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New guidance on EPCs for solar PV installations

DCLG tightens up on rules for producing EPCs for solar PV installations to support the Feed-in-Tariff, but do they improve the process or just add cost and increase carbon emissions?

Concern appears to have been raised as a result of a National PV Company suggesting that assessors should do the survey as normal to confirm if a “D” was achievable but not lodge until either a) the panels were on or b) it was confirmed that the panels were not going to be done. Then, if applicable, that the EPC be lodged showing the higher rating created by the panels on the strength of an MCS certificate and a photograph showing the panels installed on the building.

As long as the photograph is sufficient to demonstrate that the panels are on the right building i.e. not just a photo of a roof with panels on, this would seem to be just as robust as the assessor going back to site and taking a photo of the building with panels on. The MCS certificate itself is also subject to a robust quality assurance and audit process.

There also seems to have been concern about an entirely different PV organisation suggesting that people collect the information needed to produce an EPC and provide it to them so an Energy Assessor could create the EPC from it when the panels were on. That would be using data collectors and is rightly not permitted.

It looks as if the two separate issues have been confused with each other and a knee-jerk response outlawed both. When you look at them logically the former makes complete sense and the latter was wrong. We shouldn’t get diverted by the fact that a National PV provider was encouraging the client friendly process. Exactly the same principle makes absolute sense where a local DEA is doing assessments for a local PV provider.

Making the Energy Assessor go back to site rather than allowing the PV installer to send a legal document that says what they have installed and a photograph that proves they have done it seems counterproductive. It appears to add unnecessary cost to the process at a time when the drive is to make energy efficiency improvements as cost effective as possible. It also creates carbon emission from additional travel miles when the process is supposed to reduce carbon emissions.

What the government actually needs is…

a) Renewable technologies installed - so making the process harder / more expensive is not helpful.

b) To improve the perceived value of EPCs - so making you have 2 of them instead of one to get the FiT doesn’t really help.

c) To have EPCs representative of the property, so lodging one just before you make an improvement makes a lot less sense than lodging one immediately after you have. If the pre-solar one is “D” or above nobody will want to pay for the post solar one so many properties will have an EPC that is immediately too low. That will distort the average results and encourage the belief that you just have to have an EPC to tick a box; it doesn’t actually matter whether it accurately represents the property.

d) To reduce carbon emissions – so doubling the miles travelled to carry out the job is definitely counterproductive.

It is also interesting to note that the decision from DCLG is apparently to ensure Energy Assessors comply with the Scheme Operating Requirements (SOR), but I have not seen anything indicating which part of the SOR they believe the client friendly approach would breach. That would be interesting to know and hopefully at some point it will become clear. In situations like this however there is always the option available to DCLG  of changing the SOR to enable development of best practice to reflect changes in market demand and improve the customer experience rather than restricting practice to match the document .

At the end of the day the bottom line should be to ensure that the customer experience is as positive as possible while delivering the objective. Closing the door on a professionally managed and verifiable method of producing an EPC that reflects the building efficiency from the date of issue forward, but that also encourages take up of a measure, does not seem to fit the overall objective.

30 June 2012

Ian Sturt DipHI, DipNDEA(L4), Dip DEC

HI Devon Energy Assessment

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