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

Good aspiration but needs to be supported by financial incentives and legislation
Clear and achievable standards for the energy efficiency of the housing stock are required if we are to eradicate fuel poverty and meet climate change targets. I would agree that the proposal meets this requirement. It is understood that the proposal is underpinned by a large-scale programme of energy improvements to the housing stock via SEEP. This will ensure that owners are provided with appropriate levels of support to help them meet the standard within the timescale.
It should also be acknowledged that EPC’s are theoretical in nature and even highly rated buildings can be operated inefficiently. Some account of actual energy consumptions should be incorporated into the standards required.

Yes, there should be exclusions in circumstances where, for construction and design reasons, it will not be technically feasible or practical for some buildings to achieve this standard.
Examples could include older and listed buildings or where the cost of meeting the standard is financially prohibitive. Other exclusions may be required where owners cannot afford the cost of improvements or where improvements are dependent on the consent of adjacent owners. Consideration of Listed building legislation and a more pragmatic approach to modern materials to ensure listed buildings can be economically used and lived in should be applied.

Only in very limited and defined situations. In general the Scottish government should provide the financial incentives and support to make it happen.
However , where affordability is an issue, consent of other owners is required or investment is dependent on funding from other sources such as Government Grants, ECO funding etc.

Cost effective over its lifetime is not a sufficient financial incentive to carry out work on your home, owners will need to see a benefit in reduced energy costs particularly some lower income households who may struggle to meet the upfront costs of improvement and need financial assistance to deliver measures to their homes.
If investment payback is not calculated within 5-10 years, tax relief or other incentive schemes may be needed.
Does the definition of cost-effective solely relate to energy costs and exclude aspects such as maintenance adaptation works? Would whole life costing not be a more suitable approach?

Essential activity around education and designing systems that are automated and easy to use.
Improved insulation can result in issues of dampness and condensation within homes as well as affecting air quality. Important that improvements are delivered in a holistic way to ensure that adverse, secondary impacts are avoided. Support and advice to homeowners should cover ventilation systems.

In terms of nothing else being available to assess energy efficiency and environmental impact then EPC’s continue to be the option that is most appropriate however it should be noted the EPC’s are a theoretical assessment, not an actual assessment of the efficiency.
Increases in fuel prices are a major driver of fuel poverty but are driven by market forces. Suggest that the methodology behind EPCs is appropriately weighted to take account of changes in fuel prices. It is important when planning the delivery of measures that a like-for-like comparison of the standard can be achieved pre and post- improvement.

Private rented sector is significantly different from social rented sector with numerous landlords of varying ability and character, we are still enforcing issues of illegal multiple occupation and failure to register as a landlord, to suggest that these landlords will meet a 2030 target is unrealistic without strengthening the legislative framework around enforcement including sale orders on property for landlords falling foul of legislation and convictions.
There are particular issues of fuel poverty, poor energy efficiency and property condition in the PRS that need to be addressed as a priority. Given the starting point of many PRS properties, the proposal is ambitious. To achieve the target it is important that appropriate levels of support are given to landlords to help them meet the standard. Also important that a robust enforcement framework is in place to ensure that landlords meet their obligations. Given the potential cost of improvements, PRS tenants should be adequately protected to ensure that landlords do not attempt to recover costs through unreasonable rent increases.

Agree with a phased approach to encouraging owners to take action. Owner buy-in will be critical to the success of the proposal.

Staged provision of information and advice to allow householders to assess and evaluate the range of measures that would be available and appropriate in order to try and achieve the standard, e.g.
1 simple online tool informing them what current standard is and what could be done to achieve a C in their property.
2 Phone call support to technical advisor to discuss particular property related queries
3 Impartial home visit to asses property suitability
4 support to access the delivery supply chain
Note: current advice provided with EPCs (Recommendations Report) is mainly generic and not practical or suitable. This has to be avoided for the targets to be achieved.
Older and vulnerable households may need intensive, “handholding” support, similar to Care and Repair.

