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

Age^[4]

The age of the highest income householder is closely related to their tenure. Compared with the age distribution of Scottish householders, those in the private rented sector have a younger age profile;

• around half (47%, or 159,000 households) of PRS highest income householders are under 35 compared to 16% (395,000 households) of all Scottish householders
• around 12% (41,000) are aged 65+ compared to 31% (760,000) in Scotland as a whole.

As such, 40% (159,000) of households headed by a householder under 35 are in the PRS. Of these, 5% (8,000) are affected by regulation to Band E, and 20% (31,000) are affected by regulation to Band D. As a result, 35% of those affected by regulating to a minimum standard of Band are headed by householders under 35, which is less than the proportion in the PRS as a whole.

Furthermore, the proportion of Band E households in the PRS headed by a householder under 35 is also lower than in the PRS as a whole, as householders under 35 are less common in homes that are rated Band F or Band G in the PRS (27% in this group compared to 47% in the PRS overall).

In contrast, 5% (41,000) of householders headed by householder over 65 live in the PRS. Of these, 17% (7,000) are affected by regulation to Band E, and 36% (15,000) are affected by regulation to Band D. Therefore, 17% (15,000) of all PRS households affected by moving to a minimum standard of Band D are headed by householders aged 65 or older (similar to the proportion of households headed by over 65 year olds in the PRS as a whole) and around 24% of those affected by moving to a minimum standard of Band E (higher than the proportion in the PRS as a whole) are headed by householders aged 65 or older.

For the PRS as a whole, 9% of households are affected by regulation to Band E, and 26% to Band D.

Therefore, while fewer older households live in the PRS compared to younger households, proportionally more will be

affected by the regulations to Band E and Band D than younger households, as older households are more likely to live in less energy efficient PRS properties. However, due to the younger profile of the PRS as a whole, more younger households will be affected overall.

The incidence of families in the regulated properties is also similar to the private rented sector as a whole and to Scotland. Almost quarter of low energy efficiency dwellings in the PRS are occupied by households with at least one child aged under 16 (22% of PRS dwellings in current Bands E, F or G and 23% of PRS dwellings in current Bands F or G); the differences with the shares of families in the PRS as a whole (25%) and in Scotland (23%) are not statistically significant.

2015-2017 Scottish House Condition Survey

We do not think that there will be any adverse impacts from the policy because of a person's age. While there is potential for disruption while work is carried out, the tenant will benefit from having a warmer home, and this may particularly benefit vulnerable older residents and children by improving their warmth and reducing their risks of respiratory diseases, etc, which can be linked to poor energy efficiency.

Disability^[5]

Around 44% of households (equivalent to 1,068,000 households) in Scotland in 2015-2017 reported at least one person who is long-term sick or disabled (LTSD). This figure covers all household members, including children. Around 10% (107,000) of LTSD households live in the PRS – consequently 32% of the PRS overall report a household member having some long-standing health problem, lower than the rate in Scotland overall. The LTSD rates for the groups affected by the minimum Band E or Band D standard are both 38%. The differences with the private rented sector as a whole (32%) are not statistically significant.

Therefore there is no evidence to suggest that PRS households where one or more person suffers a long-standing health problem or disability would be disproportionately affected by regulation to improve energy efficiency in the PRS. However, because households with LTSD are less likely to live in private rented accommodation, they are less likely to be affected by the policy proposal.

2015-2017 Scottish House Condition Survey

We do not think that there will be any adverse impacts from the policy because of a person's disability. While there is potential for disruption while work is carried out, the tenant will benefit from having a warmer home, and this may particularly benefit tenants with a disability by improving their warmth and reducing their risks of respiratory diseases, etc, which can be linked to poor energy efficiency.

There is no evidence to suggest that, overall, a minimum energy efficiency standard would disproportionately affect people with a disability.

Sex

14% of households which are female headed live in the PRS, equivalent to 141,000 households. Of these households, 25% (33,000) live in low energy efficient PRS dwellings (Bands E,F or G). As a result, two-fifths of all low energy efficient dwellings in the PRS are occupied by households which are female-headed; 40% (35,000 households) of PRS dwellings in current Bands E, F or G and 39% (11,000 households) of those currently rated Band F or Band G. The differences with the share of householders in the PRS as a whole (42%) and in Scotland (41%) which are headed by a female householder are not statistically significant. The incidence of families in the regulated groups is also similar to the private rented sector as a whole and to Scotland, where around a quarter of households contain at least one child aged under 16.

