Response 542513068

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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
Radio button: Ticked Agree
Radio button: Unticked Disagree
Please explain your view.
In general I agree, as long as it is recognised that some old buildings particularly in rural areas may need to have some leeway. Overall I suspect this is a small percentage of the current housing stock

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

Please select one item
Radio button: Ticked Agree
Radio button: Unticked Disagree
Please explain your view.
In general yes, but there needs to be a recognition that this may not be possible ( or at least economically practicable) in all houses. eg those with stone built walls and lathe and plaster lining

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

Please explain your view.
The fabric first approach is sound

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.
This is very complex and I don't fully understand it, but the last paragraph of Annexe A
would seem to be the best approach
'where a property does not meet the EPC band C standard by the installation of any measures to improve EER, there may be potential to introduce a requirement that the EIR is not made worse following the installation of those measures'

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.
There should be the ambition to reduce the carbon footprint of households further in the future

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

Please select one item
Radio button: Unticked Agree
Radio button: Ticked Disagree
Please explain your view.
Not sure - it depends what advice and financial help is available to householders and whether the infrastucture is in place e.g if the 5 households on our electricity line all opted for some form of electric heating SPEN would need to put in more capacity, possibly 3 phase. Who would pay for it?
We have been told in the past when just one house (ours) looked at ground source that we would need more capacity and we would have to pay for the installation (>£7000)

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
Radio button: Unticked Agree
Radio button: Ticked Disagree
Please explain your view.
The new standards should be introduced geographically. The introduction of broadband has shown that it is clearly easier to upgrade some places than others. If the point of sale is the trigger some houses which could be easily upgraded may not be done for years where others that are more difficult may be impossible to sell because the infrastructure is not available.
Also if the matter is approached geographically rather than at the whim of individual householders there is room to consider an overall approach, such as district heating schemes or upgrading electric connections. The present system where it is up to a single householder to negotiate with SPEN is inefficient and they treat everyone independently and charge accordingly.

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
Radio button: Ticked Agree
Radio button: Unticked Disagree

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.

Please explain your view.
I don't think it will be possible to sell houses without the standard in place as solicitors will warn against it. If it is passed to the buyer they will expect a large discount. Some houses will be unsaleable and likely to be bought by speculators at low cost who may do nothing with them for years (like shops in town centres)
If a house is very unlikely to meet the standard perhaps it is better to consider demolition and rebuilding

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
Radio button: Ticked Agree
Radio button: Unticked Disagree
Please explain your view.
It is more cost effective to put in insulation etc whilst a property is being renovated

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

Please explain your view.
It should be inspected by a qualified person independent of the builders/renovators
Please explain your view.
If it was made a statutory duty of Local Government there would need to be enough funding to make sure enough properly qualified and competent officers were employed.
In the past, our experience of building control officers enforcing necessary measures has been very poor.

An independent energy surveyor system might be better.
Whoever it is they should visit during construction and not just after it is completed

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.
First there should be some arbitration body to oversee difficult cases where either the building has particular problems (e.g Listed) or the owner has insufficient resources or capacity
Then fines - related to the property's carbon footprint but careful consideration should be given to circumstances.
If a person genuinely could not afford to upgrade their property perhaps they should be given a government loan which would be repaid at an affordable rate or else a charge could be put on the property as a percentage of its value, and this percentage repaid whenever the property is sold

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

Please explain your view.
If the improvements are actually feasible (no matter if they are actually cost effective) and
if the owner of the property is deemed to be able to afford them, they could be given annual recurring fines proportional to the excess carbon which they produce. The cost of a unit could be increased annually.

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

Please explain your view.
I feel the people most likely to try and avoid their responsibility, probably also most likely to deny man made climate change probably will not mind about the fines.
They should be fined through the courts so their names appear in the public domain

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

Please explain your view.
Elderly people in old properties
People with low incomes
People in fuel poverty

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?

Please explain your view.
Either the local council but better a separate body similar to SEPA

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?

Please explain your view.
Cost effectiveness should include benefit to society and reduction in carbon emissions.
It should be done as a whole building project rather than as each measure is put in place

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.
In rural areas, capacity and quality of connection to mains electricity may mean that the cost of implementing air or ground source heating becomes prohibitive.

Planning permissions??

Neighbours in a shared property?

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
Radio button: Ticked Agree
Radio button: Unticked Disagree

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

Please select one item
Radio button: Ticked Agree
Radio button: Unticked Disagree
Please explain your view.
But it depends on the building

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?

Please explain your view.
Nationally

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.
I think the occupancy based assessment is very important. Some people would use a lot more energy living in our house than we do, but it would be very costly. Generally we have cut down on using our central heating but heat individual rooms as necessary with electric fan heaters in the small rooms and wood burning in the large rooms and always use shutters and curtains at night. We expect to wear layers of warm clothes in winter Future occupants who might expect to walk around in tee shirts would not be comfortable here and to raise the energy efficiency standard sufficient for such behaviour would be prohibitively expensive

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.
Zero carbon should take precedence over strict regulatory compliance

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.
All necessary training should be put in place. If they are self employed and have to pay for qualifications they should be able to pay them back over time (like student loans)

They should be separate from any construction company and should be monitored, perhaps licensed? Their work should be subject to unannounced spot checks

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.
Our experience of getting installers i.e plumbers, builders, joiners to do any job in this area is not good. They all have more jobs than than they can cope with and long waiting lists and tend to concentrate on big projects. We have lived here a long time and know that their standards are very high, if a job looks as if it will be in the least bit difficult or complicated they do not even give a quote. I suspect if they look at something and think it is not technically feasible they will just say they won't do it. Then we have to wonder if we trust the ones who say it can be done?

If I can get a qualified installer who has come with good recommendations I would say they should determine feasibility

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.
They are all important (see above)

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.
If work is undertaken and checked it should be guaranteed and certificated so that future sales of the property should not be compromised. Perhaps the installer should also be insured? (like an architect or for dry rot treatment)

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.
Yes.

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
Radio button: Ticked Agree
Radio button: Unticked Disagree

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