Energy Performance Certificate reform: consultation analysis

Executive Summary

The Scottish Government committed in the Heat in Buildings Strategy to bring forward proposals to reform Energy Performance Certificates (EPCs). This is in response to criticisms from key stakeholders such as the Climate Change Committee that certificates are not properly aligned with meeting net zero objectives. Feedback from an initial consultation on EPC reform in 2021 led to further policy development. It is now considered that a revised set of ratings^[1] is likely to be needed on the certificates to improve the ability of EPCs to support net zero policies.

In July 2023, the Scottish Government launched a public consultation on EPC reform, which ended in October 2023. This sought views on wider reforms in domestic and non-domestic EPCs to ensure they are fit for purpose to support future heat in buildings regulations. The consultation gave all who wished to comment an opportunity to do so. However, given the self-selecting nature of this type of exercise, any figures quoted here cannot be extrapolated to a wider population outwith the respondent sample.

Respondent Profile

In total, there were 323 responses to the consultation paper, of which 122 were from organisations and 201 from individuals. A majority of organisation responses came from representative bodies, businesses in the construction sector and local authorities. A full breakdown of responses is provided in the respondent profile table on page 6; and a full breakdown for each question, by sub-group, in Appendix 1.

In general, organisations tended to be more positive about the suggested proposals than individuals. Those working within the EPC process, local authorities, in the construction sector and housing providers tended to be more positive than other organisation sub-groups.

General Comments

There was broad support from organisations for the principal elements of EPC reform set out in the consultation paper. These included a revised rating system; a shortened validity period; a digital and accessible format; and changes to the operational system.

Individuals were less supportive of EPC reform because of perceived concerns about affordability and the practicality of energy upgrades. Many individuals felt that a standardised EPC model is not suitable for certain types of property, including traditional stone-built properties, tenements and listed buildings. As such, there were some requests for more individualised EPCs for different types of property.

There were calls for EPCs to be presented clearly in a user-friendly and easy to understand format so that all users understand the information presented.

There were calls for funding packages and grants to be made available for people to undertake retrofit measures. The Scottish Government did not propose that a reformed EPC would force people into undertaking retrofit measures. However, there was also a perception from many individuals that EPCs could be used to force people into undertaking retrofit measures or preventing house sales.

The Proposed Ratings (Metrics)

The proposed revised ratings for domestic and non-domestic EPCs were broadly welcomed by organisations. However, there were some concerns over the accuracy of EPC assessments in general. Over half the respondents felt the fabric rating should not include domestic hot water heat demand. There was general agreement with mapping the fabric rating against an A-G scale. There was majority agreement that more prominence should be given to the energy efficiency features of a home. However, views were split on whether the fabric rating A-G scale should be aligned to the current energy efficiency rating (EER), or for setting the bands independently of this. There were some calls from individuals and organisations for real life fabric, energy consumption and heating system data to be used, rather than standardised data.

A minority of respondents agreed with the set of ratings proposed to display on non-domestic EPCs. Organisations were more supportive of these proposed ratings than individuals. A view was expressed that revised non-domestic EPC ratings should help to counteract the perceived poor quality of data provided under the current ratings. Views, mainly from organisations, were positive on having a relative Energy Rating that would align with the rating system used in other parts of the UK. However, there were some comments that it can be difficult to set ratings for non-domestic buildings because of the variety of building types and uses across the country. There were some calls from organisations and individuals for consistency between domestic and non-domestic EPCs to help reduce complexity.

A number of respondents including individuals and organisations, thought that older housing stock would be disadvantaged or marked down by the new ratings. Concerns were expressed over the measurement and assessment process for these, given they were perceived as inherently less efficient and difficult or impossible to retrofit.

Purpose and Validity Period of EPCs

There was majority agreement that the primary role of the EPC should be to provide basic energy efficiency information for the purpose of comparison and act as a prompt to reconsider retrofit schemes. However, there was only minority support for the validity period of EPCs to be reduced from ten to five years. A key advantage in reducing the validity period is that it would allow for more up-to-date and accurate information. This was seen to be of use to policymakers and organisations rather than individuals. Both of these elements were supported by higher numbers of organisations than individuals.

There were some suggestions for variable validity periods, depending on the property type and whether any changes had been undertaken on a property. However, it was felt (mostly by individuals) that the decision to obtain a new EPC should be the choice of a property owner. That said, respondents identified specific trigger points, such as when retrofit work is undertaken, when a new EPC could be required. Some respondents – mainly individuals – felt EPCs should be required only for new homes and not older properties.

EPCs were perceived, mainly by organisations, to be useful across a range of policy areas. These included climate change, LHEES and heat networks, EESSH, the Heat in Buildings Strategy, fuel poverty and Just Transition targets. They were also perceived as allowing for better targeting of resources for schemes. The EPC is an energy report and there were no proposals within the Scottish Government’s consultation on EPC reform to require change of heating system to an electrical heating system. However, there appear to be some perceptions that this could be the case. As a result, there were some concerns that EPC reform could inadvertently lead to higher levels of fuel poverty. This was because electrical heating systems are more expensive to install and can have high running costs.

Digital and Accessible EPC Format and Content Proposals

Higher numbers of respondents (more organisations than individuals) supported the proposal that EPCs should move from PDF to webpage format. However, many respondents felt that a range of EPC format options should be offered. This would counteract any problems with internet access and / or a lack of digital understanding on the part of some consumers. Some respondents noted that a change to a webpage format would offer greater accessibility, flexibility and user-friendliness. This would also allow for access to updated and tailored data. This would also offer opportunities for data linkage, signposting users to sources of support and advice and for policymakers to use in meeting policy targets.

There was majority support from organisations and individuals for the proposal to improve signposting to further support and advice schemes on the EPC. This could help increase consumer awareness on energy savings and emission reductions. However, there were provisos that any signposting needs to be clear, independent, user-friendly and up-to-date. There were some suggestions that signposting should be to Home Energy Scotland (HES) advice rather than directly to service providers.

There was majority support for historical EPCs to be publicly accessible on the EPC register, (while clearly marked as historic). Just under half the respondents (more organisations than individuals) felt the EPC register should be accessible by Application Program Interface (API).

There were some concerns over the potential for data breaches and / or abuse of personal data by marketing companies wanting to cold call potential customers.

Quality Assurance and Approved Organisation Framework Proposals

There was support for the proposals to review and update the auditing and assurance requirements for EPCs in Scotland. This was supported more by organisations than individuals. There was support for the consistency of high standards and accuracy of information. The current system was seen by some as not producing consistency and there were some issues around quality. Respondents wanted to see good governance and administration of the system to gain consumers’ trust.

Respondents noted concerns over a potential lack of qualified and skilled assessors if there is an increase in the number of EPCs that are requested. There were calls for assessors to undergo training to attain the required accreditations and skills. This would mean consistency across assessors in the way they produce EPCs.

Legislating for EPC Reform and Timeline

Views were mixed on the timeline for EPC reform. However, the most supported timeline was to align reform implementation with the launch of SAP 11 (now known as the Home Energy Model) in 2025. Some organisations felt the full implications of EPC reform cannot be understood until the legislation for the Heat in Buildings Bill is published. This led to some requests for clarity on the forthcoming Heat in Buildings Bill and regulatory changes, given their potential impact on EPC reform.