1. The Domestic Sector
1. What are your views on our proposal for owner occupied and private rented properties to achieve the Long-Term Domestic Standard EPC Energy Efficiency Rating Band C by 2040 at the latest?
Question 1: What are your views on the proposed target to maximise the proportion of social housing meeting EPC Band B by 2032?
Great sympathy with the objectives but believe that technologies are coming to market far faster than intelligent usable regulations can be created.
The accumulation of regulations, tends to create a regulatory white out.
Resources should instead be used to create a Buildings Environmental Sustainability Code similar to the Highway code in legal status. This would mean that the BES Code would not be law but failure to comply with advice in it could be taken into account in legal proceedings. Current jargon appears to describe this status as non statutory, sub-target and interim.
Energy Performance Certificates would be transferred into the BES Code and share the Code’s legal status.
The BES Code of advice would be more amenable to evolution than legislation is to changing.
Thus existing BES Code items, superceded by new disruptive technology game changing products on the market, could be removed and the new technology products can be added.
Illustrative examples on light bulbs and how local wasting energy gets to local fuel poor homes are below in this Q1 answer. Two further situations are in the Q5 answer Poor Air Quality as they fit that topic.
Light bulbs
Filament light bulbs which were overtaken by long life light bulbs are themselves now overtaken by Light Emitting Diode light bulbs.
After kitting out my house with long life high efficiency bulbs, unsolicited mailings by energy utilities overflowed a shelf with more long life high efficiency light bulbs.
LED bulbs now create a need to dispose of bundles of superceded hazardous mercury waste long life high efficiency bulbs, some of which are unused.
The unsolicited mailing were a response to pressure, if not regulatory requirements on energy utilities, to foster energy efficiency.
Local Wasting Energy
Over large areas of the Highlands and Islands :-
a) a high proportion of homes are fuel poverty households with limited capital in buildings which are damp, expensive to heat , etc
b) the UK electricity grid management chooses how much power it takes from the power offered at any point in time by local existing grid connected generators. Exact figures are not to hand but meaningful proportions of available offered electrical power are being refused.
c) the UK wide grid electricity energy policy is refusing grid connections to new Highland and Island generator proposals unless they come with an additional customer to take the additional energy the new generation scheme will generate.
d) a current issue on the island of Lewis is whether a large, remotely owned, intrusive renewable energy scheme incorporating an additional grid interconnector should be permitted.
Homes in these geographical areas where electrical power is being refused would benefit from development of means :-
a) to identify at any point in time how much surplus local renewable energy from locally owned generators is being rejected by the UK grid and going to waste
b) switches and controllers, using the broadband connectivity already provided in remote areas by the Scottish Government, to offer, accept, connect and meter the surplus electricity.
c) a human intelligence business model
i) where levels of power exported and/or the associated revenue are not reduced [outside revenue coming in to community groups generators is at least maintained]
ii) residence qualified locals, to have priority when bidding for locally generated surplus energy. [Local demand may peak overnight for storage heating, etc. whereas UK grid peaks are morning and late afternoon ?]
iii) once extra sales income from selling run of river, tidal, wind, etc., power that would otherwise go to waste, covers fair wear and tear and extra billing, the rest is profit straight to the bottom line.
iv) when the business model has been tailored to fit and has cut its teeth operationally on island and remote communities we have an innovative energy pricing business model product to roll out, scale up and export. First within Scotland, then to the developing world and possibly to mainstream power utilities.
The accumulation of regulations, tends to create a regulatory white out.
Resources should instead be used to create a Buildings Environmental Sustainability Code similar to the Highway code in legal status. This would mean that the BES Code would not be law but failure to comply with advice in it could be taken into account in legal proceedings. Current jargon appears to describe this status as non statutory, sub-target and interim.
Energy Performance Certificates would be transferred into the BES Code and share the Code’s legal status.
The BES Code of advice would be more amenable to evolution than legislation is to changing.
