Landlords are being encouraged to carry out retrofitting works to their properties to improve their Energy Performance Certificate (EPC) rating – and in particular, to improve the insulation.
But listen up. Here is a warning from a landlord who did just that.
A Landlord’s Story
The landlord, who we will call Sue, carried out a full ‘gut and refurb’ on a house nearly 10 years ago. The works included insulating walls and floors, which resulted in an EPC rating for the property of C.
This was done under the building regulations, and Sue had a certificate. However, EPCs only last for ten years, so now she has to get a new one.
She went to the same EPC surveyor but guess what? He told her he would have to downgrade the rating to a D because he can’t actually see the insulation!
Which is a problem. Obviously, once the insulation has been installed, it will be covered up.
The surveyor apparently suggested that he drill holes in the walls and floor to check. But as the property has just been redecorated and had new flooring laid, this was not really an option.
So what did Sue do?
She told me
The building regs certificate does not state in any detail what works have been done which I did query at the time with the surveying company, but that is how it is.
I have now got the regulating body to agree to look at photos of the refurbishment and take a view on the situation, but this is not a certainty.
Fortunately, I do have lots of photos of the refurbishment but I can’t locate the original correspondence with the building regs surveyor, and whether they will have it nearly 10 years on, I have yet to find out.
Sue ended her story by suggesting that I pass it on to warn other landlords.
So what should you do?
If you are doing works, such as insulation, which will be hidden after they are completed, it is essential that you retain proof of what has been done. So this could be:
- A detailed report from the installer
- Photographs taken at the time recording the works
- Detailed receipted invoices which set out the work done
But make sure you can prove that the walls, floor or ceiling have been properly insulated.
Otherwise, you may have to drill holes before you can get your C certificate.
Does anyone have any similar stories to share?
I had the very same issues as Sue, but the point I’d like to make is this.
I had the spray foam insulation to the roof, which as you have pointed out on one of your other blogs, renders it impossible to get a mortgage on, unless it’s removed, yet the government are encouraging us to do it, even giving grants.
When my ERC ran out, the assessor said it didn’t count for anything, I was only keeping the roof warm. I had to get my tenant to remove everything from the loft, take the flooring up so he could see the insulation, which wasn’t enough, then raise the floor to increase the space for more insulation. I still only came out with a D because there is only electric heating, all be it modern, state of the art electric radiators. No gas supply to the village and is oil a green option anymore?
So, what do I do? add solar panels… no south facing roof.. put in a heat pump? thousands! Like a lot of landlords, I’ll be selling up, as long as I can get a buyer with the foam roof insulation!!
I think a similar situation could arise regarding electrical safety. I have recently had the smoke alarms interlinked, as required in Wa!es, but I do not have any proof that it’s been done. Nothing was itemised on the invoice and the EICR, as far as I can tell, does not show it. But I appreciate this wouldn’t be as disruptive as proving insulation.
Hi Mandy, Assuming I understand your situation correctly, if the smoke detectors are interlinked, this is readily verifiable – whether it be by your good self or others – simply by pressing the “test” button on one of the detectors and, if the other detector also sounds automatically then they are interlinked. (If it doesn’t sound then it is either not interlinked or there is a problem that needs to be investigated further.
Along with others I have, on many occasions in the past – and on various Landlord forum, been making the point that I have a number of properties that have a “D” rating and, that the EPC documents indicate there is no insulation in both flat roof areas or in the main loft areas of the properties despite such insulation actually being in place, because I physically installed it during renovation works.
When questioned about this I have been informed by the – so called energy surveyors (it seems that anyone can attend the course with no previous building experience and become accredited) – that they are told that such inspections are “non invasive”. Which they interpret as meaning they don’t even pop their heads into the main loft voids to check.
The system is really bordering on corrupt with Landlords, such as myself, potentially having to spend money on a property – maybe on internal wall insulation etc – that is already in compliance with an EPC rating of “C” but, because of how the “system” is set up existing insulation measures are ignored.
I had the same insulation issue The EPC assessor would not accept a letter from my building control company or visible insulated board in the gas cupboard in the living room as he said I could just insulated round that cupboard
I wonder what the legal position on this would be if you had the necessary (but not visible) requirements installed to meet minimum EPC regs, but the tenant for example won’t permit invasive discovery? Im sure few tenants would appreciate their floors being dug up!
