This report presents analysis of responses to the Energy Efficient Scotland: Improving Energy Efficiency in Owner-Occupied Homes public consultation. The consultation exercise ran from 19 December 2019 to 9 April 2020.
The Scottish Government received 148 responses to the consultation and this report presents the analysis of these responses.
|Category||Number of respondents||Percentage of respondents|
|Building component manufacturers or services||4||3%|
|Energy-related private sector||13||9%|
|Local authority or interagency partnership||10||7%|
|Private landlord or property management||1||1%|
|Professional or representative body||24||16%|
|Public sector or body||2||1%|
|Scottish Government delivery partner||2||1%|
Improving the energy efficiency of buildings in Scotland is an important aim for the Scottish Government, particularly in contributing to priorities around fuel poverty (by ensuring that homes are more affordable to heat) and climate change (by helping to reduce emissions of greenhouse gases).
In 2018, the Scottish Government published the Energy Efficient Scotland Route Map, a 20-year programme aimed at making Scotland's buildings warmer, greener and more energy efficient. The Route Map set out proposals that all owner-occupied homes should reach Energy Performance Certificate (EPC) Band C by 2040, including consideration of a mandatory requirement to reach this standard from 2030. An update to the Route Map will be included in the Scottish Government's draft Heat in Buildings Strategy, which will be published in February 2021.
The Scottish Government conducted a consultation in 2019 to inform further development of the Energy Efficient Scotland programme. The findings of this consultation, together with the increasing focus on the climate emergency, led to the Scottish Government committing in its Programme for Government 2019-20 to publish proposals to accelerate the timescale for improving energy efficiency standards in owner-occupied housing.
Following this, the Improving Energy Efficiency in Owner-Occupied Homes consultation document set out the Scottish Government's proposals for the nature of the proposed standard for owner-occupied homes and for the intention to make this legally-binding from 2024. The consultation invited feedback from the public to help shape plans for improving energy efficiency in owner-occupied housing.
3 Approach to the analysis
The consultation involved a questionnaire with 32 questions, of which 23 were free-text and nine had both a multiple choice and free-text component.
Responses to the multiple choice questions were quantitatively analysed and a breakdown of responses by respondent type and organisation sector is presented in Appendix 1. Responses to the free-text questions were coded into relevant themes and sub-themes and the analysis of these is presented in this report.
The key findings from the analysis are outlined next.
4 Levels of agreement with the proposals in the consultation document
Views on whether there should be a legally-binding standard were mixed, with 55% of those who answered the question agreeing that there should be a legally-binding energy efficiency standard for owner-occupied housing, and 45% disagreeing. Organisations were more likely to support this proposal than individuals.
There were also mixed views about the suitability of EPC Band C as the required standard. A small majority of respondents (54%) agreed that EPC Band C should be the standard required to be met by homeowners. Again, organisations were more likely to agree with this than individuals. However, 46% of respondents disagreed and a substantial number raised concerns about the effectiveness of the EPC including among them half of the professional bodies responding to the consultation.
The balance of opinion was not in favour of 2024 as the date to introduce the mandatory standard. More than half of respondents (62%) disagreed with this proposal, with many stating that it was too early, although organisations (60%) were more likely to be in favour of this start-point than individuals (23%).
A majority (57%) agreed that the point of sale should be a trigger point for a property to meet the legally-binding standard. However, some (43%) disagreed, with concerns that this could negatively impact on the housing market.
Support for the point of major renovation being a trigger point was stronger, with many respondents (72%) agreeing with this proposal. Agreement levels were particularly high among organisations (90%). Views among individuals were more varied (59% agreed), with some concerns about the additional costs being added to already costly renovations.
Many respondents (70%) supported the proposal that, even if a property cannot fully meet the standard, it should be required to get as close as possible to it.
There were mixed responses to the proposal that any exemptions or abeyances from the standard should be time-limited. Overall, 56% of respondents agreed, and organisations (85%) were more likely than individuals (39%) to be in favour of this.
Many respondents (62%) agreed that grant funding from the public purse to support homeowners to meet the standard should be focused on households that are vulnerable or in fuel poverty. Organisations (85%) in particular were mostly in favour of this, although views were more mixed among individuals (46% agreed).
5 Cross-cutting themes
In addition, a number of cross-cutting issues emerged from the research. These are described below.
5.1 The impact on homeowners in rural areas
A recurring theme was the potential negative impact on homeowners in rural areas if the standard were to become legally-binding. Concerns relating to the higher proportion of older properties in rural areas were raised. These included the challenges and costs of getting older properties to meet the standard, difficulties in accessing tradespeople and the fact that many properties in rural areas are off the gas grid. Respondents reported that homeowners in such properties have to consider different solutions in relation to making their home more energy efficient.
5.2 Concerns about vulnerable groups – older people and those in fuel poverty
There was some concern that the financial impact of making costly energy efficiency improvements to meet the standard would affect older people and people living in fuel poverty more acutely. Some respondents noted that these two groups of people were also more likely to be living in properties which were more difficult to upgrade.
5.3 Challenges facing owners of older homes
Many respondents noted the high number of older homes in Scotland which are below EPC Band C currently, and the high costs that could be involved in making the necessary changes to these properties to achieve this rating.
5.4 Need for adequate finance and information to incentivise people to make changes
Respondents noted the need to raise awareness among the public of the benefits of meeting the standard; the finance available to support energy efficiency improvements to be made; and sources of advice, support and technical help.
5.5 Affordability and financial support
There was concern among many respondents that the energy efficiency improvements required to meet the standard could be prohibitively expensive for homeowners. Respondents were widely in favour of financial support being made available, with mixed views about whether this should take the form of loans, equity release schemes, grants or other forms of support.
5.6 Need for changes to the EPC
Many respondents raised concerns about the effectiveness of the metric used to measure energy efficiency within the EPC. Individuals and representatives of professional bodies were most concerned that it was not an appropriate measure of energy efficiency in homes. Some called for it to be revised while others felt that another mechanism entirely should be used.
5.7 Need for compliance to be monitored and penalties to be issued for non-compliance
The need for a robust compliance regime was highlighted as essential if the standard were to become legally-binding. There were mixed views about where any compliance body should sit – with some respondents suggesting this should be the role of local authorities and others calling for an independent body to be set up to ensure compliance.
5.8 Ensuring impartial and appropriate assessments and recommendations
There were mixed views about who should assess a property's energy efficiency rating and provide any advice and recommendations for bringing the property up to the required standard. Some respondents agreed that Domestic Energy Assessors should undertake this role, albeit with some upskilling, while others felt that other professionals such as architects and surveyors would be better placed to take on this role.
Another recurring theme among respondents was the need to ensure that whoever undertakes the assessment provides impartial advice and should not stand to gain in any way from the proposed work.
5.9 National standards
Some respondents emphasised the need for national standards or a scheme for accreditation/approval of installers, potentially backed by statutory bodies to ensure that any energy efficiency improvements made to homes are completed to a high standard.