Energy Performance Certificates and Listed Buildings

Energy Performance Certificates are documents, which tell you how energy efficient a building is and gives it a rating from A to G. It gives an indication as to how costly it will be to heat and light a property and what the carbon dioxide emissions are likely to be.

There is a requirement for all let residential properties to have a minimum EPC rating of E unless there is an applicable exemption.

From January 2013 there has been a qualified exemption for listed buildings so that they are not generally required to have an EPC when sold or let. The exemption is qualified stating “Insofar as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance”. This means that if such works would unacceptably alter the building’s character or appearance then a listed building would qualify for an exemption.

The energy efficiency of an older building can be improved in a number of ways and they could have a very minimal impact on the character and appearance of a building e.g. changing to a more efficient boiler. Listed buildings can vary considerably in the extent that they can accommodate change and the guidance on this suggests that “building owners will need to take a view as to whether this will be the case for their buildings” and “If there is any doubt as to whether works would unacceptably alter the character or appearance of a building, building owners may wish to seek the advice of their local authority’s conservation office”.

However, with the rising costs of living and keeping warm should there be a moral obligation on landlords to ensure that their properties are maintained to be as energy efficient as possible? Not to mention the push to meet our carbon net zero target by 2050?  It is more than likely that listed buildings will be required to obtain EPCs and comply with energy efficiency legislation in the future given the fact the Government has committed to review EPC recommendations for listed buildings to make them more suitable to older properties.as part of its EPC Action Plan published in September 2020.

Below is a good example of a landlord who has decided not to rely on exemptions for their listed buildings

Case Study

The Clovelly Estate is located in Devon and is managed by The Honourable John Rous. The estate includes the harbour village of Clovelly, which is known as one of the prettiest villages in Devon. The village is a working fishing village that dates back over 400 years and there are no holiday homes allowed. People wishing to live in Clovelly are required to apply and residents are encouraged to get involved in the many community groups that span village life.

The estate considered that the EPC rating is a necessity in a competitive market for attracting tenants, whether or not a building is listed. The idea was to improve warmth and comfort for tenants and to reduce heating bills. The estate has undertaken a retrofit programme to improve the EPC rating of their listed buildings to at least band E.

Due to the heritage of the village they chose to start with measures that least affect the historic fabric of the buildings. The key areas for improvements were roof insulation, draught exclusion, secondary glazing and high-specification night storage heaters.

With regard to the loft insulation, key areas of concern were avoiding bust pipes and condensation. As such all pipes were lagged ensuring every inch was covered and all joints were taped.

Many bedrooms in the village have sloping ceilings with no more than a sheet of plasterboard between the room and the space between the rafters. It was decided that they should add 75mm polyurethane insulation board onto the sloping ceilings followed by plaster board and then to re-plaster and re-paint. While this technique is labour-intensive and costly, the heat savings are large.

Draught proofing was also essential but whilst also maintaining ventilation to avoid damp. Floor insulation about cellars, tank lagging, blocking up unused fireplaces and external wall insulation methods were also used.

Tenants have reported that their fuel bills had reduced and that their experiences of living in the houses had completely changed.

This project has set a precedent in the retrofitting world, proving that listed buildings can be sympathetically brought up to modern standards of insulation. The Clovelly Estate were winners of the Landlord of the Year award at the Landlord/Housing Association Award in 2019.