Again, exactly the same issue as Sue (and others). I used a Domestic Energy Assessor who would accept the architect’s drawings from 14 years ago that specified 100mm celotex accompanied by the Building Regulations sign-off confirming the property had been extended (into the loft) in compliance with the then regulations. Although it seemed perfectly obvious that this ought to be acceptable proof of insulation having been installed, it was a bone of contention (fortunately, I had a picture of the build at the time with a stack of celotex in the corner of the shot – that was the clincher…)
Same problem as others – new roofs done with Invoices saying insulated to current standards, building certs etc and the back addition areas are described as ‘no insulation assumed’ when they are fully insulated to current standard.
Tried discussing with EPC assessor re pictures, invoices etc and he didn’t want to engage. NRLA recommended fully documenting invoices, photos etc but not sure it will be accepted; I need wall insulation to reach a C for some properties but whatis the point if the EPC assessors won’t accept evidence.
If the government want landlords initially, and the general public by 2035, to improve the insulation of properties then this needs sorting.
Have exactly this problem on all 3 of my properties in Wales. They were all gutted back to the bare walls and the floors dug up etc. Internal walls insulated, floors insulated and loft insulation to current regs. Not one of the properties has come up to a C rating because we did all the work ourselves and didn’t use registered installers. I tried showing the inspector the various invoices for the different kinds of insulation purchased. Showed him the internal windowsills which are now 10″ etc as proof of the internal insulation but none of the work done has been counted (not even the loft insulation which he didn’t even bother to go up into the lofts to view!) All the tenants have commented on how warm the houses are and all are very happy and have been our tenants for over 10 years . We will not be spending one penny more on further insulation and when push comes to shove these properties will go on the market and another 6 adults and 9 children will become homeless in Wales. We really can’t be bothered with the hassle anymore.
Surely if a building inspector checked the work and certified compliance the inspecting body (local authority or approved) will have full records of the work they inspected and will provide them on demand.
I had the same issue. The 230 year old house had a D ratting EPC from 2011. Five cms of insulation was added to the ground floor rooms after insistence by the local building inspectors during renovation. This made the rooms noticeably smaller. Then we had all new triple glaze windows and doors added at a cost of about £5,000.
On renewal of the EPC in 2021 we were given an E rating. On querying how we could possibly have been down graded the inspector said he could tell there was insulation in the walls but didn’t have any written evidence from the building inspectors. Note- he didn’t ask for any.
I looked at the planning permission documents from the council and there was no mention of the insulation installed. He also chose to ignore a sample of the insulation I left out for him to see. He also said new triple glaze windows didn’t really make a difference – really?
I think I paid £70 to the inspector for a crummy, inaccurate EPC report.
It was a bit annoying at the time but now the government are changing the min EPC ratings for a rental to a C by 2035. Looks like we will have to drill holes in the wall to show the depth of the insulation, order a new EPC and hold the hand of the inspector to ensure he does the job correctly!
Maybe when you do this, you should get a professional, for example a surveyor, to check as well and certify, perhaps by signing an affidavit, that the insulation is there and state how thick it is.
Then hopefully you won’t have the same problem in 10 years time.
I think the whole system is corrupt. I has an EPC assessor ‘Paul from XX services to come and promise that if I got him to get roof fully kauf insulated i would get a ‘C’ grade. I paid the £446.50 in January and have still not got a certificate.
His ‘bosses’ XXX, say they will refund £45 to get someone else to come and do a report, as Paul was not AT THE TIME permitted to issue certificates.
(Editorial note – names removed to protect the site from any claims)
Wow! I thought I was alone when I encountered the very same problem. I have a grade 2 listed building which is converted into 2 flats; one at top and one at bottom.
Top flat maintained a C and bottom flat downgraded from C to D. The assessor would not accept photos as evidence, wanted floor lifted to see insulation.
I have another flat where EPC is about to run out and got a provisional EPC specifically asking the assessor to discuss options to raise it from D to C which he said he would but he merely did the EPC without any meaningful recommendations, suggesting I find a builder instead who could advice! waste of money or should I say nice gig to become an assessor and earn money for old hat!
I feel there is something extremely wrong when building regs certs are not good enough evidence for EPC assessor. What sort of madness is this? Why is there not government guidance on what is acceptable evidence so people who get work done can make sure they have it when they are getting the work done?