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
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
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
One issue with the above approach is that it doesn't show how good the building is given the limitations of the fabric of the building. A modern build could in theory have an A rating but be a C which indicates that work needs to be done.
An older building could be an E but that is the best it can be.
Listing both the current rating and the maximum for the fabric of the building makes sense.
An older building could be an E but that is the best it can be.
Listing both the current rating and the maximum for the fabric of the building makes sense.
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
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Don't know
Should not include, please give reasons for your views
Domestic hot water is particular to the inhabitants of the building, children using more and so on. My experience of EPC's is that the number doesn't bear any resemblance to reality
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
Radio button:
Unticked
Yes
Radio button:
Unticked
No
Radio button:
Ticked
Don't know
Please provide further details here
Without examples it is difficult to see what is meant here.
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
Radio button:
Unticked
Yes
Radio button:
Unticked
No
Radio button:
Ticked
Don’t know
Please explain you view further
I have no experience in this area so can't comment,
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
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
Don’t know
Question 10. Do you agree that the validity period of EPCs should be reduced from 10 to five years?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Don't know
Please give details for your answer
I can't see any point to this.
If you're selling the house and the EPC is out of data as you've had work done it's in your interest to get an EPC done to show the new efficiency.
A similar argument can be used for landlords although this is an argument to locking this into a similar cycle as to other certificates a landlord needs.
Reducing to five years doesn't do anything as far as I can see.
If you're selling the house and the EPC is out of data as you've had work done it's in your interest to get an EPC done to show the new efficiency.
A similar argument can be used for landlords although this is an argument to locking this into a similar cycle as to other certificates a landlord needs.
Reducing to five years doesn't do anything as far as I can see.
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
One issue is that at this point in time EPCs are being used as almost the sole arbiter on grants and loans for improvements.
For older properties improvements don't offer the same EPC improvement as to newer properties which means that older properties can't access these funds. Which means that older properties remain poorly insulated.
Using this measure for future legislation is worrying and will discriminate against island and highland communities where older croft style properties suffer from poorer ratings due to their construction and also are very expensive to retrofit.
By using EPC ratings to control things such as sales (which is one idea I've heard) you will end up destroying the housing market on islands leading to further depopulation and mean that older people end up trapped in unsuitable housing.
Care has to be taken to ensure that this does not happen and regional and cultural issues are considered.
For older properties improvements don't offer the same EPC improvement as to newer properties which means that older properties can't access these funds. Which means that older properties remain poorly insulated.
Using this measure for future legislation is worrying and will discriminate against island and highland communities where older croft style properties suffer from poorer ratings due to their construction and also are very expensive to retrofit.
By using EPC ratings to control things such as sales (which is one idea I've heard) you will end up destroying the housing market on islands leading to further depopulation and mean that older people end up trapped in unsuitable housing.
Care has to be taken to ensure that this does not happen and regional and cultural issues are considered.
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
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Don’t know
Please provide further details here
1. PDF's can be designed to be accessible. It's not a problem with PDF's it's a problem with their production.
2. PDF's can be designed to be viewable on mobile devices.
3. Approximately 5% of the population doesn't have access to the internet, 10% don't have access to mobile. Conversely 3% are blind. By moving to webpage format you are reducing inclusion by moving to a webpage format. You're making it twice as bad.
4. The additional step to validate an EPC is really important for security, having a secondary system to validify accuracy is really important and can prevent fraud etc.
5. Presenting more information can be done in a PDF in an appendix. 2 page summary (as now) with all further detail in an appendix.
6. In remote regions internet access (mobile) is spotty at best and accessing the information on a mobile is going to be difficult anyway.
7. This is a solution looking for a problem.
8. You'll introduce phishing into the EPC system.
The purpose of an EPC is to provide a snapshot as it was when performed (such as an MOT certificate does). Making it a live document doesn't help with this and if anything makes things more complicated.
The MOT approach is a good example of a system that works. You have a document given to you to prove what the car was like on the day. An online history of the vehicle that can be checked and a security check (V5) to access extra information.
Not meaning to be rude but the move to webpage seems to be one of the new buzzwords. A year ago it was blockchain this and blockchain that. In the next revision of this I'd expect to see AI and chatgpt mentioned.
2. PDF's can be designed to be viewable on mobile devices.
3. Approximately 5% of the population doesn't have access to the internet, 10% don't have access to mobile. Conversely 3% are blind. By moving to webpage format you are reducing inclusion by moving to a webpage format. You're making it twice as bad.
4. The additional step to validate an EPC is really important for security, having a secondary system to validify accuracy is really important and can prevent fraud etc.
5. Presenting more information can be done in a PDF in an appendix. 2 page summary (as now) with all further detail in an appendix.
6. In remote regions internet access (mobile) is spotty at best and accessing the information on a mobile is going to be difficult anyway.
7. This is a solution looking for a problem.
8. You'll introduce phishing into the EPC system.
The purpose of an EPC is to provide a snapshot as it was when performed (such as an MOT certificate does). Making it a live document doesn't help with this and if anything makes things more complicated.
The MOT approach is a good example of a system that works. You have a document given to you to prove what the car was like on the day. An online history of the vehicle that can be checked and a security check (V5) to access extra information.
Not meaning to be rude but the move to webpage seems to be one of the new buzzwords. A year ago it was blockchain this and blockchain that. In the next revision of this I'd expect to see AI and chatgpt mentioned.
Question 13. Do you agree with our proposal to improve signposting to further support and advice schemes on the EPC?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Don't know
Please provide further details here
This isn't the purpose of an EPC. An EPC has a purpose it the same way as an energy label on a TV or freezer.
What is proposed here is a good idea but for a different set of issues. The information held in a database like this could be used to produce an EPC but it is not an EPC.
What is proposed here is a good idea but for a different set of issues. The information held in a database like this could be used to produce an EPC but it is not an EPC.
Question 14. Do you agree historical EPCs should be publicly accessible on the EPC register (while clearly marked as historic)?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Unticked
No
Radio button:
Ticked
Don't know
Question 15. Do you agree that the EPC register should be accessible by API?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Unticked
No
Radio button:
Ticked
Don't know
Please give reasons for your view
As above I think that this is looking this the wrong way. An EPC is an output from a database of information and not a feed into a database.
Question 16. Do you have any further comments on our proposals to move to a digital and accessible EPC?
Please explain you view further
Based on what I have read this is a mistake - it's conflating an EPC with home improvements and the like.
The ideas behind liking information together is good but too undefined at the moment to be practical for a document that has legal standing.
The ideas behind liking information together is good but too undefined at the moment to be practical for a document that has legal standing.
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
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
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
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
Don't know
Please give details for your answer
Given the vagueness of the proposals above and the complexities of what is required there is no way that this will be ready by 2025. I doubt you'd even be able to firm up the requirements by then.
EPCs are a vital part of home reports and thus the housing market, having unrealistic and overambitious schedules could have the knock on effect of affecting sales and prices.
EPCs are a vital part of home reports and thus the housing market, having unrealistic and overambitious schedules could have the knock on effect of affecting sales and prices.
About you
Are you responding as an individual or an organisation?
Please select one item
(Required)
Radio button:
Ticked
Individual
Radio button:
Unticked
Organisation