Recommendation 9

In respect of criteria B, C and D, the Government says it is considering a cap on costs, above which landlords would be considered compliant, as is already the case with the minimum energy efficiency standards (MEES). We agree with this, on the basis that it would be unreasonable and counter-productive to expose landlords with older stock to the cost of upgrades. In the case of the MEES and criterion D, however, this should not mean that some homes get neglected, especially given the extremely strong correlation between energy efficiency and decency. We also do not understand why the Government does not simply align criterion D with the MEES. It would seem an easy, if modest, simplification of an overly complicated regulatory regime.