Stroma’s response to Energy Efficient Scotland

In May 2018, the Scottish Government published a consultation on proposals for improving the energy efficiency of buildings across Scotland.

Energy Efficiency Scotland  proposed a minimum energy efficiency target for all buildings in Scotland to help reduce energy costs, improve living standards (tackle fuel poverty), whilst reducing greenhouse gas emissions to meet climate change targets.

To help develop the programme and set achievable timelines, individuals, organisations and public bodies were asked to respond to the consultation to express their views and concerns.

Andy Parkin, Director of Energy Certification, has published Stroma Certification’s response to the Energy Efficient Scotland consultation.

1. What are your views on our proposal for owner occupied and private rented properties to achieve the Long-Term Domestic Standard EPC Energy Efficiency Rating Band C by 2040 at the latest?

Stroma Certification believe that any proposal must have a long-term goal, and this should be both ambitious, but also achievable.

Whilst a C rating represents a significant improvement goal for the majority of properties that are rated E, F and G at present, given current technologies and costs, existing technologies will get more effective and cheaper to install over time. Equally, newer technologies will help the worse performing properties achieve higher ratings than currently possible.

Stroma Certification feel that intermediate rating targets should be set at proportionally spaced points in time to help work towards this goal.

Achieving E for the majority of properties is achievable at present, but achieving D may take more time. So, there may need to be greater spacing between the achievement dates as the rating target increases.

2. Do you think we should allow for situations where a lower standard is acceptable?

Yes. There should always be allowances for properties that cannot meet the standard set.

This could be more likely if the standard is set too high, too quickly.

Whether it’s by setting a lower standard, or by issuing detailed guidance on what the person/authority responsible for a building must do if they cannot meet the standard.

However, the requirements on substandard properties should not be a simple 'I can’t comply, so I don't need to do anything' exemption; rather a responsible party should be able to show that they have done as much as is reasonably expected to the property to improve its efficiency.

3. Do you think we should allow for situations where a longer period for improvement is allowed? Please explain your answer, giving examples.

Yes, as noted above, it may be that poorer performing buildings will need more time to achieve the standard.

For example, where a package of measures is needed, or certain measures need to be installed in a certain order, then extra time could be allowed to ensure the property is brought up to standard.

It may also be possible that the number of properties need a certain measure to meet the standard and demand is outstripping supply, or the skilled labour needed to install the measure. An example being external wall insulation.

Where the above example occurs, then evidence could be obtained to apply for a reasonable extension to the timescales.

4. We are proposing that the definition of a cost-effective measure is that it should pay back over its lifetime. What are your views on this definition?

A measure should pay for the majority of itself over its lifetime. Measure should also offer other benefits to the occupant, and this should be considered as part of the cost effectiveness calculation, and not just the monetary saving.

Many measures offer improvements to occupant’s warmth/living standards and convenience. These are less easy to measure in terms of cost effectiveness, but Stroma Certification believes these are often as important, and also bring more perceived value to a property, which could be somewhat measured or perceived.

The Green Deal measure calculation methodology has shown that there are few measures that pay for themselves over their lifetime, but certain measures pay for themselves several times over, so a package of measures (some high return, and some low return) could allow the high return measures to offset the lower return measures that do deliver higher living standard benefits.

Loft insulation is a measure that would be considered cost-effective in the simplest terms in that it is low cost, but high-saving.

New double glazing is high-cost and returns relatively low savings on the EPC. However, it can reduce drafts, making the property feel warmer, whilst adding value to the property.

5. What are your views on the issue of air quality in relation to the Long-Term Domestic Standard?

Air quality and overheating are two common issues associated with improving the efficiency of the building, particularly where the improvements result in sealing the property and preventing movement of air.

The package of measures should therefore consider the ventilation of the property, above the usual combustion considerations of heating systems and fires (in the example of wall insulation).

