CIH response to DESNZ consultation on the Home Energy Model methodology for assessing existing dwellings and producing new Energy Performance Certificates metrics

Strongly agree.

a) Quality of assessments and EPCs:

• assessment accuracy

• trust, usability, or consistency in EPCs

• how inputs are communicated to consumers/householders

b) Impact on assessors’ workloads, costs, training, and skills

c) Implementation risks, for example: QA/audit and fraud risk, supply chain readiness and training needs

d) Anything else you feel is relevant.

Housing professionals we have consulted with are generally in favour of the modular approach. However, they have informed us of the following potential challenges that should be considered when the government’s approach is finalised. 

With regards to assessment accuracy:

• There is a possibility that the subjective entry of data by Domestic Energy Assessors (DEAs) has a disproportionate impact on the overall results. For example, different DEAs may use different proportions of dwelling-specific information and simplified inputs for similar homes, which could introduce inconsistencies. EPCs should have a way of reflecting this, for example by displaying in metadata which inputs are dwelling-specific, and which are assumed.
• There may be practical challenges in ensuring that DEAs have access to data, proving that certain works have been carried out, especially when DEAs may miss evidence. For example, we are aware of situations where DEAs have assumed no cavity wall insulation because they have been unable to identify drill holes, despite the landlord having documentation to show cavity wall insulation has been installed. A modular approach does not seem to reduce this risk.

With regards to assessor workloads, costs, training and skills:

• A modular approach is likely to take longer. Members of our MEES SIG have shared information that, under RdSAP10, in-house DEAs are completing three assessments per day, compared to five under RdSAP9.94. They expect this to reduce further when HEM is introduced, increasing the number of DEAs they will have to employ.
• We have also heard concerns about the additional training requirements that internally employed DEAs will need to undergo to undertake a modular approach, and the impact this will have on the ability of social housing providers that use this delivery model to undertake the required number of EPCs for meeting the 2030 MEES deadline.
• The outcome of the government’s consultations on MEES in the rented sectors will likely drive many social and private landlords to renew current EPC Band C (i.e. SAP/EER C) homes before 2030, to take advantage of the transition period, and commission EPC assessments on homes that previously had no EPC at all. This will increase assessor workload and likely require the expansion of the DEA workforce between now and 2030.
• Overall, this evidence suggests the demand for DEAs will increase between now and 2030, and that this demand may struggle to be met by the existing workforce. In 2023, Elmhurst had approximately 7,600 DEAs registered, but as green job demand (7.8 per cent) continues to outstrip the rate of job growth (3.4 per cent), further government action is likely to be required to accelerate the training of a larger number of competent DEAs to undertake the required number of EPCs between now and 2030.  

With regards to implementation risks:

• The government must make sure that training and accreditation processes are rigorous to prevent the possibility of bad actors capitalising on the likely increased demand for EPCs, or being ‘steered’ by landlords to produce EPCs with ratings that comply with MEES. Audit and proper quality assurance will be key and should be undertaken independently wherever possible.
• The transition to the modular version of HEM must be carefully managed. Members of our MEES SIG expect the transition to the modular version of HEM to be more disruptive than the transition between RdSAP9.94 and RdSAP10. In social housing, this is due to added complexities and the requirement for internal energy modelling analyses to be updated, analyses that in turn are usually reliant on external energy modelling firms. The government must manage the transition to the modular version of HEM to ensure this disruption is minimised, especially for social housing providers.

With regards to any other issues we foresee:

• The recently announced delay to the launch of new EPCs to 2027 could have an adverse impact on the ability of social and private landlords to plan their approach to meeting MEES, especially landlords that own multiple thousands of homes. The government must remain aware of this possibility, and we would encourage early engagement with landlords, as well as industry, to understand the consequences of the delay. 

No views.

If a modular approach is adopted, the term “Reduced data HEM” (RdHEM) may not accurately reflect the model’s structure or purpose. We want to ensure the terminology clearly conveys this flexibility and avoids confusion with previous approaches. A clear, intuitive name will help stakeholders understand the purpose of the methodology and distinguish it from both full HEM and legacy RdSAP. Potential options for the new name are:

• HEM for Existing Dwellings (HEMEX)

• HEM Input Expansion (HEMIE)

• Mixed Data for HEM (MdHEM), or

• Reduced data HEM (RdHEM).

