In UK100's response to the Ministry of Housing, Communities & Local Government and Department for Energy Security & Net Zero consultation on reforms to the Energy Performance of Buildings regime, the network of 117 local authorities calls for fundamental changes to the EPC methodology and enforcement framework.
As a network of local authorities committed to achieving net zero ahead of the national 2050 target, UK100 highlighted several critical priorities for reform:
- Fabric efficiency focus - Strongly supporting a fabric performance metric as the cornerstone of reformed EPCs for both domestic and non-domestic buildings
- Heating system assessment - Advocating for a dedicated heating system metric that properly evaluates efficiency and encourages low-carbon alternatives
- Carbon measurement - Endorsing the inclusion of carbon-based metrics to help local authorities track building emissions and guide decarbonisation strategies
- Enforcement capabilities - Calling for better data sharing and a mandatory national landlord register to address significant enforcement challenges facing local authorities
The submission emphasised how current EPC methodologies disadvantage off-gas properties and fail to adequately assess real-world building performance, with UK100 research showing that most off-gas properties cannot reach EPC C under the current cost-based approach.
UK100 highlighted enforcement challenges revealed in their "Powers in Place" report, noting that only 17 of 268 councils had sufficient resources to properly enforce existing standards, with annual enforcement costs reaching up to £140,000 per authority.
The response advocated for more effective data sharing between authorities and recommended that policy interventions like grants or standards should be based on stable fabric efficiency metrics rather than volatile energy cost indicators.
UK100 has offered to convene discussions with its member local authorities to explore these themes in greater detail with government officials.
