The Heritage Alliance (THA) has submitted evidence to the Department for Energy Security & Net Zero (DESNZ) on its consultation on improving the energy performance of privately rented homes.
THA writes:
…. England’s built environment is the oldest in Europe, with 1 in 3 homes built before 1919. These homes are not incompatible with climate adaption, but the wrong approach will do more harm than good. The UK needs to double the number of conservation-skilled retrofit contractors if it is to meet its Net Zero targets by 2050. To support this, we hope to see in future a National Retrofit Strategy which packages skills, training, funding, standards and advice and includes plans to reform of EPCs to include a whole house assessment approach for historic buildings, and the creation of a one-stop-shop advisory service for historic homeowners seeking qualified retrofit advice.
We broadly support the government’s efforts to improve energy efficiency in the private rented sector but have significant concerns about how proposals will impact heritage properties.
Regarding EPC reform and assessment methodology, the current approach is particularly weak for heritage buildings and requires substantial improvement. There are significant skills shortages and knowledge gaps among assessors regarding traditional construction methods, which leads to inconsistent assessments and inappropriate recommendations. We strongly urge for stakeholders with heritage expertise to be involved in developing new EPC metrics, including the planned Home Energy Model (HEM), to ensure they account for the unique characteristics of heritage buildings…
…We offer several additional recommendations to improve the proposals. National Listed Building Consent Orders would streamline approvals for routine works, reducing the administrative burden on both landlords and local authorities. A reuse-first approach with fiscal incentives for repair and a review of permitted development within the planning system, including removal of PD for demolition, would support repair and maintenance alongside environmental objectives. A new Culture Growth Fund would include targeted capital funding for heritage infrastructure to support appropriate retrofitting. An exemption for short-term lets at this time, which often operate in heritage properties, would recognise their unique characteristics and the lack of preparedness in this sector. Finally, a national retrofit strategy, including enhanced training and capacity-building in the heritage retrofit sector, should be prioritised before implementing new requirements.
The heritage sector remains committed to working with government to ensure energy efficiency improvements in the private rented sector are implemented in ways that respect the unique character and constraints of our heritage buildings while delivering meaningful environmental benefits.
