Energy Efficient Scotland: consultation analysis
Analysis of responses to our public consultation 'Energy Efficient Scotland: making our homes and buildings warmer, greener and more efficient'.
The role of assessment to support the domestic energy efficiency standards
In paragraphs 46-50, the consultation paper explains a proposal to set up a Short Life Working Group (SLWG) which will consider research commissioned by the Scottish Government in response to concerns raised previously regarding the use of EPC methodology to set improvement targets under the Energy Efficient Scotland Programme. The group will also move forward with development of additional assessment requirements and formulating how an Energy Efficient Scotland assessment will be delivered.
Question 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.
Several respondents welcomed the establishment of the SLWG, while others commented on its membership or noted that they would like to be involved. Other general remarks were that respondents were content with the group's current remit, that it would be helpful to see the current remit, or that they had little to contribute until the research commissioned by the Scottish Government is available.
There were a large number of ideas for additional things the SLWG could consider, and the list below is not comprehensive. Suggestions, each made by one or a small number of respondents included:
- Alignment of Energy Efficient Scotland with related policy initiatives and with broader housing needs.
- The role that building level assessments could play in supporting energy efficiency standards.
- The risk of legal challenge.
- Definitions of 'technical and feasible' and 'cost-effective' and guidance on how the cost-effectiveness of a measure will be measured.
- Measurement and management of indoor air quality.
- A focus on the accuracy of advice given by installers.
- Consumer protection - a mechanism to provide redress for householders in the event of poor assessments, advice or workmanship. The recommendations of the Each Home Counts Review were highlighted.
- Consumer research on understanding of EPCs and what people want from them. The need to appreciate the position of homeowners and why they may struggle to meet required standards was seen as an important step.
- Expand the focus of the Route Map to include a behavioural change programme.
- The role of low carbon heat including low carbon district heat networks. Solar power and micro hydro were also highlighted.
- An annual target retrofit rate for a renewables-compatible building stock by 2050.
It was also thought that the time it will take for a policy linked to triggers such as change of ownership or tenancy to deliver the desired goals should be considered.
There were relatively few comments clearly specific to the new additional assessment proposed, but suggestions were that the SLWG should:
- Set up a framework for monitoring and evaluation of the new process.
- Develop the technical and quality assurance aspects of the scheme. For example, issues around fire safety or product/system certification. Consideration of the impact of product substitution was also proposed.
- Ensure recommended retrofit measures are compatible with each other and with the existing structure. Work at UK level to develop a new PAS 2035 standard to ensure a greater focus on the whole house and the interplay between measures was noted, with a proposal that the SLWG should have a similar focus.
- Consider how social and welfare benefits from different interventions can be captured.
It was also argued that the SLWG should be free to develop a single assessment if that proved a better alternative to the two assessments currently proposed, and that such an assessment should be both comprehensive and evidence-based.
Other respondents focused their comments on aspects of the current EPC system that they would like to see changed or made points on delivery, including the training of assessors.
Comments on the EPC assessment
Several respondents expressed views that the EPC assessment needs to be more accurate or consistent, and that it does not reflect the actual energy efficiency of many properties. It was argued that the suitability of the current SAP and RdSAP methodologies should be considered and their limitations better understood. However, it was also argued that in the event of a change to RdSAP methodology, an impact assessment should be carried out to identify situations where owners may be disadvantaged and to develop approaches to moderate that impact.
Since the EPC rating is becoming a regulatory tool, the importance of ratings being trustworthy was emphasised. Proposed changes, each suggested by one or a small number of respondents, focused on the need to:
- Include an occupancy assessment to reflect how householders use energy.
- Make the underlying heating regime and assumed energy costs clear on the EPC to allow households to understand how their choices affect the estimated usage and savings. Modelling more than one standard regime was also seen as reflecting differences in households.
- Incorporate real life information on actual energy usage, such as smart meter consumption data, information on boiler efficiency, heating controls and local weather.
- Improve the quality of the data used to underpin the EPC system and update changes more quickly.
