It is frustrating that despite all the evidence to the contrary, we are still hearing the argument that people do not need an EPC because their building is listed. As far as we can ascertain….

1) Listed buildings are NOT exempt from needing an EPC on sale or rental because of their listing. 

2) Listed buildings are also NOT exempt from complying with the Minimum Energy Efficiency Standard (MEES) because of their listing. 

A very small proportion of listed buildings may be exempt because there are no energy efficiency measures that could be carried out without unacceptably altering their character. There are hardly any of those sorts of buildings. Having got an EPC the chances are there will be at least one measure that could be carried out without unacceptably altering the character or appearance which is why listing is not sufficient for exemption. 

There is no logical reason why just because we know some measures will not be possible, we should avoid looking for others that will be. The energy efficiency of virtually all listed buildings can be improved, and needs to be improved to keep them viable for people to live and/or work in. 

Many of the people living in listed properties will be in or close to fuel poverty because of the high cost of heating them (or living in conditions hazardous to their health because they cannot adequately heat them). That is why EPCs for listed buildings are essential. 

If we don't tackle energy efficiency in listed buildings, we will end up with them becoming a sort of under-class of building that nobody can afford to live in. It would be difficult to justify an interpretation of the regulations that would encourage that to happen. 

At the time of writing this article, I currently have on my desk 2 projects looking at ways of appropriately improving and incorporating low or zero carbon (LZC) technology into Grade 1 listed buildings. This is for clients who are seeking to cut their energy use and carbon emissions because it is the right thing to do, despite the challenges presented by their buildings. They are certainly not looking at using those challenges as an excuse to get out of doing the right thing. 

Walk around a National Trust property and take a good look at it. The boiler that is feeding those ancient column radiators will probably be a high efficiency one. It may be biomass. They will potentially have BMS control of the heating, possibly linked to some pretty elaborate sensor arrangements to control humidity as well temperature. There could well be heat pumps and possibly solar tucked away where you can't see them. The light bulbs inside those antique shades and chandeliers will mostly be LED. 

The moral is simply that there are very few buildings where you cannot significantly improve the energy efficiency without unacceptably altering the character or appearance. If you have a listed building, it probably means you will not be able to get the EPC rating as high as you could if it was not listed. It almost certainly does not mean you don’t need an EPC, and it does not mean you cannot improve the energy efficiency of your building. 

See the full Proficiency guidance notes at Listed Building Guidance