There are over 9,000 Grade I listed buildings and 20,000 Grade II* listed buildings in England. In the past there has been an assumption that listed buildings would be exempt, however this isn’t the case.
With the advent of minimum energy efficiency standards (MEES) all building will require an EPC to see if they are exempt from improvements (recommendations) for let.
For example the windows and externals are listed, if the EPC recommendations suggest replacing these with say PVC double glazing then this does not need to be implemented. Therefore you could be exempt from carrying out these works.
Minimum Energy Efficiency Standards (MEES) which make it unlawful to grant new leases of properties with an F or G rating.
From 2023 these standards will make subsisting lettings of F or G-rated commercial properties unlawful too (2020 for residential properties).
EPC regulations do not simply state that listed buildings are exempt from the requirement to obtain EPCs but rather they are exempt, insofar as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance. This is a subtle, but important, difference.
For example, if it was suggested that the old single-pane sash windows of a listed property be replaced with new double-glazed windows, then this is likely to “unacceptably alter” the character of a property where the façade and/or windows were the listed feature resulting in the property being exempt from the EPC requirements. However, if it was simply recommended that the internal lighting be replaced with more efficient LED lighting, then the façade would be unaffected and so in this circumstance the character and nature of the property would not be unacceptably altered and the property would not be exempt for EPC purposes.
In order to determine whether a particular property is exempt, a property owner will first need to work out (i) what the potential or recommended energy efficiency improvement works are for the property and (ii) whether implementing those recommendations would unacceptably alter the character or appearance of the property. It is likely that an EPC assessor will need to be instructed to evaluate this. Property owners essentially need to undertake an EPC survey to work out whether an EPC survey is required.
A property owner would also have to inspect the listing particulars of the property to ascertain what the unique listed characteristics are. There is ambiguity as to what constitutes “unacceptably altering” those listed features and who is the arbiter of that decision; is the property owner, the EPC surveyor, English Heritage or the local planning authority?
Should you need any further clarification or advice on this subject, please do get in touch with PRE Surveyors or