Additionally, Stroma Certification would like the Scottish Government to consider the existing issues of air quality in general, particularly in built up areas, where air quality is already poor and potentially dangerous to the public or vulnerable members of the public. Stroma Certification would be supportive of air quality studies and monitoring in properties to better understand and inform the public of how to better use their properties with air quality in mind.

6. The EPC Rating of a property can be affected by changes to the underlying methodology and to fuel price data. How do you suggest that the Programme takes account of this in setting the Long-Term Domestic Standard?

Stroma Certification feels that the EPC should be the starting point for many current and future initiatives and incentives. The EPC should also be used after major works are completed at a property to demonstrate improvement over time, and to keep the register up-to-date.

Stroma Certification feels that the EPC should be more 'interactive' in the way it is used by the public. In that the public should be able to view the EPC and interact with it more effectively to better understand what it says about their property, next steps to make improvements, and use the data about their property in conjunction with other data to their benefit.

The EPC should be the base data for many uses in the future that could use its metrics without affecting how the EPC is produced by an energy assessor, or the way these metrics are displayed. Changing the look of the EPC should only be done to allow the public to better understand it, and not to give favourable results.

One example is that the EPC currently uses the fuel cost in the EER - the first graph which is the most commonly used and understood. If the EER didn't use fuel cost, then all prior EPCs produced would change or become less useful as a comparison tool. However, the base EPC could maintain the fuel cost basis of calculating the EER, which could then be manipulated in the interactive EPC to show actual fuel costs, or local fuel costs, or even with the fuel cost removed, to get the thermal envelop asset rating result. This would allow the EPC to be used for multiple reasons with accurate information for that purpose. This layered interactively would help future proof the EPC.

The EPC methodology needs to be kept up-to-date in response to new technologies and property data availability that could be used by an energy assessor to make the EPC more accurate.

7. What are your views on the proposal that all PRS properties meet EPC Energy Efficiency Rating Band C by 2030?

Stroma Certification feels that this is a challenging, but an achievable target. Stroma Certification doesn't have any additional evidence or data to support this comment, other than social housing properties tend to be better rated than the rest of the housing sector, due to an earlier focus on energy efficiency being in place, which has resulted in these higher EPC ratings in general.

8. What are your views on our proposal for an initial period of encouraging action?

A certain segment of the owner-occupied sector will be responsive to encouragement, but Stroma Certification feels that many owner occupiers will not consider energy efficiency improvements with a view to meeting a certain standard, unless there is a financial reward for improving and/or penalty for failing to improve to the standard.

There is anecdotal evidence present in England and Wales where lenders are not willing to lend the full mortgage amount to a potential buyer of a property if the EPC isn’t currently E or above, due to MEES (some lenders are requiring a D). This is because there’s a risk to the lender of the property being devalued in years to come if it cannot be rented out.

This kind of unintended consequence is having an effect and should be investigated, as this is enough of a penalty to focus a seller’s mind when putting a house on the market.

9. What information would be useful for householders to be able to access on how to achieve EPC Energy Efficiency Rating Band C before 2030?

The Scottish Government should consider looking at the BEIS guidance material on the buying and selling and rental process. The purpose of these in progress documents offer clear guidance on how to buy, sell and rent properties.

Early guidance could be added to similar documents in Scotland which could introduce this principle to current and potential householders.

Doing this from the inception of the policy would help steer the public and ensure that people are aware of this trigger point. Sellers often improve properties when willing to attract buyers and buyers often improve properties shortly after purchasing, so offering advice at this point would be beneficial.

Likewise, empowering DEAs to offer information to homeowners when performing an EPC at any trigger point would help to inform. They are capable of discussing current rating, what effects improvements have on the property and advising on the next steps.

10. What are your views on our proposal to follow this initial period with mandating action?

Mandating action will focus homeowners on achieving the standard. Without enforced action, the standard would not be achieved.

11. What are your views on our proposal that 2030 is the right point to start mandating action to achieve EPC Energy Efficiency Rating Band C?

