A review of the Scottish domestic EPC reform consultation
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In July 2021, the Scottish Government launched its Domestic EPC Reform Consultation as part of its Draft Heat in Buildings Strategy. In the document's foreword, Michael Matheson, Scotland's Cabinet Secretary for Net Zero, Energy and Transport, stated that "Over the next 24 years we will transform Scotland's homes and workplaces, so they are warmer, greener and more efficient". As part of this ambition, new regulations will be implemented, including reforming the current Energy Performance Certificate (EPC).
The process of reforming domestic energy has been broken down into three stages:
- Stage 1 – Consultation on EPC metrics
- Stage 2 – Develop a process to inform property owners of the steps they should take to meet the required standards
- Stage 3 – Consultation on the proposed regulations, including their impact on people at risk of fuel poverty.
Here we review stage 1, the EPC consultation process.
Additional information on the EPC
The current Scottish EPC contains much detailed information beyond what we have described. The proposal is to maintain this information to provide property owners with all the information they need to make sensible decisions on saving energy. These include:
Recommended measures – the EPC supplies two lists of property owners' potential improvements. These are "Top actions you can take to save money and make your home more efficient" and "Recommended measures". Both show the indicative cost and typical annual or three-yearly savings. The latter list also shows the impact of the measures on energy and environmental ratings.
Summary of the Energy performance-related features – this lists building elements such as Walls, floor, main heating, hot water, etc., their description, and star ratings of their energy efficiency and environmental impact.
Estimated energy costs of your home – this lists heating, hot water, and lighting along with the current energy costs over three years and potential energy costs after taking the recommended energy-saving measures. It also provides total potential savings.
Your Home's Heat Demand states the current heat demand for space heating and water heating, along with the potential impact of loft, cavity wall, and solid wall insulation. You may need this information to apply for Renewable Heat Incentive (RHI) payments.
Context
In December 2020, the Scottish Government published "Securing a green recovery on a path to net zero: climate change plan 2018-2032 update", committing to reduce emissions by 75% by 2030 and net-zero by 2045. Building heating emits 23% of Scotland's greenhouse gas emissions. To achieve these ambitious targets, property owners must change the heating systems in over two million homes.
The previous consultation on Improving Energy Efficiency of Owner-Occupied Homes highlighted the need to change the current EPC process as it is not an appropriate measure of home energy efficiency in its current form. Also, the Climate Change Committee indicated that some aspects of the existing EPC could disincentivise property owners from taking energy-saving measures.
As a result, the Government launched a consultation process to investigate their proposal to reform the current EPC to one that is more useful and includes additional and repurposed metrics.
Energy Performance Certificates
EPCs provide information on the current energy efficiency of properties, measures that could potentially improve this, and an estimated cost of doing so. Energy efficiency and its environmental impact, in terms of CO2 emissions, are graded from A to G with arrows and numeric values to indicate current and potential future ratings. Ratings are calculated using dwelling type, floor area, construction type, insulation, heating, fuel prices, ventilation, and lighting. An energy indicator states the energy required to provide the household with one kilowatt of power.
Under current legislation, property owners must provide an EPC following the construction, sale or letting of a building to a new tenant. The recent consultation concerns domestic dwellings only. EPCs are available on the EPC register website.
Proposal to introduce an Energy Cost Rating, Carbon Emissions Rating, and Energy Use Rating
A problem with the current EPC is that including fuel costs in the calculation could result in a paradox where installing a zero-emissions system could worsen the rating, which does not incentivise people to install zero-emissions heating. To avoid this, the Government proposes keeping the metric but renaming it as an Energy Cost Rating.
For clarity, it is also proposed that Environmental Impact (CO2) Rating (EIR) is rebranded as a Carbon Emissions Rating (CER), though the reported figures will remain the same.
The third proposed change is to introduce an Energy Use Rating to provide additional information on the property's energy use to indicate how energy efficiency measures and heating systems potentially reduce energy use.
In summary, the Government proposes the new EPC format will show:
- Energy Use Rating: showing energy use based on kWh/m2/year.
- Carbon Emissions Rating: carbon dioxide emissions for a dwelling in kg CO2/m2/year (currently the EIR).
- Energy Cost Rating: potential running costs expressed in pounds per year (currently the EER).
