Since the beginning of the 2018/2019 tax year, privately rented domestic properties must comply with the Minimum Energy Efficiency Standard (MEES) as introduced in the Energy Efficiency (Private Rented Property)(England and Wales) Regulations 2015. One of the key aspects of the new legislation is that any domestic property with an EPC F or G rating is defined as ‘sub-standard’ and it is illegal to let the property on a new tenancy (including renewal of existing tenancies); and it will be no longer possible to continue existing tenancies beyond 1st April 2020 unless energy efficiency improvements are made.
Should a landlord be found in breach of the MEES, the local authority could impose a fine of up to £5,000.
The landlord’s challenge with failing rented homes
One argument by Paul Forrester in Insulate Magazine argues that the properties currently falling foul of the MEES will be likely to be among the hardest properties to treat; and that their owners will need support to make sure that any work carried out is of a reasonable standard and appropriate to the building’s construction. Forrester also presents two challenges:
• How can work on hard-to-treat properties be done both economically and sympathetically, with a view to long term health of the building?
• Are there ways to engage with landlords about these complex issues when they’re only just becoming aware of the MEES itself?
Meeting the first challenge, or the ‘technical’ challenge of finding suitable retrofit solutions to bring the property in line with the MEES is actually fairly straightforward; as it is simply a matter of installing suitable insulation and building services. Identifying what suitable insulation requires a bit more thought, but is not insuperable.
However, solutions for the second challenge, or the ‘communicative’ challenge will need to be adapted for how receptive the landlord is to regulatory changes; and there is a need for the supply chain to form new bridges between the construction and housing industries. In order to consider any approach to these challenges, it should be defined what the MEES is and why this standard is important.
Minimum Energy Efficiency Standard explained
There are seven energy efficiency ratings on an Energy Performance Certificate (EPC) designated with a letter A, B, C, D, E, F or G; with A having the highest energy efficiency standard and G being the worst. The Minimum Energy Efficiency Standard (MEES) to legally let a domestic property is E.
The correct energy rating for a flat or house is determined from the Standard Assessment Procedure (SAP) score. This is calculated based on the predicted cost for providing heating and hot water using the Government’s SAP method; which includes measuring the size and shape of the dwelling, calculating the heat losses through the building fabric and estimating the energy consumption of space and hot water heating. As all the information for a full SAP energy calculation may not be available, an accredited Domestic Energy Assessor may use ‘Reduced SAP’ (RdSAP) to calculate the SAP score and produce a valid EPC (Energy Performance Certificate).
Not all privately rented homes have to comply with the MEES and can be registered on the Exemptions Register. Guidance for acceptable exceptions can be found on the DBEIS website. However, all exemptions will still require a valid EPC and most require evidence of an attempt to investigate adding energy efficiency improvements.
Every home is required to have a valid EPC available for existing and prospective new tenants as part of the UK’s commitment to the EU Energy Performance of Buildings Directive. The EPC is typically a two-page document with suggested energy efficiency improvements and most importantly the EPC rating which makes it easy to compare different properties for energy-efficiency; but it also make it very easy to see at a glance whether a property is sub-standard.
Achieving MEES with thermal loft insulation
The first energy efficiency improvement should be loft insulation. Heat rises, so it’s to be expected that up to 25% of heat is lost through the roof in an uninsulated home. Many lofts are insulated with mineral wool between the ceiling joists, leaving a ventilated cold loft space that can be used for storage; but this also leaves the loft outside of the heated envelope and means that it cannot be used as habitable space.
Upgrading the loft for achieving the MEES could be an opportunity to build an additional bedroom and increase the value of the property, in which case the roof will need to be insulated along the rafters. Insulation such as Raftertherm can be applied to do this.
The energy efficiency of building elements such as a pitched roof is quantified by the thermal transmittance (U-value) and measured in Watts per square metre per Kelvin (W∙m 2∙K 1 or W/m2K); the lower the U-value the more energy efficient the building element is; which should not exceed 0·18 W∙m 2∙K 1 for pitched roofs insulated at rafter level in England and Wales.