Do you have any views on the proposed alternative name(s) that would better capture the intent and flexibility of a modular version of HEM? Do you have any other suggested options that are not listed above?

We do not have strong views on this. Whatever abbreviation is chosen, it is unlikely to have a material impact on the understanding of the modular version of HEM by professionals who will need to use it.

However, some housing professionals have informed us they would prefer RdHEM because it would ensure continuity with the language of RdSAP. The term RdHEM is also already being used among some housing professionals to refer to the eventual replacement for RdSAP. 

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any additional comments or evidence to support your answer.

Agree. 

We have received mixed feedback on the proposal to use the FEE in our engagement with housing professionals and members of our MEES SIG. There are clearly contrasting views across the social and private rented sectors, and we encourage the government to carefully consider the responses of individual landlords and the evidence they submit to support their views.

After consideration, CIH supports the government’s intention to use FEE. For us, the critical factor that has led us to this decision is its ability to incorporate overheating risk.

CIH has a longstanding programme of policy development and research on overheating, and we strongly welcome the inclusion of heat adaptation in the Warm Homes Plan. We also welcome the commitment to integrate heat adaptation measures into the government’s low-income capital retrofit schemes in the future, something that we advocated strongly for in our response to the government’s consultation on updating the fuel poverty strategy.

Previously, we have identified that SAP’s inability to recognise heat adaptation measures such as shutters, blinds, and reflective paint as the most significant barrier to integrating heat adaptation measures into retrofit programmes. The government’s intention to use the FEE should overcome this barrier, and enable households to begin installing the heat adaptation measures that, as the Climate Change Committee has noted, will be absolutely necessary in a world in excess of two degrees warmer than preindustrial levels. 

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any additional comments or evidence to support your answer, including evidence on the sorts of measures that should be prioritised under this metric.

Agree.

As the government has recognised in its partial response to its consultation on MEES in the social rented sector, most social housing providers have been working towards a target of EPC Band C (i.e. SAP/EER C) by 2030 for their homes for several years, despite the absence of a formalised regulatory framework. Significant progress has been made, with substantial bill savings for residents. In the private rented sector, progress has been slower, but many private landlords have also improved their homes to EPC Band C in the last few years.

The government has also recognised, by moving the social rented sector MEES transition period to 2030, that any change in target metrics could be extremely disruptive for the sector’s short- and medium-term retrofit planning, and business planning more generally.

If there is not as close an equivalence as possible between the C/D boundary in the current EER rating and the C/D boundary in the Fabric Performance metric, it could cause significant disruption to landlord business planning, especially in the social rented sector. Ideally, as many homes as possible that meet SAP/EER C now should meet ‘Fabric C’ when their EPCs are recalculated in RdHEM.

We would also make the following comments about the Fabric Performance metric:

• Regardless of the way Fabric Performance is evaluated, the key issue is where the minimum standard is set. In the context of MEES, this standard must achieve a balance between being deliverable and financially viable for landlords across a wide range of archetypes (e.g. bungalows, flats, pre-1919 solid-wall homes), while being strong enough to make homes genuinely cheaper and easier to heat, especially with a heat pump.
  • We encourage the government to carefully consider the responses of individual social landlords to the consultation on this matter, especially on how realistic different minimum standards would be for their homes.
• A member of our MEES SIG noted that it might be helpful to split the figures generated by the FEE into space heating demand (SHD) and space cooling demand (SCD). SHD would enable building performance to be evaluated in the context of industry net zero standards, while SCD would enable the targeting of heat adaptation interventions.
• If the FEE is used, more research and development is required on how passive measures such as shading and vegetation are incorporated.
• For some archetypes, especially older homes and those with solid walls and other complex features, FEE may be challenging to implement, especially if the minimum standard is ambitious. This is because it the modular approach is more likely to rely more on assumptions rather than dwelling-specific data for these homes, where dwelling-specific data is less likely to be available. 

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any comments or evidence to support your answer.

Agree.

Housing professionals are already using approaches allied to SMETERs to obtain more accurate information about energy use inside homes. We support the government’s ongoing intention to incorporate SMETERs-linked approaches into the EPC regime. However, we believe the methodology will require ongoing refinement to adequately reflect fabric performance in some archetypes, such as homes with electric heating.

Our comments in response to Q17 in relation to the accessibility of smart meter data also apply here. 

No views.

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any additional comments or evidence to support your answer.

