Energy Efficient Scotland - improving energy efficiency in owner-occupied homes: consultation analysis

Chapter 5: Conclusions

The Energy Efficient Scotland: Improving Energy Efficiency in Owner-Occupied Homes consultation document set out the Scottish Government's proposals for the nature of the proposed energy efficiency standard for owner-occupied homes (EPC Band C or better), and for the intention to make this legally-binding from 2024. The consultation invited feedback from the public to inform measures around energy efficiency in the owner-occupied sector. and have been incorporated into the update to the Energy Efficient Scotland Route Map as part of the draft Heat in Buildings Strategy, which will be published in February 2021. 

The consultation exercise ran from 19 December 2019 to 9 April 2020 and this report has presented an analysis of responses to this consultation.

The questions were wide-ranging, and findings related to each of them have been outlined in detail in this report. Many of the views expressed were mixed, with numbers of respondents in favour of the proposals often being similar to those against the proposals overall. Organisations tended to be more likely to be in favour of proposals than individuals. 

A number of key findings emerged from the consultation and these are summarised below.

Of the quantitative questions which were asked, and required an agree/disagree response, the following findings emerged: 

• There were mixed views on whether there should be a legally-binding standard, with organisations being more likely to support this than individuals. 
• A majority of respondents agreed that EPC Band C should be the standard required to be met by homeowners, but a substantial number of respondents raised concerns about the effectiveness of the EPC including among them half of the professional bodies responding to the consultation.
• A majority of respondents disagreed that 2024 is the right start date for the mandatory standard to start operating, with many stating that it was too early. Organisations were more likely to be in favour of this start-point than individuals.
• The majority agreed with the proposal that the point of sale should be a trigger point for a property to meet the legally-binding standard. However, almost as many disagreed, with concerns that this could negatively impact on the housing market.
• The majority of respondents agreed that point of major renovation should be a trigger point for a property to meet the legally-binding standard, with agreement levels particularly high among organisations. Individuals responding were more mixed in their views, with some concerns about additional costs being added to already costly renovations.
• Many respondents - 70% - agreed that, even if a property can't fully meet the standard, it should be required to get as close as possible to it.
• There were mixed responses to the proposal that any exemptions or abeyances from the standard should be time-limited, with organisations more likely than individuals to agree.
• Most respondents agreed that grant funding from the public purse should be focused on households who are vulnerable or in fuel poverty, although views were more mixed among individuals than organisations (who were largely in favour).

In addition, a number of cross-cutting issues emerged from the research. These are described below:

5.1 The impact on homeowners in rural areas

On numerous occasions respondents made reference to a potential negative impact on homeowners in rural areas if the standard were to become legally-binding. This related frequently to the higher proportion of older properties in rural areas, and the challenges of getting older properties to meet the standard – these challenges included the potentially higher cost of energy efficiency improvements for older properties, and difficulties in accessing tradespeople. In addition, respondents noted that many properties in rural areas were off the gas grid and therefore have to consider different options in relation to making their property energy efficient.

5.2 Concerns about vulnerable groups – older people and those in fuel poverty

Some respondents were concerned that older people, and people living in fuel poverty were likely to be most adversely affected financially if they were required to make costly energy efficiency improvements to their homes in order to meet the standard. Some respondents noted that these two groups of people were also more likely to be living in properties which were more difficult to upgrade.

5.3 Challenges facing owners of older homes

Many respondents noted the high number of older homes in Scotland which were below EPC Band C currently, and the high costs that could be involved in making the necessary energy efficiency improvements to these properties to achieve this rating. Some respondents were concerned that these changes would be unaffordable to many homeowners and that financial assistance would be required. Others were of the view that decisions to make such changes to properties should be the choice of the owners and not mandated by government.

5.4 Need for adequate finance and information to incentivise people to make changes

Respondents noted the need to raise awareness among the public of the benefits of meeting the standard; the finance available to support energy efficiency improvements to be made; and sources of advice, support and technical help.

5.5 Affordability and financial support

Many respondents raised concerns that the energy efficiency improvements required to meet the standard could be prohibitively expensive for homeowners. Some emphasised the impact this could have on the housing market, particularly if the point of sale became the point at which compliance was required. They were concerned that this could result in people not moving home or downsizing, which would lead to blockages in the housing market.

Respondents were widely in favour of financial support being made available, with mixed views about whether this should take the form of loans, equity release schemes, grants or other forms of support. 

5.6 Need for changes to the EPC 

Many respondents raised concerns about the effectiveness of the metric used to measure energy efficiency within the EPC. Individuals and representatives of professional bodies were most concerned that it was not an appropriate measure of energy efficiency in homes. Some called for it to be revised while others felt that another mechanism entirely should be used.

5.7 Need for compliance to be monitored and penalties to be issued for non-compliance

The need for a robust compliance regime was highlighted more generally as essential if the standard were to become legally-binding. There were mixed views about where any compliance body should sit – with some respondents suggesting this should be the role of local authorities and others calling for an independent body to be set up to ensure compliance. Many noted the importance of staff involved in compliance monitoring having the right experience and being well trained.

5.8 Ensuring impartial and appropriate assessments and recommendations

Another key theme was the need to ensure that assessments of a property's energy efficiency rating, and any subsequent advice and recommendations for work to bring the property up to the required standard, are made appropriately. Some respondents agreed with the proposal that Domestic Energy Assessors could provide this advisory role, although many of these respondents felt they would require upskilling to fulfil this role, while others felt that other professionals such as architects and surveyors would be better placed to take on this role. 

Another recurring theme among respondents was the need to ensure that whoever undertakes the assessment provides impartial advice and should not stand to gain in any way from the proposed work.

5.9 National standards

Some respondents emphasised the need for national standards or a scheme for accreditation/approval of installers, potentially backed by statutory bodies to ensure that any energy efficiency improvements made to homes are completed to a high standard.