Response 149220655

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Consultation Questions: Domestic Energy Performance Certificate Metric Reform Proposals

Question 1. Do you agree with the set of metrics that we propose to display on the reformed Energy Performance Certificate?

Please select one item
Yes
No
Don’t know

Question 2. Are there additional metrics that you think should be included on the EPC, or metrics that you do not think should be included?

Should be included, please give reasons for your views
I am not sure whether the use of lpg gas cylinders or oil for heating is adequately covered, which is the main source of heating energy in rural Scotland, where mains gas is not available.

Question 3. Considering our proposal to include a Fabric Rating on EPCs, do you think this metric should include domestic hot water heat demand?

Please select one item
Yes
No
Don't know

Question 4. Do you have a view on the way that the Fabric Rating mapped against a scale, for example, how ‘A’ or ‘G’ rated performance is determined?

Please provide further details here
The above link does not work. I am therefore not sure that the right system is in place for old stone built buildings. These have thick walls, but limited in insultation, but I have a friend who works for the National Trust in old building renovation and he is adamant that buildings of a certain age should not be stripped out just to add insulation, as the wall thickness should adequately protect the house both in Summer and Winter.

Question 5. Do you agree with our proposal to give more prominence to the energy efficiency features of the home (such as the depth of loft insulation)?

Please select one item
Yes
No
Don't know

Consultation Questions: Non-Domestic Energy Performance Certificate Metric Reform Proposals

Question 6. Do you agree with the set of metrics that we propose to display on non-domestic EPCs?

Please select one item
Yes
No
Don’t know

Question 7. Are there any additional metrics that you think should be displayed, or any in the proposed set that should not be included?

Should have additional metrics, please explain your view further
I think properties of a certain age should be assessed individually, as one size approach does not work. Houses built from the 1940s onwards would have had more regulation, but that does not mean those that pre-date this should be subject to major upheaval if there is no issue of damp or heat loss.

Consultation Questions: EPC Purpose and Validity

Question 8. Do you agree with us that the primary role of the EPC should be to provide basic energy efficiency information for the purpose of comparison and act as a prompt to consider retrofit options?

Please select one item
Yes
No
Don’t know
Please give details for your answer
I think it should be a choice for homeowners in the current financial climate to decide whether retrofit measures are appropriate for themselves. There needs to be some accommodation for this in any new legislation, or at least some exclusion clauses that people can look to for exemption, should the costs be prohibitive.

Question 11. We welcome any views on the usefulness of our proposals for other relevant policy areas, such as fuel poverty or the delivery of government schemes. Please provide any comments you wish to share.

Please give details for your answer
If 100% grants were available for assistance with improving energy efficiency, or 0% loans, then that would allow for work to be undertaken without excessive financial burden.

Consultation Questions: Digital and Accessible EPC Format and Content

Question 12. Do you agree with our proposal that EPCs should move from PDF to webpage format?

Please select one item
Yes
No
Don’t know
Please provide further details here
Some people still prefer to be able to download a page, print it and study it. You could have a combination of both, or choice, so the information is as accessible to as many as possible, in their preferred format.

Question 13. Do you agree with our proposal to improve signposting to further support and advice schemes on the EPC?

Please select one item
Yes
No
Don't know

Question 14. Do you agree historical EPCs should be publicly accessible on the EPC register (while clearly marked as historic)?

Please select one item
Yes
No
Don't know

Question 15. Do you agree that the EPC register should be accessible by API?

Please select one item
Yes
No
Don't know

Consultation Questions: EPC Auditing and Assurance

Question 17. Do you agree with our proposals to review and update the auditing and assurance requirements for EPCs in Scotland?

Please select one item
Yes
No
Don't know

Consultation Questions: Legislating for EPC Reform and Timeline

Question 19. Do you have a view on our timeline for reform implementation?

Please select one item
Yes
No
Don't know
Please give details for your answer
I believe its unrealistic. I would have thought that 2026-27 should be the target.

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