Agree.

We have set out our views on the different principles for the design and methodology of the Heating System metric below. 

The band boundary for a C rating should be set such that it does not incentivise fossil fuel heating systems.

We strongly agree with this principle.

Hybrid heating systems.

We strongly agree with this principle. The purpose of the Heating System metric should be to incentivise decarbonisation. Any heating appliance that uses fossil fuels should not meet ‘Heating C’.

This also applies to any so-called hydrogen ready boilers, which should not be considered to meet ‘Heating C’ under any circumstances.

Among bands below C, the most efficient, relatively low-carbon fossil fuel systems should still be recognised over less efficient alternatives.

We agree.

Systems with high efficiency and low carbon emissions, such as electric heat pumps and low-carbon heat networks, would always score a C and above.

We agree.

However, we believe further work is needed on what this principle means for heat networks. Heat networks with a decarbonised supply (e.g. district schemes powered by heat pumps) can still be inefficient. A low-carbon heat network is not necessarily a heat network with high efficiency, and given the ongoing lack of a price cap in the heat network market and uncertainty over how Ofgem’s fair pricing framework will be implemented, this could pose a challenge for household affordability.

We would add that in the social housing sector, there is considerable concern and uncertainty about how various government policies on heat networks will interact with each other. In the last year, the government and Ofgem have taken forward policies on heat network regulation, zoning, the Heat Network Technical Assurance Scheme (HNTAS), MEES, EPC reform, and the design of HEM. All of these policies are extremely consequential for social housing providers, who own and/or operate approximately 60 per cent of heat networks across Great Britain. However, there has been very little recognition from the government and Ofgem as to the interplay between, and aggregate impact of, these policies. The MEES consultation for the social rented sector did not mention heat networks at all (outside of the call for evidence on decarbonisation), and the HNTAS consultation has been developed without any seeming regard for how not-for-profit organisations will pay for upgrades that will have a total cost to the sector of billions.

In the context of the present consultation on HEM, the complexity in defining and meeting ‘Heating C’ is likely to be compounded by the challenging situation that could occur for social homes located in heat network zones, whose compliance with MEES via ‘Heating C’ is likely to be dependent on factors outside the control of the housing provider. In addition, some social homes are connected to heat networks that are not owned or operated by the social housing provider. In these situations, compliance with MEES ‘Heating C’ is also likely to be outside of their control.

More clarity is urgently required on how the government intends these various policies to be enacted by social housing providers who own and/or operate heat networks, including the essential question of how they will be paid for and what exemptions will be allowed.

Other comments

Lastly, we would make the following comments on the Heating System metric:

• We would be interested in how HEM will treat homes with multiple heating types that are designed to work together. Housing professionals and members of our MEES SIG are increasingly interested in approaches that do this. For example, air source heat pumps or high heat retention storage heaters (HHRSHs) could be used in homes to provide a low-level background heat and keep the temperature gradient low, with infrared heating used on demand to provide boosts to thermal comfort where desired by a resident. Alternatively, there is interest in different approaches that separate heating and hot water provision. In a well-insulated home, the hot water load can be more significant than the heat load. Separating these out, for example, by having a heat battery installed alongside an air source heat pump, supplemented by solar PV, could help. The government should explore how HEM might treat innovative approaches like these.
• Relatedly, one of the historic challenges with innovative heating technologies has been the extent to which they are penalised in SAP. Some housing professionals have informed us they have been unable to fully explore the potential of alternative clean heating solutions, especially infrared heating, because of this. This barrier is likely to become larger as MEES is introduced to the social rented sector. It is possible providers will be unwilling to trial new technologies that are penalised in HEM to avoid compromising their regulatory compliance. To be clear, we think infrared heating and similar solutions should play a minor role in heat decarbonisation, but the HEM should be flexible enough, and updated frequently enough, to reflect innovations in heating technology and allow pilots of new solutions to take place. 

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any additional comments or evidence to support your answer.

Neither agree nor disagree.

We have set out our views on the two parts of this proposal below.

Direct electric without storage

CIH generally agrees that direct electric with no (or insufficient) storage should play a more minor role in the decarbonisation of heating. If the government sets ‘Heating C’ in such a way that direct electric (e.g. panel heaters) are included, there is a significant risk that some landlords will look to retrofit them as the cheapest option for meeting MEES. We feel this is a particular risk in some parts of the private rented sector, where installing panel heaters may be the cheapest option to meet the choice of secondary standard by 2030. It is likely that this will exacerbate or create fuel poverty, especially if the home is only insulated to minimum fabric standards and has no microgeneration.

