Energy Efficient Scotland: consultation analysis

The Programme and use of EPC data (Domestic and Non-domestic)

Use of data to support building owners and public bodies

The consultation paper notes that the Scottish Government plans to improve the way data is gathered and presented, both to support building owners in undertaking improvements and also in monitoring and enforcement of regulations. The intention is that better use of available information will improve understanding of how buildings can be improved simply and effectively.

Question 25 - What additional data would help building owners in the delivery of the Energy Efficient Scotland Programme? How would this be used?

Respondents cross referenced between Questions 25 to 28. To avoid duplication, comments have been covered at the most appropriate of the questions in the section.

Advice, guidance and information

Some respondents identified topics that should be covered in information, advice and guidance:

• The range of energy efficiency measures available, including those suitable for a building of the type they own.
• Installation and running costs, maintenance and benefits of any measures implemented.
• What is involved in installing particular measures.
• Grants, loans and approved installers for funded works.
• Other accredited and competent installers. This was raised by a small number of Local Authority respondents.

Providing owners with access to case studies and signposting initiatives, such as the EST Green Homes Network, was also proposed.

In terms of the delivery of information and advice, the importance of independent expert advice was highlighted, as was the need for advice to be tailored to the building, and in the case of non-domestic buildings, to their use.

Online information or information packs in a range of formats and including links to energy advice schemes were called for.

Assessment and improvements

Providing data that explains the detailed inputs, assumptions and calculations used to arrive at an EPC rating for a property was proposed:

Provision of a detailed itemised point-by-point calculation to support the rating. At present the ratings have zero credibility and the calculation process is kept secret.
Individual respondent

It was also suggested that better information on the calculated relative performances and financial savings offered by each recommended improvement would assist building owners to choose options which would deliver the biggest energy savings and would assist with budgeting and planning for improvements.

Specific ideas, in each case raised by one only respondent, were:

• Splitting information in the EPC between heat and other energy, providing more information on energy demands relating to cooling.
• Providing anticipated retrofit costs for meeting the 2040 target.
• Improving the building type and construction information on non-domestic EPCs to permit easier comparison of buildings.

Other suggestions

Other suggestions about additional data that would be helpful to building owners in the delivery of Energy Efficient Scotland, in each case raised by one or a small number of respondents:

• Building passports and roadmaps - introducing 'building passports' or 'renovation roadmaps' to help owners see the pathway to reaching targets. Expanding the online information held on buildings, provided that owners agree, was also proposed. Third sector and Energy related private sector respondents made these suggestions.
• Wider stock or supply mapping – it was suggested that mapping hard-to-heat homes and providing owners with data about the efficiency of different housing stock could be helpful. A map indicating all the alternative fuel, heat and power supplies and networks in an area was also proposed.
• Before and after comparisons - it was proposed that comparisons could help owners of similar type properties decide on works to their own property, but also that the approach could help in assessing the ongoing effectiveness of EPC assessments and improvement recommendations.
• Smart meter data – the information becoming available through smart meters was seen as useful, and it was argued that energy use readings can help motivate changes in behaviour around energy use and assist in identifying suitable retrofit options. Third sector respondents more frequently raised this issue.
• Whole building level data for tenements - a small number of Third sector or Scottish Government delivery agent respondents saw whole-building information as important to delivering the most cost-effective approach to energy efficiency improvements for tenement buildings.

An awareness-raising campaign around the Energy Efficient Scotland Programme covering both domestic and non-domestic should also be undertaken.

Question 26 - What additional data would be helpful to others in the delivery of the Energy Efficient Scotland Programme? How would this be used?

Advantages of making data available

A small number of respondents noted that it would be helpful if private businesses, such as energy efficiency measure installers and energy providers, had access to more of the data than is currently collected. In particular, access to up-to-date EPCs and to more of the detailed data behind an EPC was requested:

Data sharing is a great opportunity for stakeholders to help target support for fuel poor households and should ultimately help the Scottish Government deliver its ambitious Energy Efficient Scotland Programme.
Energy related private sector respondent

Other reasons given, in each case by one or a small number of respondents, were that it would:

• Allow installers to provide tailored advice for consumers.
• Reduce the need to re-measure and re-assess items that have already been assessed.
• Support the evaluation of proposals such as 'allowable solutions' or solutions to support communities meet local energy targets.

It was reported that new powers contained in the Digital Economy Act 2017 could enable the sharing of data to support the tackling of fuel poverty. Other comments were that building owners could be asked to agree to being contacted by third parties at the point of assessment.

Although the focus tended to be on making information available to the private sector, it was also argued that Home Energy Scotland advisors should be able to access data with the customer's permission.

Property-based data

In addition to more general comments about improving or developing databases holding information on properties, bringing existing databases together into a single central property data base was proposed. Further comments, in each case by one or a small number of respondents, were:

• The Home Analytics data published by EST Scotland brings together several data sets in one online location and is extremely useful (with the caveat that some data cleansing may be required).
• A new resource could be created with the amalgamation of existing data sets. Data held by the National Energy Efficiency Data (NEED) Framework could contribute to a central property database.

Suggestions about the type of information it would be helpful to hold in a central database were primarily raised by an Energy related private sector respondent and were:

• Up-to-date EPC data.
• Indication of a 2040 Band C exception (if exceptions are adopted).
• Listed building status/conservation area status.
• Distance to the nearest gas main.
• Building Warrants, refurbishment and improvements works undertaken.
• Presence of micro-renewables.
• Up-to-date fuel poverty support eligibility and ECO eligibility.
• Contact details for the property.
• Local climate or weather data.

Another perspective, raised by a Local Authority respondent, was that easy access to multiple data sets should help comparison between Local Authority areas and assist in developing LHEES and setting baseline positions.