There is therefore no evidence that female headed households in the PRS or households with children in the PRS may be more likely to be affected by a minimum Band E or Band D standard than other households.

2015-2017 Scottish House Condition Survey

We think that there will be positive impacts on any tenant living in a home affected by the proposals as homes will be warmer and easier to heat.

There is no evidence to suggest that, overall, a minimum energy efficiency standard would disproportionately affect either sex.

Pregnancy and Maternity

There is no information in either the SHCS or the Census relating to pregnancy

We think that there will be positive impacts on any tenant living in a home affected by the proposals as homes will be warmer and easier to heat.

Gender Reassignment

There is limited information on housing tenure for transgender people. This information was not collected in the census or the SHCS, and housing providers do not routinely gather such data. A Scottish Transgender Alliance survey in 2012 reported that 11% of 526 respondents rented privately as a joint tenant and 9% rented privately as a single tenant

Scottish Government Equality Outcomes: Lesbian, Gay, Bisexual and Transgender (LGBT) Evidence Review (http://www.scotland.gov.uk/P ublications/2013/04/7520/4)

We think that there will be positive impacts on any tenant living in a home affected by the proposals as homes will be warmer and easier to heat.

We do not know of any reason why minimum standards for energy efficiency would disproportionately affect people in this category.

Sexual Orientation

There is limited information on housing tenure for sexual orientation. This information was not collected in the census or the SHCS, and housing providers do not routinely gather such data.

We think that there will be positive impacts on any tenant living in a home affected by the proposals as homes will be warmer and easier to heat . We do not know of any reason why minimum standards for energy efficiency would disproportionately affect people because of their sexual orientation.

Race

On census day 2011 there were approximately 200,000 Black, Asian and Minority Ethnic (BAME) people in Scotland, making up just over 4% of the population. However they make up around 10% of the population living in the private rented sector.

The SHCS sample is not sufficiently large to allow a breakdown of the regulated groups by ethnicity and to analyse the equality impact of the proposed regulations on ethnic minorities, even with three years of data combined.

However, data available from the Census indicates that BAME communities are largely concentrated in urban locations. The SHCS estimates private rented sector dwellings in urban areas have a higher (i.e. better) energy efficiency profile (4% of PRS urban dwellings were in Bands F or G in 2015-2017 compared to 33% of PRS rural dwellings), therefore fewer of these dwellings are likely to be required to take action under these regulations.

There is therefore no strong evidence that BAME populations would be adversely affected by the policy options

2011 Census

We think that there will be positive impacts on any tenant living in a home affected by the proposals as homes will be warmer and easier to heat. We do not know of any reason why minimum standards for energy efficiency would disproportionately affect people due to their race.

Religion or Belief

According to the 2011 Census, in Scotland, 56% of the population report having a religion: 54% report as being Christian, 1.4% as being Muslim. Minority religion groups (Buddhist, Hindu, Jewish, Muslim, Sikh) tend to be concentrated in Glasgow and Edinburgh.

Information relating to the housing of those with religious beliefs is limited. The Census provides the religion of people aged 16+ broken down by tenure. This shows a similar proportion of people with no religion in the PRS (36%) compared to Scotland as a whole (34%). The proportion of private tenants with minority religious beliefs (Muslim 1%, Hindu 0.1% and Buddhist 0.2%) is also similar to the Scotland as a whole.

Due to sample size constraints, it is not possible to analyse affected households by religious belief using the SHCS, even when three years of data are merged, however Census data indicates that minority religions are largely concentrated in urban areas, where fewer private rented sector dwellings are likely to be required to take action under these regulations: 33% (18,000 dwellings) of rural PRS dwellings are rated in EPC Bands F or G, compared to 4% of urban dwellings (11,000 dwellings).

There is therefore no strong evidence that populations of minority religions would be adversely affected by the policy options

2011 Census (Table KS209SCb and AT_124_2011)

We think that there will be positive impacts on any tenant living in a home affected by the proposals as homes will be warmer and easier to heat. We do not know of any reason why minimum standards for energy efficiency would disproportionately affect people due to their religion and belief.

Marriage and Civil Partnership (the Scottish Government does not require assessment against this protected characteristic unless the policy or practice relates to work, for example HR policies and practices - refer to Definitions of Protected Characteristics document for details)

As this policy does not relate to the protected characteristic, in the home environment or in relation to the workplace, we have not considered it for this EQIA.