Yes, many owners will not take action unless there is a mandatory requirement underpinned by a robust enforcement framework. (But see previous points on financial incentives and payback periods).

Difficult to put a timescale on this but 10 years of voluntary activity and preparation is a starting point but should be preceded by an intensive period of encouragement and support through HEEPS and related activity.

Many owners will not respond unless there is stick of penalties as well as the carrot of support, however there would need to be some consideration of appropriate levels of penalty.
Significant concerns around monitoring, enforcement and resources required. Is this a realistic proposition given that local authorities cannot resource their current statutory duties? (There are no mechanisms in place to deal with existing housing in this way).

All permanent housing, including holiday homes, croft homes and agricultural tenancies should be required to meet the standard, both for fuel poverty and climate change reasons. Holiday homes can easily transfer quickly and easily to permanent occupation and therefore their status can be fluid and subject to definition for Council Tax exemption purposes. Croft homes and agricultural tenancies are often occupied by households on low incomes and at risk of fuel poverty. Whereas Park Home residents may be at risk of fuel poverty, there will be technical difficulties in achieving the improvements required and exemptions may be appropriate. There can also be issues with the long-term viability of these properties as suitable housing accommodation and implications for building standards if caravans fall under a warrant process.

Fully support the aim to remove energy efficiency as a driver of fuel poverty but this proposal will apply mainly to the private sector as landlords will be required to reach the standard as part of EESSH. The implementation of this proposal should ensure that programmes of support for energy efficiency improvements are targeted to households in fuel poverty.
It should be noted that fuel poor can be transient and not directly associated with the house they are living in at the time.

Yes, for reasons as above and that fuel poor is related to the family income and fuel cost rather than the house, would this prevent Private Sector from renting to low income families in order to avoid this duty.

Agree that the approach to assessment should take account of issues associated with particular properties for which the standard approach and types of measures may not be suitable. The quality of accommodation in terms of design, space standards and accessibility may be factors. Improving the energy efficiency of properties that fall far below modern or acceptable standards of accommodation may not be a good use of resources.
There should be consideration given to the provision of the range and cost of professional advice and assessment options to deliver this part of the proposal.
Staged provision of information and advice to allow householders to assess and evaluate the range
of measures that would be available and appropriate in order to try and achieve the standard, e.g.
1 simple online tool informing them what current standard is and what could be done to achieve a C in their property.
2 Phone call support to technical advisor to discuss particular property related queries
3 Impartial home visit to asses property suitability
4 support to access the delivery supply chain
5 Independent Quality Assurance on works undertaken

Local authorities, which currently have statutory responsibility for house condition and related standards, would be best placed as agents of enforcement but they will require adequate resources to implement a local compliance and enforcement framework. Further, private rented sector legislation and control is not sufficient to control it.

Listed building solutions need to become more pragmatic allowing affordable solutions to energy efficiency and modern materials, listed buildings have great heritage value but they also need to meet the needs of modern living to provide an economical building. Historic Environment Scotland needs a culture change to achieve this.
Operational patterns, e.g. seasonal bias needs to be taken into account to reflect impact of measures.

Benchmarking is an essential technique to determine energy efficiencies, however it is only effective if the undertaken with all relevant factors accounted for. Building related benchmarks must incorporate factors such as area, occupancy patterns, age of building, heating system type, building function etc. Where buildings include a process or production related element to it’s energy consumption, this must be sub-metered.
To initially set benchmarks for building types etc the collation and validation of data will be a significant undertaking. This should be streamlined where possible through obtaining energy consumption data directly from suppliers, rather than individual households. Suppliers should continue to submit all consumption data on an annual basis.

At present properties for lease/sale have to be > 1000m2 for the 2016 regs to apply, but it is now proposed to phase in all buildings. The indicative timescale in the route map is for buildings of 200-1,000m2 to come in scope from 2026. It is important that the phasing has such timescales to allow property owners to plan and obviously finance for implementation is a particular pressure for Councils.

