EPC on a church - exempt?

[saint]

He is certainly a commercial EPC assessor and has done a fair few for us now and i'm very confident in his abilities but I agree this may well be the case.....

<it looks more like he's saying that because of the standard exemption for churches the building should be exempt - ie he's applying a blanket exemption to churches because of flaws in the software.>

Thanks for your input and just as a side issue. There is a building of more standard construction about 20m from the church and fed from the church. i.e. service head and meter in the church. Supply from here to DB2 in the other building. Could / should he carry out an EPC on this building?

 

[BruceB]

You may just have stumbled upon the way out. Para 3.97 of the guidance, for which TedM provided a link above, states that where the PV installation is connected to multiple relevant buildings then only one of them needs to have an EPC level D. So if this other building has heating there is a good chance that taking account of the PV it will achieve level D.

 

[saint]

Its interesting how the different FIT providers look at this.

One is asking simply for a letter on headed paper etc stating the building is a place of worship and is therefore exempt. The guy in the FIT team said they had accepted several letters of exemption for places of worship and those installations were all receiving the standard generation tariff.

The second is saying the letter of exemption must meet all the following criteria.

In order to be exempt from the Energy Performance Certificate (EPC) requirement (under FITs), the evidence supplied must include the following key points,

• The installation address cannot physically have an EPC
• It is a “non relevant” building
• here is no internal conditioning, ie. The internal climate is not controlled.
• It is not wired or attached to any other relevant building.
  

If the above is not covered in the evidence provided, we would be unable to accept this in the place of an EPC, therefore the customer would only qualify to recieve the lower tariff price without an EPC or an exemption EPC letter.

Its crazy that they are not all playing by the same rules.

 

[Ian-LS]

another reason why ofgem are a waste of space

 

[TedM]

And why there will be more problems down the road when an audit uncovers those 'place of worship' letters that are not acceptable to OFGEM.

 

[TedM]

Another way around this, if a church cannot meet the requirement of an EPC 'D' band, is to use the, relatively, new community EPC opt-out clause. See https://www.ofgem.gov.uk/ofgem-publications/58937/fit-community-and-school-guidance.pdf

This was brought in from last December and the church would need to exactly meet the definition in 2.4 to be eligible - churches do not automatically qualify. They might need to create a CIC for the purpose.

All they would then need is an EPC of at least 'G', i.e. the bottom band - but they would still need to have the EPC and would qualify for the top tariff. If you go this route then you need to precisely follow the OFGEM application procedure, which is in addition to applying for a FiT contract.

 

[Gavin A]

Another way around this, if a church cannot meet the requirement of an EPC 'D' band, is to use the, relatively, new community EPC opt-out clause. See https://www.ofgem.gov.uk/ofgem-publications/58937/fit-community-and-school-guidance.pdf

This was brought in from last December and the church would need to exactly meet the definition in 2.4 to be eligible - churches do not automatically qualify. They might need to create a CIC for the purpose.

All they would then need is an EPC of at least 'G', i.e. the bottom band - but they would still need to have the EPC and would qualify for the top tariff. If you go this route then you need to precisely follow the OFGEM application procedure, which is in addition to applying for a FiT contract.

yes, they would need to create a CIC to do it, which IMO is a ridiculous regulatory burden to put onto a charity simply for not meeting the specific definition of a community organisation laid out in the legislation. I think this is another area where DECC would lose if taken to Judicial review, and I really hope that one of the churches will actually do this.

Setting up a CIC is not something to be undertaken lightly, it involves annual Accounts to companies house, plus annual statements to show how they've met their community benefit obligations, so comes with a fairly high annual admin cost attached. Not something that's going to be viable for a 4 or 10kWp system, even a 50kWp system it's a bit much to ask really.

I believe this came about due to where the pressure for this came from - ie it came from those pushing CIC's, rather than the church / charity sector, and those pushing CIC's took the attitude that churches could just set up a CIC if they wanted to, so there wasn't an issue... which obviously is a load of rubbish.