Commercial Energy Performance Certificates

Commercial EPCsYou will have heard of the residential Energy Performance Certificates or EPCs that were instituted last year as part of the Home Information Pack legislation, but did you know that there is a Commercial Energy Performance Certificate that is currently being rolled out?

It is easy to assume that because both the residential and commercial EPC share the same name that they are similar entities and require similar surveys or skills, but nothing could be further from the truth. It is best to think of them as cousins, related in history, but separate families.

When is a Commercial Energy Performance Certificate (CEPC) required? You may not have been aware of it, but Commercial EPCs actually began to roll out this year, coming into force from April 2008. Already all non domestic buildings above 2,500 square metres that are being constructed, sold, major renovations or let will require a CEPC.  By 1st October 2008 this will be rolled out to all remaining commercial properties. As always there are exemptions, such as places of worship, buildings scheduled for demolition or temporary buildings. Anyone involved with any non domestic property should seek expert advice as to whether they need one or not, as there are stringent penalties for non compliance.


So what is a Commercial Energy Performance Certificate? Well, first off, there is no Home Information Pack equivalent in the commercial sector, the Commercial Energy Performance Certificate is designed to function on its own. Next, the survey itself is a thorough assessment of a non domestic building, from the construction fabric, through to the lighting, heating and ventilation systems that are in place. From there the data is analysed to produce a rating of how energy efficient the building is along with accompanying reports recommending potential improvements.

Sounds similar to a normal residential EPC? The general procedure is much the same, but on a Commercial EPC is far more intensive. A Commercial Energy Assessor (CEA) is a dedicated and qualified specialist in their field. An assessment site survey could last several days or need a team of assessors on a larger property, requiring full access throughout all areas, access above any false ceiling and access to plant equipment, even onto the roof on some occasions.  A CEA will also ask for access to various documents such as maintenance logs, gas certificates, pressure testing certificates, floor plans and elevation drawings. Finally, the software used in analysing the data is far more comprehensive than that involved in the residential sector, as are the final reports.

But that isn’t the only difference between the residential EPC and the commercial EPC environments. In the residential sector a qualified Domestic Energy Assessor (DEA) can cover all existing domestic properties and provide EPCs as required. In the Commercial sector properties are broken up into Levels based on various property factors. A Commercial Energy Assessor has to be qualified for the property level that they are undertaking.

So, all in all, the Commercial EPC is a very different entity from that in the Residential sector, even though they do share some core ideas. The Commercial EPC is a complicated environment and professional advice should always be sought. Try to avoid using panels or middle men, and speak directly to the experts in their field. This market will rely heavily on the quality of the professionals in it, so make a good choice when you engage a company or an independent contractor for your CEPC.

One final thought for the day. Rumours abound in the market that the government will postpone the Commercial Energy Performance Certificate, just as they did with the Home Information Pack a year ago. This is unlikely to happen for several reasons, not least of which is that the CEPC has been rolled out throughout the year without respite, no matter the issue.

Written by Symon Silvester.


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34 Responses to “Commercial Energy Performance Certificates”

  1. While Commercial EPC’s for properties of 2500sq m+ they represent only a small element of the commercial property market. CLG guidelines say all commercials must have an EPC on October 1st NOT just properties coming to the market from that date. CLG will not say how many assessors are accredited. My reasearch in the past 2 weeks indicates that there are only 375 qualified for Level 3 and above. Another 53 are qualified to only do DEC’s! It is believed that 220,000 Commercial EPC’s per year- a monthly average of 18,333. Quite how the number of assessors can cope with 18,000+ per month and the number of properties already on the market is beyond me.

  2. Hi John,

    They are quite detailed numbers and figures you quote. Would you mind expanding on how you reached these figures.

    It would be beneficial if commercial energy assessor numbers were officially released by the CLG as are the domestic energy assessor figures; this would help give a good picture of potential work loads commercial energy assessors could expect.

