Secretary of State for Energy and Climate Change Ed Davey is finally laying regulations before Parliament that are intended to bring the coldest and leakiest private-rented homes up to a minimum Energy Performance Certificate of Band E by April 2018. Having long campaigned for minimum standards for the sector, we welcome this overdue breakthrough. This campaign has had to overcome considerable resistance to minimum standards, and we agree with what Ed Davey says in the Guardian today:
“Not everyone in this government wants more regulation. But in energy efficiency, regulations play a crucial role.”
But today’s development does not go far enough. Given Britain’s status as the ‘Cold Man of Europe’ (see the Guardian’s infographic, based on our earlier briefing), and that energy efficiency support for households, particularly fuel poor households, has collapsed this winter, we cannot stress enough that the regulations have got to go further in at least two important respects (see our response to the domestic PRS consultation for more):
The minimum standard should not have been based on the principle of ‘no net or upfront costs’ to landlords. It is quite wrong, as a matter of both law and practice, that a regulatory framework should be dependent upon a set of financing mechanisms – i.e. the Green Deal and Energy Company Obligation – that may not even exist in 2018. We therefore believe that all properties within scope of the regulations should be required to meet a minimum standard of EPC Band E, up to a maximum spend of £6,000. More broadly, all domestic private rented properties should be within scope of the minimum standard regulations, not just those with a valid EPC.
- Government should have today set a trajectory for increasing the minimum standard to EPC D in 2022 and to EPC C in 2026. An EPC rating of E is only the best of the worst, and a trajectory would have encouraged landlords to go further in one go, which in countless properties is easy and sensible to do.
We look forward to working with the next government on making sure these regulations become as meaningful and forward-looking as they can and should be to match the challenge our housing stock and fuel poverty poses.