Publication - Impact assessment

The Energy Efficiency (Private Rented Property) (Scotland) regulations 2020: BRIA

Business and regulatory impact assessment (BRIA) for the Energy Efficiency (Domestic Private Rented Property) (Scotland) regulations 2020.

47 page PDF

573.6 kB

47 page PDF

573.6 kB

Contents
The Energy Efficiency (Private Rented Property) (Scotland) regulations 2020: BRIA
13. Summary and recommendation

47 page PDF

573.6 kB

13. Summary and recommendation

The recommended approach is to introduce regulations at the point of turnover coupled with a backstop date, as well as setting a trajectory so that the minimum EPC is raised over time from an E to a D. In the absence of such regulation, the required retrofitting of low energy efficiency dwellings in the private rented sector is unlikely to happen, or will only happen more slowly than is required for purposes of the delivering the Scottish Government's objectives relating to climate change, energy efficiency, fuel poverty, and delivering a high-quality private rented sector.

The combination of point of rental and backstop date, coupled with setting the trajectory with an initial E and only raising it subsequently to a D, will allow the regulations to be introduced in a phased approach so as to reduce any disruption to landlords and tenants, while ensuring that within a reasonable time period all tenants in the private rented sector are assured of minimum standards of energy efficiency.

Setting a cost cap for each stage acts as a safeguard to ensure that upgrades are not installed where they will be excessively expensive.

The key summary costs and benefits were set out above in Table 6 and Table 9, which are reproduced below.

Costs and benefits of raising all stock to an EPC of E

Total Average
Dwellings below EPC E 33,000
Cost and benefits within private rented sector
Upgrade cost £37.5m £1,140
Hidden cost £3.8m £110
Post-upgrade EPC cost £2.3m £70
Annual fuel bill savings (before in-use factors) £14.5m £440
Annual fuel bill savings (after in-use factors) £10.9m £330
NPV before in-use factors £261.2m £7,920
NPV after in-use factors £180.8m £5,480
Emissions abatement (CO2e)
Annual carbon savings before in-use factors (kgCO2e) 0.072Mt 2.2t
Annual carbon savings after in-use factors (kgCO2e) 0.052Mt 1.6t
Annual carbon savings after in-use factors and comfort taking 0.044Mt 1.3t
Annual non-traded carbon savings after in-use factors and comfort taking 0.035Mt 1.1t

Costs and benefits of raising dwellings to an EPC of D after they have already been raised to an EPC of E

Total Average
Dwellings below EPC D 83,000
Cost and benefits within private rented sector
Upgrade cost £167m £2,010
Hidden cost £17m £200
Post-upgrade EPC cost £6m £70
Annual fuel bill savings (before in-use factors) £21m £250
Annual fuel bill savings (after in-use factors) £16m £190
Net present value before in-use factors £196m £2,360
Net present value after in-use factors £92m £1,110
Emissions abatement (CO2e)
Annual carbon savings before in-use factors (kgCO2e) 0.12Mt 1.4t
Annual carbon savings after in-use factors (kgCO2e) 0.09Mt 1.1t
Annual carbon savings after in-use factors and comfort taking 0.08Mt 0.9t
Annual non-traded carbon savings after in-use factors and comfort taking 0.06Mt 0.7t

Contact

Email: denise.buchanan@gov.scot