“Ignore Energy Performance Certificate advice”: new Government policy?

The UK government has reversed its advice on improving the energy performance of buildings in order to increase the uptake of heat pumps. Andrew Warren writes on the Business Green website how the British Energy Efficiency Federation, of which he is Chairman, is questioning the analysis that led to the change in consumer advice. What are your views?

Installing heat pumps without proper regard for fabric improvement will lead to problems in the future

The Department of Energy Security and Net Zero (DESNZ) is now deliberately encouraging householders to ignore all the recommendations included in a home’s Energy Performance Certificate (EPC) .

Such recommendations are intended to show the most cost effective ways in which the energy efficiency of a home can be improved. Well over half of the homes in Britain already have a current EPC,  required whenever occupancy alters, either via sales or new leases.

The advice tendered by the specialist EPC assessors concentrates upon improving the energy performance of the  building itself, in order to reduce fuel bills that have doubled in real terms over the past three years. To date, no EPC assessor in the residential sector has ever recommended that a householder install a heat pump in order to reduce fuel bills.

Last month, DESNZ issued an announcement. Unusually, it contained no ministerial imprimatur. The announcement  permits  beneficiaries of a subsidy worth £7,500 of taxpayers’ money to install a heat pump – the Boiler Upgrade Scheme – to ignore previous requirements to install minimum standards of loft and cavity wall insulation building fabric recommendations included within that home’s Energy Performance Certificate .

Members  of the British Energy Efficiency Federation – associations concerned with all aspects of saving fuel – are querying whether the government has any quantitative information upon which to base such a reversal on established policy priority. This priority has long emphasised that energy improvements to buildings must concentrate upon the “fabric first”.

Members are even more appalled by the revelations contained within the  National Audit Office (NAO) report on heat pump installations, published the following day on March 15, concerning the key barriers to progressing  government policy on residential heat pumps.

This NAO Report contains a section entitled ‘monitoring progress against key barriers’. This section specifically states that “DESNZ does not have all the information it needs on heat pump installations to identify key barriers to uptake. DESNZ told us that it builds much of its understanding of the key barriers to installing heat pumps through commissioned research, industry insight and qualitative information”.

But there is significantly no reference whatsoever to any quantitative research to justify  such a complete U-turn.

And when it comes to qualitative information, this unexpected response follows a public consultation held by DESNZ in 2023. Analysis of views submitted reveals that over 75 per cent  of respondents actually supported retaining existing requirements on  minimum insulation building fabric requirements .

The NAO’s report also states that “DESNZ plans to increase demand for heat pumps through a mix of grants and regulations.”

It specifies these as measures to reduce the installation cost to consumers of heat pumps, including increasing the value of the Boiler Upgrade Scheme grant; and introducing new regulations on housebuilders (for which the Department for Levelling Up, Housing and Communities, DLUHC, is responsible) and boiler manufacturers.

It would appear that the NAO had not been informed about the likelihood, let alone confirmation, of DESNZ’s perverse decision to ignore Energy Performance Certificate recommendations. It is a decision which undermines a key measure of building energy performance that has been relied on for the past 17 years.

What is clear is that, throughout the construction industry,  there is now widespread concern about the consequences of heat pumps being installed without proper regard for consequent fabric improvements. This is simply storing up problems for the future. Every responsible heat pump manufacturer has always appreciated this concomitant requirement.

It is noticeable that the loudest welcome for this policy reversal has been from the “purveyors of pollution” themselves: the representatives of companies anxious to sell more, not less, kilowatt hours of electricity.

Last year DESNZ commissioned detailed heat trial studies into electrification. These examined consumer satisfaction with heat pumps following installation. They also assessed the actual – as opposed to theoretical – coefficients of performance of such pumps installed under the Boiler Upgrade Scheme.

The results of these studies were completed some time ago. Again, it seems that these details were not shared with the NAO. These have still not been formally published. They need to be, if only to reassure doubters that the civil servants’ confidence in heat pumps’ performance is completely justified.

As does a complete reassessment of the problems being created by the short term panic of junior officials, concerned by the slow start to the roll out of heat pumps. A second U-turn is now mandatory.