Other issues

Often reflecting points raised at Question 24, other issues raised are set out in turn.

Providing access to energy use and smart meter data. Further comments were that annual energy consumption data linked to property characteristics would support national monitoring against future targets, and could help improve accuracy in the Scotland Heat Map and the development of LHEES. Also, that it would help assessors customise performance improvement interventions. Local Authority respondents were amongst those commenting.

It was also argued that utility companies sharing data on prepayment meter locations and cases of 'self-disconnection' with Local Authorities could assist in tackling fuel poverty.

Location data and mapping. It was felt that mapping of EPCs would be helpful in highlighting areas or clusters of buildings with low energy efficiency and would assist Local Authorities to develop detailed local maps to underpin targeted programmes and investment linked to the LHEES.

Other comments, in each case raised by one respondent:

• A fuel poverty map based on the new definition of fuel poverty would help Advice organisations target fuel poverty alleviation campaigns.
• Data on privately-owned non-traditional house types and locations would be helpful as would data on buildings currently reliant on high carbon fuels.
• More detailed local information from Distribution Network Operators in their Heat Maps could better assist Local Authorities to scope and plan projects, particularly in respect of renewable generation and district heating schemes delivering combined heat and power.
• Data on heat, electricity and surplus energy generated by industrial or production processes in non-domestic buildings could enhance current Heat Maps and identify opportunities for collaboration around utilisation of renewables and district heating.

Question 27 - We will investigate the benefit in providing new online resources or tools to support building owners to access and use data to help them improve their properties. What particular types of resources or tools would you find useful and why?

In terms of the type of resource respondents were looking for, comments often focused on some form of interactive online tool. (Ideas of a similar nature were put forward at earlier questions, particularly at Question 9.) Advantages of this type of approach, in each case highlighted by a small number of respondents, were that it would allow owners to benchmark the performance of their own building with other similar buildings and would offer owners of buildings without an EPC a way of estimating what their property might achieve. Third sector respondents made this latter point.

Specific ideas as to what any tool should do:

• Show how possible changes to the building would affect its EPC rating. Specifically, it should track any changes to a building over time and map a path to reaching EPC ratings.
• Generate cost-effectiveness information on proposed energy efficiency measures based on real use data. Local Authority respondents more frequently raised this issue.
• Enable owners to understand which low carbon heating options might be appropriate for their property and give feedback on the likely feasibility of any possible measure.
• Offer a whole-building assessment for owners in tenements.
• Enable the user to request quotes, including from those operating locally to them.

Topics that respondents wanted to see covered in any online resources were:

• Details for suitably qualified and accredited assessors or installers. This was the most-frequently suggested topic and came from a broad range of respondents.
• Grants and financial assistance that may be available.
• The importance of maintaining the building fabric.
• How energy consumption in non-domestic buildings can be managed.
• How the EPC rating of non-traditional house types can be improved and ventilation of traditionally built properties.
• Case studies to help owners understand the benefits of and what is involved in different improvement solutions for different building types. Building component manufacturers or services respondents were amongst those who made this suggestion.

It was also recommended that if building renovation passports or roadmaps are introduced, any online tools should take this into account.

In terms of what any online resources should look like:

• Be easy to access and use, including being available through a smartphone app. Local Authority respondents more frequently raised this issue.
• Present comprehensive information but signpost onwards where necessary.
• Provide supporting information about how to interpret any data provided.

However, it was also felt that the views and preferences of potential users should be gathered on the design and content of any online tools. A review of existing online tools, websites and linked services relating to energy advice was proposed. These were interactive tools about health and social care, the Each Home Counts website, and the way online access to EPC information is provided by the UK Government.

It was also thought that as many owners now receive electronic copies of their EPCs, these documents should have embedded links to independent advice services and specialist advice for particular building types, such as Historic Environment Scotland.

Although generally supportive of the online approach, respondents did raise some concerns or highlight certain issues:

• There remains a need for access to independent advice around implementing energy efficiency measures. This was the most frequently raised concern and came from a broad range of respondents.
• Interventions for non-domestic buildings require a higher level and range of technical expertise and an interactive online tool may not be appropriate. However, providing information and links to expert advice could be useful.
• The needs of owners without access to the internet must also be taken into account when developing resources.

Question 28 - In addition to the above, we welcome any specific comments or observations you may have on the future use of the data that is gathered from energy assessments.

Comments at Question 28 tended to address issues already covered in the analysis presented at earlier questions. Some respondents, including Academic, Energy related private sector, Local Authority and Private landlord or property management respondents, raised concerns about the accuracy of EPC data and a methodology that relies on assumptions and modelling. It was argued that more could be done to monitor and enforce standards of practice in energy assessment to support the collection of more accurate data.

Other comments frequently focused on improved access to property assessment and/or energy use data. These concerns were raised by a broad range of respondents. Reasons given for wanting more data to be made available in future were that it would:

• Support improvements to assessment approaches, including through the use of accurate energy use data.
• Enable better targeting of resources, improvement action and information.
• Support a better understanding of the overall condition of stock across the country, including overall progress against Energy Efficient Scotland targets, and also identify any variations in progress based on area or build type.
• Help with the evaluation of different improvement measures. In particular, using data from improvement project failures to learn lessons.
• Support expansion of the green mortgage market.
• Enable stakeholders to contribute more productively and creatively to further discussions on the programme.

There was concern that historical data on a property which could aid more accurate future assessments may be lost when a new assessment is recorded, and it was recommended that historical assessment data should be kept. There were also calls to change the way data is presented currently to a more end-user friendly format.

Although there was an appetite for more data to be made available, the need for adequate data protection for owners and customers was highlighted. It was also cautioned that the sharing of data should not leave people open to poor sales practices.