We have been made aware of conflicting guidance being given to assessors by accreditation schemes on the subject of whether or not to include the operational rating (OR) from a previous DEC if there has been a compliance gap.
This is disappointing because this subject was discussed in depth by the DEC conventions group in 2019 and an approach agreed by all schemes. The appointed representatives from all schemes, with input from AECOM, Landmark and (what is now) DLUHC agreed that “yes, you do”.
Having reached this agreement between all schemes at the DEC Conventions Group it was a surprise to find at our DEC assessor CPD session that at least one scheme has subsequently had some support staff telling assessors something different. We were also made aware of an instance of a member having failed audit for doing exactly what everyone (including that scheme) had all agreed they should do.
We call on all schemes to ensure all support staff and auditors are fully aware of what their DEC representatives collectively determined was the correct approach. That a compliance gap DOES NOT mean the preceding operational ratings are omitted from the DEC.
The determining factor is simply that the OR has been "displayed" by the occupier during the last two years before the nominated date. When it was valid from and to does not matter.
Therefore, you do also include the OR from the previous DEC when renewing a 10 year validity DEC (unless the building has undergone a change of use or occupier during that time).
To provide clarity for assessors and a reminder for schemes, we have put together a summary of what was agreed and where in the current official guidance it comes from.
If a scheme now wants to move away from the previously agreed approach, it is essential that they negotiate a change with all other schemes and do not simply do their own thing.
The summary of what was agreed by all schemes and why can be found HERE.
(For the benefit of any schemes questioning the validity of this article, the intended application approved by your representative on the DEC Convention Group will be found in the part headed "Section 4, 4.1.4. Energy consumption and measurement period" on page 8 of the minutes of the meeting on Thursday 27th June 2019).