The Next Steps: EPCS and the establishment of the

Green Homes Service: Consultation

Summary of responses

www.communities.gov.uk
community, opportunity, prosperity
The Next Steps: EPCS and the establishment of the
Green Homes Service: Consultation
Summary of responses

July 2009
Department for Communities and Local Government
Communities and Local Government
Eland House
Bressenden Place
London
SW1E 5DU
Telephone: 020 7944 4400
Website: www.communities.gov.uk

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July 2009

Reference Number: 08 EPBD 05540

ISBN: 978-1-4098-0501-4
Contents
Page

Introduction 5

Summary of responses to consultation 6

Conclusion 13

Annex A – List of respondents 14

 Introduction 5

Introduction
On 23 June 2008 the Government published a consultation on the following issues:

• To give the EST access to the information contained in domestic EPCs so that they
can identify F and G rated homes and target them with an offer of advice and help
• To give the Carbon Trust access to the information contained in non-domestic EPCs
• To allow energy assessors to search the register by address as well as by UPRN
• To allow public access to the non-domestic register in order to see whether a
building has an EPC, but not to download or access the EPC.

The consultation asked three questions:

1. What are your views on these proposals?

2. Do you think the safeguards proposed on access to the registers are

sufficient?

3. If you do not think the safeguards are sufficient what are the reasons for
your opinion, and are there other safeguards that you can suggest to meet
your concerns?

The consultation closed on 1 September. This document summarises the responses and
gives the Government’s view.
6 The Next Steps: EPCS and the establishment of the Green Homes Service: Consultation
Summary of responses to consultation
For access, in full
or in part
30
67%
Issues raised in responses
Proposal
To give the EST access
to the information
contained in domestic
EPCs so that they can
identify F and G rated
homes and target them
with an offer of advice
and help
Against access, in No comment
full or in part
6 9
13% 20%
Issues raised
Data should not be passed
on to any third party by
the EST. There is a danger
of homeowners becoming
the target of indiscriminate
advertising. More details are
needed on the proposed
safeguards.
What financial incentives
will be put in place to
help buyers implement
recommendations?
How will EST ensure details
reach the buyer?
Will EST write to tenants or
to landlords? If the former,
will tenants receive multiple
mailings?
It would be helpful for the
EST to publish aggregated
data
Total
45
100%
Comments
The Government agrees.
Data will be supplied to
the EST under the terms
of a Memorandum of
Understanding, and
any breach will lead to
immediate withdrawal of
access. The MoU will spell
out amongst other things
what safeguards are to be
adopted.
A range of incentives are
already in place through
schemes such as Warm Front
and CERT.
This is a matter for the EST.
This is a matter for the
EST. But there will not be
multiple mailings: they will
be controlled by the EST
through a mailing house.
The Government agrees.
The information on the
EPC registers will over time
build up into an invaluable
resource for tracking the
energy efficiency of the
nation’s building stock.
Stakeholders will be invited
to help formulate a strategy
for the use and publication
of this data.