The proposed timescale of 2030 appears to give a reasonable period of time for all stakeholders to improve their properties to a rating of C (or get close to it), so that it’s likely that they can achieve a C within a period following 2030.

It would seem logical for all properties sold after 2030 to achieve C, or as close to C as is cost-effective, as per the comments for Q9. A backstop date could then be placed for 2035 for all properties to achieve a C, irrespective of whether they are put up for sale or not.

Financial penalties (a tax on the property) could be used to enforce substandard properties that are private owner/occupied, and a fine and ban on renting substandard properties for those in the rental sector.

12. What are your views on our proposal for owner occupied properties to be subject to penalties for non-compliance?

See Q11.

Taxation is often a useful method of penalty and one that would cease once the property is brought up to standard.

This has been successful in the motor industry, where taxation is applied to fuel and the vehicle where emissions are over a certain level. There has been a substantial rise in electric vehicles and smaller petrol engine hybrids; away from larger diesel engine cars.

13. What are your views on requiring all types of accommodation to meet the Long‑Term Domestic Standard over time? Please explain your answer, giving examples of accommodation you think should/should not be required to meet the Long-Term Domestic Standard if relevant.

Stroma Certification believe that properties which lead to fuel poverty need to be brought up to standard wherever possible.

One particular area are HMOs, which for too long have avoided having an EPC produced because of the way single rooms are rented out.

Stroma Certification believes that all HMOs should have an EPC displayed on-site, and this EPC should be updated regularly (annually) in order to maintain their licence. Landlords should be mandated to update these properties regularly to ensure that their occupants (often the poor who cannot afford to rent or buy a property) are not thrown into fuel poverty.

14. Please provide your views on our proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band C by 2030, where technically feasible and cost effective?

Stroma Certification agrees with this proposal, if all occupants who are in fuel poverty can be identified and effectively assisted without penalty.

Rental Properties

However, Stroma Certification are concerned that the fuel poor may end up being vilified and unable to rent a property if it means that landlords need to advance their expenditure on a property to meet the standard. This could lead to the fuel poor being evicted or refused tenancy if they are deemed to be fuel poor upon a credit/affordability check.

Privately Owned Properties

Likewise, those who are fuel poor need to be helped via ECO or other initiatives to ensure that by 2030 they are living in a property that meets the standard. Any penalty for the owner would only result in greater fuel poverty.

The only way to ensure this would be for the EPC to be kept at the heart of any funding for properties owned or occupied by the fuel poor.

15. Please provide your views on the proposal that all homes with fuel poor households are to reach EPC Energy Efficiency Rating Band B by 2040, where technically feasible, cost-effective and possible within limits affordable to the public purse?

Stroma Certification agrees with this proposal - please see the above answer.

However, a B rating on many properties would require renewable or future technology, and this would need to be cost-effective by 2040.

Stroma Certification suggests that this target is reviewed in 2030 and 2035 to ensure it’s feasible.

16. In addition to what we have set out in paras 46-50, what should the Energy Efficient Scotland Assessment Short Life Working Group also consider? Please explain your answer.

Stroma Certification would like Scottish Government to consider the qualifications currently in place and the expense that energy assessors have already undertaken.

Many assessors are already Green Deal Advisers (GDAs) and this qualification already encompasses the provision of advice and bespoke plans.

However, it’s fair to say that there are gaps in some assessor’s knowledge and not in others, and this is very much dependant on the prior experience and current job roles they have.

Weak areas identified by Stroma Certification are traditional buildings, system build style properties and bespoke modern constructions (the latter is not necessarily important to this topic). Additionally, the more recent and emerging technologies are areas that all assessors who don't work as heating engineers would need additional training.

Stroma Certification would welcome being part of the Working Group.

17. What are your views on whether the Long-Term Domestic Standard should be enforced at a local or national level? Please explain your answer.

