The Energy Efficiency (Private Rented Property) (Scotland) regulations 2020: EQIA

Stage 1: Framing

Results of framing exercise

13. The purpose of the Regulations and associated guidance is to introduce energy efficiency standards to improve energy efficiency in the worst performing private rented housing, to reduce emissions and help tackle fuel poverty.

14. In this assessment, we have analysed evidence gathered under the following headings: age, disability, gender, gender identity/transgender people, sexual orientation, gender reassignment, race, religion and belief. Where there were gaps in evidence we used the consultation period to look for evidence to fill them.

15. Evidence for this assessment was drawn from the Scottish House Condition Survey (SHCS) module of the Scottish Household Survey (SHS) collected in the period 2015-2017 and, where insufficient information was available from this source, from the 2011 census.

16. The statistics referred to in this assessment may relate to the characteristics of the highest income householder (hereafter, 'the householder') – e.g. the evidence given in relation to age and gender - or to the characteristics of any of the members within the household – e.g. the evidence provided under the disability heading.

17. The term 'Private Rented Sector' (PRS) is used to describe any tenure where the occupant does not own the dwelling and the landlord is not a local authority or registered social landlord (RSL). The policy will affect the occupants and owners (landlords) of low energy efficiency dwellings in privately rented properties which are covered by the repairing standard. Energy efficiency is defined using the Energy Performance Certificate Energy Efficiency Rating Band A - Band G, where G is the least efficient and A is the most efficient, and is based on the 2012 Standard Assessment Procedure (SAP) methodology. Energy efficiency ratings are available from the SHCS on a SAP 2012 basis for the latest three reporting years (2015,2016 and 2017).

18. From 1 April 2020 the regulations will affect properties with an EPC below Band E and from 1 April 2022 for properties with an EPC below Band D (as the standard will increase over time).

19. Any decision to raise the standard after 2025 would be taken in the context of the contribution of minimum standards to the Climate Change Plan and the development of a new long term strategy for tackling fuel poverty.

20. This assessment presents evidence on both options, as summarised in the table in Annex One. Results for the regulation to Band E are more tentative, as they are based on a relatively small sample (111 cases, compared to 311 cases for the regulation to Band D, and 1,072 in the PRS as a whole). However, with the responses received from the consultation analysis, we can draw conclusive evidence about the differences between the policy options in terms of their equality impact.

21. We have gathered evidence for each of the equality groups as outlined above and has been considered together with additional evidence resulting from consultation responses.

Extent/level of EQIA required

22. From the evidence we have gathered, we do not think that any households with people that have protected characteristics will be disproportionately affected by the proposed energy efficiency standards compared to households as a whole.

23. Retrofit works may, in some instances, lead to disruption in homes and some equality groups may be more vulnerable during these times. However, by allowing a reasonable lead-in time for changes, landlords will be able to plan any major works between tenancies, or other convenient times, and in the longer term, the benefits to all tenants should outweigh any temporary inconvenience. We do not anticipate the scale of work would be sufficient to require households to move out while work is being done but this will obviously depend on the individuals situation and amount of improvement needed.