Houses of Parliament
Westminster,
London SW1A 0AA,
Monday 24th February 2025
Dear Secretary of State for Energy Security and Net Zero, Ed Miliband MP, Secretary of State for Housing, Communities and Local Government, Angela Rayner MP and Chief Medical Officer, Professor Sir Chris Whitty,
On behalf of a coalition advocating that access to a healthy home is a basic human right, we urge the government to broaden the scope of the current Energy Performance Certificate (EPC) consultation to include indoor environmental quality (IEQ) as an urgent intervention that will improve public health, reduce energy bills, and avoid further degradation of our housing stock.
We commend initiatives such as Awaab’s Law and the Renters’ Rights Bill in protecting households but risk overlooking indoor air quality as a critical environmental health issue, as highlighted by England’s Chief Medical Officer in 2022. Updating the EPC to include IEQ assessments would help homeowners and tenants balance heat, air, and water for better health and lower heating costs.
With the Warm Homes Plan and ongoing consultations on Minimum Energy Efficiency Standards, timely action is crucial. Without it, retrofits may inadvertently worsen conditions—improving insulation while neglecting ventilation, leading to damp and mould. Factors like proper guttering can mean the difference between a warm, dry home and one plagued by cold and damp.
The EPC is an important transactional tool, uniquely positioned to safeguard people and properties and reduce the burden on public services.
THE PROBLEM
PUBLIC COST - We spend 90% of our time indoors. Poor IEQ causes chronic illness and costs the NHS £1 billion+ annually, unnecessarily. Tackling indoor air pollution could save up to £40 billion a year.
UNVENTILATED HOMES - Since 2010, Part F of the Building Regulations has impacted new builds and some retrofitted properties, approximately 7 million homes. However, 22 million homes remain at risk due to inadequate or absent ventilation.
WET, DAMP & MOULDY HOMES - 10% of the population live in unhealthy housing with 65,000 homes having a ‘Category 1’ health risk associated with damp. Retrofit insulation alone will exacerbate the situation.
COST TO FIX - Local authorities and housing associations are already under severe financial and operational strain. Continuing or worsening damp and mould issues will place even greater pressure on already stretched resources.
SHORTAGE OF EXPERTS - The UK faces a national shortage of qualified remediation specialists. This has led to ineffective 'wash and block' approaches, which exacerbate problems rather than resolving them—further endangering public health.
SYSTEM FLAW - The current EPC system has little impact on millions of existing households, due to them not being sold or rented or an existing EPC not being renewed regularly enough.
GOVERNMENT SCHEMES ARE FAILING HOMES - Evidence from the recent Department for Energy Security & Net Zero Select Committee inquiry has demonstrated that the UK’s current retrofit standards framework is failing households to the detriment of the person and the property.
FALLING SHORT: Failing to consider IEQ as part of the EPC process means the UK is effectively ignoring recent revisions to the Energy Performance of Buildings Directive which requires an IEQ assessment.
THE SOLUTION
BROADEN EPC SCOPE - Take a broader, more holistic approach to enabling healthier homes and update the EPC to include all IEQ determinants (e.g. guttering and ventilation).
TRAINING - Leverage the Home Energy Model (HEM) transition to train assessors on IEQ elements.
MANDATE UPDATED EPC TO STRENGTHEN RETROFIT SCHEMES - Improved EPC assessments will guarantee retrofit programmes are delivering at a base level and protecting public health.
MORE REGULAR - Mandate EPCs to be completed every two years, or immediately after any installation of key IEQ determinants, including, but not limited to, the retrofit measures within the Warm Homes Plan.
COMPLIANT – Align with the rest of Europe and comply with the revised Energy Performance of Buildings Directive.
PUBLIC AWARENESS - Utilise the updated EPC as an opportunity to launch a public health awareness campaign ahead of winter 2025/26.
Our request to you
We are calling for the scope of the EPC consultation currently underway to be broadened to protect public health and the UK’s housing stock. We request an urgent meeting to discuss practical steps for implementing these vital reforms.
