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Agreed, the EPC recommendation for our Passivhaus was that we should get solar water heating, despite already having hot water via PV (sunamp unit) and not being able to use solar thermal for the vast majority of the year due to the thermal store background temperature being too high... I explained this to the EPC person but they just scratched their head.
JonoMarshall
Totally, it seems like a very vague assessment of building performance and doesn't really tell anyone anything very useful. It's easy to use as a yardstick when you can pretty much have a guess at what it's telling you anyway, but pretty much useless in scenarios like above, which will presumably become more common as people try and upgrade/retro-fit older homes.