislation) more reason to sell?

Even if the current situation stays exactly as is, one thing is for sure - there are going to be less tenants passing stricter referencing and so those who don't meet the full referencing standard will be effectively barred from the private rental market as a whole.

Councils are going to be in utter meltdown.

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