The CLA [Alliance member] sought clarity earlier this year on whether listed buildings are exempt from the legal requirement to provide an Energy Performance Certificate (EPC) upon sale or rent. From April 2018 it will be illegal for a private landlord to let a property with an energy performance certificate (EPC) rating lower than E to a new tenant and to an existing tenant from April 2020.
The Government has now published new Guidance for non-dwellings and Guidance for dwellings. Both note that buildings protected as part of a designated environment or because of their special architectural or historical merit are exempt from the requirements to have an energy performance certificate insofar as compliance with minimum energy performance requirements would unacceptably alter their character or appearance. To comply with minimum energy performance requirements, many of the recommendations in an EPC report e.g. double glazing, new doors and windows, external wall insulation, and external boiler flues would likely result in unacceptable alterations in the majority of historic buildings. These can include buildings protected as part of a designated environment or because of their special architectural or historical merit (e.g. listed buildings or buildings within a conservation area). In these cases, an EPC would not be required. Building owners will need to take a view as to whether this will be the case for their buildings. If there is any doubt as to whether works would unacceptably alter the character or appearance of a building, building owners may wish to seek the advice of their local authority’s conservation officer.