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

Not every building will be able to achieve a band C and it is important to consider the implications of this. For instance, a traditional building may be able to achieve an EPC band D and have 200 years of use left. To demolish this and replace it with a building with an EPC band B which has a design life of 30 years would likely be economically, environmentally and socially less prefferable.

In view of this, we are broadly content with this proposal, provided that the technical and financial exemptions discussed in subsequent sections are appropriate to the particular issues relating to the improvement of energy efficiency in traditional and historic buildings.

See above

See above

A definition of cost effective as one which pays for itself in the lifetime of the measure is appropriate in principle. However, this will require accurate, up-to-date, independent data on the expected lifetime of a measure. It is worth noting that if this definition of a cost effective measure is adopted, double glazing is unlikely to be included in applicable measures.

There is no question in the consultation regarding the technical feasibility of measures. The proposal states that “a new assessment, building on the EPC process, should be developed to identify what is technically feasible”. We support this, but would welcome clarity on who will develop this assessment and who will undertake it. Current EPC assessors are not on the whole qualified to carry out such a detailed technical feasibility assessment. Considerable training will be required if this commitment is to be met, with input from specialists in a wide range of measures and building types. There are currently various groups discussing possible changes to EPC’s and this should be considered as part of the EES development.

The issue of air quality is critical to the long term success of efforts to improve energy efficiency. Ensuring that energy efficiency improvements are balanced with the needs of ventilation and the removal of moisture from buildings should be at the heart of the Energy Efficient Scotland framework.

The effects of moisture concentrations cause dampness and mould growth which can be damaging to building fabric and human health . The dangers associated with this are likely to be greater where the most significant interventions are made to a building, and therefore will increase with introduction of requirements to reach EPC band C. Monitoring of buildings to ensure air quality is of a sufficient standard and the introduction of measures such as humidity controlled ventilation should be considered. It is important however that this does not only consider moisture within a room but also in areas that are hidden from view, for example behind IWI and above loft insulation.

The methodology for undertaking EPC assessments requires amendment in a number of areas to ensure it is fit for purpose, especially in the context of traditionally constructed buildings. This is likely to be an ongoing process throughout the lifetime of the proposed Energy Efficient Scotland program. It would be difficult, however, to apply revised methodology to existing EPC’s, therefore reliance on periodic updating of a buildings EPC is likely to be required.
The chart on page 10 raises some important issues which are not specifically referred to in questions 1-32. The Advice and Service elements of the offer depend on the availability of good quality, independent advice” but it is not clear who will provide this advice and what training / qualifications they will have. Currently EST provide a lot of advice in this area, however their advisors are unlikely to have the requisite technical knowledge of traditional buildings to provide advice on measures which can achieve an EPC band C without detrimental effects . The independence of this advice is paramount and must be separate from industry / trade bodies such NIA and INCA as these are not independent. Determining who delivers this advice, and who considers technical exemptions is critical to the success of this process.

Regardless of the tenure an EPC band C will be very hard to meet for some building types and appropriate exemptions will be required.

Information regarding how traditional / historic buildings perform in terms of moisture, air movement / ventilation and heat would be useful for householders as would the way different materials perform. In addition to this an understanding of condensation and mould would be beneficial. Householders should have access to independent advice from those with an in depth understanding of the issues surrounding insulating buildings, air movement and moisture related issues.

If action becomes mandatory, it will be important to be clear who would be liable for any consequent failures of building fabric. For instance, if an owner occupier installs loft insulation to avoid a penalty and that action leads to rot in sarking boards, who would be responsible?

We are content with this proposal, assuming that the appropriate technical exemptions in relation to traditional / historic buildings are in place.

We are content with this proposal, assuming that the appropriate technical exemptions in relation to traditional / historic buildings are in place.

We are content with this proposal, assuming that the appropriate technical exemptions in relation to traditional / historic buildings are in place.

We are content with this proposal, assuming that the appropriate technical exemptions in relation to traditional / historic buildings are in place.

We are content with this proposal, assuming that the appropriate technical and financial exemptions in relation to traditional / historic buildings are in place.

The short life working group should consider the needs of buildings with different building fabric types and the issues they create. This should include traditional buildings, system built structures and timber frame buildings.

Moisture issues in buildings of all types should be considered by the SLWG. This should include condensation (surface and interstitial), mould growth, decay of building fabric, occupancy rates and tenure, indoor air quality and ventilation.The need to address wider building defects before any insulation work takes place should also be discussed.

Work has been carried out in England and Wales that could help inform this, but additional research may also be required. We also consider that the 'notional building' approach could be considered in the context of domestic buildings.

At this stage, we do not have a view on this. However, we consider it is important to also establish who will be the arbiter of exemptions and if this will be at a local or national level. Wherever enforcement and exemptions are considered, having properly trained people who understand the complexities of a range of building types will be essential.

Specific building characteristics should include construction materials, methods of construction, how materials handle moisture, vulnerability to decay, occupancy rate and tenure.

We are content with this proposal, assuming that the appropriate technical exemptions in relation to traditional / historic buildings are in place.

Funding energy efficiency measures would encourage uptake in the public sector. Measures which are innovative and which are specifically targeted at particular building types would also encourage their uptake.

Data surrounding building types which struggle to achieve a given EPC rating would be helpful and should be fairly easy to extract. Outwith EPC data, a thorough analysis of failures in buildings following energy efficiency work would be useful in gauging which measures cause problems in the short, medium and long term.

Any online resource or tool should be tailored to reflect the needs of a diverse range of building types, a one size fits all approach will do more harm than good. Unlike previous schemes in the social rented sector which would have oversight from those experienced in buildings, in the private sector it is likely to be homeowners commissioning work directly. In view of this, it will be important that data is supported by guidance to its interpretation, to facilitate good decision making.

Sufficient information should also be provided on how energy efficiency measures will affect homes especially in relation to indoor air quality, ventilation and condensation.

The most useful data will be that on failures so lessons can be learned for future work.

You may wish to consider whether legislative changes would be required to establish where responsibility for potential building failures lies if works to improve energy efficiency become mandatory (see our response to Q10).

Local authorities and Building Standards Division could be key to delivering new legal requirements.