Energy Efficient Scotland: consultation analysis

Executive Summary

This summary presents the main findings from the analysis of responses to the consultation on Energy Efficient Scotland: Making our homes and buildings warmer, greener and more efficient.

The main focus of this consultation was on proposals for setting long-term domestic energy efficiency standards for homes in the private rented and owner occupied sectors. It also sought views on standards for non-domestic buildings, use of Energy Performance Certificate (EPC) data, and on potential legislative changes.

The consultation opened on 2 May 2018 and closed on 27 July 2018. It asked 32 questions. In total 130 responses were received, of which 94 were from groups or organisations and 36 from individual members of the public.

All homes must reach at least an EPC Energy Efficiency Rating Band C by 2040, where technically feasible and cost-effective

Some respondents made a broad statement of support for the proposals or agreed the value of setting long-term targets, although approval was frequently accompanied by a caveat that the date specified should be earlier than 2040.

Various concerns were raised with aspects of the current EPC system. These included that some properties may be unable to achieve Band C, for example as a result of their traditional construction type, rural location, or being off-gas grid.

Situations where a lower standard is acceptable

A substantial majority of respondents thought there should be situations where a lower standard is acceptable. The most frequently cited were: hard-to-treat buildings; listed buildings; when measures are not cost-effective; in mixed tenure buildings; in remote or island locations; and where measures are not technically feasible.

The small number of respondents who did not agree argued that an EPC C rating is deliverable for most properties and that new technologies will also assist.

Situations where a longer period for improvement is allowed

A majority of respondents thought there should be situations where a longer period for improvement is allowed. Frequently cited examples included: where improvements are very expensive or unaffordable; where other repairs to the building fabric are also required; where there are limited supply chains; where consent or financial contributions from multiple owners are required; and where occupants (often tenants) find the required work too disruptive or to have health impacts, or when work would be better carried out when properties become vacant.

Among respondents who did not agree with extensions being given, the most frequent reason was that the proposed time scales are already long enough.

Definition of a cost-effective measure is that it should payback over its lifetime

Some respondents who commented argued that more information is required about who would make decisions and on the payback calculation. There were calls for the definition of 'cost-effective' to be clarified.

With respect to the private rented sector, it was argued that the concept of payback does not apply in the same way, as the landlord makes the investment but the tenant benefits from reduced energy bills. It was thought that rents are likely to rise.

Air quality and the Long-Term Domestic Standard (LTDS)

Some respondents agreed that air quality is an important issue which the Scottish Government is right to consider in relation to the LTDS. While acknowledging the importance of good ventilation, a small number of respondents also pointed to the role of occupier behaviour in creating some of the problems with dampness and mould.

Taking account of changes to the underlying methodology and to fuel price data

It was acknowledged that EPC methodology or data needs to be updated, including to reflect the advent of new technologies. A process for fast tracking new innovations was proposed.

There were mixed views on the possibility of employing conversion tables to correct for variations in EPC methodology over time.

Proposal that all Private Rented Sector (PRS) properties meet EPC Band C by 2030

There was widespread agreement with the proposal that all PRS properties should achieve EPC Band C by 2030. Setting out a long-term trajectory and/or a staged approach were also supported.

Among respondents who disagreed with the proposal, the most frequent argument was that the policy is not realistic, particularly with respect to traditional or hard-to-treat properties, those in rural areas, or those that are off-gas grid.

Proposal for an initial period of encouraging action for owner occupiers

Comments from those who agreed with the proposal included that it is a reasonable or positive approach, or that it allows time to develop regulatory mechanisms.

Respondents who did not agree tended to take one of two positions: that the policy represents government interference in a matter of personal choice, or that there is no evidence that a further period of encouragement will be effective.

Information that would be useful for householders for owner occupiers

Comments tended to focus on access to practical information on appropriate improvement options, their cost and likely savings, funding opportunities, and finding reliable or approved contractors.

Provision of advice online, by telephone, face-to-face, or in the home were all proposed, as was the need for advice to be simple, user friendly and tailored to vulnerable households where appropriate.

Proposal to follow the initial period with mandating action for owner occupiers

Respondents who expressed a clear view that the Scottish Government should not follow a period of encouragement with mandating action tended to argue that this is interference in a matter of personal choice, or that incentives are required instead.

Among respondents who supported the proposal, the most frequently made points were that mandatory action will be needed to achieve targets and that householders will need to know what the sanctions for non-compliance will be.

Proposal that 2030 is the right point to start mandating action to achieve EPC Energy Efficiency Rating Band C

Among respondents who agreed that 2030 is appropriate, comments included that this gives enough time for raising awareness. Some respondents added caveats, such as the need for appropriate exceptions and grant funding to be available.

Some respondents, predominantly individuals, argued that there should be no mandatory action at all, particularly in relation to the owner occupied sector.

Proposal for owner occupied properties to be subject to penalties for non-compliance

Among respondents who thought owner occupied properties should be subject to penalties for non-compliance, arguments included that a voluntary system alone is unlikely to be effective.

Respondents who did not consider a penalty for non-compliance to be advisable or acceptable argued that the policy compromises freedom of choice, is not possible or practical to achieve in some cases, or may have adverse effects on the housing market.

Requiring all types of accommodation to meet the LTDS over time

Some respondents thought that all types of accommodation should meet the LTDS, including because of the importance of combating fuel poverty.

Among those who commented specifically on park or mobile homes there were mixed views. The majority of those commenting argued that agricultural tenancies, Houses in Multiple Occupation and holiday lets should be covered by the LTDS.

Proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band C by 2030, where technically feasible and cost-effective

Some respondents who agreed with the proposal, or who agreed in principle, highlighted the importance of removing poor energy efficiency as a driver for fuel poverty or noted associated potential benefits such as improved health outcomes.

