EPCs: Failing to plan is planning to Fail
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The Scottish government has just published the minimum EPC draft regulations and guidance. This is something that Aberdeen landlords have to consider very carefully, particularly because a considerable number of granite properties, typical of our unique architectural style, may fall short of the future requirements.
Let’s explore what these EPC minimum requirements are going to be, the implementation time scale, and what to do if you find that your property will be non-compliant in the future.
The new standards and introductory period.
There are four deadlines that landlords will need to consider:
Private Rented Sector (PRS) properties will need to achieve an EPC of E or above for any new tenancies from 1st April 2020.
By 31st March 2022, all PRS properties will need to achieve an EPC of E or above, regardless of when the tenancy started.
From 1st April 2022 (one day later!) properties will need to achieve an EPC of D or above for any new tenancies.
By 31st March 2015 all PRS properties must have an EPC of D or above, regardless on when the tenancy started.
Exemptions
In some cases landlords will be able to request an exemption to the above requirement. These cases will include:
When works in listed properties or properties in conservation areas are not approved by the relevant authority.
When it’s not technically feasible to improve the property.
When owners in a flatted building refuse consent to carry out works in common areas.
When the tenants in-situ refuse consent to carry out works.
When, after completing the ‘relevant energy efficient improvements’, the property fails to achieve the required EPC level. ‘Relevant energy efficient improvements’ are the improvements recommended in the EPC report that can be financed by means of funding provided by a grant or loan from Scottish Ministers. The detail of these grants and loans is still to be released.
When the costs of the ‘relevant energy efficient improvements’ required by 31st March 2022 exceed £5,000, and when the cost of the ‘relevant energy efficient improvements’ required after 1st April 2022 exceed an additional £5,000.
In any of the exemption cases above, the landlord will need to seek a formal ‘Exemption from the Standard’ issued by the local authority.
So, what should I do?
In summary, landlords could follow these three simple steps to make sure that they are best prepared for the EPC regulation changes ahead.
Check current EPC rating. If current level is D or above (i.e. A to D), there is nothing to do. An EPC Level E or F will require some attention at some point in the future.
If current EPC level is E or F, put a plan together to bring the level up in accordance to the EPC report recommendations.
If the information available shows that even after applying the EPC report recommendations the future EPC level won’t achieve the minimum required standard, or the situation of the property is within one of the exempted cases mentioned above, start liaising with the local authority to make sure that an ‘Exemption from the Standard’ is in place prior to the relevant deadline.
Since the information released so far is in draft format only, there is no need to take immediate action, but good forward planning always minimises costs and disruption of any well run property business.