Questions on domestic EPCs
1. Do you agree with the set of metrics that we propose to display on the reformed EPC?
Yes
2. Are there additional metrics that you think should be included on the EPC, or metrics that you do not think should be included?
No
3. Considering our proposal to include a Fabric Rating on EPCs, do think this metric should include domestic hot water heat demand?
No
Current disincentives in EPCs to the adoption of net zero heating system are a core reason for the EPC reform. On balance, the avoidance of creating new disincentives to the adoption of zero emission heating systems is more important than the disadvantages of not including domestic water heat demand in the Fabric Rating section. As highlighted by the example provided “domestic hot water heat demand is affected by the type of hot water system. This means changing the dwelling’s hot water system type could impact the ‘fabric' metric. This is a particular policy concern when moving from a gas combi boiler to an electric system with storage (and consequently adding unavoidable storage losses), such as a heat pump. While this reflects the reality of changing to a system with storage, it could be confusing for an owner to see their fabric rating unexpectedly worsen after installing a net zero compliant system.”
4. Do you have a view on the way that the Fabric Rating mapped against a scale, for example, how ‘A’ or ‘G’ rated performance is determined?
Yes
Linking with the previous system would help to align is with existing policies and make the meaning clear.
5. Do you agree with our proposal to give more prominence to the energy efficiency features of the home (such as the depth of loft insulation)?
Yes
Questions on Non-Domestic EPC
6. Do you agree with the set of metrics that we propose to display on non-domestic EPCs?
Yes
Tailored recommendations to each category of non-domestic building (restaurant etc.) makes sense.
7. Are there any additional metrics that you think should be displayed, or any in the proposed set that should not be included?
No
EPC Purpose and Validity
8. Do you agree with us that the primary role of the EPC should be to provide basic energy efficiency information for the purpose of comparison and act as a prompt to consider retrofit options?
Yes
9. If you disagree or have further comments about the role of the EPC, please provide your comments.
N/A
10. Do you agree that the validity period of EPCs should be reduced from 10 to five years?
Yes
11. We welcome any views on the usefulness of our proposals for other relevant policy areas, such as fuel poverty or the delivery of government schemes. Please provide any comments you wish to share.
Collectively, these changes could simplify access to EPCs and specific signposting to funding while the real time access to the Scottish EPC Register will allow the Council to identify whether a building is in a current or planned heat network zone. It would also make EPCs more up-to-date and reliable which would support strategic planning of heat decarbonisation through Local Heat and Energy Efficiency Strategies.
12. Do you agree with our proposal that EPCs should move from PDF to webpage format?
Yes
13. Do you agree with our proposal to improve signposting to further support and advice schemes on the EPC?
Yes
14. Do you agree historical EPCs should be publicly accessible on the EPC register (while clearly marked as historic)?
Yes
15. Do you agree that the EPC register should be accessible by API?
Yes
16. Do you have any further comments on our proposals to move to a digital and accessible EPC?
No
EPC Auditing and Assurance
17. Do you agree with our proposals to review and update the audit and assurance requirements for EPCs in Scotland?
Yes
18. Please detail any additional assurance activity that you think would be appropriate to enhance the accuracy and reliability of EPCs.
N/A