Response 356959829

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Part 1 - Setting the energy efficiency standard for owner-occupied housing

1. Do you agree or disagree that there should be a legally-binding energy efficiency standard for owner-occupied housing?

Please select one item
Agree
Disagree
Please explain your view.
Mandatory punitive measures at point of sale are not the way to encourage owner occupiers to make energy efficient improvements, incentivising these decisions through grants or zero-interest loans are.

2. Do you agree or disagree that EPC Energy Efficiency Rating band C is the appropriate standard to use?

Please select one item
Agree
Disagree
Please explain your view.
EPC is a blunt tool not suitable for all circumstances. I have designed zero-heating houses which only achieve a C rating, despite consuming very little energy.

3. What are your views on the “fabric first” approach?

Fabric first is the correct approach to energy efficiency, both in terms of performance and cost.

4. In your view, how can we ensure that when EPCs are used to determine compliance with the standard, they are robust and not easily open to misuse?

Please explain your view.
EPC system not fit for purpose.

5. Do you think the standard should be fixed, or should it be subject to periodic review and change over time?

Please explain your view.
EPC not suitable.

6. Do you agree or disagree that 2024 is the right start date for the mandatory standard to start operating?

Please select one item
Agree
Disagree
Please explain your view.
Too soon for mandatory standard shifting costs to homeowners.

7. Do you agree or disagree with point of sale as an appropriate trigger point for a property to meet the legally-binding standard?

Please select one item
Agree
Disagree
Please explain your view.
I fundamentally disagree with the point of sale approach, which will have a negative impact on the housing market.

8. Do you agree or disagree that responsibility for meeting the standard should pass to the buyer if the standard is not already met at point of sale, as described above?

Please select one item
Agree
Disagree
Please explain your views and give any evidence you have, whether you agree or disagree.
Same reasons as question 7.

9. What, if any, unintended consequences do you think could happen as a result of these proposals? For example, any positive or negative effects on the house sales market.

I think there will be a negative impact on the housing market, as mandatory measures will act as a disincentive to free movement within the housing market, adding to the cost of home moves. People are likely to live in energy inefficient homes until the point of sale.

10. Do you agree or disagree with point of major renovation as an appropriate trigger point for a property to meet the legally-binding standard?

Please select one item
Agree
Disagree
Please explain your view.
This is a sensible approach.

11. What is your view on how “major renovation” should be defined? Should the Energy Performance of Buildings Directive definition, as described in Annex B, be used?

Please explain your view.
The definition of major renovation seems sensible, but I would prefer to see it linked to increase in floor area than the percentage of the envelope undergoing renovation.

12. How could a requirement to meet the energy efficiency standard at point of major renovation be checked and enforced?

Building warrant applications.
3rd party certifies would be preferable, but the cheapest and most likely route is via building standard officers.

13. What do you think would be a fair and appropriate method to ensure compliance, if the legally-binding standard is not met? What type of penalty system would be appropriate?

Please explain your view.
No penalty system. The system should be incentive rather than punishment based.

14. Should a penalty for failing to comply with the standard be one-off or recurring?

See answer to 13.

15. At what level, approximately, should any penalty be set?

See answer to 13.

16. Are there any particular groups of people who could be adversely affected, more than others, by enforcement processes and charges?

Those living in houses which fall between historic houses (which are likely to receive dispensation, and newer dwellings.

17. Which body or bodies should check if the standard has been complied with at the trigger point, and should be responsible for levying any penalty?

No penalty as per answers above.

18. Considering the information set out in the consultation document, specifically Part One and in Annex D, what are your views on the best way to approach cost effectiveness, taking into account the trade-offs between how easy to understand and how sophisticated different definitions are, and how the different definitions might affect the number of homes that actually achieve the EPC C standard?

Simple measures (associated with fabric first anyway) are preferable, and it is important that in each circumstance reasonable works are not required, in order to meet a one-size-fits-all standard.

19. Other than technical feasibility and cost effectiveness, are there any other reasons why a homeowner may not be able to bring their property up to EPC C at point of sale or renovation, and would need to be given an exemption or abeyance? (For example, difficulties of getting permission from other owners for common parts of buildings.)