Thus existing BES Code items, superceded by new disruptive technology game changing products on the market, could be removed and the new technology products can be added.
Illustrative examples on light bulbs and how local wasting energy gets to local fuel poor homes are below in this Q1 answer. Two further situations are in the Q5 answer Poor Air Quality as they fit that topic.
Light bulbs
Filament light bulbs which were overtaken by long life light bulbs are themselves now overtaken by Light Emitting Diode light bulbs.
After kitting out my house with long life high efficiency bulbs, unsolicited mailings by energy utilities overflowed a shelf with more long life high efficiency light bulbs.
LED bulbs now create a need to dispose of bundles of superceded hazardous mercury waste long life high efficiency bulbs, some of which are unused.
The unsolicited mailing were a response to pressure, if not regulatory requirements on energy utilities, to foster energy efficiency.
Local Wasting Energy
Over large areas of the Highlands and Islands :-
a) a high proportion of homes are fuel poverty households with limited capital in buildings which are damp, expensive to heat , etc
b) the UK electricity grid management chooses how much power it takes from the power offered at any point in time by local existing grid connected generators. Exact figures are not to hand but meaningful proportions of available offered electrical power are being refused.
c) the UK wide grid electricity energy policy is refusing grid connections to new Highland and Island generator proposals unless they come with an additional customer to take the additional energy the new generation scheme will generate.
d) a current issue on the island of Lewis is whether a large, remotely owned, intrusive renewable energy scheme incorporating an additional grid interconnector should be permitted.
Homes in these geographical areas where electrical power is being refused would benefit from development of means :-
a) to identify at any point in time how much surplus local renewable energy from locally owned generators is being rejected by the UK grid and going to waste
b) switches and controllers, using the broadband connectivity already provided in remote areas by the Scottish Government, to offer, accept, connect and meter the surplus electricity.
c) a human intelligence business model
i) where levels of power exported and/or the associated revenue are not reduced [outside revenue coming in to community groups generators is at least maintained]
ii) residence qualified locals, to have priority when bidding for locally generated surplus energy. [Local demand may peak overnight for storage heating, etc. whereas UK grid peaks are morning and late afternoon ?]
iii) once extra sales income from selling run of river, tidal, wind, etc., power that would otherwise go to waste, covers fair wear and tear and extra billing, the rest is profit straight to the bottom line.
iv) when the business model has been tailored to fit and has cut its teeth operationally on island and remote communities we have an innovative energy pricing business model product to roll out, scale up and export. First within Scotland, then to the developing world and possibly to mainstream power utilities.
2. Do you think we should allow for situations where a lower standard is acceptable?
Please select one item
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Ticked
Yes
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Unticked
No
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Don't know
Please explain your answer, giving examples.
See the answer to Q1. above.
More a different standard in tune with local geographic economic sense.
More a different standard in tune with local geographic economic sense.
3. Do you think we should allow for situations where a longer period for improvement is allowed?
Please select one item
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Yes
Radio button:
Unticked
No
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Don't know
Please explain your answer, giving examples.
See answers to Q1 and Q2 above.
4. We are proposing that the definition of a cost-effective measure is that it should payback over its lifetime. What are your views on this definition?
4. We are proposing that the definition of a cost effective measure is that it should pay back over its lifetime. What are your views on this definition?
No view.
5. What are your views on the issue of air quality in relation to the Long-Term Domestic Standard?
5. What are your views on the issue of air quality in relation to the Long-Term Domestic Standard?
Here are two air quality improvement mechanisms for a BES Code....... See answer to Q1.
1) Indoor air quality depends on the air being changed … ventilation.
People in Nova Scotia in Canada have always lived in draught sealed houses to prevent losing heat during winters so cold the sea may freeze. Each winter day for ten minutes in the morning the Nova Scotians open their doors and windows wide in order to change the air in the house completely.
2) Unventilated properties tend to have condensation, mould, mildew, etc. The better the draught-proofing the worse the ventilation.