There are potentially many benefits in the joint consideration of building and process energy efficiencies, e.g. heat recovery, power generation, district heating etc and these opportunities should be developed wherever possible. However there is a risk that production considerations will be overwhelming compared to building initiatives and not all opportunities would be realised.
As the process operates for commercial gain, the EES programme should not provide financial support/investment.

Provide Grant money to do the work our spend to save programmes require a 5 year pay back, end austerity so we can afford to borrow money, remove the constraints around closing rural schools so we can reduce our asset base and energy footprint, provide ring fenced money for the employment of energy teams to design and deliver these projects as the rest of the staffing resource is about to be cut significantly.
The above reflects the reality of where Local Authorities are with respect to energy efficiency. We have a strong desire to support and lead on this matter, however there are so many other pressures we cannot justify energy efficiency over other issues.
Given the on-going financial straits that are applicable to local authorities only mandatory and supported measures have any realistic chance of being delivered.

Provide Grant money to do the work our spend to save programmes require a 5 year pay back, end austerity so we can afford to borrow money, remove the constraints around closing rural schools so we can reduce our asset base and energy footprint, provide ring fenced money for the employment of energy teams to design and deliver these projects as the rest of the staffing resource is about to be cut significantly.
Given the on-going financial straits that are applicable to local authorities only mandatory and supported measures have any realistic chance of being delivered.

Simple information on what can be done and how.
How do they actually go about implementing the measures.
Actual fuel use data and occupation levels would be useful.

As above

Remote online offering on its own would not have much benefit. Staged provision of information and advice is required to allow householders to assess and evaluate the range of measures available and appropriate in order to try and achieve the standard, e.g.
1 simple online tool informing them what current standard is and what could be done to achieve a C in their property.
2 Phone call support to technical advisor to discuss particular property related queries
3 Impartial home visit to asses property suitability
4 support to access the delivery supply chain
Information should be based on the actual effect of improvements (before and after) on property types rather than notional improvements as noted in EPC’s.

Gather data from suppliers on an on-going annual basis in a consistent format. More efficient, accurate and predictable.
Include actual consumption data in home reports, not just theoretical EPC data.

Existing legislation does not amount to much, the only mandatory requirements to local authorities at present is to submit an annual carbon report and to prepare a LHEES at some point soon, in a format and comprehensiveness as yet not determined. There are lots of good intentions, however when money is tight, they are quickly discounted.
Local Authorities do not necessarily have the resources or knowledge for heat and energy efficiency strategies and funding would need to be ring fenced and made available for this purpose. In the current financial context additional money that is not ring fenced will go towards delivering existing statutory duties not new ones.
Local authorities already have the powers through Planning to consent district heating networks, powers to force companies to provide waste heat to existing networks would be beneficial, planning powers to force new premises to supply to existing networks would be useful, what is critical is giving the same rights of wayleave to district heating companies that are enjoyed by Scottish gas and electricity networks.
Rural areas are often disadvantaged with the lack of gas, low density makes district heating unattractive, research is needed in better forms of renewable electric to heat, and appropriate tariffs to reduce costs, hydrogen into the gas network produced locally. Too much of this is central belt and urban solutions which is fine but then don’t burden rural authorities with the same level of requirements unless you’re willing to invest at a high rate per population to achieve similar results.

Further legislation and prescribed mandatory actions would assist in meeting the goals of the programme, however support would need to be provided as detailed in response to Q29 above.
Financial Appraisal of projects/investment – realistically the current legislation promotes cheapest capital cost. Enforce consistent whole public sector change to Carbon / WLC appraisal or some other measure that doesn’t deliver the most basic short term solution.
All building related decisions/actions etc should be streamlined towards the goals of the programme, e.g. new builds to have connection points for DH, regardless of whether there is a system currently present. Minor marginal cost with potentially significantly facilitating benefits in the future.
All SG departments to “get on board”. Having Historic Environment Scotland opposing proposals or Scottish Water refuse permission for access is a common reason many schemes fail.

Scottish government should be responsible as then it might be sufficiently funded.