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EPCs on 257s


Several members have reported that they are being asked to supply an EPC for their 257 property as part of their Portsmouth Licensing application. Is there such a thing? We asked an expert...

What is a 257

Basically, any property that has been sub-divided into smaller dwellings that cannot show that all alterations meet building regulations requirements. So basically, any conversions prior to the early 1990's and any since for which the necessary Building Control paperwork cannot be produced.

Many large Victorian villas in Southsea have been converted into 4 or 5 apartments and thus will now be '257's'.

The interesting thing is, that the Licensing team are only interested if most of the property is tenanted - so 2 identical properties both converted into 4 flats, one with 3 tenants and 1 owner occupier will be a 257 whereas the other, with 3 owner occupiers and 1 tenant will not be a 257.

What makes it more challenging is that only the communal areas are subject to licensing - so whilst the council are probably correct to ensure that no EPC category 'F' or 'G' properties are let, as many of these properties only have a porch that is 'communal', what is it the EPC assessor is expected to assess?

One Such Example

One member stated, "They are asking for an EPC on the entrance hall way to 4 different flats, not the property that's going to be rented so they are saying entrance hall way has to be above E and soon could need to be a C.

If all of the flats were 2 beds or rented to family's there is no HMO licence of any kind needed at the property yet the council can say 'We may decide you are not fit to manage an HMO ' , How can that be correct?"  He went on to say, "Had a chat with my EPC assessor and she and her colleague both said it was pointless and ridiculous but they are happy to do it.

As as there are only 2 Led lights in the hall way no heating or hot water it wouldn't lose heat and would be very efficient so could be EPC B or C

For me £55 cost of EPC split 4 ways not worth the time proving the council wrong.

Other Thoughts

 We asked Alice for her view and she said, "Interesting and a bit of a grey area if you read this....

A guide to Energy Performance Certificates for the construction, sale and let of non-dwellings - GOV.UK (

Not specific to 257s and converted blocks but there is an example of mixed use (office and residential) and that implies you only need an EPC if there is a communal heating system and it specifically states communal areas are not included.

The communal areas are not habitable spaces so I do wonder if a draughty front door is actually going to cause any residents issues."

Another assessor just said, "Not sure a domestic EPC could be done on communal areas as there would be no habitable room count. I've never had to input this before. I've just tried to do a draft EPC and software is flagging up an error 'Habitable Room count must be entered'."

We will check with other assessors and share their views as we receive them - in the interim, the issue is that landlords will be forced to pay for worthless EPC's as it is cheaper than failing the 5-year suitability test for a licence and from a PCC perspective, what is it that could be enforced if a communal porchway is unheated in one of these properties say?

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