Proposal Issues raised
Information should not
be limited to F and G
properties. Significant
recommendations for energy
efficient measures may be
contained in properties with
C,D and E ratings.
In order to write to all F and
G rated properties, the EST
and CT will need to identify
these properties. Therefore it
appears that the information
cannot be supplied in such
a way as to be anonymous
as mentioned in the
consultation.
If the government is keen
to educate people about
making their F and G rated
properties more energy
efficient, it might be easier,
and certainly pose fewer
data protection concerns, to
run an advertising campaign
in the national media.
EST and CT data handling
processes should be
demonstrably transparent
and both organisations
should put in place systems
for responding to valid
disputes.
Other organisations should
be offered access to the
data.
Summary of responses to consultation 7
Comments
The Government will
consider this in due course as
part of the evaluation of the
Green Homes Service.
EPCs are supplied for
properties, not individuals.
EPCs will make it clear to
consumers that information
will be made available to the
EST.
The Government has
already undertaken a major
advertising campaign, Act on
CO2
The Government agrees.
Data will be supplied to
the EST under the terms
of a Memorandum of
Understanding, and
any breach will lead to
immediate withdrawal of
access.
The Government has no
plans to do so but is willing
to listen to representations.
8 The Next Steps: EPCS and the establishment of the Green Homes Service: Consultation
Proposal
To give the Carbon
Trust access to the
information contained
in non-domestic EPCs
Issues raised
The proposals about how
the Carbon Trust will use
data need to be more
specific.
Data should not be passed
to any third party by the CT.
Other organisations such as
NIFES and ESTA should also
be given access to the data.
It would be helpful for the
Carbon Trust to publish
aggregated data.
Comments
The Government will work
with the Carbon Trust and
stakeholders to develop
more specific proposals for
legislation in the Spring.
The Government agrees.
Data will be supplied to
the CT under the terms
of a Memorandum of
Understanding, and
any breach will lead to
immediate withdrawal of
access
The Government will work
with the Carbon Trust and
stakeholders to develop
more specific proposals for
legislation in the Spring
The Government agrees.
The information on the
EPC registers will over time
build up into an invaluable
resource for tracking the
energy efficiency of the
nation’s building stock.
Stakeholders will be invited
to help formulate a strategy
for the use and publication
of this data.

Proposal Issues raised
To allow energy There are concerns that
assessors to search the assessors will misuse access
register by address as by selling on data since they
well as by UPRN will have access to market
information not available to
others.
Landlords should be given
direct access to the register.
Energy Assessors should
have access to RdSAP. This
would provide assessors with
fuller data than is available
from the EPC alone.
The proposals fall far short
of providing reasonable
access to the data currently
held in the national registers
of EPCs.
Summary of responses to consultation 9
Comments
The Government will work
with accreditation schemes
to ensure such abuses do not
happen. Any assessor found
to have misused access will
immediately be removed
from the register and will no
longer be able to work as an
assessor.
The Government has no
plans to do so.
The Government will
consider this in due course.
The Government is
considering a long-term
strategy for the data held in
EPCs.
10 The Next Steps: EPCS and the establishment of the Green Homes Service: Consultation
Proposal Issues raised
To allow public access There is a danger that the
to the non-domestic public will misunderstand
register in order to see the ratings given on an EPC.
whether a building
has an EPC, but not to
download or access the
EPC
EPCs for schools should be
made available to Dept for
Children, Schools & Families
so schools can be more
energy efficient.
The current proposal is
unworkable, as there is
a duplication of effort by
Landmark. An alternative
approach is that assessors
gain access via the IT systems
already in place within the
accreditation schemes.
Land Registry Data files should
automatically be issued to
HM Land Registry
The consultation The title of the consultation
document was misleading.
Comments
The public will not have
access either to the EPC
or the rating. They will be
able only to see whether
a building has an EPC.
This is designed to avoid
duplication and expense to
sellers and landlords.
The Government will
consider this further.
The Government will work
with the EST on setting up
the relevant structures and
will seek a full evaluation of
the results.
The Government has no
plans to do so.
The title of the consultation
referred to all EPCs, domestic
and non-domestic.
 Summary of responses to consultation 11

Proposal Issues raised Comments

EPCs Local authorities should be
given access to the data
contained in EPCs.
The information on the
EPC registers will over time
build up into an invaluable
resource for tracking the
energy efficiency of the
nation’s building stock.
Stakeholders will be invited
to help formulate a strategy
for the use and publication
of this data.

The Land Registry should The Government has no

be given access to the data plans to do so but is willing
contained in EPCs. This to listen to representations.
would allow a welcome pack
on energy efficiency to be
sent to all new homeowners.

An explicit link should be The Government has no

made to the HHSRS system plans to do so but is willing
to ensure that households to listen to representations
in homes with poor energy and to explore the issues
efficiency were identified. further.