Dehumidifiers are devices to cool moist air to the dew point temperature at which the water vapour in moist air changes into water again. This non hazardous condensed water is collected in a tank or connected to a drain.
A dehumidifier consumes electricity to run its pump and process controller and outputs heat and water. The clever scientific bit is that the latent heat of vaporisation taken from the condensing water also comes out as heat energy.
The latent heat for a litre of water to change to a kg of steam, or vice versa, is 0.63 kWhr. Our electricity and gas bills charge us around 16p and 4p respectively for kWhr units.
As a comparison the latent heat of vaporisation is roughly six and two thirds times the latent heat of freezing.
Dehumidifiers are cheap, compact and their low power means installation is plugging into a 13 amp socket. In common with many cheap smart technology products, a commercial outfit could not make a viable business from selling dehumidifiers as water vapour latent heat source, heat pumps.
A pathfinder project for a damp property with electric only heating.
Part of the electricity presently feeding to electric heaters would instead be routed to power dehumidifiers.
The results should be more heat being delivered to the property, a reduction in the relative humidity in the property to healthy levels with no increase in the electricity bill.
Another pathfinder could compare a dehumidifier with a curtain or cover guiding the air flow round a rack of washing to the existing arrangements for drying washing.
1) Indoor air quality depends on the air being changed … ventilation.
People in Nova Scotia in Canada have always lived in draught sealed houses to prevent losing heat during winters so cold the sea may freeze. Each winter day for ten minutes in the morning the Nova Scotians open their doors and windows wide in order to change the air in the house completely.
2) Unventilated properties tend to have condensation, mould, mildew, etc. The better the draught-proofing the worse the ventilation.
Dehumidifiers are devices to cool moist air to the dew point temperature at which the water vapour in moist air changes into water again. This non hazardous condensed water is collected in a tank or connected to a drain.
A dehumidifier consumes electricity to run its pump and process controller and outputs heat and water. The clever scientific bit is that the latent heat of vaporisation taken from the condensing water also comes out as heat energy.
The latent heat for a litre of water to change to a kg of steam, or vice versa, is 0.63 kWhr. Our electricity and gas bills charge us around 16p and 4p respectively for kWhr units.
As a comparison the latent heat of vaporisation is roughly six and two thirds times the latent heat of freezing.
Dehumidifiers are cheap, compact and their low power means installation is plugging into a 13 amp socket. In common with many cheap smart technology products, a commercial outfit could not make a viable business from selling dehumidifiers as water vapour latent heat source, heat pumps.
A pathfinder project for a damp property with electric only heating.
Part of the electricity presently feeding to electric heaters would instead be routed to power dehumidifiers.
The results should be more heat being delivered to the property, a reduction in the relative humidity in the property to healthy levels with no increase in the electricity bill.
Another pathfinder could compare a dehumidifier with a curtain or cover guiding the air flow round a rack of washing to the existing arrangements for drying washing.
6. The EPC Rating of a property can be affected by changes to the underlying methodology and to fuel price data. How do you suggest that the Programme takes account of this in setting the Long-Term Domestic Standard?
5. The EPC Rating of a property can be affected by changes to the underlying methodology and to fuel price data. How do you suggest that the programme takes account of this in setting the Long Term Residential standard?
See answer to Q1. above
7. What are your views on the proposal that all PRS properties meet EPC Energy Efficiency Rating Band C by 2030?
6. What are your views on the proposal that all PRS properties meet EPC energy efficiency band C by 2030?
See answer to Q1. above
8. What are your views on our proposal for an initial period of encouraging action?
8. What are your views on our proposal for an initial period of encouraging action?
Delete "an initial period of ".
See BES Code in answer to Q1. as an encouragement and facilitiation vehicle.
See the answer to Q16 regarding a Reference Toolbox.
See BES Code in answer to Q1. as an encouragement and facilitiation vehicle.
See the answer to Q16 regarding a Reference Toolbox.
