Energy Performance Certificate reform consultation: response

4. EPC Operational Infrastructure

We Asked

For both domestic and non-domestic EPCs we proposed to:

• Clarify the purpose of EPCs;
• Reduce the validity period from 10 to five years;
• Modernise the Scottish EPC design format, including moving to a digital webpage format, adding interactive links to signpost further advice and support, and providing links to more tailored recommendations
• Expand the sharing of non-personal EPC data to allow more effective use of this useful resource, including direct public access to current and historical EPC records (this would also apply to other related certificates, including Energy Action Plans);
• Improve the assurance behind EPC assessments by updating the auditing requirements with a risk-based, smart auditing approach. The operating requirements for approved organisations and their members would also be updated.
• Continue to review the use of actual energy use data to inform EPCs, and to continue to consider work that could support the future development of Green Building Passports.
• Introduce regulations in Winter 2023-24, though we noted that we would review the UK Government’s development of SAP11 (now called the Home Energy Model) and consider aligning our EPC reforms with its launch.
• In line with the above, we also set out that we would work with the UK Government and other devolved administrations in the development of the new Home Energy Model which will replace SAP as the calculation methodology used to generate EPCs. This includes development of the Scottish EPC Register and surrounding infrastructure to support the transition.

We asked the following questions on these proposals:

4.1 EPC Purpose and Validity

8. Do you agree with us 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 consider retrofit options?

Yes/No/Don’t know

Please give details for your answer

9. If you disagree, or have further comments about the role of the EPC, please provide your comments.

Please give details for your answer

10. Do you agree that the validity period of EPCs should be reduced from 10 to five years?

Please give details for your answer

11. We welcome any views on the usefulness of our proposals for other relevant policy areas, such as fuel poverty or the delivery of government schemes. Please provide any comments you wish to share.

Please give details for your answer

4.2 Digital and Accessible EPC Format and Content

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

Yes/No/Don’t know

Please provide further details here

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

Yes/No/Don’t know

Please provide further details here

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

Yes/No/Don’t know

Please give reasons for your view

15. Do you agree that the EPC register should be accessible by API?

Yes/No/Don’t know

Please give reasons for your view

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

This could include services that you think EPCs should signpost to, or comments about the use of an API to access the EPC database.

Please explain your view further

4.3 EPC Auditing and Assurance

17. Do you agree with our proposals to review and update the auditing and assurance requirements for EPCs in Scotland?

Yes/No/Don’t know

Please explain your view further

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

Please give details for your answer

Consultation Questions : Legislating for EPC Reform and Timeline

19. Do you have a view on our timeline for reform implementation?

Yes/No/Don’t know

Please give details for your answer

4.4 Purpose and Validity Period

You Said

Key Findings

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

• 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 consider retrofit schemes (Q8)
• There was minority support for the validity period of EPCs to be reduced from 10 to five years (Q10)

Key themes

• There were calls for funding packages and grants to be made available for people to undertake retrofit changes that might be suggested on an EPC
• Concerns that EPCs could be used to force people into undertaking retrofit measures or in preventing house sales (mainly noted by individuals)
• There were some comments that the decision to obtain a new EPC should be the choice of a property owner. Conversely, some respondents felt there are specific points that would or should trigger the need for a new EPC
• The reduced validity period should only apply to new buildings. This was because some heating systems or generic retrofit recommendations are perceived to be inappropriate for some housing stock. Allied to this, there were views that EPCs should not provide retrofit options and advice that could contradict a full technical survey
• A key advantage to a reduction in the validity period of an EPC was that it allows for the provision of more up-to-date and accurate information. However, there were also some calls for EPCs to provide clear, good quality information and signposting to services

Next most frequent themes

• Suggestions for variable validity periods were suggested by some respondents, depending on the type of property and work already undertaken on a property
• Some respondents – primarily individuals – felt that EPCs are of limited usefulness and that specialist retrofit advice from other sources is more useful
• There were some concerns from organisations that changes could have an impact on the housing market in terms of reducing the number of available properties
• There were some queries over a potential lack of assessors to undertake the necessary work

Other themes

• EPCs were perceived to be useful for a range of policy areas as well as better targeting of resources for schemes. However, there were some concerns this could lead to higher levels of fuel poverty, given that electrical heating systems are more expensive
• Some organisations felt the full implications of EPC reform will not be understood until the legislation for the Heat in Buildings Bill is published
• Some respondents expressed views that the development of SAP 11 and the associated SBEM and RdSAP methodologies need to reflect the impact of market changes

We Will Do

We will proceed with our proposal to make clear in the messaging around EPCs that they are intended as a basic, standardised assessment and not a substitute for detailed, technical, retrofit assessment and advice. The EPC will therefore continue to signpost consumers towards that more detailed retrofit assessment and advice on which energy efficiency and clean heat measures are suitable, including via the proposed Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) which we are considering in response to the consultation on proposals for a Heat in Buildings Bill.

We will redesign the EPC as set out at the Certificate Redesign section above. As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use – more details are set out below in section 6 below on Actual Energy Use Data.

We have considered feedback on our proposal to reduce the EPC validity period. This would reduce the validity period for EPCs from 10 years to five years, though would only apply if the validity period is not overridden by another existing requirement (e.g. where a Government funding scheme requires a new EPC, or where a new EPC is already required as part of a Home Report).

We have decided to reduce the validity period of EPCs to five years. We have decided to introduce these measures because we want to protect consumers and ensure they have the most-up-to-date and relevant information when purchasing or renting a property, or seeking advice on improvements they could make to their building to meet any mandatory standards. We do not think a 10-year validity period is appropriate for EPCs to provide that consumer protection. An EPC that is 10 years old will not provide a potential or current tenant or building owner with up-to-date information about the performance of a building, or be able to take into account any changes that have been made in subsequent years.

Together, these measures will also help track improvement in buildings across the housing stock.

4.5 Digital and Accessible

You Said

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

We Will Do

We have decided to move to a webpage as the default way an EPC is viewed, from the current PDF format. We have set out our planned EPC Redesign in the Certificate Redesign section above. This follows the current PDF format and we will consider how best to adapt this to webpage format as part of the Register upgrade work. We have noted the need to ensure that the EPC format allows for a printable version, for example to allow it to be included in a Home Report or for people who do not have access to the internet. As will be set out in the forthcoming, related technical consultation following this Government Response, we are now working to design and build a new EPC Register to the latest digital standards for accessibility, which will implement these changes when the revised regulations come into force.

We intend to modernise the data sharing provisions set out in the EPC regulations. We have listened to requests for wider data sharing, particularly from businesses, local authorities, and registered social landlords. We are also working with the UK Government to review responses to its own consultation on EPC reform, and the proposals it made around data sharing, to consider consistency across the UK. The Scottish Government will put in place provisions that allow non-personal data to be shared by the Keeper of the Register, including the EPC Report Reference Number. This will, for example, allow registered social landlords to more easily see the performance of their stock and how improvement programmes change this over time.

It is important to emphasise that this data sharing relates only to non-personal data, and would not include names or other details about the homeowner (which are not stored on the EPC register) or the EPC assessor.

We intend that these provisions will be implemented by introducing live Application Programming Interface (API) access to the EPC register, allowing interested parties to query the register in real time.

As part of our proposed move to the more accessible, digital format for EPCs we have also now commissioned research to scope out the potential content for a new dynamic EPC User Interface. This would include interactive features allowing consumers to input different variables in terms of their behaviour and preferences, to understand the likely impact that this would have on their energy use – more details are set out below in the Potential Future Reform section below on Actual Energy Use Data.