How can a minimum EPC rating be met for MEES where the services have been removed?

How can a minimum EPC rating be met for MEES where the services have been removed?

A building stripped of services will have a poor EPC rating and will likely not pass the minimum EPC rating required in England & Wales. The EPC rating may be a G when marketed. An agreement may be drawn up to say the building is to be let on a licence in the first instance and that the new tenant fits out the building to meet MEES before it is then leased on a long term lease. Legal advice should be sought.

Region: England & Wales

Topic: Energy in commercial buildings

Designed or altered to be used separately

A separate EPC may be required for parts of buildings designed or altered to be used separately. 

A part of a building designed or altered to be used separately is where the accommodation is suitable for separate occupation. This could be indicated by the accommodation having its own access, separate provision of heating and ventilation or shared heating and ventilation but with separate energy metering and the ability by the occupier to independently control those services. The part could be deemed to be separate even if some facilities (ie kitchen and toilet facilities) were shared.


Is an EPC required for the whole building or only the part being sold or let?

In general terms the EPC should be for the property that is being sold or let.

Where it is the whole of the building being sold or let then an EPC, or combination of EPCs, must be provided that covers the whole building. For example there may be one EPC for the whole building or a combination of one EPC per unit plus a separate EPC for the communal areas.

If part of the building being sold / let is designed / altered for separate use then:

1. If the building has a common heating system serving that part and other parts the EPC provided could be either the EPC fir the whole building or an EPC for that part but reflecting an apportioned part of the central plant efficiency.

2. If the building has it's own common heating system then the EPC provided should be of the part only.

Communal areas are ignored when producing the EPC for a part. This guidance is provided from Para 4.2 of the document Improving the energy efficiency of our buildings; A guide to energy performance certificates for the construction, sale and let of non-dwellings produced by Communities and Local Government. A copy is available here: Communites Local Government EPC Guidance 2008


Can a landlord wait until a tenant decides to lease the property before I commission an EPC?

An EPC is required prior to a tenant's decision to lease of purchase a property. The EPC grade should be displayed in advertisements in commercial media and must be available for issue to all prospective tenants. Where an EPC is not provided a landlord may be subject to a penalty charge notice of £500, minimum.

Region: Scotland

I own a block of flats, do I need an EPC for every dwelling?

Where an owner owns a block of flats a separate EPC is required for each dwelling. You cannot commission one EPC for the whole building.

What if an EPC address isn't listed on the central EPC register?

Where an EPC address for a building isn't listed or is listed incorrectly then the Energy Assessor is required to make a request. Where the property is in England or Wales this is almost by return however in Scotland it is a longer process. The EST state the timeframes for processing complete missing address requests are as follows:

Domestic – within 3 working days from receipt of email
Non-domestic – within 5 working days from receipt of email.

If we have an enquiry with regards to the content of your request then this may take longer.

How long is an EPC valid for?

An EPC is valid for 10 years.

Multiple occupancy buildings

Q. In a multi-occupancy building, is an EPC required for the whole building or for each occupancy?

A. Where a whole building is for sale then an EPC can be produced for the whole building including all individual parts including common parts. Where each part has an independent heating system then if an EPC exists for a whole building then separate EPCs should be obtained when letting each part. 

The most flexible and relevant option is to produce EPCs for each individual unit. The EPC will be specifically tailored to that unit and it will be easier to consider the effect of carrying out the improvements.

EPCs for multi-let buildings

The above diagram is an extract from a Communities and Local Government (CLG) document. The full document is available here.

Is an EPC required for a shell building?

Yes, where the expectation is that a unit will be conditioned an EPC is required. The following rules are required to be met when preparing an EPC for a shell unit. However, the detail needs to be established at a local level on a case by case basis:

. No heating – use electric resistance heating as per SBEM.

. Other services – make as few assumptions as possible and only where necessary to make the calculation work in SBEM.

. Any assumptions that must be made, which involve fixed services which are subject to minimum levels of energy efficiency in building regulations should default to the least onerous levels. 

Note: where the building offered for sale or rental is a new building, the EPC will be provided as part of the building warrant process. For a shell building with incomplete services installation, the EPC will be based upon a notional services specification which meets building regulations for the proposed building type and use.

Farm buildings and EPCs

Many farm buildings are exempt from the requirement to obtain an EPC. Most buildings which are sold or rented out will require an EPC. The intention is that an EPC is not required for:

1. buildings which do not use fuel or power for controlling the temperature of the internal environment (for instance a cattle shed)

2. non-domestic buildings and buildings that are ancillary to a dwelling that are stand-alone having an area less than 50 square metres (for instance a stand -alone retail unit. Possibly some petrol station kiosk buildings)

3. conversions, alterations and extensions to buildings other than alterations and extensions to stand-alone buildings having an area less than 50 square metres that would increase the area to 50 square metres or more, or alterations to buildings involving the fit-out of the shell which the subject of a continuing requirement;

4. limited life buildings which have an intended life of less than 2 years; and

5. buildings that are subject to Schedule 1 of the Building (Scotland) Regulations 2004, as amended. Buildings such as this include a nuclear power station, monument, agricultural greenhouse, a railway locomotive building, caravan or mobile home, temporary building (not used for more than 28 consecutive days or in excess of 60 days.

Is an EPC result likely to have changed?