9. What information would be useful for householders to be able to access on how to achieve EPC Energy Efficiency Rating Band C before 2030?
9. What information would be useful for householders to be able to access on how to achieve EPC energy efficiency band C before 2030?
See BES Code in answer to Q1.
10. What are your views on our proposal to follow this initial period with mandating action?
10. What are your views on our proposal to follow this initial period with mandating action?
Mandating action will gum up the housing and letting markets by reducing supply, increasing costs, etc. without reducing demand by tenants and owner occupiers.
11. What are your views on our proposal that 2030 is the right point to start mandating action to achieve EPC Energy Efficiency Rating Band C?
11. What are your views on our proposal that 2030 is the right point to start mandating action to achieve EPC energy efficiency band C?
EPC is a moving goalposts standard.
Under the BES Code set up in the answer to Q1, mating legislation could provide for action in extreme cases of BES Code breaches as soon as the legislation has come into force.
Such action, punishing the really bad boys rather than the whole class, might attract publicity and encourage the others.
Under the BES Code set up in the answer to Q1, mating legislation could provide for action in extreme cases of BES Code breaches as soon as the legislation has come into force.
Such action, punishing the really bad boys rather than the whole class, might attract publicity and encourage the others.
12. What are you views on our proposal for owner occupied properties to be subject to penalties for non-compliance?
12. What are you views on our proposal for owner occupied properties to be subject to penalties for non-compliance?
See Q11 above.
13. What are your views on requiring all types of accommodation to meet the Long-Term Domestic Standard over time?
Please explain your answer, giving examples of accommodation you think should/should not be required to meet the Long-Term Domestic Standard if relevant.
The BES Code described in the answer to Q1 and its mating legislation could cover all types of homes and buildings.
Case law starting with the more extreme cases would establish reasonable guidelines for these areas.
Case law starting with the more extreme cases would establish reasonable guidelines for these areas.
14. Please provide your views on our proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band C by 2030, where technically feasible and cost-effective?
14. Please provide your views on our proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band C by 2030, where technically feasible and cost-effective?
This will make fuel poor households most unwelcome tenants, adding to their low credit rating.
The worry and upheaval caused by enforcement on incumbent owner occupiers could be expected to affect their health and happiness adversely.
See also Q1 and other earlier answers.
The worry and upheaval caused by enforcement on incumbent owner occupiers could be expected to affect their health and happiness adversely.
See also Q1 and other earlier answers.
15. Please provide your views on our proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band B by 2040, where technically feasible, cost-effective and possible within limits affordable to the public purse?
15. Please provide your views on our proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band B by 2040, where technically feasible, cost-effective and possible within limits affordable to the public purse?
See earlier answers.
Legislating so far in the future is intruding on the future rights of voters to vote for policies appropriate to then current conditions.
Assuming EPC's continue to exist means they could have become a long term barrier to innovations not presently imagined.
Current innovations as illustrative examples:
Electrical storage batteries costs have fallen rapidly. Large commercial battery installations are quoting to supply peak lopping, here's some we downloaded from the grid earlier, grid electricty..
How does the EPC regime respond to domestic scale battery schemes ?
Heat batteries now exist. These heat batteries can be charged in a few minutes by a heat tanker.
Waste to energy schemes are exploring selling their process heat directly. Conventional utilities might develop peak lopping tariffs for supplying end users' heat batteries rather than adding distribution infrastructure capacity.
Legislating so far in the future is intruding on the future rights of voters to vote for policies appropriate to then current conditions.
Assuming EPC's continue to exist means they could have become a long term barrier to innovations not presently imagined.
Current innovations as illustrative examples:
Electrical storage batteries costs have fallen rapidly. Large commercial battery installations are quoting to supply peak lopping, here's some we downloaded from the grid earlier, grid electricty..
How does the EPC regime respond to domestic scale battery schemes ?
Heat batteries now exist. These heat batteries can be charged in a few minutes by a heat tanker.
