Energy Performance Certificate reform: consultation analysis

Quality Assurance and Approved Organisation Framework proposals

Key Findings

• A large minority of respondents supported the proposals to review and update the auditing and assurance requirements for EPCs in Scotland (Q17)

Key themes

• Improvements to auditing and assurance requirements were broadly welcomed, with some comments that the current system does not produce consistency and there are some issues around quality
• Support for the consistency of high standards and accuracy of information, amid concerns about variations and discrepancies in EPC outcomes
• Smart auditing was broadly welcomed as being effective

Next most frequent themes

• Good governance and administration of the system was urged in order to gain consumers’ trust
• On additional assurance activities, a better system to help ensure the consistency of EPC surveys and assessments was advocated, including better ways of flagging inconsistencies
• Allied to this there were recommendations for the collection of real performance data
• Calls were made to ensure that assessors undergo proper training to attain the requisite accreditations and skills

Other themes

• Support for allowances and flexibility to be provided for traditionally built buildings and for enabling stakeholders to be able to challenge assessments and EPCs
• Concerns were expressed about extra burdens, costs and regulation on consumers arising from extra assurance requirements
• Other concerns were a perceived lack of clarity and detail in the auditing and assurance proposals

Q17: Do you agree with our proposals to review and update the audit and assurance requirements for EPCs in Scotland?

A large minority of respondents to the consultation agreed with the proposals, while a significant minority disagreed. Almost all organisations who gave a definite response agreed, while individuals agreed and disagreed in almost equal numbers. Across organisation sub-groups, the highest levels of agreement came from those involved in the EPC process, those in the construction sector and local authorities.

Respondents were then asked to provide further details explaining their answer, with 149 choosing to comment. A majority of the comments were supportive in nature.

Comments supporting the proposal

General support was provided by a large minority of respondents who welcomed any improvements to auditing and assurance, commenting for example that these were sensible and overdue.

There was also some concern that the current system is unfit for purpose. For example, it was perceived as not producing consistency amid quality issues with EPCs and fraud concerns. A significant minority expanded on these issues. These included:

• Random variation
• EPCs with incorrect floor areas and construction areas
• Falsification around deflation of energy efficiency to gain access to the scheme
• Incorrect identification of primary heating sources
• Omissions of secondary heating sources

A significant minority thought improvements to auditing and assurance would help ensure the consistency of high survey standards, as well as the reliability of data and the competency and expertise of assessors. Accuracy of information in EPCs may also be improved, perhaps by providing a true reflection of energy efficiency to consumers and other stakeholders. Allied to this were a small minority of comments in favour of using actual or measured energy use in EPC calculations, perhaps alongside the SAP methodology.

The proposal to introduce a smart auditing process was welcomed by a significant minority. This was seen as effective, with support for automated triggering of audits when certain criteria are hit. Also, the ability to identify errors in assessments more systematically than random checks was praised. It was also noted that this would synchronise with auditing regimes in other jurisdictions, and that it resulted in improvements when implemented in England and Wales.

There were also a small minority of views that the improvements would help gain public trust, with the result that more attention would be paid to EPCs and subsequent signposting. Allied to this were requests to include routes for redress or complaints procedures for consumers if problems emerged with assessments.

Caveats to Support

A significant minority of respondents qualified their support, and did not want to see further burdens or costs placed on homeowners, occupants, businesses, or local authorities. A small minority each intimated they would be supportive if:

• The auditing and assurance system is well designed and works well in practice
• There are other checks independently of smart auditing
• There are sufficient numbers of assessors undergoing proper training and attaining suitable accreditations and skills
• The processes are in line with those in the rest of the UK

Comments opposing the proposal

Only a small minority of comments gave reasons for not agreeing with the proposal. The following reasons were mentioned:

• The current auditing and assurance system works well
• Concerns about increased bureaucracy, regulation and costs
• Scepticism as to whether the proposals will be administered properly, citing concerns over government impartiality and suspicions over unscrupulous use
• Lack of impact of smart or risk-based audits which are already being used in industry
• Scepticism as to whether the accuracy of basic input information and data produced by EPCs will improve

Additionally there were a small minority of concerns about a lack of detail as to what is intended.

Finally a significant minority reiterated their negative opinions about the EPC proposals overall.

Q18: Please detail any additional assurance activity that you think would be appropriate to enhance the accuracy and reliability of EPCs

This question elicited 129 responses, a large majority of which outlined a wide variety of additional assurance measures. Two themes however were the most frequently mentioned, each by a significant minority of respondents.

Additional Assurance Activities

Firstly, there was support for a better system to help ensure the consistency of EPC surveys and assessments. Current perceptions were that data can be inaccurate and unreliable. Respondents wanted to see better ways of flagging inconsistencies, and an energy assessor suggested increasing the Minimum Evidence Requirements. Allied to this, a significant minority of respondents again advocated the addition or collection of real performance data. It was suggested that predicted energy use was flawed, and that there should be a move away from ‘assumed’ input. The use of equipment to measure heat loss was recommended, along with letting assessors use their expertise to physically check installed insulation and building fabric.

Secondly, there were calls to ensure that assessors undergo proper training to attain the requisite accreditations and skills. It was perceived that different knowledge bases and specific qualifications would be needed for differently constructed buildings. Additionally, oversight of accreditation schemes was suggested as a further aid to help align consultants’ standards. A small minority also sought more effective audits for energy assessors by way of annual checks or peer reviews.

Other extra assurance activities were proposed by a small minority as follows:

• Enforcing standards or taking action where issues are discovered
• Enabling consumers and third parties to challenge assessments and EPCs
• Making input data (e.g. for SAP) and assessors detailed calculations publicly available to property owners to allow for transparency and validation
• More frequent and regular audits allied to greater numbers of assessors
• More tailored or practical improvement measures included in an EPC

It was also suggested that assurance processes should be aligned with those in the rest of the UK. An efficient system for triggering audit alerts, automated tests or sanity checks on submitted EPC data was also proposed.

Other comments

There were also requests for allowances or flexibility to be shown in the cases of traditionally built (e.g. pre 1919) buildings and other non-standard homes and situations. It was recommended that assessors have specific accreditation for these. Also, that specific policy guidance or legislation is provided to ensure these properties are not unfairly penalised. Flexibility was also requested for other construction facets such as fabric condition, age and thermal bridging.

A small minority commented on the impact of SAP and RdSAP methodologies. There were suggestions that reforms to EPCs should wait until new versions of these have been published. There were also requests for regular SAP updates to reflect energy price changes. Also, procedures to verify that findings are accurate as these methodologies will have a large impact on the success of EPC reforms. There were perceptions that SAP training is based on English archetypes and therefore unsuitable for Scotland. It was also felt there can be inconsistencies where multiple heating controls are involved, with Passivhaus software (Passivhaus Planning Package - PHPP) being more accurate and reliable.

In the adoption of smart auditing, there were a small minority of comments about being aware of perceived unfair audit triggers and the importance of highlighting assessor-related inconsistencies.