Perhaps. Non-domestic EPC results may well differ slightly from a few years ago even although nothing in the building has changed. The current SBEM engine is version 4 and even since version 3.5 there have been changes made that will effect the way the calculation engine determines the EPC rating. We have found that the most recent SBEM version is likely to improve the rating a building achieves. Changes to the approved software method have reduced during 2013 2014 with the expectation that any further changes will be small so as to create a level platform for comparison.

Is an EPC required for a lease renewal?

EPC FAQs, Frequently Asked Questions, EPCs EPC Frequently Asked QuestionsAn Energy Performance Certtificates is not required for a lease renewal of a non-domestic building in Scotland

EPCs are required to enable potential buyers, tenants or building occupiers to consider the energy performance of a building. Certain transactions would not amount to a sale or let to a new owner or tenant and would therefore not require an EPC and these include.

• lease renewals or extensions

• compulsory purchase orders

• lease surrenders.

This source of this information is The Energy Performance of Buildings (Scotland) Amendment (No.2) Regulations 2012. (SSI 2012no.208)

Regulation 5 Part 4. (4) Any reference in this regulation to the letting of a building or building unit does not include the renewal of an existing lease with the same tenant.

Regulation 5 within this document replaces regulation 5 of the 20028 Regulations to provide that an energy performance certificate is to be shown to a prospective new tenant or buyer and provided to an actual buyer or tenant.

Is the EPC rating system different in Scotland and England?

Yes. The calculation rating system for EPC ratings in England and Scotland is different and EPC grades should not be directly compared. Please see our full article here.

Are EPC recommendations mandatory?

No. Although by implementing some of the recommendations this may reduce running costs and increase the attractiveness of the property to prospective occupiers and/or investors. In ENgland and Wales minimum EPC requirements are due to be introduced.

Do holiday homes require an EPC?

Do holiday homes require an Energy Performance Certificate?

Residential property rented out for the purpose of a holiday do not require an EPC. An EPC is required though when the letting period to the same person is for 12 weeks or more.

Is an EPC required for sheltered housing?

A domestic EPC (produced under RdSAP) is required for individual residential properties. An non-domestic EPC (carried out using SBEM) is required for common areas.

What is the penalty for not having an EPC?

Local Authorities can take enforcement action to ensure compliance under Section 25 of the Building (Scotland) Act 2003. Penalty charge notices may be issued in this case.

Is a care home a public building?

No, a care home is not a public building for the purposes of EPC legislation. An EPC would only be required if a self contained unit within the the care home was for sale or to let.

Design lighting calculations

Why is a Design Lighting Calculation useful?

The assumptions that SBEM makes when calculating energy use of lighting is different based on the information available. With no lighting information available, SBEM makes assumptions based on the lighting type for instance T5, T8 HF tri, T12 , CFL or Tungsten etc. The assumptions on the efficacy of these lighting types are highly conservative and so produces a worse EPC rating than might be the case.

What's the solution to not using SBEM's assumptions for lighting?

If a building’s original full lighting design is available, and there is no discrepancy between that and the observed lighting within the building, the wattage and lux values, from that design, should be entered using the ‘Full lighting design carried out’ option in SBEM. 

SBEM allows the option of entering the lighting design data if a lighting survey undertaken in accordance with the Society of Light and Lighting (SLL) can be carried out. Evidence of achieving a complete blackout of windows and the required calculations to establish the grid size for the measurements taken must be provided.

Shell buildings

What is a "shell building" for the purposes of building control?

Shell and core EPCsA shell building for the purposes of building regulations and EPC production is not simply a building with no heating or lighting.

In the context of application for building warrant, a shell building is defined as a building where elements of the fixed building services are absent and further installation work will be required before the building can be occupied and used. A staged building warrant, covering both shell and subsequent fit out work, is not subject to the following process. Shell buildings are subject to the compliance check against the TER under the conditions specified in clause 6.1.10 of Section 6. Guidance on provisions and details of the limiting standards for shell and fit out buildings are specified in clauses 6.2.3, 6.2.4, 6.2.5, and 6.2.6 of Section 6.

Assessment under standard 6.1 is required both for the shell building warrant and also for the subsequent fit-out works, provided a continuing requirement in this respect is placed upon the shell warrant. Regardless of whether or not a building warrant is required for fit-out work, this continuing requirement must be discharged before the building can be occupied (refer to clause 5.6 of the BSD Procedural Handbook).

Assumption when an EPC is produced for a 'shell building' as defined by building regulations

Assessment of the fit-out work should be made using the category ‘other buildings’ under ‘S6 type of building’. Assessment of the shell building should show that the building, as completed, could meet standard 6.1. This is done by providing a completed service specification for each zone, identifying which services are to be installed as part to shell works and which are assumed to form part of a subsequent fit-out. Assumed (uninstalled) services should be defined at zone level by identifying whether the zone is a fit-out area (approved software tools must allow for this identification).

Standing heat losses

Standing heat losses in Domestic Hot Water calorifiers

In order to reduce energy usage and the requirment to re-heat hot water due to standing cooling, storage vessels should be insulated. Scottish Building standards outline minimum specifications in Section 6.4 that storage vessels must comply with. These standing heat losses are measured in kWh per 24 hour period. An example of maximum heat losses are as follows: 200 litre storage vessel - 2.1 kWh/24h. 300 litres - 2.6 kWh/24h. 400 litrres - 3.1 kwh/24h. (2013)

In addition to guidance within clause 6.4.1 of the scottish non-domestic building regulations, other pipework that connect to the vessel, including any vent pipe or primary flow and return should also be insulated from their point of connection to the vessel to a distance of about 1m or to where they pass into the building fabric.