Waste to energy schemes are exploring selling their process heat directly. Conventional utilities might develop peak lopping tariffs for supplying end users' heat batteries rather than adding distribution infrastructure capacity.
16. In addition to what we have set out in paras 46 - 50, what should the Energy Efficient Scotland Assessment Short Life Working Group also consider?
Please explain your answer.
Taking into account our answers above we suggest this Short Life Working Group be given a different remit.
This would be to assemble a Reference Toolbox of all solutions, past, present and emerging, together with a procedure for keeping the Toolbox up to date.
The core objective might be widened from energy to all factors contributing to better homes and lifestyles.
This would be to assemble a Reference Toolbox of all solutions, past, present and emerging, together with a procedure for keeping the Toolbox up to date.
The core objective might be widened from energy to all factors contributing to better homes and lifestyles.
17. What are your views on whether the Long-Term Domestic Standard should be enforced at a local or national level?
Please explain your answer.
Under the proposals in our answers we would anticipate that the volume of enforcement action would be low and focused on the worse cases.
These factors would indicate a small national enforcement unit with critical mass expertise.
Spreading enforcement round thirty two local authorities would require many people to be trained. Ongoing resources would be needed to achieve a workable level of consistency and predictability.
Local authorities could have a policing, and periodic reporting to the national enforcement unit, role added to their current registration duties.
These factors would indicate a small national enforcement unit with critical mass expertise.
Spreading enforcement round thirty two local authorities would require many people to be trained. Ongoing resources would be needed to achieve a workable level of consistency and predictability.
Local authorities could have a policing, and periodic reporting to the national enforcement unit, role added to their current registration duties.
2. The Non-Domestic Sector
18. Are there specific building characteristics you consider should be included in research to ensure that future improvement targets reflect the diverse nature of our non-domestic building stock?
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Yes
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No
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Don't know
19. What are your views on the way calculated energy use from building assessments are presented and/or benchmarked?
We are particularly interested in what arrangements you favour and how you think they would be useful.
No coment
20. What are your views on the proposed planned work to review improvement targets?
20. What are your views on the proposed planned work to review improvement targets?
no comment
21. What are your views on our proposals for phasing the regulations from 2020?
21. What are your views on our proposals for phasing the regulations from 2020?
no comment
22. Should advice and support to invest in the energy efficiency of industrial or manufacturing buildings align with wider advice and support on how to reduce energy consumed for productive processes?
If so, please suggest how improving efficiency in building and ‘process’ energy could work together, and what opportunities and challenges might this present?
no comment
23. What more could the Scottish Government do to encourage the public sector to accelerate energy efficiency across their building stock?
23. What more could the Scottish Government do to encourage the public sector to accelerate energy efficiency across their building stock?
no comment
24. What more could the Scottish Government do to encourage the public sector to accelerate heat decarbonisation across their building stock?
23. What more could the Scottish Government do to encourage the public sector to accelerate heat decarbonisation across their building stock?
no comment
3. The Programme and use of EPC data (Domestic and Non-Domestic
25. What additional data would help building owners in the delivery of the Energy Efficient Scotland Programme? How would this be used?
25. What additional data would help building owners in the delivery of The Programme? How would this be used?
See answers to Q1 and Q16
26. What additional data would be helpful to others in the delivery of the Energy Efficient Scotland Programme? How would this be used?
26. What additional data would be helpful to others in the delivery of The Programme? How would this be used?
See answers to Q1 and Q16
27. We will investigate the benefit in providing new online resources or tools to support building owners to access and use data to help them improve their properties. What particular types of resources or tools would you find useful and why?
27. We will investigate the benefit in providing new online resources or tools to support building owners to access and use data to help them improve their properties. What particular types of resources or tools would you find useful and why?
see answers to Q1 and Q16
About you
What is your name?
Name
Bob Garrow
Are you responding as an individual or an organisation?
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Individual
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Organisation