However, the government must be aware that excluding direct electric heating from ‘Heating C’ could have complex consequences on the development of new homes that must be carefully thought through. Specifically, members of our MEES SIG are building, or are in the process of designing, homes that will be compliant with the forthcoming Future Homes Standard or the industry-leading UK Net Zero Carbon Buildings Standard (UKNZCBS). We have been informed of several developments that have extremely high fabric performance levels, on-site microgeneration, hot water delivered by small air source heat pumps, and electric panel heaters without storage for space heating. The design and/or SAP assessments for these homes show low running costs and comfortable compliance with the Future Homes Standard. This issue would also occur with Passivhaus homes, which may have a very small heat load delivered by panel heaters.

To give one specific example, with evidence, CIH works closely with the housing association Midland Heart. Midland Heart’s Project 80 delivered the UK’s first Future Homes Standard compliant homes with social housing residents in situ. Monitoring and evaluation of this project demonstrated that panel heaters can provide an efficient, low-carbon heating option and are considered acceptable and useable by residents. The findings of this evaluation are available here, see pages 11 and 12 for the detailed specification and design performance for each house type. Type 2 homes were fitted with panel heaters.

The government must also consider how to support social and private landlords with existing direct electric heating in their homes. Statistics vary, but data from the latest English Housing Survey (Annex Tables 2.5. and 2.6.) shows that there are already a large number of electric heaters across rented housing. Specifically, in 2024, 3.7 per cent of all homes were fitted with storage heaters (which, if old, are likely to have insufficient storage to meet ‘Heating C’), and 3.5 per cent of all homes were fitted with fixed room heaters or portable heaters. This amounts to approximately 1,855,000 homes in England, of which approximately 1,046,000 are rented homes, and fixed room heaters are particularly prevalent in the private rented sector (390,000 homes or 7.9 per cent of all private rented homes). While, on average, these heaters are more expensive to run than alternative options, replacing them to meet ‘Heating C’ would pose a financial challenge to social landlords, and to some private landlords that rent their homes at below-market and social rent rates. As we have noted elsewhere in this response, many of these landlords continue to experience broader financial and regulatory pressures, such as the cost of repairs and maintenance, or building new homes. Government should consider how to support these landlords with the consequences of this proposal.  

Overall, we acknowledge that the government must strike a balance between not incentivising the retrofitting of direct electric heating that could increase running costs in existing homes, and encouraging innovation in the delivery of new homes. Despite this, it would be incongruous if Future Homes Standard and/or UKNZCBS compliant homes with direct electric, delivering low running costs and accepted by residents, are deemed uncompliant with the ‘Heating C’ metric in MEES.

We do not have a view on a preferred solution to this, but some suggestions are:

• Homes that are compliant with the Future Homes Standard (when published) are automatically and perpetually compliant with MEES on all three metrics (Fabric, Heating, and Smart), as long as their operational carbon is zero once the electricity grid has been fully decarbonised.
• Homes that are compliant with the Future Homes Standard are automatically compliant with MEES on all three metrics until their original heating source (e.g. direct electric) reaches the end of its lifespan. At this point, an alternative form of heating (e.g. HHRSHs, a heat pump) could be retrofitted to meet ‘Heating C’.

Storage-based technologies

We agree with this part of the proposal.

As with direct electric, we agree that HHRSHs and similar technologies with storage capabilities should play a more minor role in decarbonisation, compared to heat networks and heat pumps. 

There is also evidence that they can be hard to use easily and effectively by residents, which can lead to feelings of alienation and dissatisfaction. This correlates with evidence from evaluations of previous fuel poverty projects that included discussions of storage heaters. One evaluation, for example, found that “interviewees with storage heaters in their properties frequently described them as difficult (if not impossible) to control effectively.”

However, we do think that with the correct electricity tariffs, the proper use of Demand Side Response (DSR) and load shifting, and the provision of tailored, accurate advice about their use to households, HHRSHs and similar technologies can be an affordable solution that provides thermal comfort for some homes.