  3. CIBSE almost 200, BRE around 70, ECMK 5, NHER 5 – information obtained direct from the Accreditation Boards themselves. STROMA 125, RICS 16, QUIDOS 2 & 53 DEC only qualification arrived at by analysis of those shown on http://www.ndepcregister.com. Neither ELMHURST or NORTHGATE appeared on ndepc register and were not prepared to divulge numbers. BESCA, HVCA & HIC Ltd are under the same control and say they will not start Accreditation until towards end of year. NAPIT the person who may be able to provide numbers is on holiday until September 3rd!

    CLG have rejected a Freedom of Information Act request seeking disclosure of numbers of CEA’s in training, qualified and accredited because ” At this point in time, the harm that may be caused to the success of the project, which is in the public interest,outweighs the general public interest of disclosure.” Quite how it is not in the public interest to speak about something that is in the public interest seems to defy common sense!

    One has to wonder why you would not disclose the numbers of CEA’s if sufficient were readily available to adequately service the commercial market.

    Hope this adequately answers your question. If you need any further information do not hesitate to contact me.

  4. Thanks for sharing your research John and wondered if it was figures gained through accreditation schemes. We did some similar research though admittedly not as thorough, however we were given different figures from 2 of the accreditation schemes you refer to.

    This can easily be explained due to assessors constantly qualifying and becoming accredited therefore the numbers increasing. Even more reason it would be interesting to know the exact numbers of people in the system, training, qualified and accredited.

  5. Hi John

    I am a little confused with your comments. Noone is ignoring a shortage of CEAs in the market, that is a fact and it is also a fact that the roll out so far for 10,000 and 2,500 sq m2 has gone ahead without hold up despite the shortage. Noone is refusing to disclose numbers of CEAs.

    Finally, I have to correct your assumption on CEPCs. The DCLG Guidance on Non Dwellings which covers CEPCs and DECs guidance states the following on page 10:

    “1.3 When Energy Perfromance Certificates are required.

    From 6 April 2008 those buildings with a total useful floor area greater than 10,000 m2…will require an Energy Performance Certificate on construction, sale or let.

    From 1 July 2008 those buildings with a total useful floor area greater than 2,500 m2…will require an Energy Performance Certficate on construction, sale or let.

    From 1 October 2008, all remaining buildings that are not dwellings will require an Energy Performance Certificate on construction, sale or let.

    EPCs for the sale or letting of buildings will be valid for 10 years.”

    Sorry to take up so much space but it is clearly laid out that buildings will need one only after these days when constructed, sold, or let. There is a requirement as well for renovations which may change the energy efficiency of the building.

    There is no requirement for a CEPC to be done on ALL buildings by these dates. Please also note that the article only talks about CEPCs, not DECs. DECs are a different entity completely.

    The current proposed aspect of a CEPC is, like with the residential EPC, that it must be made available or placed into a potential buyers/tenants hands before the exchange of contracts. Which in the commercial sector will mean instructing an CEPC at the beginning of the process and it being completed before the exchange of contracts. In commercial property this could be months, which is a far longer time span to get a CEPC done, taking into account the shortage.

    Noone is disputing your claim of a shortage. There is. But the roll out is going ahead regardless.

    I hope this adequately addresses your points.

    Symon

  6. The regulations Symon refers to are ‘DCLG Guidance on Non Dwellings‘ which covers CEPCs and DECs for the construction, sale or let of non-domestic dwellings.

    These guidance notes were revised on 2nd July 2008 and can be found on the link.

  7. Morning Symon,

    Sorry if I have caused confusion. Yes it may be that 10,000 & 2,500 sq m properties have been done without problem I have never suggested there was a problem for such properties specifically. I’m sorry but it is a fact that CLG are refusing to say how many CEA’s there are accredited I have the paperwork to prove it. ELMHURST will not say how many they have accredited I have spoken to them. STROMA will neither confirm or deny my estimated figures again I have spoken to them. If you know the exact numbers I would be pleased to hear it.

