Question to the Department for Energy Security & Net Zero:
To ask His Majesty's Government what preparations they are making to manage any increase in applications for leaseholder and third-party consent exemptions ahead of the proposed changes to the minimum energy efficiency standards; and what assessment they have made of the prevalence of freeholder refusal of consent for energy efficiency improvements.
The Department for Energy Security and Net Zero provides an Exemptions Register to enable landlords to register exemptions. The Exemptions Register has sufficient capacity to handle an increase in exemption registrations.
The impact assessment published alongside the government response to the ‘Improving the energy performance of privately rented homes’ consultation contains information on expected prevalence of exemptions, and information on treatment of exemptions in the modelling can be found in the attached table.
Table - Treatment of exemptions in the PRS MEES modelling
Exemption | Treatment in modelling |
High-Cost exemption | Modelled: If the cost of making even the cheapest improvement exceeds the cost cap, we do not upgrade a property. |
All Relevant Improvements Made exemption | Modelled: If no relevant improvements can be made then no improvements are made in the modelling. |
Cost Cap exemption | Modelled: Where landlords install measures and hit the cost cap before reaching MEES, the model stops upgrading the property. |
Property Value Adjustment exemption (affordability exemption) | Not modelled: This exemption allows landlords of properties valued below £100,000 to work to a cost cap that is 10% of the property’s value. The NBM does not contain property prices to allow robust modelling of the exemption. |
Solid Wall Insulation (SWI) exemption | Modelled: For simplicity, we assume all landlords who can take advantage of this exemption do so (there may in reality be a small number of landlords who still wish to install SWI). Thus, our modelling results do not include SWI. |
Negative Impacts exemption | Not modelled: We do not account for specific cases where a measure is recommended on an EPC, but determined to negatively impact a property or its value through some other assessment. |
Third-Party Consent exemption | Partially modelled: We do account for in-situ tenants not consenting to improvements at a rate of 10%. However, we do not account for refused consent from other third parties, including superior landlords (freeholders) and local authorities through planning permission processes. |
New landlord exemption | Not modelled: We do not account for property transfers, but given new landlords exemptions only last for 6 months this will not significantly affect modelling results |