Domestic and non-domestic energy performance certificates: review

2. Energy Performance Certification in Scotland

2.1 Introduction to EPCs

The provision of an EPC in Scotland can be summarised as a four-part process:

1. the assessment / survey of the building by an accredited person;

2. a calculation using a government approved methodology;

3. the lodgement of the results onto a national register to store the data; and,

4. the production of a certificate to an agreed Scottish format

The Scottish Government maintains an online resource containing 12 ‘Guidance Leaflets’ on a range of issues relating to the provision of domestic and non-domestic EPCs in Scotland^[9].

2.2 Background to Energy Performance Certificates

The original policy driver for the current system on EPCs was the European Union’s (EU) Energy Performance in Buildings Directive 2002 (EPBD)^[10] with its objective to promote the improvement of the energy performance of buildings across EU member states. The EPBD included, amongst others, the following requirements:

• to apply a methodology to calculate the energy performance of buildings (under Article 3);
• to ensure that when buildings with a total useful floor area over 1000 m² undergo major renovation, their energy performance is upgraded in order to meet minimum requirements in so far as this is technically, functionally and economically feasible. (under Article 6);
• to ensure that when buildings are constructed, sold or rented out, an energy performance certificate is made available to the owner or by the owner to the prospective buyer or tenant, as the case might be. The energy performance certificate for buildings was to include reference values and be accompanied by recommendations for the cost-effective improvement of its energy performance. (under Article 7); and,
• to ensure that the certification of buildings is carried out in an independent manner by qualified and/or accredited experts (under Article 10).

This directive was transposed into Scottish statute via The Energy Performance of Buildings (Scotland) Regulations 2008^[11]. Under Section 6 of these regulations,

“6.— (1) An energy performance certificate must–

(a) express the asset rating of the building in a way approved by the Scottish Ministers under regulation 7(b);

(b) include a reference value;

(c) include cost effective recommendations for improving the energy performance of the building;

(d) include the following information–
(i) the address of the building;
(ii) where the certificate is issued by a qualified member of an approved organisation, the name of the approved organisation of which the person issuing the certificate is a member; and
(iii) the date on which it was issued; and

(e) be issued by a qualified member of an approved organisation for that category of building, or accepted by a verifier following submission of a completion certificate in accordance with regulation 41 of the Building (Procedure) (Scotland) Regulations 2004(1).”

In Scotland, the requirement to produce an EPC came into effect for all new buildings applying for a Building Warrant on or after May 1, 2007, and for existing buildings when constructed, sold or rented from January 4th, 2009. Since then, there have been various amendments and revisions to the calculation methodologies, the conventions governing the assessments of buildings, the format of the EPCs, and the Scottish EPC register.

2.3 Calculations Using Approved Methodologies

Underpinning the production of an EPC for a building in Scotland are various approved methodologies (i.e. SAP, RdSAP, and SBEM) which define the algorithms used to calculate the energy performance of a building, and approved computer software^[12] that does the calculations. The two are inextricably linked.

Legislation on both domestic and non-domestic Building Regulations, and on housing matters, are devolved matters. That Scotland uses the same methodologies as the rest of the UK for assessing the energy performance of buildings was a matter of choice. During the period leading up to the formal introduction of the system of EPCs in Scotland, the Scottish Government via the then Scottish Building Standards Agency explored the development of a Scottish-derived system of rating the energy performance of buildings, the Scottish Energy Rating Tool (SERT).^[13][14] Ultimately, the Scottish Government took the decision in 2008 to adopt the same respective methodologies being used across the rest of the UK, that is,

• the Standard Assessment Procedure (SAP) for new domestic dwellings^[15]
• the Reduced Data Standard Assessment Procedure (RdSAP) for existing domestic dwellings^[16]
• the Simplified Building Energy Model (SBEM) / National Calculation Methodology (NCM) for new and existing non-domestic buildings^[17]

The details that underpin these methodologies are published and all freely available online.^[18][19][20]

Oversight of these three methodologies is maintained by two different UK government Departments: the Department of Business, Energy and Industrial Strategy (BEIS) lead on SAP and RdSAP; the Ministry of Housing, Communities and Local Government (MHCLG) lead on SBEM. Both operate in consultation with representatives of the devolved administrations (including Scotland), the Building Research Establishment (BRE), industry participants, software producers / accreditation schemes, and the national registers. BEIS has recently finished a public consultation exercise on the next iteration of SAP, to be known as SAP 10^[21].