The complexity of fuel poverty was highlighted, and the Scottish Government was advised to link energy efficiency to other strategies relating to tackling fuel poverty.

Proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band B by 2040, where technically feasible, cost-effective and possible within limits affordable to the public purse

Respondents who agreed with the ambition commented on the value of setting out a long-term trajectory, including that it may be most cost-effective to improve to a higher standard in one go.

Points made by respondents who did not agree included that the proposed standard may be too ambitious or unattainable unless publicly funded.

What the Energy Efficient Scotland Assessment Short Life Working Group (SLWG) should also consider

Suggested topics for the SLWG to consider included: alignment with other policy initiatives and broader housing needs; definitions of 'technical and feasible' and 'cost-effective'; and guidance on how cost-effectiveness will be measured. There was also a focus on consumer protection.

Whether the Long-Term Domestic Standard should be enforced at a local or national level

Reasons given for enforcement at a local level included the importance of local knowledge, the relevant information already held by Local Authorities, and possible synergies with other Local Authority functions.

Points in favour of enforcement at national level included that this would facilitate a uniform or consistent approach or that Local Authorities do not have the resources or capacity to enforce the policy.

Specific building characteristics to be included in research to ensure that future improvement targets reflect the diverse nature of our non-domestic building stock

A majority of respondents thought that specific building characteristics should be accounted for in research. Issues were raised about the importance of considering the design, purpose or use of a building. It was suggested that any research would need to consider the occupancy of a building and occupant behaviours.

The way calculated energy use from building assessments are is presented and/or benchmarked

Views on assessing energy performance against a notional building specification were mixed, with some supporting the approach, including because it could enable more accurate and better aligned assessments for different types of buildings. Others raised concerns, including that varying conditions across different parts of Scotland need to be taken into account.

Proposed planned work to review improvement targets

Some respondents noted their support for the review of improvement targets. It was hoped that the review will help in setting realistic targets, providing predictions for future energy savings and producing data on real energy savings. It was suggested the review should cover the scope, impact and resource implications of targets.

Proposals for phasing the regulations from 2020

Some respondents supported the proposals for phasing of regulations from 2020. Further comments included that the approach allows time to secure funding for improvements and for markets and supply chains to develop. An alternative proposal was harmonisation of dates for both non-domestic and domestic property.

Should advice and support to invest in the energy efficiency of industrial or manufacturing buildings align with wider advice and support on how to reduce energy consumed for productive processes

A majority thought advice and support should be aligned with wider advice and support on how to reduce energy consumed for productive processes. In terms of the range of advice and support needed, comments included that many manufacturing and industrial processes require very specialist expertise to assess cost-effective energy efficiency improvements.

What more could the Scottish Government could do to encourage the public sector to accelerate energy efficiency across their building stock

The issue of capital funding and resourcing Local Authorities to drive acceleration on energy efficiency improvements in the non-domestic public buildings stock was raised frequently, including with a proposal for grant funding to Local Authorities.

What more the Scottish Government could do to encourage the public sector to accelerate heat decarbonisation across their building stock

General comments included that fabric improvements should precede decarbonisation of heating. Respondents also identified issues which, if addressed, could help accelerate heat decarbonisation - for example, encouraging more private sector businesses to connect to district heat networks.

Additional data to help building owners in the delivery of the Energy Efficient Scotland Programme

Some respondents focused on the provision of information, advice and guidance, including on the range of energy efficiency measures available and installation and running costs. The importance of independent expert advice was highlighted, as was the need for advice to be tailored to the building.

Additional data that would be helpful to others in the delivery of the Energy Efficient Scotland Programme

Some respondents noted that it would be helpful if private businesses had access to more of the data collected. Suggestions about the type of information it would be helpful to hold in a central database included: up-to-date EPC data; and an indication of a 2040 Band C exception (if exceptions are adopted).

Particular types of resources or tools that would be useful

Comments frequently focused on interactive online tools. Advantages of this type of approach included that it would allow owners to benchmark performance of their own building with other similar buildings. Case studies to help owners understand the benefits of different improvement solutions were proposed.

Specific comments or observations on the future use of the data that is gathered from energy assessments

It was suggested that more could be done to monitor and enforce standards of practice in energy assessment to support the collection of more accurate data. There were also calls for more end-user friendly presentation of data.

The implementation and enforcement of existing legislation relating to energy efficiency and heating of buildings in Scotland

General comments included that without a robust quality and standards framework, there is a risk that the Energy Efficient Scotland Programme will not deliver the outcomes the Scottish Government is hoping for.

There was a concern that new legislation will place more responsibility for implementation and enforcement on to Local Authorities and, as at previous questions, the resource implications for Local Authorities were highlighted.

Changes needed (if any) to this existing legislation

Areas of legislation or regulation to which respondents thought changes might be required were refurbishment or extension of existing buildings, and quality standards for the thermal retrofit industry. More broadly, it was felt that Local Authorities will need direct legislative mandates to develop and implement Local Heat and Energy Efficiency Strategies (LHEES).

Other elements of the programme that may require new or amended legislation to enable the Energy Efficient Scotland Programme to operate

Comments were that there should be a statutory framework for Energy Efficient Scotland, including targets and scrutiny provisions. The need to integrate with other relevant policy developments was highlighted, with reference to the new fuel poverty targets and the strategic fit with Local Housing Strategies and LHEES.

Organisation(s) responsible for delivering any new legal requirements

Most frequently, respondents thought that the Scottish Government and Local Authorities together should be responsible for delivering any new legal requirements. Other respondents thought an independent body should be responsible for enforcement.