Energy Efficiency Standard for Social Housing Review - Just Transition, Metric and Heating System subgroup minutes: 30 November 2022

Minutes from the meeting of the subgroup on 30 November 2022.

Attendees and apologies

  • Angela Morgan, Port of Leith Housing Association
  • Bruce Cuthbertson, Tenant representative
  • Callum Neil, Scottish Government
  • Cassandra Dove, SFHA
  • Chris Morgan, John Gilbert Architects
  • Duncan Smith, River Clyde Homes
  • Jackie Timmons, City of Edinburgh Council
  • Lori McElroy, University of Strathclyde
  • Paul Leask, Hjaltland Housing Association
  • Scott Restrick, Link Group Ltd
  • Simon Roberts, Scottish Government


  • Ciara O'Connor, Scottish Government

Items and actions

  • SG to gather information on the outcome of the short life working group consultation on presentation of EPC assessment. Due December 2022

  • subgroup members to share and review options papers in preparation of next meeting. Due December 2022

  • SG to have information on DNOs to share mid-December. Due December 2022


List of attendees available.

Simon Roberts welcomed everyone and opened for any comments on the minutes and actions of from last meeting. Everyone content and SG to send round the response on DNOs. 

SAP calculations

Scott Restrick provided a summary of the issues posed by using SAP as a metric.

rdSAP is has the benefit of being relatively cheap and simple to train assessors, making it widely available. The SAP rating being a number in the range 1 – 100 also makes it easy to compare the energy performance of different properties. However, the scale is not linear, so it is not possible to say one property at 50 is 10% better than another at 60, for example.

The fundamentals of rdSAP is that it is non-invasive procedure, i.e. assessors do not need to take the house apart or cause any damage when carrying out the assessment. This means that some important features are missed from the assessment. SAP calculations on new build properties are much more detailed, meaning that the property can lose SAP points when an rdSAP is calculated years down the line when the newbuild SAP has expired.

SAP calculations include an energy cost deflator (ECD), which is a factoring mechanism used to bring the ratings back to 1993 pricing levels. The cost deflator is based on the gas price (80%) and economy 7 off peak electricity price (20%). Fuel costs for domestic supply now move more differentially than in the past, causing issues with the calculation of the SAP score, a single multiplier cannot now robustly correct for the movement of oil, gas and electricity prices.

Under the current EPC method an electric heated property (including heat pumps) is negatively affected due to the cost of electricity not being corrected sufficiently with the ECD. In the new SAP methodology (SAP 10.2), this effect will be more pronounced, in fact it is unlikely that a new EPC would recommend heat pumps.

SAP already calculates the required kWh/m2/year for all regulated energy, which can be utilised as a metric.

It should be noted that BRE are looking to move on from SAP 10 to a net zero focussed calculations tool SAP 11 (BRE announces new project with BEIS to modernise home energy rating scheme in time for Future Homes Standard).

It should be made clear to tenants that SAP only measures regulated energy use (heating, hot water and lightning) and does not account for other energy use (appliances etc).

Currently for property with a gas combi boiler for heating and hot water in conjunction with an electric shower SAP ignores the energy required for the electric shower, underestimating the hot water energy demand. This will be resolved in future iterations of SAP from v10.2.

Lori noted there was a consultation on the presentation of EPC assessments done by the short life working group – SG to look into this.

It was noted that studies conducted by Changeworks show that SAP is not completely accurate, particularly with older properties being underestimated in their energy use.

It was questioned whether it was possible to make assumptions on unregulated energy demand based on number of bedrooms, as SAP only considers regulated energy demand. The Occupancy Assessment process as part of the Green Deal tackled this.

Review of draft options paper

Members of the subgroup were invited to provide their feedback on the draft options paper circulated to the group prior to the meeting.

It was agreed that while it is important to move away from an EPC rating as the metric there are still some useful outputs from SAP calculations that can be used.

Cassandra shared an expanded options table with additional columns. Cassandra to upload document to objective connect for comment from the group.

It was noted that affordability for tenants is difficult to measure, as everyone’s situation is unique, so it’s important to focus on getting properties to meet the required standard, not reliant on tenant behaviour.

Chris has also a version of the options paper, to be uploaded to objective connect for review from the group.


Discussion on tenant’s perspectives:
Where landlords are installing zero emissions heating systems they should be using meter readings to show how much the system reduces consumption. If prospective tenants are unable to afford the property then what else can be done to help.

The cost effectiveness of measures is important to have the biggest impact on fuel poverty. From a tenant’s perspective any increase in rent that is going towards paying for energy efficiency upgrades should be met with an equal reduction in energy bill.

Discussion on the issues with multi tenure:

  • private homeowners have a different standard to meet so no incentive to agree with stock improvement proposals from social landlords
  • social landlords need a technical reason for defending plans for installing insulation – complying with a standard is not a valid reason in itself
  • landlords require support with legal authority to carry out works
  • issues with worst performing stock not eligible for funding
  • could there be a separate standard for multi tenure blocks?

It was noted that in properties where the fabric had been improved so much that residents required minimal heating that there was no motivation to move away from gas.

Any other business

The next meeting is scheduled for 12 December 2022. Outcomes from the next meeting will feed into the next meeting of the main EESSH2 review group.

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