New Builds and EPC's ... ...

[Worcester]

Did anyone else notice the change on 10th May last year - that the EPC date must be BEFORE the commissioning date.

As we are doing mainly new build work these days, as there is / was a specific tariff for New Build properties, and inherenely they would be better than a 'D' I though I'd get clarification from Ofgem as to when and how this tariff could be applied and was if there was an easy way to apply the EER.

Here's the response from Ofgem:

I am afraid there are no specific provisions on how to apply the Energy Efficiency Requirement (EER) to new build properties.
The requirement of the current legislation is that for installations with an application date on or after 10 May 2016, the EPC of level D or above must have been issued before the commissioning date of the FIT installation.
The failure to provide a valid EPC of level D or above at or before these dates will result in the installation receiving the lower tariff. No exceptions or set of different rules apply for the case of new builds.

The EER therefore applies as follows:

• For installations with an application date on or after 10 May 2016, the EPC of level D or above must have been issued before the commissioning date of the FIT installation.
• For installations with an application date before 10 May 2016 but on or after 15 January 2016 an EPC level of D or above must have been issued on or before the commissioning date.
• For installations with an application date before 15 January 2016 an EPC level D or above must have been issued on or before the Eligibility Date of the FIT installation.

What we have been advising Generators is first for the house to be completed, next an EPC assessment to be carried out and then for the installation to be commissioned. An MCS certificate is not required for an EPC assessment to be completed.​

Hope that helps.

 

[Energetic]

Thank you for this, i've got a couple of new builds on the go atm also. Is it still the case that off plan EPC's are not able to be used in a FIT application?

 

[Worcester]

Thank you for this, i've got a couple of new builds on the go atm also. Is it still the case that off plan EPC's are not able to be used in a FIT application?

No such legal thing as an 'off plan' EPC Almost all our new build EPC's are not done by a visit, they tend to be done by the same people doing the SAP calcs, and outsourced building control. They do require certification by the builder that it has been built as designed and they also require copies of the air tightness certificates / MVHR commissioning documents etc., from that they produce an 'interim' EPC for the purposes of claiming the FiT and then produce and EPC for building control once they've got the MCS certificate for the PV system.

We have just had one though where he simply asked for the details of the panels as installed, and he produced an EPC off that, we have subsequently installed the inverter and commissioned it. - Probably more of the ignorance of the assessor than anything else.

Two recent anomalies we've had:
We replaced the LPG boiler with an ASHP, the LPG boiler was given 4 stars, the ASHP 2 stars......

On another a vented DHW cylinder controlled by sensor attached to heat pump, assessor couldn't list it as a thermostat, so it came up with a recommendation for a DHW cylinder stat....

 

[Energetic]

I spoke to one of my DEA's yesterday who said that if the array is visible it has to be included in the EPC even if the system is not connected. It apparently can be put in as disconnected???

Does it matter if the PV is included or not if that the date on the MCS cert is after the EPC? Clearly the spirit of the rule is that the PV is not included in the EPC.

 

[Worcester]

@Energetic

There's spirit and letter, from our discussions and communications with Ofgem, spirit is irrelevant, they only go by letter, so if our MCS commissioning date is after the EPC date, that's is all that matters.

We have so many anomalies on EPC's wrt the RHI that it is a manipulative farce.

 

[Gavin A]

The solar PV can not be on the EPC, there need to be 2 EPCs, one for the FIT application without the solar, a 2nd for building regs with the solar after it's commissioned.

The EPC assessor is wrong, a solar system is not a solar system unless it's actually commissioned and working. They probably could fudge it to be included if they wanted to, but they can also not include it, and shouldn't if there's no MCS cert.

IME the EPC assessors were requiring MCS certs as evidence of the solar PV system capacity for the EPC anyway.

Also - from plan EPCs are produced in advance of the building work starting, they can't be used for FIT submission. The other key thing being that a standard EPC assessor can't just go and produce the EPC for the FIT, it has to be the EPC assessor who did the EPC from plan who then lodges it as it needs the air tightness test results etc etc which aren't on a standard EPC, and they're effectively locked out of the system until the from plan EPC is converted to a final EPC.

It may be that some systems will slip through the net with an EPC that includes the solar on it as long as the date is right, however if anyone actually looks at the EPC and checks for solar being included then the customer will receive the lowest FIT rate.

We went through all this with OFgem, DECC, and STA in the winter of 2016, it's a dogs dinner but unfortunately DECC didn't actually care about it, saying effectively that new builds could just get the lower rate and lump it because in their view they had lower costs anyway.