Domestic and non-domestic energy performance certificates: review

7. Conclusions

Within the responses to the three public consultation documents that formed the basis of this report, satisfaction with the current system of assessing the energy performance of buildings in Scotland ranged from it being considered too subjective, flawed, inaccurate, inconsistent, not reflecting the true thermal performance of a building, and not fit for purpose, at one end of the spectrum; through to offering a simple, readily accepted, easy to understand, cost effective tool to underpin high level policy analysis to improve the energy performance of the dwelling stock at the other end. That there is truth in both extremes reflects the evolving purposes of the EPC system.

The current EPC process was designed to produce an asset rating to comply with the requirements of the EPBD. What may have been sufficient as a general measure of energy performance, using a simplified energy model and an A to G banding may not be appropriate if the same system is utilised to regulate compliance with energy efficiency standards in existing buildings.

To date the Scottish Government has aligned itself the rest of the UK on the calculation methodologies and assessment conventions, providing a consistent approach across all four nations. The Scottish Government has taken a different approach in some areas relating to EPCs and assessors, e.g. with regard to the establishment of protocol arrangements, the format of the domestic sector EPC, displaying EPCs in non-domestic buildings, and the creation of a Scottish register for lodging the EPCs, Action Plans and Display Energy Certificates. Going forward, it is within the remit of the Scottish Government to change or amend further any or all of the four components of the EPC process.

Taking ownership of the calculation methodologies and effectively establishing a Scottish SAP is likely to incur significant costs, efforts, and resources. However, the process of negotiating and agreeing desired changes with a number of other vested interests within the current arrangements may not address all of the issues of concern. Taking a more hands-on control of the shaping of assessor conventions, re-negotiating the existing protocol arrangements with regard to assessor training, and reformatting the EPC, could allow an increased Scottish dimension to be added to the EPC process without changing the underlying methodologies or calculations.

This review extracted 1066 contributions relating to SAP, RdSAP, SBEM and EPCs from the 343 published responses to the three consultation documents that were the source data for this report. These responses were collated, and grouped through a thematic analysis to identify topics and technical issues that were examined and discussed in more detail across 4 workshops that were organised in 4 different locations across Scotland in 2018. The 1066 contributions have been distilled down into 80 possible actions for the Scottish Government’s consideration in taking forward the EPC process in Scotland. These possible actions are summarised and organised by whether they are related to calculation issues, assessment issues, reporting issues, or database issues in the final section of this report.