Energy Performance Certificate reform: consultation analysis

Digital and Accessible EPC Format and Content Proposals

Key Findings

Across the questions asked in this chapter, the same issues tended to emerge repeatedly.

• Higher numbers of respondents supported the proposal that EPCs should move from PDF to webpage format (Q12)
• There was majority support for the proposal to improve signposting to further support and advice schemes on the EPC (Q13)
• There was majority support for historical EPCs to be publicly accessible on the EPC register (while clearly marked as historic) (Q14)
• A large minority of respondents felt the EPC register should be accessible by API (Q15)

Key themes

• Advantages of a webpage format are its accessibility and user-friendliness, greater flexibility and access to ongoing updated and tailored data. It also offers opportunities for data linkage, signposting users to sources of support and advice, and for policymakers to better meet policy targets
• Signposting to further support and advice schemes was perceived to be useful and could help to increase consumer awareness on energy savings and emissions reductions. There were some suggestions that signposting should be to the Home Energy Scotland advice service rather than directly to service providers. However, if signposting is provided to specific suppliers, this will need to be to independent, competent and reliable service providers
• However, there were calls for a range of options to meet all needs. This included a capacity to download a hard copy or PDF version, particularly for individuals who do not have internet access or digital skills. There were concerns about lack of internet access and / or digital knowledge for some individuals
• There some concerns over the potential for data breaches and / or abuse of personal data by marketing companies wanting to cold call potential customers

Next most frequent themes

• Some criteria were outlined for signposting. This included that it should be appropriate to a building’s age and type of property, be up-to-date and clear, user-friendly, concise and unambiguous
• The provision of historic EPCs was seen to be useful for tracking progression towards net zero and energy savings. However, it was felt these would be more useful to organisations than individuals. It was also felt that changes to EPC ratings would reduce opportunities for direct comparison over time
• Accessibility by API was seen to be of use primarily for organisations

Webpage EPCs

Q12: Do you agree with our proposal that EPCs should move from PDF to webpage format?

A large minority of respondents agreed with the proposal that EPCs should move from PDF to webpage format. There were higher levels of support from organisations than from individuals. Across organisation sub-groups, there were higher levels of agreement from local authorities, utility companies and those involved in the construction sector.

A total of 188 respondents across all sub-groups provided commentary in support of their initial response to this question. Many of these – mostly organisations – tended to echo the reasons given in the consultation paper.

Support for a webpage format

Respondents outlined a number of key advantages. These included that a webpage would be more accessible and user-friendly, while offering greater flexibility and access to data. A small minority of organisations noted this would create a dynamic source of consumer advice and allow flexibility to be adapted over time. A live document was also seen to offer the opportunity to be updated on an ongoing basis. This would also offer opportunities for data linkage and provide access to a central register for research and policy purposes.

It was also seen as providing opportunities to signpost users to sources of support and advice. Additionally, for policy makers to better target buildings for improvement measures and to help them meet policy targets. Additionally, a small minority of respondents noted that it would be useful to be able to carry out a bulk download in order to compare properties and obtain real time updates for these. This approach would also allow for different layers of information to be collated, depending on each audience accessing it.

Qualified support

While levels of support for this proposal were generally high, a large minority of respondents across all sub-groups noted some qualifications for their support.

A small minority of organisations noted the need for a capacity to download a hard copy or PDF version in a standard printable format. For example, RSLs and housing associations are required to display a copy of an EPC in each property they rent. It was also noted that there would be a need for webpages to display the same content consistently across browsers and formats, which could be costly.

Concerns over this approach

Higher numbers of individuals noted concerns than did organisations. However, there were instances where concerns were shared across both key sub-groups. A key theme, from a significant minority of respondents, was that a number of individuals do not have internet access or have a lack of digital understanding. As such, different options for these people need to be provided. It was felt that this proposal should not negatively impact on accessibility. Also that any system introduced needs to be easy to use for varying abilities to use.

On this basis, it is not surprising that a significant minority of individuals pointed to a need for a range of options that would meet all needs. Their suggestions included access to hard copy EPCs and EPCs in PDF format. Advantages noted for a PDF included:

• It is easier to download on more devices
• It is available to print and share with others
• Some people are more used to using PDF files
• They are easier to store and retain as a permanent document.

A significant number of individuals felt that the current system works well and that there is no need for changes to be made. Conversely, some a similar number felt EPCs should be presented in whatever format is most accessible and easy to use. Finally, there were a small minority of comments on the need to provide EPCs in whatever format is cheapest.

Signposting and Further Steps

Q13: Do you agree with our proposal to improve signposting to further support and advice schemes on the EPC?

A majority of respondents were supportive of the proposal to improve signposting to further support and advice schemes on the EPC. Once again, higher numbers of organisations were supportive of this proposal than individuals. In relation to organisation sub-groups, the highest levels of agreement came from housing providers and local authorities.

A total of 152 respondents provided commentary in support of their initial response to this question. Again, a number of these cited the advantages noted in the consultation paper. A small minority of organisations also felt that this would help to increase consumer awareness which they saw as key to delivery of energy savings and emissions reductions.

As at previous questions, there were some qualifying comments made by respondents. These included the need to signpost to independent, competent and reliable service providers who are suitably qualified and have the necessary professional expertise. It was also suggested there should be links to Trustmark installers or Competent Person Schemes. A small minority of respondents specifically referred to the Home Energy Scotland (HES) advice service. This service is seen as professional and offering a holistic approach to energy use in the home. There were also some references to Energy Company Obligation (ECO) schemes.