- Improve the accuracy of both installation cost estimates and the potential future savings associated with recommended efficiency measures. Provide real examples.
- Reduce the number of assumptions made during the assessment process.
- Include consideration of repair and maintenance.
- Produce recommendations specific to the property.
- Reconsider costs in rural and island areas, to incorporate rural premiums.
- Consider future heating options with the expectation that choices will be more complex, and that factors such as outside space may be more important.
With respect to different building types and locations it was thought that the SLWG should consider the approach to assessment of:
- Hard-to-treat, traditionally constructed buildings.
- System-built structures, timber frame buildings, other buildings of non-standard construction and rooms in roofs.
- Flatted tenement property with common parts.
- Listed buildings.
- Rural homes.
Working with groups with an interest in different building types and locations was suggested, with research by the Sustainable Traditional Buildings Alliance and treatment techniques piloted by Historic Scotland both referenced.
Training of assessors
Some respondents, including Academic, Local Authority, Public sector or body – other, and Third sector respondents, highlighted the importance of assessors having appropriate skills and training, with a recommendation that experience from early stages of implementation should be fed back into training. Accreditation for assessors was also seen as important, and separation of assessment and sales functions was proposed to avoid any perceptions of a conflict of interest.
Tighter quality control for EPC production was also identified as necessary, particularly where the assessor has freedom to use different approaches resulting in different rating outcomes. Rooms in roofs were offered as an example of this:
There are some features such as room in roof which [an assessor] has freedom to model very differently, taking either a standard default approach or a more accurate approach. There needs to be a consistent approach … requiring more accurate measurement of different features...
Local Authority respondent
A requirement for additional training on traditional buildings and system-built properties was highlighted, as was the need for assessors who are not heating engineers to receive additional training on emerging technologies.
An appeals mechanism for correcting errors in EPC reports was suggested, and that this would be facilitated by inclusion in the report of all the data entries made by the assessor, so errors can be challenged. The need to encourage householders to keep records to demonstrate work done was highlighted.
The importance of ensuring that enough assessors are available, especially before backstop dates and in remote or island locations was highlighted. A fixed fee for the assessment cost was also proposed.
The EPC report
In an effort to improve understanding of the EPC report and recommendations it was argued that the report might be streamlined and also that plain English should be used. An approach where more practical mixes of measures are illustrated was proposed, and also that additional information such as signposting to Home Energy Scotland, funding schemes and installers should be provided.
A move towards digital EPCs was recommended. Introduction of a building passport and a roadmap to meeting the long-term standard was also advocated, with a suggestion that this could allow access to building data online and allow for more targeted advice to be directly accessible for homeowners. The possibility that an online EPC or linked property information might be updated automatically, without a further survey, after an approved measure is installed was also raised.
Installers and supply chains
The need to ensure the necessary skills and capacity to install the required energy efficiency measures, especially in rural areas, was highlighted by a small number of respondents. Proposals for further work were training students in developing technologies, supporting local communities to develop sustainable capacity, and making it easier for skilled local tradesmen to be involved in delivery programmes. However, to avoid giving opportunities to rogue or unqualified traders, accreditation for workmanship was advised, as was providing a list of approved providers, including customer reviews of accredited companies and providing independent quality assurance.
With respect to grants, loans or other incentives, comments were that a single scheme would be easier for homeowners to understand and that affordability issues will need to be considered, in particular where multiple measures are needed at the same time. Past experience of difficulties in encouraging installation of measures, even when fully grant funded, was noted and linked to a view that there may be resistance to the take-up of any loans offered.
Replacement of annual funding rounds with a three-year rolling programme was also proposed, which would have benefits for homeowners and also limit the amount of staff time taken up with evaluating more frequent rounds of bids.
The importance of engaging with homeowners to optimise voluntary uptake of energy efficiency measures was highlighted, and that any promotional materials should be both clear and visual. Other suggestions were an online advice tool, and the availability of telephone support from technical advisors.
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