Please explain your view.
EPC blunt tool not fit for purpose, and doesn’t reflect some different types of efficient home (breathing wall for example).

20. Do you agree or disagree that, even if a property can’t fully meet the standard, it should be required to get as close as possible to it?

Please select one item
Agree
Disagree
Please explain your view.
See answers above.

21. Do you agree or disagree that any exemptions or abeyances from the standard should be time-limited?

Please select one item
Agree
Disagree
Please explain your view.
Reasonable time frames should be set.

22. Which body or bodies should take decisions about granting abeyances? Should this be done at a local level or centrally at a national level?

3rd party certified energy assessors.

Part 2 - Helping homeowners to meet the energy efficiency standard

23. The Short Life Working Group (SLWG) on Assessment propose that any new assessment regime should exist on two levels, comprising both a mandatory asset-based assessment and an optional occupancy-based assessment. What are your views on this approach? Do you agree that an occupancy assessment should be optional? Are there specific inputs that should be included in both?

Please explain your view.
Occupancy assessment should be optional. There should be no mandatory standard. Behaviour is better changed through incentives.

24. The SLWG on Assessment propose that the output of the assessment should be a report with tailored recommendations that set a clear pathway to both regulatory compliance (i.e. EPC band C) and zero carbon. There are conflicts between meeting the EPC rating and zero carbon. What are your views on how this can be handled/mitigated?

Please explain your view.
Both tools are blunt and not really fit for purpose. Zero-carbon is not appropriate for the vast majority of existing housing stock. EPC could be a viable system if improved, but are too often generated considering vague measures, by people who do not understand the measures (surveyors at point of sale for example).

25. The new assessment proposals from the SLWG on Assessment include more of an advisory role for the assessor. What are your views on the additional skills and training required to deliver this role? Are existing Domestic Energy Assessors best placed to provide the tailored recommendations? What risks and conflicts do you foresee and how would you propose to mitigate them?

Please explain your view.
Assessors are usually deal-based, and may not be well placed to close sided the practicalities of carrying out improvement works to existing dwellings.

26. The SLWG on Assessment propose that the tailored recommendations to improve energy efficiency and achieve zero carbon should consider the legal designation of buildings, obvious defects or condition issues, and local costings. Do you foresee any liability issues in this approach and if so, what suggestions do you have to mitigate them? Do you believe the inclusion of local costings to be practical and what are your thoughts on what level should be considered ‘local’? Should the local cost of energy also be considered?

Please explain your view.
Local costs of energy are not crucial, as reducing energy use (regardless of the cost of a unit of energy) must be the key.

27. The SLWG on Assessment propose that the assessment should provide a theoretical indication of whether recommendations are technically feasible. Please provide your views on who should determine actual technical feasibility? Should this be a qualified installer or someone else?

Please explain your view.
3rd party assessor, paid a fee by homeowner. This assessment should not be carried out by anyone employed by the state, whether directly or indirectly.

28. In your view, what are the most important considerations for homeowners who are required to meet the legally-binding standard, in relation to skills, supply chain, consumer protection and quality assurance?

Please explain your view.
Legally binding standard is fundamentally incorrect approach.

29. What are your views on how the Quality, Skills and Consumer Protection SLWG recommendations specifically have an impact on the owner occupied sector?

Please explain your view.
N/A

30. In your opinion, is this the right range of Scottish Government financial support schemes? Are there any gaps, regarding either types of financial product or groups of people who may be excluded from being able to access products?

Please explain your view.
Incentives should be available to everyone, and not means tested. Grants and interest free loans should be available for all retro-fit insulation approaches.

31. Do you agree or disagree that grant funding from the public purse should be focused on households who are vulnerable or in fuel poverty?

Please select one item
Agree
Disagree
Please explain your view.
I both agree and disagree. People in fuel poverty clearly require prioritisation in order to improve their homes for thermal comfort.

However larger and more affluent homes are likely to consume greater amounts of energy, and as a result are an area where real reductions can be achieved.

32. In your opinion, what sources of non-government, private sector support are people most likely to want to access? (eg from banks, building societies, credit unions, mortgage providers)

Please explain your view.
Mortgage providers, as most homeowners already have a mortgage, and it would be an easy range of products to ‘bolt-on’ to existing services.

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