The EPC needs to be There is an ongoing process

improved as a document
of change control and
improvement to the content
and format of EPCs overseen
by two technical steering
groups.

There is insufficient guidance The Government published

on the application of EPCs.
guidance on commercial
EPCs in January; an updated
version was published in the
summer. Guidance can also
be obtained from the CLG
website and from the EPBD
helpline.
12 The Next Steps: EPCS and the establishment of the Green Homes Service: Consultation
Proposal Issues raised
The role of energy assessors
should be expanded to
include the giving of energy
advice based on an EPC.
EPCs should be required for
all lets and not just those of
self-contained dwellings.
Other issues The Government has
made insufficient use of
the expertise of property
experienced individuals in
developing its proposals.
This does a disservice to the
proud traditions of our civil
service.
Householders need clear
guidance on cost effective
improvements and where to
go for trusted qualified trade
persons.
Main focus of the
consultation appears to be
the need for behavioural
change to encourage energy
efficiency in homes. This
needs to be monitored
closely.
There is a need for a greatly
improved scientific and
empirically well founded
knowledge base on buildings
energy use in the UK.
Comments
The Government is working
closely with energy assessors
on the future development
of their role.
The Government has
legislated in terms of its
understanding of the
requirements of the EPBD.
The Government has
developed policy on EPBD
with the assistance of
nine stakeholder groups
comprising a wide range
of interests including
property experienced
individuals, representative
property organisations and
commercial property lawyers.
The Government agrees.
The Government agrees. The
implementation of the GHS
will be evaluated.
Over time the information
contained on the EPC
registers will provide such a
knowledge base.
 Conclusion 13

Conclusion
The Government is grateful to all those who responded to the consultation.

The large majority of respondents supported the proposals for access although a number of
valuable points were made about the need for adequate data protection and protection of
consumers. The Government will consider these carefully in implementing the proposals. In
particular it proposes to take further time to work up detailed proposals for the Carbon Trust
to have access to the non-domestic EPC register, and will not therefore include this proposal in
the current package of legislation. A number of wider issues around access to and use of the
data contained in EPCs were also raised, and the Government will consider these.
14 The Next Steps: EPCS and the establishment of the Green Homes Service: Consultation

Annex A

List of respondents
Companies who have provided feedback for the EST Consultation

1. Association for the Conservation of Energy

2. BCSC
3. British Property Federation
4. Chartered Institution of Building Services Engineers
5. Commission for Architecture and the Built Environment
6. Crosher James
7. Degree Days Direct Ltd
8. Energy Efficiency Partnership for Homes
9. Energy Saving Trust
10. Gleeds
11. Goring Chase Residents Association Ltd
12. Government Contracts
13. Greater London Authority
14. Green Surveys Limited
15. Health and Environmental Action Services
16. Home Energy Conservation Officer
17. Homes Matter
18. Jones Lang LaSalle
19. L’Atelier
20. Local Government Association
21. London Borough of Richmond Upon Thames
22. National Energy Services
23. National Insulation Association
24. National Landlords Association
25. Neighbourhood Services
26. Northgate Public Services
27. NTL World
28. Oil Firing Technical Association
29. RBWM
30. Reading Borough Council
31. Reigate and Banstead Borough Council
32. Royal Institution of Chartered Surveyors
33. Schools Capital Design Team
34. Sheldon Reed Ltd & SR Inspectors
35. Somerset County Council
 Annex A 15

36. South Coast Home Inspectors

37. Stephenson Harwood
38. Surveys Ltd
39. Taylor Wessing
40. The Energy Efficiency Company
41. Trading Standards Institute
42. Tunbridge Wells Borough Council
43. University College London
44. WSP Energy
45. WWF
 ISBN 978-1409805014

ISBN: 978-1-4098-0501-4 9 781409 805014