EPC reform needs to work for residents in the homes we manage day to day. Changes to the methodology should support better decisions on where to invest, without creating additional disruption or cost for households already facing affordability pressures.
Our response focuses on how the Home Energy Model will operate in practice across large and diverse portfolios. This includes older homes with limited construction data, high-rise and mixed-tenure buildings, and areas where delivery is constrained by building safety requirements, leaseholder processes and supply chain capacity.
As currently proposed, there is a risk that new metrics and thresholds drive investment based on modelling outputs rather than real performance. Homes close to the C/D boundary can shift band based on minor survey inputs, creating pressure to carry out low-impact measures simply to meet compliance. At the same time, rigid cost caps and conservative defaults could lead to significant spend on hard-to-treat homes where improvements to comfort, bills or carbon are limited.
A workable framework needs clearer transition arrangements, proportionate treatment of existing stock and flexibility in how compliance is achieved. This includes recognising delivery constraints in flats and dense urban settings, ensuring exemptions operate on an assessed basis, and targeting investment where it will deliver the greatest benefit for residents. Affordability must also be addressed alongside efficiency, including through targeted support such as a social housing energy tariff.