Scotland Proposes Radical Changes to EPCs and Aims to Slash Validity Period in Half
The Scottish Government has recently unveiled its ambitious plans for Energy Performance Certificates (EPCs) through a comprehensive new consultation. The proposals are set to revolutionize the way energy efficiency is assessed, with changes spanning metrics, accessibility, and data usage. The consultation is open for feedback until the 10th of October 2023, closing at 23:59.
Background and Evolution of the Consultation:
The journey towards enhancing Domestic Energy Performance Certificates began in 2021 when the Scottish Government initiated discussions on potential amendments. The core principle underlying these changes was the importance of offering homeowners high-quality advice and information to grasp their property’s current energy rating and make well-informed decisions to enhance its energy efficiency.
Originally, the Scottish Government intended to conduct three separate stages of consultation on EPCs. However, after considering responses, conducting further research, and delving deeper into the Heat In Buildings policy, the approach was modified. Now, stages two and three of the consultation will be incorporated into a forthcoming consultation focused on a proposed regulatory framework for heat and energy efficiency, expected to be published in 2023.
Summary of the 2021 Consultation:
In the 2021 consultation, a crucial proposal involved introducing a new delivered energy metric to domestic EPCs. Based on valuable feedback and engagement from stakeholders, the Scottish Government is now considering alternative options.
Currently, the existing EPC is based on two metrics:
1. Energy Efficiency Rating (£): Reflecting running costs (£ per m2)
2. Environmental Impact Rating: Measuring emissions (kg CO2e per m2)
The consultation suggests adding a third metric called ‘Energy Use Rating,’ informing property owners about their dwelling’s energy consumption. The other two metrics will be retained but renamed as ‘Energy Cost Rating’ and ‘Carbon Emissions Rating’ for better clarity.
Following numerous responses and feedback, the Scottish Government has released a fresh consultation with revised proposals.
Summary of the New Consultation:
Building on further research and comprehensive feedback, the Scottish Government now proposes the following changes:
Domestic EPCs:
1. Fabric Rating: Providing a clear assessment of a dwelling’s fabric efficiency, i.e., the energy needed to achieve standard internal conditions supplied by the heating system.
2. Cost Rating: Presented on a 0-100 rating index instead of a £/m2/yr indicator, as the latter could mislead homeowners into assuming predicted running costs.
3. Heating System Type: Including information about the system’s efficiency, potentially introducing a classification from high efficiency zero direct emission heating systems to heating systems with direct emissions.
Additionally, the EPC will display the Emissions Rating and Energy Use Indicator, offering valuable information to stakeholders. Furthermore, the EPC will feature a comprehensive list describing the dwelling’s energy efficiency features.
Non-Domestic EPCs:
The Scottish Government’s proposals for Non-Domestic EPCs include:
1. Energy Rating (A to G): Based on modeled emissions relative to a reference building, aligning with the UK’s rating system.
2. Direct Emissions (kg of CO2e/m2/yr): Indicating the building’s modeled direct emissions, facilitating a focus on individual building decarbonization.
3. Energy Use (kWh/m2/yr): Presenting the building’s modeled energy use under standardized conditions for easy comparisons.
The consultation also emphasizes making the heating system type and fuel more prominent on the EPC.
Purpose and Validity Period of EPCs:
The Scottish Government reiterates the key role of EPCs as a primary step towards improving energy efficiency and achieving zero direct emissions. To ensure more up-to-date information is available to prospective owners and tenants, the consultation proposes reducing the EPC’s validity period from ten years to five. This means that an updated EPC would be required if one has not been issued in the last five years, triggered by events like property sale or new tenancy.
Additional Proposals:
Apart from the aforementioned changes, the Scottish Government is keen to shift away from PDF-based EPCs towards a more digital solution, similar to what is already adopted in England and Wales. Modernizing the EPC Register will unlock the potential to utilize EPC data fully, delivering significant advantages in the pursuit of net-zero targets.
Timeline:
The Scottish Government aims to implement the reformed EPC shortly after amending the Energy Performance of Buildings Regulations, planned for this winter, and ahead of the proposed Heat in Buildings regulations.
Elmhurst’s Response:
Elmhurst, an industry-leading organization, expresses enthusiasm about the live consultation. Acknowledging EPCs as a crucial asset to the industry and the UK’s net-zero aspirations, Elmhurst highlights the importance of providing homeowners with coherent information for informed decision-making. Embracing the proposed changes, such as reduced validity periods and additional metrics, aligns with Elmhurst’s previous advocacy efforts for clearer and up-to-date information. Finally, Elmhurst views the consultation as a positive indication of the Scottish Government’s commitment to investing in the future of energy efficiency and the EPC, benefiting DEAs and OCDEAs in the process.