Heat and Energy Efficiency Technical Suitability Assessment (HEETSA): scoping consultation

1. Introduction

1.1 Background

The Scottish Government is committed to ensuring that emissions from heating our buildings fall in line with net zero by 2045. We also want them to achieve a good level of energy efficiency. We want to do this in a way that is fair and which reduces fuel poverty. This will require collective action from government, from building owners and from the supply chain as our existing building stock is progressively retrofitted with clean heating systems and energy efficiency measures over the next two decades.

The Scottish Government’s Heat in Buildings Programme is taking action to provide advice, support, and funding to building owners and tenants on retrofitting their properties. It will also see us introduce new legislation which will underpin that action, to give certainty and set the framework for investment. That legislation will include:

• introducing a Heat in Buildings Bill to set a target for decarbonising heating systems by 2045; to create powers to set minimum energy efficiency standards for owner occupier and non-domestic properties; and developing particular requirements for large, non-domestic premises, including powers to require public sector buildings, to connect to district heating when available;
• progressing regulations under the Energy Act 2011 to introduce a minimum energy efficiency standard (MEES) in the private rented sector (PRS). These regulations would mean all privately rented properties, as far as possible, achieving a Heat Retention Rating of Band C on the reformed Energy Performance Certificate (EPC);
• laying regulations under the Energy Act 2023 to introduce reformed EPCs, which will introduce a new rating system for domestic and non-domestic properties to give improved information on a property’s energy efficiency, and the emissions and performance of its heating system.

For social housing, the Scottish Government continues to work with the social housing sector and stakeholders on the introduction of a Social Housing Net Zero Standard, using existing powers of the Scottish Housing Regulator. This standard will replace the second iteration of the Energy Efficiency Standard for Social Housing (EESSH2).

The Scottish Government recognises that when these new legislative and regulatory requirements are introduced, building owners and tenants will want to understand the specific impacts for their properties, especially where regulations could require them to take action. That means that building owners will normally want to seek the opinion and advice of experts before committing to retrofit new heating systems or energy efficiency measures.

Those experts will often be advisers in Scottish Government-supported advice programmes like Home Energy Scotland or Business Energy Scotland, or those working for a local authority overseeing an Area-Based Scheme (ABS) or national programme such as Warmer Homes Scotland. They will often be building professionals such as surveyors or architects, or installers working in the supply chain, such as heating system engineers. For many, their first point of contact will be an EPC assessor conducting an assessment of their building as part of generating a Home Report or producing an EPC when a property is to be advertised for let.

This consultation focuses on the role that assessment can play in supporting building owners seeking to improve the energy efficiency of, and reduce the emissions from heating, their property. It proposes that a Heat & Energy Efficiency Technical Suitability Assessment be established as an optional additional step ‘beyond the EPC.’ This assessment could be used in circumstances where it would be beneficial to building owners to have additional information on which energy efficiency measures and clean heating systems would, or would not, be appropriate for their building.

Our proposals focus only on the assessment process itself – the methodologies used and the skills and qualifications of the practitioners. They do not cover the subsequent installation of measures, where there are already existing quality assurance schemes such as the Microgeneration Certification Scheme (MCS) for the installation of renewable heating systems and TrustMark for the installation of energy efficiency measures.

We are therefore scoping the design of HEETSA to focus on the assessment of dwellings for retrofit, and the identification and evaluation of improvement options. We are not proposing that it would cover the design and specification of measures or the monitoring and evaluation of projects. This would be in line with parts a) and b) of the PAS 2035 typology^[7].

HEETSA would enhance part (b) of the PAS 2035 typology by also including assessment of clean heating system technical suitability.

We recognise that there is an end-to-end consumer journey from the initial point of assessment and receipt of retrofit advice, through to installation of measures, and then subsequent evaluation and inspection of their performance. We are seeking views on the relationship between our proposals for HEETSA and the subsequent installation and evaluation of any improvements recommended by a HEETSA.

Relationship with the EPC

For most building owners and tenants, and for many Scottish and UK Government programmes, the EPC acts as the first point of information on the building’s current energy performance. The reforms we are making will ensure that the EPC sets out clearer and more relevant information on the building’s current and potential contribution to net zero. These will include a new rating on domestic certificates, setting out information on the emissions and efficiency of the current heating system and giving information on alternative, non-polluting heating systems. There will also be a new rating for heat retention, which will consider installed energy efficiency measures, and how these might potentially be improved.

The Scottish Government Response to our EPC Reform consultation^[8] set out that we recognise the limits to the information an EPC assessment can tell a building owner – i.e. that it can give them factual information about elements of the building which require further investigation, before a decision is taken to act. This reflects the fact that an EPC is a standardised, non-intrusive assessment, which cannot be a substitute for a more detailed technical survey. This is particularly important when determining which measures are suitable (or unsuitable) for buildings which are more technically complex or harder-to-decarbonise, such as traditional and protected buildings or tenements.