In addition, HHRSHs are currently being installed in some homes by social landlords as part of Wave 3 of the Warm Homes: Social Housing Fund. Delivery of Wave 3 has essentially just commenced, with latest statistics from February 2026 showing 14 installations of electric storage heating to date. In addition, latest government statistics from February 2026 show that to date, 1,914 electric storage heaters have been installed through Wave 2.1 of the Social Housing Decarbonisation Fund, with a further 103 electric storage heaters installed to date through Wave 2.2. As far as possible, the design of the HEM should not incentivise the premature replacement of electric heating systems being installed with grant funding through government capital programmes. 

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Do you have any views on how these should be reflected in EPCs (whether in terms of banding or advice to consumers?)

Disagree.

We understand the justification for incorporating cooking into the Heating System metric. A recent academic study of 187 homes with air source heat pumps found that that one year after the installation, 21 per cent of homes still used gas, either for cooking or heating. They concluded that policy changes to encourage electric cooking and incentivise gas disconnection are required. We also agree with the consultation document that there are health benefits and cost benefits to removing gas cooking, as well as climate benefits. In particular, improvements in air quality are likely and households will benefit financially from the removal of a gas standing charge when their gas is disconnected.

However, the consultation document is also correct to note that cooking demand is a relatively small proportion of overall electricity demand in a decarbonised home. In addition, housing professionals have informed us of the following challenges, based on their day-to-day practice:

• There are multiple electric cooking appliances in a home that would need to be recognised by the EPC assessment, including microwaves, air fryers, ovens, induction hobs, slow cookers, and potentially more tangential appliances, such as food mixers.
• Relatedly, a library of makes and models, analogous to the list of boilers in the Product Characteristics Database (PCDB), would need to be developed, which may not be simple given the wide range of cooking appliances on the market.
• In social and private rented housing, the choice of cooking appliances is often left to the resident. In the context of this, it may not be appropriate to assign such a high HEM score to cooking because cooking appliances are not fully within the remit of the landlord responsible for meeting MEES.
• The inclusion of cooking within the Heating System metric could cause considerable confusion for households and landlords. Academic research has shown that cooking and heating are quite different social practices, and it is not intuitive for the former to influence a metric concerned primarily with the latter. 

In view of this, our recommendation is that cooking should be incorporated into the carbon metric that the government is developing as part of the HEM, and which will provide an estimate of the carbon emissions arising from the energy used in the building. At a later date, if desired, this metric could be placed on a regulatory footing in the rented sectors to incentivise the decarbonisation of cooking and the full removal of gas connections from homes.

If the government decides to proceed with including cooking within the HEM as part of the Heating System metric, our preference would be that electric cooking provides a small uplift to the HEM score, reflective of the small percentage of overall energy demand it is responsible for, but is not required to reach Bands A or B of the Heating System metric. Reaching Bands A or B should be primarily obtainable by heating appliances that are zero-carbon and with an extremely high efficiency (e.g. a SCOP of 3.5 or above).

In addition, if the government decides to proceed with including cooking with the HEM as part of the Heating System metric, no cooking HEM score uplift should take a home into Heating System Band C if the heating itself is not low carbon and efficient.

Lastly, we would add that we do not feel that incorporating cooking into the HEM will be sufficient to encourage households to install electric cooking and disconnect from the gas network. Bolder and more coordinated policy action is ultimately required to disconnect homes from the gas network, which we feel needs to take the form of a centralised policy decision on the future of the gas network and an associated gas network decommissioning strategy. When this decision is made, street-by-street decommissioning and disconnection will likely be required to manage the transition and gas infrastructure phase-out effectively and fairly.  

We have no view on possible additions to the list, only to note that the methodology for the Smart Readiness metric should be flexible enough to incorporate innovation in microgeneration technologies as they reach maturity. An example here would be plug-in solar PV, as recognised in the government’s Solar Roadmap.

Of the two options proposed in the consultation, we would prefer Option 1.

We acknowledge that energy storage (for example, batteries) can lead to very substantial bill savings for residents, especially if used in conjunction with solar PV, a smart meter, and a smart electricity tariff. However, the additional cost that would be incurred by social landlords to install solar PV and storage to meet ‘Smart C’ on MEES would be considerable, especially when viewed in the wider context of other sector spending priorities, such as building safety remediation, repairs and maintenance, and building new social homes. Mandating storage to meet ‘Smart C’ could also cause significant logistical issues for some landlords, who are exploring the possibility of installing batteries in their homes but encountering challenges as they do so. As set out in the government’s Solar Roadmap, the focus should be primarily on solar PV. We therefore think it would be more appropriate for energy storage to be required to achieve ‘Smart A’ or ‘Smart B’, not ‘Smart C’.

