Over recent years The Almshouse Association has received a number of enquiries on the subject of EPCs and their requirement with regards to almshouses.
We have sought expert opinion in order to offer best guidance. Our ability to offer guidance has been complicated by contradictory opinions from government and independent experts.
In guidance we published on our website in 2019 we stated that, for almshouse charities with existing residents, a new EPC is not required but, since 2008, an EPC is required for new occupations/residents and, whilst these laws do not specifically mention almshouses, consistent advice from the (then) Ministry for Housing Communities and Local Government stated that almshouses would be required to follow this legislation.
There has been some confusion with regards to the legislation which is relevant in this situation.
- The Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 relates to the requirement of a private rented property needing to achieve an EPC of E or above.
Since almshouse accommodation is not ārentedā accommodation, we believe there is scope for almshouses to be excluded from the regulation. This is in line with the majority of Housing Associations and local authorities who are also exempt.
- There is, however, a requirement to obtain an EPC when introducing a new resident as covered by The Energy Performance of Buildings (Certificates and Inspections) (England and Wales) Regulations 2007.
Although almshouses are not specifically mentioned, independent advice suggests that almshouse do need to follow this guidance when introducing a new resident. The Association does not believe that trustees must provide a copy of the EPC as standard, rather that it should be provided if requested.
- The Governmentās recent White Paper regarding the transition to net zero made a number of suggestions regarding the requirement for social housing landlords to reach EPC C by 2030 and banning the installation of new gas boilers. Specific confirmation of these policies, however, is yet to be made.
At this present time, it is not the opinion of The Almshouse Association that members will be required to reach EPC C by 2030.
- If a member is managing a Listed Building the situation is much less clear. The Association will continue to push for firm guidance on this issue.
In summary, the situation is frustrating in that Government has not provided the necessary clarity for us to reassure our members. What is clear, however, is the general direction of travel when it comes to the wider green agenda.
As such, The Almshouse Association would recommend that members do get an EPC for their dwellings as this is likely to be a useful tool in meeting the requirement of trustees to ensure the long term viability of the buildings you manage. The EPC will also allow members to make long term plans for your charity when it comes to implementing suitable energy efficiency measures.
Posted 13 December 21