    I’m not sure which edition of Guidance notes you are using as the dates of EPC launch but edition 2 (July 2008) has them on page 10. I would draw your attention to page 21 “4.1. What it means in practice” ” A valid EPC & recommendation report …. this must be at the earliest opportunity and no later than. – When any written information about the building is provided in response to a request for information received from the prospective buyer or tenant. – When a viewing is conducted.” Clearly there is confusion at CLG which really needs to be urgently addressed.

    AS far as residential EPC’s your point is valid at the moment but as I understand it the transition period ends on Oct 1st meaning all properties will need an EPC to legally remain on the market.

    I accept your point about the article and DEC’s.

    Sorry if I sound belligerant but its not aimed at EA’s but at CLG who do not appear to have thought through the complexity of CEPC’s or set out a sensible time scale for introduction.

  8. Hi John,

    These are the guidance notes i have linked to in an above comment.

    In regard to when the legislation applies, it seems clear that it only applies to non-domestic dwellings that wish to be marketed for sale,rent and when constructed.

    Therefore, exisiting properties NOT being marketed for sale,rent and when constructed (as with domestic EPCs) do NOT require a CEPC.

    If this was the case i see no doubt current assessor numbers would struggle servicing that many properties. However, this is not the case at present.

  9. Morning Hip Consultant,

    I would be interested to know the Boards, Figures and Date obtained from your research.

    Yes the figures are constantly changing this morning on ndepc register I note the number of RICS accreditations has risen by 6.25% put more simply by 1.

    No doubt the numbers will rise substantially the question is will it be in time for October 1st.

  10. I feel the numbers we have been told are not to be relied upon and do not give a ‘true picture’ of assessor numbers. The figures are not vastly different to your research from the 2 boards we spoke to.

    Unfortunately to work out the likely number of assessors in this market it is vital to take into account those studying and awaiting accreditation as this could massively expand numbers in a short period.

    Until ‘official’ commercial energy assessors figures are released it is speculation.

  11. Symon,

    In my response to your last post you mentioned that no difficulty had been encountered on 10,000 and 2,500 sq m carried out since indroduction.

    Do you know how many of these properties have had EPC’s done?

    There is an unsustantiated rumour that as far as 10,000 sq m properties are concerned it is 500 an average of 100 a month!

    It would also be interesting to know many DEC’s have been done towards the 42,500 expected to be needed. I would welcome any info in this regard that you or anyone else might have.

    John

  12. Hi John

    Thanks for your comments. I didn’t say that there wasn’t any difficulty in doing the existing CEPCs in the market, just that the roll out was going ahead regardless. That is why the rumours about a delay in October are likely to be wishful thinking. In my opinion, and with no signs the DCLG are considering changing it, the full roll out will happen on the 1st October as per the schedule. Yes, you are right the market is desperately short of assessors, at Level 3 and more so at Level 4. But the roll out has continued to happen and all evidence points to that it will continue to happen on schedule.

    What will give is the need to have the CEPC done before the sale is marketed. Some variation on having asked for the CEPC to be done, and it being done by the exchange of contracts will be the only way around this until the level of assessors pick up.

    In fact the bizarre thing is several of the larger companies and chains who don’t even need CEPCs as per the terms outlined in the guidance have actually asked for CEPCs to be done.

    The problem with the DECs is that the government delayed the NOS for DECs until the last minute, which meant noone was able to build approved training courses until the last minute, and then delayed the final versions of the free to download software required. Again a total DCLG cock up, but what else is new?

    As for the guidelines, I was reading from an old version, and having read the new version today, it just clarifies the points I have made even more.

    I am certainly not arguing with your points about shortages and the consequences of those shortages. I personally am as concerned about those as anyone. What I am more concerned about is the amount of people who either don’t know this is happening or are counting on it being delayed. We have to educate the market and hope that Trading Standards and the DCLG will show sense when companies are required to have a CEPC, and have delays in getting it done.

    I would love to be wrong, but I don’t see the DCLG cancelling or delaying the final rollout in less than a month.

    Symon

  13. Hi Hip Consultant,

    I have reread my original post and have realised it is indeed confusing.

