Scottish Energy Performance Certificate Register: consultation on funding

The Scottish Energy Performance Certificate Register (SEPCR)

1.1 Development of a central register

The Scottish EPC Register ( SEPCR) ^[7] is a central register of data for all the Energy Performance Certificates ( EPCs) and Recommendations Reports, Section 63 Action Plans, Display Energy Certificates and Advisory Reports, Green Deal Advice Reports ( GDARs) and Green Deal Plans that are produced and lodged for properties throughout Scotland.

Over 1.9 million EPCs have been lodged since its inception in January 2008, with around 20,000 further lodgements taking place on a monthly basis. With the addition of Green Deal and Section 63 assessments, the register now holds in excess of 2 million assessment records.

Lodgement of data for Energy Performance Certificates ( EPC) began in December 2008. Initially, only data for existing dwelling EPCs was lodged to the register, using the facility offered by the pre-existing Home Energy Efficiency Database ( HEED) operated by the Energy Saving Trust.

In support of an increased focus on use of EPCs in support of policy delivery, both in Scotland and elsewhere in the UK, a more comprehensive separate register (the SEPCR) was commissioned and developed. This was introduced in October 2012, with the transfer of existing data from HEED, and also supported the initial roll-out of the UK Government's Green Deal programme.

From January 2013, central lodgement was extended to cover EPCs for existing non-domestic buildings and EPCs on completion of new domestic and non-domestic buildings ^[8] . At the same time lodgement of Green Deal Advice Reports ( GDAR) to the register also began in-line with the Green Deal aspects of the Energy Act 2011. There is no central lodgement of air conditioning inspection reports (introduced under Article 15 of the Directive) in Scotland.

From 1 September 2016, energy improvement data for Action Plans, Display Energy Certificates and Advisory Reports is also lodged to the SEPCR in support of the Assessment of Energy Performance of Non-domestic Buildings (Scotland) Regulations 2016. A charge is levied for lodgement of energy improvement data and is set at the same rate as for non-domestic EPC data but, as a non-statutory fee, includes VAT at the standard rate reducing the effective income from each lodgement to £4.47.

The Energy Saving Trust ( EST) has been appointed by the Scottish Ministers as "the Keeper of the Register" and is responsible for the daily operation and maintenance of the register. In addition, the keeper manages the regular development work and software upgrades required for the register to maintain function in response to changes to the National Calculation Methodology ( NCM) and changing requirements arising from policies that access and use the data held by the register.

1.2 The need for a register of data

Energy Performance Certificates ( EPCs) and their accompanying Recommendations Reports ( RRs) are the means by which the UK implements Articles 3, 4, 6 and 11-13 of Directive 2010/31/ EU on the Energy Performance of Buildings (the Directive). All EPC assessments are now lodged to this central electronic register.

Scottish regulations implementing the Directive require the production of an EPC on the construction, sale or rental (to a new tenant) of a building and the display of EPCs in larger buildings to which the public have access. For the purpose of the Directive, an EPC is valid for a period of not more than ten years. Provision of EPCs on construction is addressed under standard 6.9 of the Building (Scotland) Regulations 2004 ^[9] . Provision in other respects is addressed under The Energy Performance of Buildings (Scotland) Regulations 2008 ^[10] .

EU legislation does not mandate the creation of a central register of energy performance data. Whilst initially beneficial from 2008, it was determined that such a resource was integral to the successful delivery of the recast Directive from January 2013. In addition, the creation of a central repository of energy performance data has now been of benefit to building owners and practitioners and is essential to the delivery of both EU and domestic energy efficiency and emissions reduction policies.

The SEPCR now provides a rich source of data on the energy performance of our existing building stock. The Scottish Government has designated energy efficiency as a National Infrastructure Priority, the cornerstone of which will be Scotland's Energy Efficiency Programme ( SEEP) - a 15 to 20 year programme. The Programme for Government commits to investing more than half a billion pounds to SEEP over the next four years, setting out a clear commitment to develop this programme with substantial annual funding.

By 2035, SEEP will have transformed the energy efficiency and heating of Scotland's buildings so that, wherever technically feasible, and practical, buildings are near zero carbon. An effective and well-resourced register of energy performance data is integral to that process - helping to target improvements as well as tracking progress.

