Energy Performance Certificate reform: consultation analysis

Concluding Comments

A number of those responding to this consultation provided their views on EPC reform. Some also provided background information to help put their response into context. These views will help the Scottish Government in taking forward plans for EPC reform. Many responses echoed points raised in the consultation paper.

Overall, responses to this consultation show broad support for EPC reform, albeit there were a number of caveats made by respondents. If changes are to be introduced, they will need to take account of the concerns outlined by respondents. For example, it will be necessary to provide EPCs in a range of different formats to ensure they are fully inclusive for all potential users.

There appears to be a degree of resistance to EPC reform from some respondents. As such, it will be important for the Scottish Government to ensure the reasons for reform are communicated effectively to the Scottish public and other users of EPCs. This will also help to bring about a more positive attitudes towards EPC reform. Increased consumer awareness may be key to the delivery of energy savings and emissions reductions.

It will be important to ensure there are adequate numbers of trained assessors with the requisite skills if there is an increase in the number of EPCs produced.

It may be worthwhile for the Scottish Government to consider variable validity periods for EPCs to allow for the different uses of domestic and non-domestic buildings. It will be also be important to consider the timing of reform implementation to streamline with the launch of SAP 11 and other intersecting initiatives.

As is typical with consultation responses, many respondents raised issues not directly related to the consultation questions. However, these issues were clearly seen as important to significant numbers of respondents. Many respondents – mainly individuals but also some housing providers and local authorities – were concerned that a reformed EPC might force them into making unsuitable retrofit changes in order to achieve a desired EPC rating. Allied to this, many had concerns about the potential costs associated with any retrofit work, particularly in more traditional stone-built buildings. Perhaps not surprisingly, many of these respondents also focused on a need for additional funding and grants to be made available to allow for retrofit work to be undertaken. Individuals, local authorities, housing associations and Registered Social Landlords (RSLs) in particular had concerns over the costs of improvement measures.

Throughout responses, a small minority of mainly individuals noted they did not agree with this consultation being undertaken, that they did not agree with EPC reform or that there is no need for EPC reform. There were also some respondents who felt that EPCs are of less importance than building warrants or other technical surveys and that EPCs are of limited overall value.