Circus, BathEnergy Performance Certificates (EPC) are a European Union (EU) Directive (European Energy Performance of Buildings Directive) with the aim of improving energy efficiency and performance of buildings. This Directive and its requirements are likely to continue in some form when the UK leaves the EU. This Directive legally requires that a residential building should achieve the minimum energy efficiency standard (MEES) and EPC rating Band E in the event that a building is being sold or rented. However, the Directive provides exemptions for ‘designated environments’ and includes listed buildings and conservation areas and in particular undesignated buildings within conservation areas. Other exemptions include:

- Places of worship
- Temporary buildings (in use for less than 2 years)
- Stand-alone buildings (useful floor area less than 50 square metres)
- Industrial sites, workshops and non-residential agricultural buildings
- Buildings to be demolished
- Holiday accommodation (rented for less than 4 months a year)
- Residential buildings (used less than 4 months a year)

In terms of listed buildings the exemption applies where the ‘minimum energy performance requirements would unacceptably alter a listed building and its architectural interest and character or the appearance of a conservation area. This exemption is consistent with the exemptions for listed buildings and buildings in conservation areas in Part L of the building regulations (The Conservation of Fuel and Power).

However, there are some concerns and uncertainty as to what works would constitute unacceptable alterations and this brief guidance note aims to provide some clarity for listed building owners or those that own buildings located in a conservation area. Listed buildings and conservation areas, as designated heritage assets, are legally protected by the primary legislation: Planning (Listed Buildings & Conservation Areas) Act 1990. In the case of listed buildings the Act requires that any works of alteration preserve the building, its setting or any features of special architectural or historic interest that it possesses. Works of alterations that have an impact on this interest require listed building consent. In the case of conservation areas there is a requirement for development to preserve or enhance the area.

The Local Planning Authority (LPA) can offer detailed advice through its pre-application service to assist home owners as to what energy efficiency measures require listed building consent or planning permission. Each building and situation has to be judged on its own merits and specific requirements. For instance, listed buildings can differ and vary considerably in terms of their construction, building materials, location, authenticity, completeness, sensitivity and therefore ability to accommodate changes in relation to energy efficiency measures. However, this does not preclude buildings from alterations that would improve their energy efficiency and it is often the case that traditionally constructed buildings are inherently energy efficient and therefore only modest alterations might be needed to achieve proportionately substantial gains and a higher EPC rating.

There are a host of low and minimal intervention measures that can be undertaken without the need for listed building consent that can significantly improve the efficiency of the building avoiding visual or physical harm. The LPA’s published SPD guidance: Energy Efficiency & Renewable Energy Guidance for Listed Buildings and Undesignated Historic Buildings and the Sustainable Construction and Retrofitting SPD offer detailed advice. There is also a plethora of other guidance and some links are provided below.

To summarise:

  • Consider wider guidance referenced below 

  • Seek advice through the Council’s pre-application service when considering proposals for energy efficiency measures. We will be able to provide advice as to whether the measures constitute acceptable alterations and whether they need listed building consent and/or planning permission.

It should not be assumed that the protected status of heritage precludes it from energy efficiency improvements and the level and scale of alteration which is acceptable will differ from one building and situation to another.  


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