1.3 Policies supported by register data and functions

The principal function of the register was to support the Scottish Government in the transposition of Directive 2002/91/ EC (recast as 2010/31/ EU), through registration of Energy Performance Certificates ( EPCs).

Since 2007, EPCs and their underlying assessment methodology have become embedded in a wide range of government policy areas as the method of reporting on and recording energy performance and emissions information for buildings. The register currently accepts data from a number of assessment tools, each delivering one aspect of the UK National Calculation Methodology ( NCM). These are:

• EPCs for dwellings, the SAP and RdSAP methodology. Information can be found at www.bre.co.uk/sap2012/
• EPCs for non-domestic buildings and buildings other than dwellings, the SBEM methodology. Information is published at www.uk-ncm.org.uk/
• Display Energy Certificates ( DECs) reporting operational energy use in non-domestic buildings. Information on application of this methodology in Scotland can be found at www.gov.scot/section63.

Since their introduction, the UK National Calculation Methodology and EPCs have and will continue to be applied across a range of policies other than EPBD and building regulations. These include:

• Home Report (Scotland, methodology strand - RdSAP). The EPC and recommendations report ( RR) is used to provide the 'energy report' required under The Housing (Scotland) Act 2006 (Prescribed Documents) Regulations 2008. The section in the RR 'About the recommended measures to improve your home's performance rating' is required under this legislation.
• Energy Efficiency Standard for Social Housing (Scotland, methodology strand: RdSAP). EESSH does not require production and lodgement of an EPC but does use the numerical value of the calculated Energy Efficiency Rating (the ' SAP rating') as the means for Local Authorities/Registered Social Landlords to demonstrate that a defined performance standard is met. Targets are differentiated by both main heating fuel type and dwelling type.
• Section 63 of the Climate Change (Scotland) Act 2009 (Scotland, methodology strand: SBEM). A non-domestic EPC assessment is used as the basis for the setting of improvement targets for larger non-domestic buildings under The Assessment of Energy Performance of Non-domestic Buildings (Scotland) Regulations 2016. Applicable from 1 September 2016, these regulations require assessment and improvement of buildings over 1,000 m². The requirement to assess is triggered by sale or rental of a building (or building unit), the same transactional trigger as for EPCs.

Assessment results in the production of an 'Action Plan' document which records improvement targets and the measures proposed to meet them. Improvement may be deferred where annual operational energy use is reported on a Display Energy Certificate using the operational ratings methodology, ORcalc. Further information on this policy and the processes applied can be found at www.gov.scot/section63.

• Green Deal ( UK Government, methodology strands - RdSAP and SBEM plus additional assessment methodology (Occupancy Assessments). An EPC is used to record the performance of a building before and after a Green Deal plan when improvement is carried out. Details of the Green Deal plan are added to the last page of the post-improvement Recommendations Report. In 2012, the RdSAP methodology was modified (improved and expanded) to support the requirements of assessment in support of the Green Deal.
• Feed-in Tariff ( UK Government, methodology strands - SAP, RdSAP and SBEM). Eligibility for standard rate tariff dependent upon meeting minimum energy efficiency requirement, based upon EPC rating. For non-domestic buildings, due to differences in post- SBEM EPC process, the Scottish Recommendations Report presents a calculated 'England & Wales Equivalent EPC rating'.
• Renewable Heat Incentive ( UK Government, methodology strand - SAP. RdSAP). Eligibility for standard rate tariff dependent upon meeting minimum energy efficiency requirement, based upon EPC rating. Recommendations Report of EPC contains information on how heat demand can be reduced by implementing specific measures.
• Energy Company Obligation ( UK Government, methodology strand - RdSAP). RdSAP calculations and lodged EPCs both used as evidence to support proposals for ECO improvement works. EPCs are used to record measures implemented and benefits, post-installation.
• Minimum standards of energy efficiency in private sector housing (Scotland, methodology strand: RdSAP (proposed)). The Scottish Government is consulting at present on proposals for the assessment and improvement of dwellings in the private rented sector, including on setting an initial minimum energy efficiency standard ( SAP band) at the point of rental of 'E' from April 2019, rising to 'D' from April 2022, with "backstop dates" by which all privately rented properties would need to meet the standard. The consultation runs until 30 June and can be accessed at: https://consult.scotland.gov.uk/better-homes-division/energy-efficiency-programme/.