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When is an EPC not required for solar PV feed-in tariffs

Posted by Cathy Debenham on 27 March 2012 at 2:38 pm

The new energy efficiency requirement for the feed-in tariff (FiTs) for solar PV kicks in on 1 April 2012. This means that the full FITs rate is only available for buildings which have an Energy Performance Certificate of band D or above. This is currently a bit less than half the UK housing stock.

The good news is that the installation of solar panels is in itself an energy efficiency measure and will bring some properties that are currently band E to band D. However, don't assume that is the case. The EPC algorithms are complicated, and the only way to be sure is to run the data through the software. Installations that don't meet the criteria, will get a significantly lower level of generation tariff: 9p per kW instead of 21p per kW for systems of 4kW or less.

The bad news is that there are a lot of questions about what buildings are exempt, and detailed guidance from Ofgem is still not available. Here are some pointers to what's in and what's out.

The common question is what about a barn in a farmyard? This is quite simple: the key bit is in DECC's FiT FAQs. It says: "Under the requirement, PV installations will only be eligible for standard FIT tariffs if they can provide a valid Energy Performance Certificate (EPC) at the time of application for FITs, showing a rating of level D or above for the property to which the solar panels are attached or wired to provide electricity."

So if the solar PV system was providing electricity for use in the farmhouse, then the farmhouse would need to have an EPC band D. Potentially, if the farmyard has a separate electricity bill, and a separate MPAN number from the farmhouse, and was not wired to the house, it may not need an EPC.

Generators will need to satisfy their FiT licensee (energy supplier) and Ofgem that it is not possible to obtain an EPC for a particular building, and that it is not wired to a building that could. Decisions on eligibility are ultimately a matter for Ofgem and the FiT supplier, not DECC.

Another condition that will contribute to a building's eligibility is whether it is capable of being heated or cooled. The issue of how they will deal with large, unheated warehouses or factories that have a small heated office space in one corner is not yet clear.

The STA is thinking of putting a series of case studies on its website as they occur to enable people to see how individual decisions are reached. Early exemptions will be considered on a case by case basis.

However, there will definitely be some buildings for which it is impossible to reach EPC band D. An example of this is old churches. When confronted with this unfairness at the Solar Power UK Roadshow in Newmarket, Alasdair Grainger, of the DECC feed-in tariff review team pointed out that FiTs have never been fair. "I live in a flat, so I can't install solar panels," he said.

More information about feed-in tariffs from YouGen

Feed-in tariff information page

Does solar PV count towards FIT energy efficiency criteria?

Green Deal Finance will work with FITs and RHI

Planning permission and building regulations: the rules for solar installations explained


If you have a question about anything in the above blog, please ask it in the comments section below.

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6 comments - read them below or add one


HelcattComment left on: 29 April 2014 at 1:19 pm

I'm just starting a renovation on my cottage in Cornwall which will include putting some underfloor heating where possible, insulating roof and walls in extension (rest is solid stone).  We are putting 4kw PV on an outbuilding soon but obviously my house won't be finished until next spring... I doubt it would reach Band D yet... so what shall I do about the EPC? Do I just accept I can't get FITS until I've finished the house when I can do an EPC?

Also, we can only have 4kw as otherwise we would need to spend 10K to upgrade the power lines.  I'm planning to install an Everhot Range cooker which will soak up the 4kw almost all by itself... I'd like to install another 4kw array on the house for the rest of our elec needs... but can I without upgrading the lines?

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Cathy Debenham

Cathy DebenhamComment left on: 11 April 2013 at 1:00 pm

I agree Basil. I'm hoping that it will be changed in the future, as FITs are brought in line with Green Deal and RHI, but I'm not going to put any money on it!

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basilbrushComment left on: 8 April 2013 at 6:26 pm

I agree entirely with the previous comment. I've spent the day looking at this and our property does not have mains gas or oil. We therefore heat using a wood burning stove. In addition we have solid walls and cannot have cavity wall insulation. It's therefore ironic that a house such as ours which would benefit from new technologies so dramatically is actually not able to apply and receive the same FiTs as those on housing estates, with mains gas and more convenient energy much lower energy bills.

What has been an absurd lesson for me today is how the EPC assessment takes no account of the improvements which cannot be made - so would expect a condensing boiler to be installed even if there is not mains gas and likewise for cavity wall insulation.

It is a nonsense and greatly disappointing!

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Linn Rafferty

Linn Rafferty from JTec Energy PerformanceComment left on: 31 March 2012 at 2:13 pm

I'd like to respond to Cathy's request for clarification of unheated warehouses and factories that include a small area of office space.. in fact, this is completely clear.  

The DCLG guidance says that for a building to fall within the requirement for an EPC, it must use energy to condition the indoor climate. This is the case where the building has any of the following fixed services: heating, mechanical ventilation or air conditioning. Where a building is expected to have heating, mechanical ventilation or air conditioning installed, it will require an EPC based on the assumed fit out.

So, for the warehouse with a small office, there is an expectation of a need for heating, even if none is currently installed.  The office worker will require some form of heating, even if only a portable fan heater! So the EPC is created on the assumed fit out, ie that the offices, wcs, kitchens, mess rooms and so on are heated, whereas the workshop area is not.

There really should not be any question over whether an EPC can be done for such properties. 

I also wonder if it's correct to say that there are some buildings e.g. old churches for which it is impossible to reach EPC band D. It's almost never impossible to improve an old building - just expensive, in some cases.  In fact, for properties that are not homes, such as old churches, it's even easier to reach a D due to the way the EPC for non-dwellings is calculated.  The rating letter is reached by comparing the current building with a building that meets a particular defined standard for that type of property.  It's because the rating reflects this comparison, rather than an absolute level of energy performance, that it's easier for less well performing properties to achieve a D.

 Whether or not you consider it fair that properties should be required to meet a standard before they can benefit from FIT payments is another thing.  For what it's worth, my opinion is that this is controversial, but it is part of the journey we must make towards an appreciation of the benefits of improving the energy performance of our buildings. 

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Cathy Debenham

Cathy DebenhamComment left on: 29 March 2012 at 9:21 am

Hopefully, when we find out the details of the renewable heat incentive, these are the homes that will benefit the most. PV isn't ideal for helping with electric heating, as mostly the heating will be on when after the sun's gone down.

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CernunnosHomesComment left on: 29 March 2012 at 8:02 am

The irony of the EPC is that those with the most need for Solar (those not fortunate enough to be on the Mains Gas Network) are least likely to hit the required level. Electric Heating (arguably most suitable for PV) has 1 star, LPG and Oil 2 and 3 starts, gas 4 or 5. Therefore PV weighted towards those who by geographical twist have gas and thus the lowest bills (and probably the least need!)

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