Energy Performance Certificate reform consultation

Need to provide metrics on Operational Carbon and Embodied Carbon

Embodied Carbon kgCO2e/m2.

75% of a building total emissions from a typical 60-year lifetime can come
from embodied carbon.

Embodied carbon needs to become regulated and subject to reducing targets.
UK Green Building Council, RIBA 2030 Challenge, LETI and ACAN agree on the need to regulate embodied carbon and that there are emerging benchmarks and methodologies which can be utilised across the construction sector.

n/a

Reduction of lifetime operational carbons is essential to meet our zero carbon target.

n/a

In 2024, a new route for compliance should be developed which allows for calculations on building performance to be made and submitted with PHPP (Passivhaus Planning Package). Harmonisation of information produced by each calculation should be considered. For avoidance of doubt, this is based on using PHPP as an alternative method of comparing DER and TER (as currently specified within the building regulations).

Scotland must define a national retrofit standard for all house types in order to drive the national delivery of retrofit, the Scottish Technical Standards is the best place for this guidance.

Advice expanded to include Loft insulation, zero / low emission heating system, wall insulation, window replacement / improvement, under floor insulation, ventilation upgrade, airtightness works, renewables.

However current SAP/EPC Surveyors & Assessors have limined survey skills, training and knowledge and these need to be improved and expanded to harmonise with PAS2035.

Same as Domestic above

Same as Domestic above

Particular emphasis on heating, ventilation and lighting.

The primary role of the EPC should be to assess, report or reduce operational and embodied carbon emissions in our building stock. This is the only cross-sector platform / tool that we have that is Consumer / market facing and we must optimise its use, validity and depth.

All retrofit should also tie in with Scottish Government Draft Heat in Buildings Strategy.

The building performance gap must be closed by regulation and associated quality assurance schemes. The Technical Standards through the production of EPC / SAP should propose a robust methodology, for assessing buildings (including in-situ U value, indoor air quality, energy) and a consistent reporting structure. This should be in line with PAS2035.

YES as this will incentivise renovation upgrading to increase future asset value.

above

Retrofit is a detailed, complex and technical process. Signposting should be to suitably qualified professional expertise & expanded to harmonise with PAS2035

Yes this is a public record of progress for the Scottish Government to regulate the upgrade of existing building stock to Zero Carbon standard. This is one of the few assessment tools that are in place to support these Policy Objectives.

14. above

n/a

The building performance gap must be closed by regulation and associated quality assurance schemes.

Calculations on building performance to be made and submitted with PHPP (Passivhaus Planning Package). Harmonisation of information produced by each calculation should be considered.

EPC/ SAP is a core tool behind the future of the building regulations and the changes we foresee as essential to decarbonise construction and meet Scotland’s Zero Carbon target. This needs to happen and soon as possible to mitigate the impacts of the Climate Crisis.