The question of whether or not a smart meter should be required is very complex, and requires more policy development in relation to both HEM and MEES. We agree with the consultation document that smart meters are fundamental to unlocking the true energy bill savings (and wider grid balancing impacts) that solar PV and batteries can provide. All households should be encouraged to install a smart meter, irrespective of whether they have microgeneration and/or storage.

We also agree with the note in the consultation that there are cases where landlords are unable to install smart meters, for example, due to resident consent. Fundamentally, the installation of smart meters is not within the control of social or private rented landlords. A landlord may encourage a resident to request a smart meter from their energy supplier, and many landlords do, but they cannot force residents to do so. Many social landlords also try to work proactively with energy suppliers when a home is between tenancies to install a smart meter, and we have been informed of many examples where this has been successful. Equally, we have also been informed of examples where social landlords have tried to do this, but have been unable to due installation timelines that would mean the home would need to be vacant for a long time before the smart meter was fitted, leading to unacceptable delays for the resident waiting to move into the home (often, it should be emphasised, out of unsuitable temporary accommodation).  

For these reasons, we welcome the note in the consultation that relevant exemptions will apply where landlords are not able to install a smart meter due to consent issues, and look forward to more detail on this being published as part of the government’s full response to its MEES for the social rented sector consultation.

As an alternative option to developing a smart meter MEES exemption, the government could consider enabling an EPC to display whether or not a smart meter is present in the home, but not including it in the requirement for reaching ‘Smart C’. In this approach, the presence of a smart meter could lead to a HEM uplift (e.g. it could take the home from a low ‘Smart C’ to a high ‘Smart C’). A home could also not be capable of going higher than a floor-level ‘Smart C’ without a smart meter (e.g. it could have a HEM score equivalent to 69 SAP points, but no more, if it does not have one). This could even be termed a ‘Smart C minus’. These are possible alternatives to a smart meter exemption, and we encourage the government to review the responses to the consultation from individual landlords and consumer groups to understand the best solution for residents and landlords alike.

Regardless of the approach taken to the Smart Readiness metric, we would encourage the government to consider a parallel workstream that is separate to the framework of MEES, and which attempts to bring together resident groups, landlord representatives, energy supplier representatives, and other relevant stakeholders (for example, Ofgem and/or SEGB) to develop collaborative approaches to increasing smart meter uptake in both rented sectors. This could include, for example, the development of Service Level Agreements between specific energy suppliers and groups of landlords working in a particular geography to communicate the benefits of smart meters to residents and agree minimum installation times for smart meters in homes between tenancies (i.e. during void works). Developing a workstream of this kind would support energy suppliers to meet updated requirements to take all reasonable steps to complete the domestic smart meter rollout by the end of 2030.

Lastly, our final comment is that a new EPC should not be required to demonstrate MEES compliance with ‘Smart C’ if a smart meter is the last measure to be installed. Specifically, if the government decides that a smart meter is required for meeting ‘Smart C’, there will be some homes with solar PV that do not have a smart meter. If one is fitted thereafter, but no other works are carried out to the home, it would not be a good use of landlord resources to commission a new EPC just to reflect a smart meter installation. The government should explore an alternative solution, such as allowing smart meter installation information from energy suppliers to be used to update an existing EPC. 

This is a critical question. If installing solar PV is sufficient to meet ‘Smart C’, it is vital that it is of sufficient size to lead to meaningful energy bill savings and lift as many households as possible out of fuel poverty.

However, evidence provided by members of our MEES SIG shows that the minimum sized array that can be installed on any given home is shaped by several factors, including archetype, shading, orientation, and roof area and slope gradient. It is also shaped by factors external to the design and construction of the home, such as Distribution Network Operator (DNO) capability to connect the array to the grid. As the consultation recognises, the installation of any kind of microgeneration may not be possible in some archetypes, such as flats. We welcome the note in the consultation that relevant exemptions will apply in these circumstances for the purposes of MEES.