    I did not intend to imply that all commercials needed an EPC from Oct 1st. What I had meant to get across was that all non domestic (commercial)premises that are being marketed on October 1st or subsequently required an EPC. This ofcourse means that existing stock on agents books needs an EPC if it is to remain on the market legally after Oct 1st.

    My points were made on this basis and are I believe valid.

    In addition to my research into EA numbers I contacted 8 firms of Commercial or Business TransFer Agents – the firms were all members of either RICS or NAEA/ICBA – and 7 were assuming that it only applied to new instructions from Oct 1st. One of the firms alone has 1200 properties on its books none of which currently have an EPC. I also know of 3 BTA firms that have instructions on around 13,500 premises that will need an EPC but so far do not have.

    Taking the 4 firms together and dividing by 375 assessors gives each assessor 39 to do for these firms and this ignores all the other BTA’s let alone the customary fare of the typical Commecial estate agent.

    Once again sorry for the confusion.

    John

  14. Hi John,

    No need to apolgise, we welcome healthy debate. It is good to receive your input and impressive to read the time and effort you have obviously spent researching the market which must be applauded. If only this had happening more frequently in the domestic EPC market we would maybe not be experiencing the problems we have with over supply of DEAs.

    I understand your calculation though are based upon numbers of assessors that we really are not sure upon. However, it does seem at present commercial energy assessors should be as challenging to secure work as DEAs are.

  15. Hi Symon,

    I agree that October 1st will not change but there will need to be a transition period for existing stock on the market at that date. That being said any date set cannot be later than January 3rd as if it is not running by Jan 4th then UK PLC can be fined £1 mill a day by the EU.

    Hopefully lots of assessors will soon be accredited but with CLG’s reticence to disclose figures I remain concerned.

    It may be that the larger companies and chains are having the work done so that the premises can be sold quickly if they need to cut debit levels or are close to breaching lending covenants? Rumour has it that Punch are having 800 pubs assessed with a view to a sale to cut debit and bolster liquidity.

    You are, in my view, absolutely right that property and business owners are largely unaware of the situation.

    John

  16. CORRECTION to my research figues.
    My estimate of accredited STROMA assessors is wrong.

    The actual figure claimed by STROMA is 45.

    It seems to be getting worse & not better.

  17. Are figures through accreditation schemes really a good way to measure assessor numbers as many also provide training.

    This seems to be a conflict of interest – are they more interested in current members or in recruiting further people for there training courses.

    It seems to be your changing figures through Stroma shows this well John.

  18. The situation where an organisation can be both a training body and an accreditation scheme has enormous potential for conflicts of interest irrespective of the industry. While I have no reason to doubt there honesty STROMA are in my view a concern because, as I understand it, they train people, they accredit the people and then employ them directly.

    On the 5th the numbers of assessors qualified was 333 however 53 were qualified for DEC’s only and 34 qualified to work in Scotland ( I understand they can only work in Scotland). Thus 246 are available to the English and Welsh commercial markets. Of this number 50% of the have been accredited by CIBSE. All my figures have been supplied by the accreditation boards themselves.

    As it is only those accredited that can issue certificates sufficient numbers need to be available if the Commercial property market is to function properly.

  19. Transition period till for premises on market before Oct 1st until Jan 1st announced yesterday to relief of many in commercial agency. The problem of assessor numbers has not gone away. Since my original research I have now spoken with all Accreditaion schemes (only Northgate have declined to provide numbers but as they have nobody on ndepcregister I’m pretty certain its zero) and excluding those who are DEC only accredited and another 34 who are Scotland only accredited I arrive at at figure as at last Friday of 246 and not the 375 I had originally arrived at. Seems the CLG learnt nothing from the domestic fiasco!

  20. Hi John,

    Thanks again for your feedback. Were you able to ascertain how many people were currently training as a commercial energy assessor or awaiting accreditation?

    N.B. the numbers quoted by John are his own personal research, no ‘official’ commercial energy assessor numbers have been released to date. It must be re-iterated that there are numerous different energy assessor qualifications. The qualification being referred to in this article is the Commercial Energy Assessor qualification.

