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Energy Performance Certificates (EPC) and Short Term Let (STL) Accommodation

EPCs were introduced into legislation through The Energy Performance of Buildings (Scotland) Regulations 2008 (EPBR). Since then any building being erected, sold, or let has required an EPC. Previously guidance was published by the Scottish Government (SG) that STL properties were exempt from this requirement, this guidance has since been withdrawn as it may have been unlawful. Although EPCs were introduced as part of European Union (EU) directives the legislation remains in place, and this is not expected to change. DM Hall can provide a wide range of Energy services to ASSC members.

What are the types of EPC?

An EPC is a certificate that gives a rating to a given building based upon its energy usage and carbon output. There are two types of EPC that can be calculated, domestic (residential) and non-domestic (commercial). The two are quite different so what is required for STL accommodation?

Most STL accommodations will be domestic in nature however larger properties may be closer in nature to a commercial property, and what if your domestic property is let often enough to be considered for business rates? The EPBR does not consider the tax status of the building when considering what type of EPC is appropriate. Instead, it refers to building regulations where a dwelling is defined as;

A unit of residential accommodation occupied (whether or not as a sole or main residence):

  1. by an individual or by individuals living together as a family; or
  2. by not more than six individuals living together as a single household (including a household where care is provided for residents)

Most STL accommodation is likely to fall into either a. or b. above however if your property provides accommodation for 7 or more people it could in theory fall out with the definitions and therefore require a non-domestic EPC. Owners of larger properties will need to take a view on whether they consider their property to fall out with the above definitions.

Domestic EPC

As discussed, a domestic EPC is likely to be the most appropriate for many STL properties. A domestic EPC is a reasonably straightforward assessment of the property taking into account the overall size of the property, its age, how it is heated, and whether or not the property benefits from double or triple glazing among a number of other elements. The calculation will result in two ratings presented in the format shown below.

Minimum Energy Efficiency Standards (MEES) are due to be introduced in Scotland for domestic private rented sector property by 2025. This will require private rented property in Scotland to achieve a certain rating, currently expected to be D, before it can be let. Clarification is being sought on whether this will apply to STL properties but early indications are that it may not apply as no tenancy is being formed. The Scottish Government will be consulting on this in due course.

A domestic EPC can only be provided by an accredited domestic energy assessor. DM Hall have a nationwide network of accredited assessors ready to help.

Non-domestic EPC

Where the STL is a larger property a non-domestic EPC may be calculated. The non-domestic EPC uses similar information to the domestic EPC such as size of the property, its age, how it is heated, and whether or not the property benefits from double or triple glazing among a number of other elements, however here the similarities end.

Calculation of a non-domestic EPC requires the building to be digitally modelled in three dimensions before a rating can be sought, this is a complex and lengthy process and as a result a non-domestic EPC is typically more expensive to produce. The calculation will produce a graph similar to the below.

As with the domestic EPC a series of recommendations to improve the building will also be provided Very large buildings, those over 1000sqm, are subject to further assessment and may be required to make physical changes to the building. If your building falls under this definition DM Hall will be able to provide specialist advise on the best way forward. Additional legislation to improve the ratings of non-domestic buildings is due to be introduced by 2025, the specifics of this legislation have not been published and DM Hall will be keeping a close eye on SG announcements in this regard.

A non-domestic EPC can only be provided by an accredited non-domestic energy assessor. DM Hall have a dedicated team of assessors ready to help.

EPC exemptions

There are a number of exemptions that a STL property may fall under. If you are unsure if any of your properties are exempt from the requirement get in touch with DM Hall for specialist advise. The following property types are likely exempt from the requirement to obtain an EPC. Static caravan or ‘parkhome’ – this may include properties such as ‘pods’ or ‘shepherds huts’ which are mounted on a chassis either having wheels or capable of having wheels fitted without modification. This may also include ‘unconventional’ accommodation such as ‘glamping’ yurts. Bed and breakfast/guest house accommodation – an EPC can only be provided over an entire ‘self contained unit’, where a guest is only renting a part of a building such as a bedroom then no EPC is required. However where the STL accommodation could reasonably be considered a ‘self contained unit’ meaning it has private living, bathing, and cooking facilities an EPC is likely to be required.

Certain holiday park accommodations where the guest is unable to select their specific residence at the time of booking.

What if I already have an EPC and what should I do with it once I have it?

EPCs have a 10 year life span, so if you bought your property within the last 10 years chances are you already have a valid EPC. You can search for valid EPCs on the Scottish EPC register – www.scottishepcregister.org.uk

Once you have an EPC rating it should be displayed on all your marketing materials, this includes printed brochures, booking websites, and social media posts.

Need more help?

DM Hall have partnered with the ASSC to provide discounted services and advise to their members. On most occasions a DM Hall assessor will be able to help over the phone at no cost. You can contact DM Hall at assc@dmhall.co.uk or call their dedicated energy department on 01383 621 262.

You can also view the SG guidance online here – www.gov.scot/publications/energy-performance- certificates-introduction

Disclaimer – Guidance Sheets are written by experienced Members of the ASSC and other experts. The information in the ‘Guidance Sheet’ is provided by the ASSC for use by Members in support of their own independent business decisions. It does not constitute advice or instruction for which the ASSC can be held liable in any way whatsoever. All Members and other readers remain responsible for the consequences of any decisions taken whether in the light of information gained from this Guidance Sheet or not.

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