Many years ago I qualified as a domestic energy assessor (DEA), and produced some of the first energy performance certificates (EPCs) for the then compulsory home information packs. When I started to develop my own reporting practices and templates, it seemed obvious to include some information about the EPC in my reports.
Since the introduction of the mandatory RICS Home Survey Standard (Professional Statement), which became effective on 1 March 2021, RICS members and regulated firms have been required to cover commentary on energy matters in all levels of reporting (see section 4.7).
At level 1, if the EPC has not been made available by others then the RICS member should obtain the most recent certificate from the appropriate central registry where practicable. The relevant energy and environmental rating should be reviewed and stated.
This is the case at level 2 as well, when checks should also be made for any obvious discrepancies between the EPC and the subject property and the implications explained to the client. At level 3, requirements for the lower levels again apply, and the RICS member should also advise on the appropriateness of any energy improvements recommended in the EPC.
The requirement at level 1 simply involves restating factual information; however, the requirements for level 2 and 3 reports are more substantial, with guidance given within the home survey standard and report templates. In this article, I want to share some of my thoughts and experience to help other surveyors to meet these requirements in a way that adds value for clients.
In this context, it is worth considering the nature of EPCs and their purpose. The intention is that they provide a homebuyer with a guide to the relative energy efficiency of a property; they are not designed to give a comprehensive, accurate breakdown of the way it will perform, but are instead based on some standard assumptions about the performance of the fabric of the building. EPCs allow a homebuyer to make some form of comparison between properties based on their likely energy use.
In many ways they are not ideal, but given the variable nature of buildings they are perhaps the best that can be offered. The most appropriate comparison is with the ranges given for electric vehicles – we all know they will not actually cover the distances stated in the manufacturer's glossy brochure, but because they are all tested to the same standard we know a Smart will not travel as far as Tesla on one charge, even if the comparative difference might vary depending on how the cars are driven. In much the same way, a buyer should be able to pick up an EPC and know that a property rated A should be cheaper to heat than one rated G.
The Home Survey Standard requires the surveyor to help the client make better use of the broad information and guidance given in the EPC. The first step is then to identify any obvious discrepancies – but this does not mean that the surveyor should aim to audit the DEA.
For example, the surveyor should not attempt to recreate the measurement methodology of a DEA, but they should note whether there is a significant discrepancy between their own measurement of the floor area or that provided by the agent and the one the DEA has provided. An error in floor area calculation can affect the energy rating, but comparing the two measurements is more often useful because it helps to identify whether the EPC has been produced before or after any major alterations or extensions to the property.
The surveyor should always flag up any errors in the DEA's identification of the construction type. Occasionally these are not in fact errors but a result of the limited options available when certifying energy use.
For instance, while most houses represent a small range of standard construction types there are some that do not, such as historic, system builds or unique constructions. A surveyor with specialist knowledge may understand the energy performance of these structures, whereas the software used to produce EPCs does not. Instead, the DEA is obliged to include the property in the closest category available to them. In such cases, the surveyor should use their specialist knowledge and experience to help their client better understand the energy performance of a property.
Another key issue to consider is the insulation in the property. EPCs are often generated using assumptions about the level of insulation, which are made without the full input of a DEA; instead, they are based on factors such as the age and construction type. An inspection carried out by a surveyor will often provide more information about the true level of insulation in a property, and this should be conveyed to the client.
Insulation is also a key factor when considering the level 3 requirements. Retrofitting insulation to a property can be one of the most cost-effective ways to improve the energy efficiency, and this often features among the recommendations made in an EPC. It should be noted that the recommendations with the report are automatically generated, and there is little or no scope for the DEA to amend them. It is therefore vital that the surveyor reviews these recommendations to ensure they are actually suitable for the property.
A classic example is cavity-wall insulation. At some properties this can be a definite benefit, but for many where a level 3 survey is likely to be instructed, it may be completely unsuitable; for example, in early cavity-wall construction where the wall's external face may not be watertight.
It may also be the case that there are defects that would render a recommendation ineffective or even detrimental. Examples may include worn pointing to an exposed wall, or issues with a roof structure that may make it unsuitable for PV panel installation. Where this is the case, the surveyor should always cross-reference relevant sections within the report.
It is also true than many level 3 surveys will be instructed for older or listed buildings where recommendations such as external solid-wall insulation or insulation under a suspended timber floor may be completely inappropriate. Here, it is vital that the surveyor advise not only that the recommendation is inappropriate but also why and detail the potential for harm to the property. Such advice may not take the place of a specialist report on energy efficiency related matters but it could help a landlord client when considering issues such as the minimum energy efficiency standards.
'The surveyor should always flag up any errors in the identification of the construction type'
As with all aspects of surveying, it is crucial that the surveyor has sufficient knowledge to advise their client.
RICS members and regulated firms must be familiar with the RICS Home Survey Standard, products and additional resources.
Prof. Sara Wilkinson FRICS, Dr Gill Armstrong, Dr Kusal Nanayakkara, Mark Willers FRICS, Prof. Jua Cilliers and Dr Robert Fleck 08 December 2023