The Government response therefore set out that we:

• ‘proposed that EPCs act only as basic evidence to support compliance with mandatory standards, and to provide an initial signpost towards more detailed assessment and technical advice where needed’;
• ‘proposed to develop an additional form of assessment beyond the EPC – a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA). This could be used to evidence flexibility needed for such buildings to comply– i.e. for exemptions or variations to mandatory standards – and to ensure that any measures installed are technically suitable’;
• ‘have listened carefully to stakeholder feedback on the limits to the role of EPC recommendations and on the need to protect consumers against any risk of installing measures that are not technically suitable for the building. We have begun work to review current retrofit assessment methodologies, with a view to endorsing existing frameworks, or developing new processes if required. We have proposed to develop a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) which would approve both retrofit assessment methodologies and retrofit assessors which are capable of providing more detailed technical advice beyond the EPC. We will set out further information on our decision on how to approach HEETSA in the response to the consultation on proposals for a Heat in Buildings Bill.’

This Scoping Consultation now meets that commitment to set out further information on our decision on how to approach HEETSA.

The graph depicts the decision-making process for HEETSA and other retrofit stages. At the top the text says HEETSA assessment decision making route. Blue boxes identify 3 stages of retrofit process. Stage 1 of Retrofit assessment is to identify building type, location and context and customer priorities through on-site assessment and interview. This leads to footnote I - Including consideration for local planning constrains, listing, building condition, funding, future penalties (current and future regulatory context, such as social landlord’s requirements to meet EPC band B). Arrow leads to the next stage. Stage two of retrofit assessment is split into two areas: select appropriate methodology such as PAS2035, EnerPHit, AECB, etc. This leads to a footnote 2 reading: Selected methodology should be supplemented with relevant guides such as Historic Environment Scotland (HES) guide to retrofit of traditional buildings where appropriate. Arrow leads to next step of stage 2 of retrofit assessment that requires to select appropriate performance verification and option evaluation tools such as PHPP, RdSAP, HEM, WUFI. Footnote 3 reads: The assessment and evaluation tools are valuable aids in informing what options may be available and the assessor to be trained in their use and the interpretation of their results. This leads to preparation of Retrofit Plan.

Stage 1 and 2 of retrofit Assessment is Governed by SG. Footnote 4 reads: Governed by the Scottish Government (SG) with independent verification and with the aim of protecting public interest. This could be within the powers of the Building (Scotland) Act, the Energy Act 2023 or others, and is yet to be determined.

Stage 3 of the Retrofit Assessment is the validation of results, follow up with homeowner/ tenant and is achieved post completion.

Source: Independent Review of HEETSA^[9].

1.2 Purpose and Objectives of this Consultation

The purpose of this Scoping Consultation is to set out the Scottish Government’s initial proposals for the scope of a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) and seek stakeholder views on:

• the overall concept of HEETSA and how it relates to the EPC and other parts of the heat and energy efficiency retrofit landscape;
• current assessment methodologies that could be used to underpin HEETSA and how potential gaps in the market could be filled;
• the skills, qualifications, and accreditation processes that would be needed to ensure that assessors were able to offer detailed advice to building owners on technical suitability of heat and energy efficiency retrofit measures;
• the circumstances in which HEETSA could be needed, how it could support proposed legislation and regulations for clean heat and energy efficiency, and what, if any, legal basis it should have.

The Scottish Government’s objective in making these initial proposals is to safeguard consumers by developing a technical suitability assessment which ensures that building owners can:

• understand which measures are appropriate, i.e. identify the ‘right’ measures when improving their energy efficiency and changing their heating systems – those which are technically appropriate for that building;
• understand which measures are not appropriate, i.e. be aware of the ‘wrong’ measures – energy efficiency measures which could create further problems such as dampness, mould, or condensation; or clean heating systems which are insufficiently sized to maintain warmth

Our aims in these proposals are therefore:

• that all building owners have a trusted and recognised route to access the highest quality assessment of the technical suitability of their buildings to receive clean heating systems and install energy efficiency measures (including information on when it would not be appropriate to do so);
• that building owners have access to an additional assessment, beyond the EPC, which can help support their compliance with, or exemption from, mandatory standards – in particular in more complex-to-decarbonise buildings such as traditional and protected buildings, those in tenements, or those in rural areas^[10] ;
• that the methodologies used to undertake such assessments have been properly quality-assured and approved as being fit-for-purpose;
• that the assessors undertaking such assessments are properly skilled, qualified, and capable of offering technical advice;
• that wherever possible, HEETSA will act as an additional safeguard to protect consumers by reducing the potential risk of building owners installing energy efficiency measures which would be technically inappropriate, which could then cause subsequent problems such as condensation, damp, or mould; or clean heating systems which are insufficiently specified to be able to heat the building effectively.

The outcome we are seeking is for all buildings to be able to achieve a good level of energy efficiency in a way that is most appropriate for that building, and to transition to the clean heating systems that are the most suitable, taking into account the building’s unique characteristics (its construction, location (potentially utilising analysis from Local Heat and Energy Efficiency Strategies) and condition) and potentially also occupants’ behaviour.

Our proposals have been informed by stakeholder responses to both the EPC Reform consultation in 2023, the Heat in Buildings Bill consultation in 2023-24, stakeholder workshops during summer 2024, and an independent research project undertaken for the Scottish Government during 2024-25, which is published alongside this scoping consultation, and which we acknowledge has informed our proposals.