Signed by:
Industry bodies and membership organisations
1. Clean Air Programme (ukcleanair.org)
2. British Electrotechnical and Allied Manufacturers' Association (BEAMA)
3. Building engineering services Association (BESA)
4. Federation of Environmental Trade Associations (FETA)
5. Building Compliance Testers Association Group (BCTA)
6. Air Tightness Testing & Measurement Association (ATTMA)
7. Sound Insulation Testing and Measurement Association (SITMA)
8. ATTMA Domestic Ventilation Commissioning Scheme (ATTMA)
9. Healthy Homes Hub
10. GO AQS
11. Total Landlord
12. Landlord Action
13. Clean Air for Kids
Charities and private organisations
14. IndoorAirAware.co.uk
15. Home Energy Matters
16. Built Environment Technology
17. Home Energy North
18. Future of the Built Environment
19. Cleanzyme
20. Corylus Architects
21. Pathogen Reduction Solutions
22. VENTI Group
23. Aereco Ltd
24. Raven Delta Group
25. Shelter
26. Viable Land Group
27. Roost Building Performance
28. Retrofit Academy
29. Connected Kerb
30. Neil Bright Associates
31. Farmwood M&E Services
32. Excool
33. Curaidh Clinic
34. JAG Property Services
35. Hale Environments
36. Envirovent
37. Intelligent Membranes
38. JR Tiling & Bathroom Services
39. Scuba Plumbing
40. Impact Air Systems
41. Energy Carbon
INDIVIDUALS
43. Professor Sir Stephen T Holgate CBE, FMedSci, MRC Clinical Professor of
Immunopharmacology UKRI Clean Air Champion and Special Advisor to the RCP on Air Quality
44. Professor Paul Lewis Emeritus Swansea University Medical School, Clean Air Programme Regional Champion Wales, Chief Scientific Officer, Health & Wellbeing 360
45. Dr Heather Price, Senior Lecturer in Environmental Geography, UKRI Regional Clean Air Champion for Scotland
46. Dr Minha Rajput-Ray, Environmental Clinician, Cambridge Public Health and Curaidh Clinic
47. Nathan Wood, MD, Farmwood Ventilation, World Ventil8 Day Chairman
48. Kelly Butler, BEAMA, Strategy Director
49. Sotirios Papathanasiou, Lead Author & Environmentalist at GO AQS
50. Jenny Danson, Healthy Homes Hub, CEO,
51. Hazel Rogers, Hazel Rogers, Research and Evaluation Manager, Shelter
52. Barry Cope, Building Compliance Testers Association Group
53. Dr Jason Palmer, Cambridge Architectural Research & Cambridge Energy
54. Philip Webb, CEO, Health & Wellbeing 360
55. Steve Malyon, Builder and Former Leicester City Council Property Repairs Manager
56. Paul Shamplina, Chief Commercial Officer, Total Landlord and founder of Landlord Action
57. Mark Thompson, Founder of ‘Get Energy Savvy’ and Former Head of Energy at Innovate UK
58. Ian Thompson, Founder, Home Energy Matters Facebook Community
59. Carl Fivash, Director, Built Environment Technology Limited
60. Amber Blackwell, Managing Director, Built Environment Technology Limited
61. Michael Cromby, Home Energy North, Environmental Health Officer, Ealing Council
62. Ele George, Founder, Elevate - Future of the Built Environment
63. Ruth Brooker, Clean Air For Kids
64. Adam White, CEO, Intelligent Membranes
65. Colm Watling, PAS 2035 Retrofit Coordinator
66. Scott Storey, CEO, Cleanzyme
67. Hazel Buckingham, Architect & Director, Corylus Architects Ltd.
68. Ian Sinclair, Founder & CEO, Pathogen Reduction Solutions Ltd
69. Bradley Pallister, VENTI Group Ltd
70. Vince House, Head of Sales and Operations, Aereco Ltd
71. Dave Kieft, CEO. Raven Delta Group
72. Lee Chapman, Site Selection for Powered Land, Viable Land Group
73. Shane Gallimore, Building Surveyor, Southway Housing
74. Sam Gwilliam, Residential Low Energy Buildings Consultant and Retrofit Assessor
75. Laura McDonnell, Senior Marketing Manager, ITEX
76. Hayley Malyon, Marketing Manager, Impact Air Systems
77. Simon Pennock, Social Investor, Connected Kerb
78. Nina Tarasow, Compliance and Risk Manager, Mitie
79. Neil Bright, Building Surveyor
80. Andrew Gaved, Editor at Large of Elemental and Installer
81. Sam Dore, European Business Manager, Excool
82. Ben Shepherd, Mechanical Engineer
83. Alan Gregory, Expert Witness, Kitchen Duct Fires,
84. Matt Perkins, Managing Director, Medicair
85. James Gilbert, Managing Director, JAG Property Services & Hale Environments
86. Rory Percival, Product Director, Envirovent
87. Chris Yates, Chief Executive, Federation of Environmental Trade Associations (including Residential Ventilation Association)
88. Yasemin D Aktas, University College London and UKCMB
89. Claire Murray-Lynch, Retrofit Assessor
90. Jenny House, Director of Member Services & Engagement, BESA
91. Clare Norton, Office Manager, Rents Property Management Services Ltd
92. Gianni Lo Iacono, Senior Lecturer in Epidemiology and Biostatistics. University of Surrey
93. Rob Cartwright, Energy Services & Solutions Director, CoreLogic
94. Rod Davies, Co-Founder of Energy Carbon
95. Mike Pitts, Deputy Challenge Director of Net Zero Heat at Innovate UK
MPs
96. Daisy Cooper, Member of Parliament for St Albans
97. Neil Duncan-Jordan, Member of Parliament for Poole
98. Dr Brian Mathew MP, Member of Parliament for Melksham & Devizes
FAMILIES
99. Lisa Malyon
101. Vicky Ball
102. Karen Malyon
103. Debbie Gall
104. Alexandra Stickles
105. Emma Preston
106. Jacqui Sedman
107. Katy Cordice
108. Claire Francis
109. Leanne Jones
110. Sarah McKinley
111. Emma Meller
112. Angie Lynch
113. Heather Fitzpatrick
114. Linda Kerr
115. Lynsey Pavsic
116. Juliette Hatch
117. Hayley Malyon
118. Toria Fox
119. Holly Shepherd
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