Energy Efficient Scotland Consultation: Making our homes and buildings warmer, greener and more efficient

Agree with the proposal as being consistent with the long-term aims of the Scottish Government’s Energy Strategy and its ambitions with regard to Climate Change and decarbonisation. The 2040 target allows 20 years to address building improvements which ought to provide sufficient time to plan for and fund any necessary improvements, where technically feasible and cost effective.

There may be limited situations where an owner occupied home cannot achieve the LTDS within this 20 year timeframe, however it is likely that these would be by exception due to technical feasibility/costs or legal barriers. In such exceptional circumstances, there should be a clear process for granting an exemption or abeyance, which is based on a rigorous investigation undertaken by qualified assessor(s) to determine the factors and whether a permitted period for exemption/abeyance will be granted.

As above, this would be by exception and subject to a clear investigative process undertaken by qualified assessors.

This definition may be too narrow. There could be circumstances where the cost of works is such that it exceeds 50% of the total resale value of a home. Suggest further consideration of this definition to include a threshold in relation to a proportion of the resale value of the property.

There are three inter-related issues for consideration with regard to energy efficiency and air quality: Firstly, monitoring and evaluation – what data and information is or could be made available through targeted interventions to measure air quality within homes and how can this be collated and scaled to produce a robust assessment of the extent and nature or air quality across all tenures and property types; secondly, what advice and information is made available to homes regarding basic behaviours and measures that can promote good ventilation and air circulation within a home without compromising thermal efficiency; and thirdly, where thermal efficiency has been increased via retrofitting homes with more effective insulation, what is the extent of need for mechanical ventilation systems, over and above behavioural measures, in order to achieve a satisfactory indoor air quality standards, what are the indicative costs and how should these be factored into the calculation of “cost effectiveness” with regard to any package of measure to achieve the LTDS for energy efficiency.

Depreciation and planned maintenance are standard considerations for asset management, including home owners. In setting the LTDS, a reasonable expectation is that early adopters that achieve the EPC band C rating may require to revisit the assessment in future years, however during this period they will benefit from the improved energy efficiency of their asset/home. A current EPC is valid for 10 years. It may be appropriate to consider either or both a buffer period prior to the milestone targets (possibly 3-5 years) and suggest a shorter period for renewing EPC assessments (possibly every 7 years) to ensure that the EPC rating remains up-to-date and valid.

Agree in principle that all rented homes should achieve a minimum common energy efficiency standard. For the PRS, the 2030 target may be challenging for certain properties, particularly multi-tenure blocks and tenement flats where common ownership and consents are additional considerations and potential barriers to implementation. Suggest that this is a particular area for Scottish Government to focus on how information, advice and support, including financial assistance, is provided to owners.

The LTDS 2040 milestone target provides for a 20 year period to address owner occupied home energy efficiency improvements. Agree that there should be an initial period for awareness raising of the LTDS and enabling/encouraging home owners to plan for and invest in home energy efficiency improvements.

The current EPC regime provides a useful baseline for considering what improvements can be made to improve a home energy efficiency rating, indicative up-front costs and annual savings. Further information, advice and assistance is available via Home Energy Scotland. The Energy Efficient Scotland ‘Able to Pay’ pilot projects will hopefully provide additional evidence of what works in terms of assisting householders to plan for investment in their homes and the lessons learned could inform future guidance. Suggest a key focus for Scottish Government be on promoting the LTDS as a “Scottish Standard” in relation to addressing Climate Change as part of a coordinated media communications and awareness raising programme.

Agree with the proposal to follow the initial period of encouraging action with a period that focuses on mandating action. In order to make this effective, it may be beneficial to draw on behavioural insights such as ‘nudge’ principles. For example, if after 2030 the majority of home owners have invested in their homes to improve energy efficiency ratings the focus of communications would be on highlighting the exception and encouraging home owners to conform.

In practical terms, the 2040 milestone would be the mandatory target and therefore there is scope to determine what would be the most effective period leading up to this to shift focus towards mandating compliance. Suggest this should be based on a consideration of how many owner occupied homes achieve the EPC Band C rating and when it meets a particular threshold where behavioural insights approaches (see above) would be effective. However, it should be noted that getting a valid baseline/benchmark may be difficult as not every home will have an EPC and therefore it may require for this to be mandated. Thereafter, it would require this information to be collated, stored in a way that can be accessed to support strategic analysis. 2030 would be a useful point at which to take stock though it may be that the shift in focus of communications happens later on, however suggest this is limited at up to 2035 after which the focus should be exclusively on mandating compliance for the final 5 years.

Non-compliance penalties can work in principle, however further details would be required as to how this might apply to the LTDS, penalty rates and the enforcement functions. It is not possible to comment further at this stage.

The LTDS should apply to any building that can be demonstrated functions as a domestic property for a minimum period of habitation within a 12 month period (for example 4 weeks). This would allow for exemptions to apply to very time limited seasonal employment or holiday lets where a property would be otherwise under/unused for other periods.