2.4 Assessment Process

The assessment process refers to the assessors, and the methods by which assessors collect the necessary data to be entered into the approved software to calculate the energy performance indicators. Different accreditation schemes exist for assessors in Scotland, and England and Wales, and Northern Ireland.

In Scotland, EPCs can only be produced by an assessor who is a member of an ‘Approved Organisation’^[22]. The Scottish Government has entered into formal agreements with various organisations whose members are considered to have the skills and expertise to produce EPCs and make recommendations on improvement measures. A list of Scottish EPC assessors is held by the Scottish EPC register^[23]. A Scottish assessor is not registered to issue EPCs in England and Wales without also being registered with an EPC accreditation scheme there; an English EPC Assessor cannot issue EPCs in Scotland without becoming a member of a Scottish Approved Organisation that has signed a protocol agreement with the Scottish Government.

To assist with promoting consistency between assessors, conventions and guides have been published and these too are online.^[24][25][26] Three separate conventions working groups overseen by BEIS and MHCLG respectively, include representatives of the devolved administrations (including Scotland), the Building Research Establishment (BRE), industry participants, software producers / accreditation schemes, and the national registers. The BRE chairs the working groups on SAP and RdSAP, while a representative of Landmark (the company that administers the EPC Register for England, Wales and Northern Ireland EPCs) chairs the SBEM/NCM working group.

2.5 Reporting Process

The reporting process here refers to the physical output from the assessment of the energy performance of a building, that is, the actual EPC and the associated energy advice report and recommendations.

While the EPBD requires that an EPC and an energy advice report be produced for a building at the point that the building is constructed, sold or rented out, the EPBD does not specify the appearance or content of these items. That EPCs in Scotland look different from those issued in England, Wales and Northern Ireland is the direct result of decisions taken by the Scottish Government on the format and content of Scottish EPCs. These formats are used to generate EPCs from data held on the Scottish EPC register and also by Approved Software in situations where the EPC is generated from within the software (e.g. a draft EPC).

The EPC format for existing Scottish domestic dwellings changed considerably on 1 October 2012, and for all other Scottish building type EPCs on 28 January 2013.

2.6 Registering an EPC in the Scottish National Database

The EPBD does not require the establishment of a national database to store EPCs or the information collected during the assessment or the results produced by the calculations. From the perspective of a national data archive, however, establishing such a register makes a lot of sense, as EPCs contain detailed information pertaining to the energy efficiency characteristics of the dwelling stock.

Initially, EPCs for existing dwellings were lodged within the Energy Saving Trust’s (EST) Home Energy Efficiency Database (HEED) (from 2009 to October 2012). New dwelling and non-domestic building EPCs were issued as paper copies by assessors using the relevant software, but they were not lodged separately. A separate Scottish Register was established for existing dwelling EPCs lodged from October 2012 onwards, and opened up to take EPCs for new build dwellings and for new and existing non-domestic buildings from January 2013.

Access to the Scottish EPC register^[27] is open to anyone to search online for an EPC either by a postcode or by the EPC’s unique registration number (i.e. its Report Reference Number (RRN)), which is on the EPC, subject to the person agreeing to abide by the Terms and Conditions of use of the website. If searched by the RRN, the website will only bring up the one relevant EPC. When searched by postcode, it will bring up a list of all the addresses at that postcode where an EPC has been issued, provide the respective RRNs, and allow the PDF of the EPC to be downloaded – but only the most recent one issued. When a new EPC for a property is lodged, any existing EPC is overwritten on the public interface of the register, though the older EPCs are still held within the system.^[28]

2.7 Going forward with EPCs in Scotland

For Scotland going forward, the fundamental aim of this report is to address identified concerns within the EPC process from a Scottish perspective, identifying where changes could be made, with the intention of making recommendations that will allow the EPC process to more accurately reflect the Scottish built environment, and by improving EPCs where practical and appropriate.