This can be easily achieved by installing 75 mm of Raftertherm between the rafters, and an additional 75 mm Raftertherm layer beneath the rafters on Raftertherm fixing brackets; finished with plasterboard on battens. The foil face of the Raftertherm provides both an air-and-vapour control layer (AVCL) to prevent interstitial condensation and its reflective surface prevents radiated heat losses.
Achieving MEES with thermal wall insulation
The correct insulation to retrofit to external walls will depend on the wall construction (whether it’s timber/steel framed or masonry), it’s exposure to wind-driven rain and the depth of the wall cavity (if there is one). For example, blown-in cavity wall insulation is only suitable for masonry cavity walls where the cavity is greater than 50 mm and still may not be suitable if there is more than sheltered exposure to wind-driven rain. However, all walls can be safely dry-lined with internal wall insulation such as Alreflex Platinum.
U-values for masonry walls insulated with Alreflex Platinum dry-lining board should not exceed not exceed 0·30 W∙m 2∙K 1, which is typically achieved with 75 mm Alreflex Platinum fixed to the wall on our Alreflex fixing brackets and finished with plasterboard on studs.
We would advise you to contact us if dealing with a timber or steel framed wall because any insulation in the frame will improve the thermal performance of the wall and reduce the requirement for additional insulation; which means that some of our other products might be more suitable such as our Alreflex 1L1 SRO foil-and-bubble sheet.
Correct installation of insulation to achieve values
However effective building insulation is at helping a property to achieve the MEES requirements, it is never going to be effective if it is not installed correctly because the landlord is unaware of the installation requirements to achieve the values.
The construction industry typically responds to incoming enquiries and designing solutions for customers rather than contacting landlords and letting agents directly. However, there are exceptions to this rule; where cold-calling contractors have approached occupants via telephone calls, leaflet drops and door-stepping to install free loft or cavity wall insulation when government-funding was available.
However, numerous faulty installations by ‘cowboy builders’ and a lack of consumer protection has created a rift of mistrust. So, even more so now, the construction industry responds to interest rather than promoting it as it is also challenging to contact landlords directly through their properties.
One thought would be to contact landlords via letting agencies; but large letting agents who manage the properties will already be au fait with the Minimum Energy Efficiency Standard and will already have advised landlords who would be in danger of breaching the new regulations.
Other landlords who are members of organisations such as the Residential Landlords Association will also have probably been made aware of the regulatory changes.
Building awareness and relationships directly with landlords
We want to be speaking to landlords who are not being briefed by letting agents or associations and we know there are many out there. Landlords who only let a small number of properties and manage the let themselves to provide a retirement or second income still need to know about MEES. Unless they have been proactive in keeping up with legislative changes, it is likely that they will have made minimal investments in their properties and may find themselves in danger of becoming albeit unwittingly ‘rogue landlords’.
Contractors are very much the public face of the construction industry; and most private landlords will know a number of tradesmen who they trust. These contractors can provide a valuable link to impart information to landlords.
If printed copies of the Government’s domestic landlord guidance or similar material were made available; these could be left with the landlord the next time they received an enquiry.
However, one of the biggest obstacles to this approach is time. It requires contractors to spend time advising landlords of something they may already be aware of; and of something which the contractor may not be able to offer a service to help with. Unless there is some sort of incentive, that time will be more spent more productively to the contractor’s benefit.
MEES solutions for hard to treat properties
It would seem then that although the construction industry can readily provide solutions to the technical challenges to insulate hard-to-treat properties, there is little possibility for the supply chain to engage with landlords directly to make them aware of the MEES in the first place.
The construction industry will have to rely on local authorities to enforce compliance with the MEES through the Energy Efficiency (Private Rented Property)(England and Wales) Regulations 2015; so that the industry can react to the landlord’s enquiries hastened along by a fine.
However, if you are a landlord who would like to understand the MEES requirements further and discuss solutions for your properties, our technical team would be happy to have a no-obligation conversation. Our technical team can be directly called on 01582 544255 or emailed at [email protected]