    The transitional arrangements – quoted from CLG

    “clarifying arrangements for the October roll-out for commercial buildings already on the market which will be similar to those put in place in April and July.This means that any non-domestic building on the market before 1st October and remaining on the market will need an EPC by 4th January at the latest. If it is sold or rented out in the meantime, an EPC must be commissioned and then handed over as soon as is practicable. This measure is intended to make it easier for owners and landlords to comply with the legislation, avoid market fluctuations and is in response to expectations from the industry”

  21. Hi Hip Consultant.

    Your absolutely right there have been no “official figures” as to assessor numbers either for those in training or accredited and CLG continue to refuse to provide them. This seems perverse when they have recently been happy to update the information on Domestic Energy Assessors.

    As regards those in training I have only just started the research. It should be borne in mind that you can have the situation where someone can be Accredited at say Level 3 but undergoing training for DEC’s and Air conditioning. For the purposes of my research I am quoting figures based on people who have not yet been Accredited in any way. Air Conditioning Only -18, DEC only -87 , Levels 3,4 & 5-122(includes 11 for Scots qualification only). These figures are derived from information received from CIBSE who account for 50% of those already accredited. Assuming the other boards are following the same pattern then it seems not unreasonable to assume that in total 36 are in training for Air Conditioning, 174 for DEC’s and 244 for Levels 3,4 & 5. This gives a grand estimated total of 454. To arrive at the numbers available to the Commercial Property market in England and Wales one must strip out the DEC only number of 174 and the Scotland only accredited of 22 and this leaves a figure of 258 – roughly the same as are already qualified. Obviously I have no idea how quickly any of these will actually be accredited – some may have only just started training and some may be so advanced that they may be accredited tomorrow.

    While the transition period to January 1st gives the property industry breathing space the only likely way to get everything done is by extensive use of Data Gatherers. After all the Accredited assessor is not legally obliged to visit the property that is the subject of the EPC

  22. yes; Commercial Energy Performance Certificates are becoming more important now…And you blog is giving good ideas for that…keep on updating…

  23. Following a successful appeal of CLG’s refusal of my Freedom of Information Act request there are at last “Official Figures” for Non Domestic Energy Assessors.
    CLG estimate that between 300 & 550 will be needed for current market conditions. Apparently only 36 people were qualified at the beginning of September yet by October 1st 471 were Accredited. The numbers in training were not known.

    This leaves us with the potential in the very near future to have, assuming CLG’s estimate of numbers needed is accurate, a glut of CEA’s – CIBSE alone have a further 135 in training for Levels 3,4 & 5.

    Interestingly the original reasoning for refusing my request originally was “..the sum of the numberof people accredited, applying for accredition and in training exceeded the approximare number estimated to be needed in the current market climate” If this were the case way back in June then the CLG’s assertion that only 36 CEA’s were qualified in Sepember and their lack of knowledge of numbers in training then I’m puzzled by their original refusal!

  24. Hi John

    Yes the CEA market seems to be changing rapidly and the numbers growing at an alarming rate. One can only hope that it does not go the same way as we have seen in the domestic market. Though there are indicators that do point to the commercial assessors field following suit.

    Thanks John for returning with your research on the CEA numbers. It is impressive you have been able to gain figures from the CLG. Have these figures been published officially as yet?

  25. Hi Hip_Consultant,

    If by “officially” you mean on CLG’s website then I do not think so. That being said I know at the end of September their press office told Roya Nikkah of the Telegraph that 550 were the number of assessors needed.

    Just out of interest after the 31st of October you will no longer be able to phone the EPBD Helpline with any questions you may have although they will continue to be contactable by e-mail for a further 6 months.

  26. Hi Hip Consultant,

    On the “Communities” website under Planning and Building frequently asked questions they state that between 300 and 550 CEA’s would be needed needed and that on October 1st 471 were accredited.

    Information seems very muddled from “Communities” as a letter from them on October 31st states that 751 were accredited on October 1st – some 280 more than already claimed. The same letter told me that 1,250 were in training.