In practical terms, with the Scottish Government’s proposed changes to the definition of fuel poverty to more closely align with income standards, fuel poor households will be concentrated almost exclusively in the rented sector. Therefore, the associated proposal for PRS homes to achieve and EPC Band C rating by 2030 would align, however it may be appropriate to consider if the proposed 2032 milestone for maximising the number of social rented homes achieving EPC Band B by 2032 (as set out in the Scottish Government’s EESSH2 Consultation) also includes a provision for all homes to achieve a minimum Band C by 2030.
Focusing on fuel poor households can enable strategic planning and area-based targeting of information, advice and assistance in terms of meeting the LTDS, and may be a key consideration for developing Local Heat and Energy Efficiency Strategies based on robust socio-economic assessment of need, and aligning with community planning LOIPs and locality plans. A key consideration for privately owned homes is determining vulnerability / fuel poverty and eligibility for assistance, such as under ECO affordable warmth and flexible eligibility provisions.

Achieving EPC Band B could require measures that are ‘Additional’ and ‘Further’, as set out in Table 5 ‘Measures modelled by case study landlords for EESSH2’ in the Scottish Government’s ‘Consultation on the Energy Efficiency Standard for Social Housing post 2020 (EESSH2)’, page 15. These measures will have a significant cost attached and could also have technical feasibility as well as legal issues, particularly with regard to properties that have areas held in common ownership, which is also noted at paragraphs 47-49 in this consultation. If owner occupiers are to fund the majority of costs for these improvements, it may result in increases in rent in excess of these savings, thus running counter to the long-term ambitions for tackling fuel poverty.

It may be useful for this group also to scope out the PRS baseline and the extent to which achieving EPC Band B by 2040 will necessitate ‘Additional’ and ‘Further’ measures (as outlined above) that will require particular information, advice and support, including financial assistance, to be targeted towards the PRS and multi-tenure properties.

This would depend on the nature and function of enforcement, for example whether as a penalty notice in the event of assessed non-compliance or a charge levied at the point of transaction. More details are required and it is not possible to comment further at this stage.

Suggest that further consideration is required in terms of the diversity of the non-domestic sector (as well as building characteristics) and how this relates to economic development and community planning. The impacts of introducing mandatory minimum energy efficiency standards will vary by industry and could pose particular compliance issues for commercial retail and hospitality sectors operating in town centres as well as more local retail and amenities. As such, this is a key consideration as part of local place-making agendas.

The consultation highlights that information regarding the non-domestic sector is less comprehensive compared to the domestic sector (paragraph 54). Agree that this is a priority for further development.

Agree with the proposals to review triggers and consideration of ‘back-stop’ dates as a means for phasing improvements. Agree, as set out in paragraph 60, that it may require multiple measures as part of a benchmarking system to address diversity within the non-domestic sector.

Agree in principle with this approach and note the intention to set out further detailed proposals in 2019 for consultation.

If non-domestic sector buildings are included within a combined asset-portfolio at a particular location, the scale may provide opportunity for bespoke targeting of advice and support. As such, it may be appropriate to consider whether a specific, dedicated programme be made available to target these ‘at scale’ heat and energy users. This could be a key consideration for developing Local Heat and Energy Efficiency Strategies (LHEES).

The rate at which local authorities can install energy efficiency measures in their current building stock will largely be determined on the level of funding available through their own Business Plan. If the Scottish Government requires this to be achieved at an accelerated pace, funding grants from central government should be considered to support local authorities in doing this.

It may be useful for the Scottish Government to offer additional expertise to local authorities to assist them in accelerating heat decarbonisation. As with the majority of actions relating to achieving climate change targets, it would be beneficial to have a national approach to this to ensure all local authority areas are working towards the same outcomes and milestones targets.

Access to utilities data detailing energy usage for individual buildings may act as a suitable evidence base to assist building owners in the delivery of the Energy Efficient Scotland Programme.

For strategic planning purposes, access to address level EPC register data could facilitate GIS thematic/zonal mapping for targeting programmes and investment and link closely to the LHEES.

If EPC register data can be provided via an online GIS platform with local authority permissions, this could support development of the LHEES and longer-term strategic planning for investment programmes.

See above.

In terms of long-term decarbonisation ambitions, a key enabling factor will be how local authorities are supported and enabled to work with the energy distribution networks as well as energy suppliers. It may be appropriate to revisit provisions of the Scotland Act 2016, sections 58 and 59, in terms of developing a Scottish approach to energy company obligations once further details are known regarding the future of the gas network.

See above.

The proposal to introduce a requirement for a LHEES would be a significant change for local authorities in terms of the statutory strategic planning framework. If this is introduced, it would be appropriate to allow sufficient time for this new framework to bed in before considering further elements, if required.

Given the scope and extent of proposed changes to the local authority statutory strategic planning framework (in terms of LHEES), it would be appropriate to consider a statutory role for a new ‘National Delivery Mechanism’, as proposed and outlined in the recent Scottish Government consultation: ‘Scotland's Energy Efficiency Programme: Second Consultation on Local Heat & Energy Efficiency Strategies, and Regulation of District and Communal Heating’ (November 2017).