Enforcing this at a national level would ensure that the country as a whole improves the building stock in a uniformed way.

It would seem logical for local authorities to be the appropriate bodies to enforce minimum standards. In England and Wales, the responsibility sits at a national level and Stroma Certification believes that there would be greater effectiveness by enforcing at a local level, as long as each local authority enforces in the same way.

However, if a local authority wishes to go above and beyond the national domestic standard, whether in terms of rating or to incorporate other performance indicators (i.e. water usage targets), then they should be encouraged to do so.

18. Are there specific building characteristics you consider should be included in research to ensure that future improvement targets reflect the diverse nature of our non-domestic building stock? If so, please set out what these are and why they should be considered.


19. What are your views on the way calculated energy use from building assessments are presented and/or benchmarked? We are particularly interested in what arrangements you favour and how you think they would be useful.

Stroma Certification is keen to explore Scottish Governments plan to move towards a benchmarking system where the performance of a building is assessed against a ‘notional building’ specification.

20. What are your views on the proposed planned work to review improvement targets?

Unable to comment

21. What are your views on our proposals for phasing the regulations from 2020?

Stroma Certification supports these proposals.

22. Should advice and support to invest in the energy efficiency of industrial or manufacturing buildings align with wider advice and support on how to reduce energy consumed for productive processes? If so, please suggest how improving efficiency in building and ‘process’ energy could work together, and what opportunities and challenges this might present?

Stroma Certification believes there are merits in this proposal, but the wider advice would be bespoke and would have to come from someone with suitable expertise in the manufacturing industry.

23. What more could the Scottish Government do to encourage the public sector to accelerate energy efficiency across their building stock?

Stroma Certification strongly suggests that all public buildings should have annually updated DEC performed on them.

24. What more could the Scottish Government do to encourage the public sector to accelerate heat decarbonisation across their building stock?

Unable to comment.

25. What additional data would help building owners in the delivery of the Energy Efficient Scotland Programme? How would this be used?

It would be useful for building owners to use the EPC data in conjunction with other data sources about their building:

  • Metering information (smart meter information)
  • Using occupancy information to better understand their actual costs
  • Be able to see the impact of individual measures/improvements and not just those that appear in appendix T currently.

Ultimately, Stroma Certification would like to see the EPC as a more interactive tool as described in Q6.

26. What additional data would be helpful to others in the delivery of the Energy Efficient Scotland Programme? How would this be used?

Not necessarily an answer to this question, however, Stroma Certification believes that the data on the EPC register should be as up-to-date as possible. In order for this to happen, EPCs should be updated once significant work should trigger a new EPC. Examples of these triggers could be:

  • Extensions to properties
  • HVAC changes/upgrades
  • Improvements to the thermal envelope

In each case, the data associated to these changes should be recorded and made reportable so that it’s stored online in a 'property passport', so that this data can be used by stakeholders - i.e. homeowners, architects, designers for future upgrades, energy assessors etc. This would allow these stakeholders to use this data for accurate updates and upgrades to the property and for future EPCs and reports to be far more accurate.

27. We will investigate the benefit in providing new online resources or tools to support building owners to access and use data to help them improve their properties. What particular types of resources or tools would you find useful and why?

Please see our answer to Q6 about the interactive EPC.

28. In addition to the above, we welcome any specific comments or observations you may have on the future use of the data that is gathered from energy assessments.

It would be useful to use the data used in new build SAP EPCs when producing an RdSAP EPC.

The SAP EPC is likely to be far more accurate than the defaults used in RdSAP, therefore, there is a risk that as these 10-year-old SAP EPCs get replaced in 2020 onwards and the detailed data that is available is replaced with less accurate data.

Stroma Certification would welcome a process where this data can be used by the DEA and used in the next EPC.

The same principle can be applied to other known values and data sets that are attributed to the property.

If you have any questions, please contact us on 01977 665 420 (ext. 614).

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