A small minority of respondents suggested that links should point homeowners to HES rather than linking in directly to information on grants. This was because HES is perceived to provide knowledgeable and consistent advice and support. However, some respondents called for signposting to relevant government funding and grant schemes. Also, for signposting to clearly defined eligibility for support schemes. Energy Systems Catapult, an academic / research organisation commented:

“The EPC should provide an accessible entry point for people to improve the energy performance of their property. It should be designed to enable informed decision-making, helping property owners to consider the options available and how these will achieve the outcomes they are interested in.”

There were also some references – mostly from a small minority of organisations – to a need for signposting to advice and support, appropriate to a building’s age and type of property. This was because it was felt that some types of heating scheme are not appropriate to all types of property. Again, heat pumps in particular were considered to be inappropriate for many older properties. A small minority of construction organisations also pointed to the need to emphasise that property developments can cause damage to the built fabric if incorrectly considered. A small minority of third sector organisations also pointed to the need for signposting not only to advice on energy efficiency but also on climate resilience measures.

A significant minority of organisations across most sub-groups pointed to a need to keep any signposting up-to-date. For example, to provide alerts for new grant funding or so that it is responsive to new and innovative products and energy solutions. Up-to-date signposting would also allow for information on a proposed or planned heat network or Smart Local Energy System (SLES).

There were also comments on the need for any sources of support and advice schemes to be clear, concise and unambiguous. Also to offer signposting that is genuinely helpful and can offer tailored and affordable solutions for buildings. At a workshop, attendees noted the need to ensure there is a balance between giving people precise information and giving them too much information. They felt that if people are provided with too much information, this may overwhelm them and lead to no action.

A small minority of respondents – all organisations – referred to the potential for a portal to provide a one-stop-shop network of organisations.

Concerns over signposting

Once again, some concerns were noted over the need to have a suitably qualified and skilled workforce at both a national and local level.

A small minority of respondents also felt that the provision of signposting is not the purpose of an EPC. This was because EPCs only provide measures of a property’s energy efficiency. Furthermore, any recommendations provided with an EPC may be unsuitable for a specific property, given their general nature. Additionally, EPCs are not a substitute for a full and detailed survey.

Data Access

Q14: Do you agree historical EPCs should be publicly accessible on the EPC register (while clearly marked as historic)?

There was majority agreement overall that historical EPCs should be publicly accessible on the EPC register. As at previous questions, support levels were higher among organisations than individuals. The organisation sub-groups with the highest levels of agreement were housing providers, those in the construction sector and those involved in the EPC process.

A total of 157 respondents provided commentary in support of their initial response to this question.

The advantages of historical EPCs being publicly accessible

A majority of respondents across all sub-groups outlined a range of advantages that making historical EPCs available would bring. These included that this would be a good way to track improvements. Also, to see what measures have been undertaken towards a progression of a move to net zero and energy savings.

A significant minority of organisations, particularly local authorities, noted the usefulness of having a public record of progress. Historical EPCs would allow for regular and transparent monitoring of progress as well as being able to ascertain the validity of any measures undertaken. This also allows organisations to use this information as a baseline reference for future monitoring. As noted by the National Insulation Association:

“This proposal will also help local authorities to understand the common issues and solutions in housing in their local area. The effective use of data is vital to give local authorities an in-depth and detailed picture of their housing stock. This will allow them to plan more effectively for council-led retrofit programmes and create local decarbonisation strategies that are tailored to the local housing stock.”

A small minority of organisations noted the provision of historical EPCs would be of greater interest and use by organisations than individuals.

A similar number of respondents also noted that if there are changes to the ratings and methodology used for EPCs, there will be no potential for direct comparison.

The disadvantages of historical EPCs being publicly accessible

A key concern noted primarily by a small minority of individuals was that of privacy issues and the need to ensure that any changes will comply with GDPR (General Data Protection Regulations)

Accessibility by API

Q15: Do you agree that the EPC register should be accessible by API?

A large minority of respondents agreed that the EPC register should be accessible by API. A higher proportion of organisations were supportive than were individuals. A significant minority of respondents provided a ‘don’t know’ response at this question. Across organisation sub-groups, those offering the highest level of agreement were in the construction sector, housing providers, local authorities and those involved in the EPC process.

A total of 137 respondents across all sub-groups provided further commentary. A number of those responding to this question – mostly organisations – echoed the points noted in the consultation paper.

A large minority of organisations identified important benefits of this approach. These included:

• Benefits for whole system planning
• Help for local authorities which are developing and working towards completing LHEES
• Allowing analysis of trends and comparisons across building stock in real time
• Useful for modelling and analysis
• A useful source for research and policy and help to identify trends and opportunities for improvements

Two key concerns arose from respondents – often, although not solely, from individuals – in relation to this proposal. The first, from a significant minority, was concerns over data protection. There were queries as to how data would be anonymised and whether this would be compatible with GDPR. There was a perception from some of these respondents that this data could be hacked or that there would be a significant risk of cyber-crime.

A small minority of respondents also noted concerns that this information could be abused by organisations wanting to target properties for marketing or scams. Respondents did not want to see this database being used for cold calling purposes.

Q16: Do you have any further comments on our proposals to move to a digital and accessible EPC?

A total of 105 respondents provided comments to this question, a number of which echoed points raised at previous questions. These included:

• The need to provide signposting to services such as funding on the EPC
• It will be an advantage to have real time information
• This will allow for improved accuracy and quality of data analysis work
• It is important to have a capacity to download a printable version of an EPC
• Concerns over digital access and that this may exclude those lacking in digital knowledge or who do not have internet access
• Concerns over the safety of data and the need for safeguards to ensure that security breaches cannot occur
• Users will need to have training so they can understand how to use and work with the data
• The need for ratings on condition, material, energy performance and ownership of buildings so that holistic information can be accessed