The government must also consider the interaction of its chosen minimum size with the MEES exemption regimes for both rented sectors. Setting a minimum solar array size too high could have the unintended impact of increasing the number of exemptions claimed by landlords, either because the time-limited spend exemption (or ‘cost cap’) would be breached by the cost of a larger system, or because one or more of the aforementioned factors (e.g. roof size) makes installing an array of that size unfeasible. This may particularly affect the delivery of MEES in the private rented sector, as meeting ‘Smart C’ may be a cheaper option for private landlords than meeting ‘Heating C’ when they make their choice of secondary standard.

In this context, members of our MEES SIG have recommended minimum sizes ranging from 1kW-3kW. We encourage the government to carefully consider the views of landlords and consumer groups on the advantages and disadvantages of different sizing options.

For the purposes of MEES, relevant exemptions should include additional factors beyond the unfeasibility of installing microgeneration in some archetypes, such as in situations where constraints associated with DNOs prevent installation.

While setting an appropriate minimum is important, the government should attempt to make sure that solar PV installed in both rented sectors maximises the energy bill savings for residents. It would be unsatisfactory if landlords chose to install a 1kW solar PV system on a roof that could accommodate 6kW, especially if they could afford to install a larger system. 

No view. However, if the government decides to include battery installation within the requirements for reaching ‘Smart C’, our points made regarding the interaction between minimum sizing, energy bill reduction, and the MEES exemption regime in response to Q14 also applies here. 

Housing professionals and members of our MEES SIG have raised the following points that are worthy of consideration.

• Social landlords would welcome the opportunity to more readily access the data that is generated by smart meters and wider SMETERs-linked approaches. This would support them to understand whether any additional interventions are required in the home, including fuel poverty support, such as in circumstances where energy use data reveals patterns of underheating/heat rationing. We would welcome further policy work on the development of open smart meter datasets, which could (with informed resident consent) be matched to individual homes without revealing how much the household is actually spending.
• Consideration should be given to how the Smart Readiness metric can recognise, or incentivise, innovative financing models, such as Power Purchase Agreements (PPAs) or solar-as-a-service. Consideration should also be given to how the metric will deal with community-level solar PV schemes that provide electricity bill savings to individual residents via centralised storage technologies. For example, one of our MEES SIG members works on the Carpenters Yard development, an innovative 113-home scheme in Epping Forest, Essex. On this scheme, the energy generated by individual solar PV panels is ‘pooled’, stored, managed, and shared through a single centralised battery system. The relevance is that on schemes such as this one, all homes can benefit from solar PV generation and battery storage, even if some individual homes do not actually have PV mounted on their roof or a battery in their cupboard. The Smart Readiness metric will need to ensure it accounts for approaches such as this, in part to not disincentivise innovation and community microgeneration and storage schemes.  

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any comments or evidence to support your answer.

Neither agree nor disagree. 

Response options: strongly agree, agree, neither agree nor disagree, disagree or strongly disagree. Please provide any comments or evidence to support your answer.

Neither agree nor disagree.

If the government decides to proceed with this change, we feel that care must be taken in the presentation of this metric in British pounds sterling. The consultation document is correct to recognise that any monetary figure will essentially be a snapshot in time and could change considerably over the validity period of the EPC.

Among other things, the factors influencing this could be:

• The level of Ofgem’s price cap (and, more widely, the future of wholesale prices, policy cost recovery on bills, and the costs of investment in the electricity and gas networks)
• The distribution of any future energy policies levied on bills across the standing charge and the unit rate
• Tariff switching, especially if households switch between (e.g.) time-of-use tariffs and default tariffs at the price cap level
• Any year-on-year variability in microgeneration (e.g. due to changes in the number of sunny days or wind. For example, according to the Met Office, specifically the latest UK State of the Climate report, the UK has generally become sunnier since the 1980s, but there is still significant variability and no definitive evidence of a future trend of sunshine amounts due to climate change)
• Energy use practices and behaviours, which are multifarious and vary considerably among households, even among households that are ostensibly similar.

If the government proceeds with this approach, it is therefore essential that the EPC contains information that allows households to understand that the monetary figure is a snapshot on the day the EPC assessment was carried out. Ideally, it should be presented in a range or be able to be updated periodically, such as every time Ofgem’s price cap changes.

We also agree with the government’s proposal to explore how the EPC can signpost to information that can give households a more accurate picture of their energy costs across the full validity period of a given EPC.

For more information about our response, please contact Matthew Scott, policy manager, at matthew.scott@cih.org