S
SRE
Thought this may be of interest to everyone before 1st August
Special Scheme Operating Requirements Top Tips
We received revised Scheme Operating Requirements from DCLG yesterday that affect all EPBD products – DEA, CEA, OCDEA and PBEA. The new SORs will be implemented as of 1 July 2012 and we are currently working through the changes to ensure our Product Rules and Membership Rules reflect the new requirements. There are some new requirements that we would like to bring to your attention immediately.
PV Panels and FITS
We have received the following guidance from DCLG yesterday:
It has been brought to DCLG’s attention that some Domestic Energy Assessors (DEAs) have received correspondence containing the following, or similar, text:
“We have obtained your details from the National Database as we have an EPC job in your postcode area.
We have an EPC instruction for a property that is about to have Solar Panels installed.
The required procedure is as follows; You will be required to issue a draft EPC initially as if the Panels had been installed.
Please record the Roof Orientation, Roof Slope and Overshading The kWp figure will be supplied for you.
Following completion of the PV installation we will provide the MCS Certificate and a photograph of the panels in order for you to lodge the EPC.
Your invoice can be submitted for immediate payment following the initial survey. You will not be required to return to the property.”
The Department does not consider any EPC that has been produced in line with the instructions contained in this or similar correspondence to be compliant with the Scheme Operating Requirements as it appears to allow an EPC to be produced without a visit to a site where the presence of the PV panel can be verified by the EA. Schemes shall, with immediate effect, consider DEAs who are found to have produced EPCs in line with these instructions to have committed a serious breach of the Code of Conduct and shall take appropriate disciplinary action. This requirement shall not however be retrospective.
Schemes shall require DEAs to produce EPCs on the basis of the evidence about the physical characteristics of the building at the time that the visual inspection is carried out. Schemes shall ensure that any documentary evidence provided by DEAs about work that has been carried out in relation to the physical characteristics of the building only concerns work that was complete at the time of the visual inspection. Schemes shall not permit DEAs to use evidence that relates to work carried out after the visual inspection.
What does this mean for you?
This guidance from DCLG clarifies that it is not acceptable to use documentary evidence of measures installed after the site visit as evidence to support the issue of an EPC.
In essence, the EPC must reflect the condition of the property on the date of inspection.
Furthermore, each EPC must be supported by the evidence required under the scheme rules – including photographs and site notes dated on the date of inspection. If the EPC is being produced following the installation of a PV system, you should include a photograph of the installed PV panels and the generation meter as evidence of the installation.
If you are contracted to assess whether the property is already Band D prior to the install, or to identify any measures additional to the proposed PV system that would need to be installed in order to achieve a Band D, we strongly recommend that you issue an EPC to reflect the property on the date of this initial inspection. This will ensure that you have proper insurance cover and an audit trail in the event of any future dispute arising.
Please note that if you do end up producing “before” and “after” installation EPC, you cannot re-use photographs or other evidence from the initial EPC in support of the post-installation EPC. For QA purposes, each EPC is considered to stand alone and must be fully supported by evidence as specified in the scheme rules.
Of course, if the initial EPC shows a Band D rating prior to the installation of the PV system, that EPC can be used to support the FIT application. However, we would always recommend getting an updated EPC after a major energy efficiency investment in order to reflect the property’s improved rating.
Special Scheme Operating Requirements Top Tips
We received revised Scheme Operating Requirements from DCLG yesterday that affect all EPBD products – DEA, CEA, OCDEA and PBEA. The new SORs will be implemented as of 1 July 2012 and we are currently working through the changes to ensure our Product Rules and Membership Rules reflect the new requirements. There are some new requirements that we would like to bring to your attention immediately.
PV Panels and FITS
We have received the following guidance from DCLG yesterday:
It has been brought to DCLG’s attention that some Domestic Energy Assessors (DEAs) have received correspondence containing the following, or similar, text:
“We have obtained your details from the National Database as we have an EPC job in your postcode area.
We have an EPC instruction for a property that is about to have Solar Panels installed.
The required procedure is as follows; You will be required to issue a draft EPC initially as if the Panels had been installed.
Please record the Roof Orientation, Roof Slope and Overshading The kWp figure will be supplied for you.
Following completion of the PV installation we will provide the MCS Certificate and a photograph of the panels in order for you to lodge the EPC.
Your invoice can be submitted for immediate payment following the initial survey. You will not be required to return to the property.”
The Department does not consider any EPC that has been produced in line with the instructions contained in this or similar correspondence to be compliant with the Scheme Operating Requirements as it appears to allow an EPC to be produced without a visit to a site where the presence of the PV panel can be verified by the EA. Schemes shall, with immediate effect, consider DEAs who are found to have produced EPCs in line with these instructions to have committed a serious breach of the Code of Conduct and shall take appropriate disciplinary action. This requirement shall not however be retrospective.
Schemes shall require DEAs to produce EPCs on the basis of the evidence about the physical characteristics of the building at the time that the visual inspection is carried out. Schemes shall ensure that any documentary evidence provided by DEAs about work that has been carried out in relation to the physical characteristics of the building only concerns work that was complete at the time of the visual inspection. Schemes shall not permit DEAs to use evidence that relates to work carried out after the visual inspection.
What does this mean for you?
This guidance from DCLG clarifies that it is not acceptable to use documentary evidence of measures installed after the site visit as evidence to support the issue of an EPC.
In essence, the EPC must reflect the condition of the property on the date of inspection.
Furthermore, each EPC must be supported by the evidence required under the scheme rules – including photographs and site notes dated on the date of inspection. If the EPC is being produced following the installation of a PV system, you should include a photograph of the installed PV panels and the generation meter as evidence of the installation.
If you are contracted to assess whether the property is already Band D prior to the install, or to identify any measures additional to the proposed PV system that would need to be installed in order to achieve a Band D, we strongly recommend that you issue an EPC to reflect the property on the date of this initial inspection. This will ensure that you have proper insurance cover and an audit trail in the event of any future dispute arising.
Please note that if you do end up producing “before” and “after” installation EPC, you cannot re-use photographs or other evidence from the initial EPC in support of the post-installation EPC. For QA purposes, each EPC is considered to stand alone and must be fully supported by evidence as specified in the scheme rules.
Of course, if the initial EPC shows a Band D rating prior to the installation of the PV system, that EPC can be used to support the FIT application. However, we would always recommend getting an updated EPC after a major energy efficiency investment in order to reflect the property’s improved rating.
