Does the EPC registration scheme fail the owners of listed buildings? 

Across the UK there are around 400,000 buildings on the listed buildings register with around 27,000 of those located across Greater London. Many of these buildings, including heritage buildings that have not been listed, are some of the most energy inefficient properties in the country.

Addressing this issue is important not only to avoid contributing further to the built environment’s negative impact on climate change, but also to ensure that buildings of social, cultural and historic significance remain in use and cared for. But does one key source of guidance on this issue, the EPC register, help or hinder owners of listed buildings?   

Owners of listed buildings face two key issues with the EPC register. The first problem stems from the lack of clarity around whether listed buildings require an EPC in the first place. There is a widely held misunderstanding that EPCs are not required for listed buildings and, if there is no valid current EPC, there is no obligation to comply with Minimum Energy Efficiency Standards (MEES).

However, the EPC regulations do not state that listed buildings are exempt from the requirement to obtain EPCs but rather they are exempt “insofar as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance.”  

However, Londoners are keen to be green. In a poll conducted by London councils in 2022, 84% of residents stated that they were concerned about climate change and 72% said that this concern had increased over the previous year. While just over half of respondents specified that they planned to make more environmentally sustainable choices, of those who did not, some  reported the cost of installing heat pumps or solar panels was too high. For listed buildings, the need to balance the conservation of the property can require specialist materials and installers, adding to costs.  

The second issue arises from the guidance offered by the EPC register to mitigate the carbon output of a property which includes suggestions already ruled out by most planning authorities. Beyond changing light bulbs or heat sources, these include installing double-glazed windows or installing insulation to walls, either internally or to the exterior of the building or insulating the loft space.  

While it would be obvious to anyone that installing UPVC windows to a heritage building would clearly affect ‘the character or appearance’ in a negative manner like for like double glazed timber-framed units are not always welcome. Depending on the design of the ceiling; flat or vaulted it would not make installing loft insulation an option for all. But it is wall insulation that is likely to cause the greatest issue.

Most older buildings, heated by fires, were built from natural materials and designed to breathe, allowing any moisture to evaporate slowly. Installing contemporary insulation materials to interior walls prevents this and often leads to damp and mould, while the option of wrapping the building externally would also alter the architectural character of it. 

The EPC register and the energy certificates from which the data is drawn would benefit from a more nuanced understanding of the construction and properties of different material types used across the diverse range of architectural design and construction methods.

The government’s guidance acknowledges that “to comply with minimum energy performance requirements, many of the recommendations in an EPC report e.g. double glazing, new doors and windows, external wall insulation and external boiler flues would likely result in unacceptable alterations in the majority of historic buildings.” 

Ahead of that, however, greater clarity around EPCs for listed buildings is required along with national, detailed guidance on acceptable works. Without clear policy and guidance from local authorities, many owners of listed buildings will expect that there is next to nothing that they can do but some councils are clarifying their position.  

Kat Martindale is head of ESG research at Savills