Another EPC question - churches this time.

[Energetic]

Had an enquiry from a church today. Initial thoughts were that it has no chance but some digging has turned up that 'places of worship' are EPC exempt under normal EPC requirements.

So the question is do the old exemptions still apply under the 'new normal' we find ourselves in with PV, or to cut a load of waffle out, Do churches require EPC's to get the good tariff?

 

[Gavin A]

tell them to wait unless you're sure they'll get a D, as the latest edict from decc is that churches (and all smaller charities) will be exempt from the D rating requirement from some time this autumn IIRC, although also IIRC they'll still need to waste their money getting an EPC done for some daft reason probably relating to arse and elbows confusion.

 

[TedM]

I don't think the community EPC exemption (which comes in from 1st December) will apply to churches as it is conditional on the organisation having no more than 50 employees.

It will only apply to an organisation if they can provide all the relevant paperwork to show that they are a recognised community company. These are defined as those companies registered as a community interest company (CIC) on the Companies House register, or co-operatives or community benefit societies registered on the FSA Mutuals Public Register, who will be able to provide their incorporation/registration certificate. Presumably there will also be a declaration to sign to say they have no more than 50 employees.

Re the original question - the 'normal' exemptions that apply to certain types of buildings from needing an EPC does not apply to the FiTs scheme.

 

[confounded]

Re the original question - the 'normal' exemptions that apply to certain types of buildings from needing an EPC does not apply to the FiTs scheme.

So does this mean churches are effectively on the non D rated EPC tariff unless there are exemptions brought in?

 

[Gavin A]

I don't think the community EPC exemption (which comes in from 1st December) will apply to churches as it is conditional on the organisation having no more than 50 employees.

It will only apply to an organisation if they can provide all the relevant paperwork to show that they are a recognised community company. These are defined as those companies registered as a community interest company (CIC) on the Companies House register, or co-operatives or community benefit societies registered on the FSA Mutuals Public Register, who will be able to provide their incorporation/registration certificate. Presumably there will also be a declaration to sign to say they have no more than 50 employees.

Re the original question - the 'normal' exemptions that apply to certain types of buildings from needing an EPC does not apply to the FiTs scheme.

I'd be amazed if it didn't apply to churches, as I'm pretty sure a fair amount of the pressure for this measure came from churches.

I'm pretty sure that most churches are semi independently owned and operated to the extent that they're responsible for the wages of the staff of the church, and own the building (or hold the deed to the building in trust) so I'd expect they'd qualify.

it'd be worth getting that clarification though.

 

[BruceB]

Has the legislation/regulations been published yet?

 

[TedM]

Not AFAIK, expected in October.

A quick search of Companies House suggests that churches are companies limited by guarantee which would mean they fall outside the community exemption anyway - they would need to be expressly CICs but there may be some I didn't see. The only relevant entries I could find on the FSA Register for religious organisations all looked like housing associations.

 

[Gavin A]

Not AFAIK, expected in October.

A quick search of Companies House suggests that churches are companies limited by guarantee which would mean they fall outside the community exemption anyway - they would need to be expressly CICs but there may be some I didn't see. The only relevant entries I could find on the FSA Register for religious organisations all looked like housing associations.

they're almost all registered charities, and certainly eligible for gift aid status, so definitely meet the HMRC test that's being applied. I did notice registered charities were missing from the list, but took that as being because the list was describing all the non-charity routes to being viewed as being for community benefit.

I'd think there'd be absolute uproar in the shires if churches we're given community benefit status by decc, not something I can see a tory government ever deliberately provoking in this way for no apparent reason.

 

[whinmoor]

Find attached a statement by the Methodist Church relating to solar panels, FiTs, EPCs etc.

It's a bit out of date and I'm not sure if they've got it all correct but Steve Hucklesby could be a guy to talk to:

[email protected]

​

View attachment Methodist Church Solar Statement.pdf

​

 

[TedM]

That document looks as though it pre-dates the DECC 2B consultation response.

Gav, the DECC definition for community schemes expressly does not include registered charities. This is from the 2B DECC response doc:

145. Given the difficulty of justifying the inclusion of all charities, and the absence of a clear, simple way of separating out different kinds of charities, we are not including these in our final definition. We do not believe that this is a barrier for charities, as they should in most cases be able to set up specific purpose vehicles for the purposes of delivering community energy projects that could be classified under the new definitions.

So maybe a church would be exempted from the need for an EPC if they go to the trouble of setting up a specific community company for the purpose.

 

[Gavin A]

in that case that is utterly nuts.

how much would the set up costs and annual accounting costs be for setting up a special purpose vehicle just to install a 4 or 10kW solar PV system?

have these idiots ever done anything in the real world in their lives?

 

[Energetic]

Thanks guys, sounds like a proper minefield. Will keep an eye on things as they progress but it seems pretty hopeless for them at the moment...

Somebody said to me that they might get a sort of relative epc in that they would get a grade against what the building is capable of acheiving rather than the absolute scale used at the moment. Anyone heard of anything like this? I've not been able to find any evidence of such a thing...