    Assuming the 751 is correct and the 1,250 actually go on and become accredited then we shall be in the situation where almost 4 times the higher number (550) suggested by the CLG as being needed will be available to the market.

    As far as the amount of work likely to be available to assessors there seems to be no definate knowledge. STROMA’s website says 220,000 per annum. CIBSE estimate 10,000 per month on their site. CLG’s press office, at the end of September, told the Telegraph, 50,000 per annum.

    If 2,000 become accredited and only 50,000 assessments are undertaken then we have the situation where the average CEA is doing 1 job every 14 days – hardly a big money earner.

    Seems to me we have a similar situation to the Domestic assessors i.e. to many assessors – to little work.

  27. Good evening,

    I appreciate all you say, but as a DEA I am receiving a constant flow of calls from corporate clients that can not locate a CEA some of my clients are solicitors whom have many shops & non-res buildings.

    I have looked into taking the next step. After reading your comments I am a tad confused. If I am receiving a good volume of enquiries would this not demonstrate a strong demand in my area?

    I bid you well

  28. Hi Colin,

    The latest figures I have seen for accredited CEA’s is 685 as at 4/11/08 and I would guestimate this will be around 100 higher by the end of December. Assuming 785 are available then this would mean there are around 42% more people available than even the uppermost number CLG believed were needed at launch!

    Obviously these are only overall numbers and it may well be that in your area there are negligable numbers of accredited – I know that in mid 0ctober that CIBSE accounted for around half of all accredited CEA’s at the time only had 3 Accredited assessors based in Norfolk, Suffolk and Canbridgeshire combined.

    The other thing to bear in mind is that just like the domestic property market the commercial property market is suffering. Big holes in the high street are already beginning to appear – Woolworth (800 units) will be gone by early January, MFI (100 units) are done for, Whittards (120 units) are almost certain to go. Many other mid sized operators could easily start to fold from Christmas Day when many retail rents fall due. Clearly many units will go to other retailers but some will not with the continuing growth in Internet retailing the demand for retail premises is shrinking. Obviously other areas of the commercial market are under presure because of the downturn.

    While the foregoing is gloomy there will always be sales and clearly someone has to do the work and there is no reason it should not go to you providing you market your services well.

    Whatever you decide good luck.

    John

  29. Last post in December, any more updates? I’m considering a CEA course but is the market flooded with advisers now? The courses are about £3,500 by the time you add up all the costs. I do work as a lighting designer, and I’ve just been told by one of the training providers (a big provider) that this is good enough to get me on the course, but in their words ” I may have do do some additional reading”. I’m not sure how I feel about this, yes it’s good you can stretch yourself and progress but equally there should be some industry defined minimum entry requirements. At the very least if you don’t have a relevant qualification you should have to pass an externally verified exam to get on the course.

    Any comments greatly appreciated.

  30. Hi Steve,

    The same applies as above but probably even more so. The market is encountering 2 general problems, oversupply and use of data collectors.

    I have no experience in lighting design and with respect do not know how this could act as a pre-requsite to becoming a commercial energy assessor.

    The number of CEAs continues to grow and reports from assessors is the situation they are experiencing is similar to what has been seen in the domestic market. Far too many assessors not enough work.

    We have seen prices reduce over recent times which could be argued it is good news for the end consumer. However, in addition to over supply the use of data collectors is being utilised more and more.

    Data collection in essence involves a non-qualified individual visiting the property requiring the Energy Performance Certificate and the ‘office based’ qualified individual entering the information gathered by the data collector.

    Whilst this practice was being employed quite infrequently and mainly in the social housing sector where many properties are very similar to each other, the expansion of this practice of collecting and utilising the data in the commercial field has been rising by some businesses attempting to lower fees, expand profit margins and gain market share.

    This is obviously a practice which qualified individuals disagree with due to lowering of fees and the quality of the data and report produced.

    Speak to people and businesses who require CEPCs and measure your reponse. The key really is research, research, research which is obviously what you are doing. Be good to hear what you decide.

  31. epc london Says:

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