Renewable technologies getting a bad press in RdSAP

I have just lodged an EPC certificate for a 400m+ Victorian house which has a NIBE air source heat pump. The vendor and I made lots of positive noise about these things and everyone was happy. Imagine my surprise that the house scored 21! To put this in perspective I substituted the heat pump with a condensing gas boiler and the property shot up to 50!

I understand that this is due to the fact that the pump uses electricity as part of it’s ‘combustion’ process but this can’t be right, can it? The government is telling people to go green, and one of the main diagnostic tools in their armoury is the Energy Performance Certificate. Yet when you use that tool on the latest technologies all it does is punish the owner!

Does anyone else have any examples?