KJ Tait

The Role of EPCs in Decarbonising our Commercial Building Stock

24 August 2023

In the pursuit of a more sustainable and environmentally conscious future within the current commercial built landscape, the Energy Performance Certificate (EPC) has assumed a pivotal role in the transition away from gas-fired boilers and the decarbonisation of heating systems.  This significance arises from the Minimum Energy Efficiency Standards (MEES), which stipulate that the minimum EPC rating for commercial lettings should be a 'B' by 2030. 


The government's response to the consultation titled 'Non-domestic Private Rented Sector minimum energy efficiency standards: EPC B Implementation', which concluded in June 2021, is still pending. This consultation introduced some intriguing proposals, such as: 

  • Shifting the standard away from the letting stage, which holds relevance for retail units.  In these cases, EPC assessments are typically conducted when the unit is being transformed into a basic shell condition.  This normally results in lower EPC ratings, often below 'E' as worst case scenarios need to be assumed by the EPC Assessor 
  • Establishing a compliance database, always demanding a consistent EPC ‘B’ rating for commercial buildings 


This second point would have two implications a) the ability to do floor EPCs would likely fall away as the onus would be on the building to achieve an EPC ‘B’ and b) an EPC ‘B’ would more than likely be required when selling the building.  


Naturally, there are exceptions to the EPC 'B' standard, which certain building owners may wish to invoke.  These exemptions encompass: 

  • A seven-year payback test, allowing for an exemption if the expenses to achieve a 'B' rating are not financially viable within this timeframe 
  • Inability to secure third-party approval, as when local planning authorities disallow the use of external heat pumps that could elevate the property to a 'B' standard 
  • Measures that could significantly devalue the property 

The consultation aimed to bolster these exemption measures and introduce a new exemption database with a five-year validity.  It is worth noting that if a building is exempt from requiring an EPC for any reason, it would not need to adhere to the EPC 'B' standard. 


Beyond direct legislative barriers, EPCs are being employed by building owners to bolster their Environmental, Social, and Governance (ESG) standing and safeguard their investments.  A growing number of building owners are seeking guidance on how to implement the necessary modifications to attain an EPC 'A' rating for their properties. 


So, how exactly are EPCs aiding in the process of decarbonisation? While multifaceted, our experience indicates that buildings constructed prior to the 2013 Building Regulations and primarily heated using gas often fall short of the EPC 'B' benchmark.  Consequently, they require an alternative heating approach. 


This is where we enter the picture as Building Services Engineers.  We consider the feasible alterations for a building, considering aspects such as roof and riser spaces, existing ventilation systems and their operation, electrical capacity, and the age/condition of systems.  


After discussion with the Client team, we will put a plan in place that will allow the building to achieve the EPC ‘B’ standard.  For any M&E aspects within that plan, we can design the systems ensuring a joined up approach between the EPC modelling and the design.  Once upgrades are completed, we would re-use our model to lodge subsequent EPCs saving our clients money by not recommissioning fresh EPCs on each occasion.