Response 885792237

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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.
Yes. This broad principle is correct if Fuel Poverty, Energy Efficiency and Carbon Reduction targets are to be met. This will however be challenging in the Outer Hebrides due to the substantial number of houses in Fuel Poverty (and Extreme Fuel Poverty) , plus the limited options for heating systems.

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.
It is important to have a target to aim for and the use of the EPC system would be appropriate to use. However, it will be challenging for many properties in the Outer Hebrides to reach this standard without substantial investment/financial support.

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

We support the ‘fabric first’ approach. This is very important to many rural areas due to the poor condition of the housing stock. The local success of the HEEPS programme and Home Energy Scotland reinforces this approach.

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.
It will be very important to ensure very robust scrutiny of the EPC process including the certification and training of surveyors. The use of locally based surveyors with knowledge of a particular area should be encouraged. It would also be appropriate to have a robust sampling process in place.

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.
It would be more appropriate to review the standard on a regular basis to ensure it is fit for purpose.

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.
Important to have a start date to allow systems to be tested and put in place. A four year lead in time would seem appropriate given the scale of the proposal. It would also give a good lead in time to make home owners aware of the requirement and to offer reassurances in terms of financial support, for example, which would also need to be tested.

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.
We feel point of sale is a sensible approach to begin with. This approach would also be easier to manage and could quickly become a normal practice that homeowners are aware off and carry out as a matter of course.

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.
Cost of works would need to be reflected in the sale price. And there could be some impact on local housing markets initially which would need to be carefully managed.

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.

Initially there could be an impact of local property markets with buyers being put off by challenging properties (which may be selling at a reasonable price) but would need substantial investment in the fabric and heating systems. This would need to be carefully monitored.

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 would also be an appropriate trigger point

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.
Yes. It is reasonable to consider 25% a reasonable major renovation.

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

This approach would likely put additional pressure on Building Control teams and would need appropriate funding. This could be challenging for most local authorities.
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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.
A financial penalty system may be appropriate, but there could be concerns about further decreasing a person’s ability to carry out appropriate renovations.

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

Recurring, possibly stepped.

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

A percentage amount against the value of the property may be appropriate.

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

A number of groups could be adversely affected including; the elderly, young families, vulnerable households, homes in remote rural areas. The types and levels of incentives would inform this.

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?

Whoever takes the lead in this will likely require additional funding and training in order to fulfil this requirement. Local Authorities could potentially play a lead role in this, but it would be challenging in the current financial climate.

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?

This needs to be easy to communicate initially as it will require buy in from home owners. It is a complex issue and difficult to grasp fully even with a working knowledge of the industry.

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.
Long terms Empty Homes in poor condition would be problematic. Also, major renovations required through the Medical Adaptation route could be problematic.

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.
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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.
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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?

National guidance, with local flexibility would be appropriate. It would be more appropriate for this to be done at local level as this would ensure local issues are given appropriate consideration.

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.
Yes, agree on this approach. It should also be mandatory for vulnerable fuel poor households.

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.
Recommendations should be clear and it should be stipulated that they should not make the EPC worse. This could be a challenging issue to resolve in certain cases.

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.
Yes, existing Assessors would be best placed. Risks of conflict likely to be around households not wanting to carry out works (or can’t afford works). This reinforces the requirement for local Assessors.

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.
The aspect of ‘local’ should be tested through an Island Communities Impact Assessment in respect of island areas.

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.
A suitably qualified expert in the field would be most appropriate, backed up with skilled and local installers.

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.
Consumer Protection would be an important aspect. Homeowners would need a great deal of reassurance that works are being done correctly and will achieved the stated aim. Registered and experienced professionals would also provide comfort. Having suitable supply chains in rural and island areas is going to be challenging, but with the right systems in place would provide additional assurance.

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.
This has to be robust. We have recent experience of supposedly skilled, accredited and qualified mainland based firms leaving behind substandard work. It is important that quality assurance and sampling is continuous. This should offer more protection to the Owner occupied sector.

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.
There is a good range of schemes in place currently, but the ambitious targets set out in this consolation are going to require these schemes to have substantial increases in funding.

There will be issues around Crofter Housing accessing loans due to matters relating to security over the property.

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.
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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.
Those which provide the greatest protection and security and an element of flexibility in difficult circumstances.

About you

What is your name?

Angela Smith

Are you responding as an individual or an organisation?

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Organisation

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