Elmhurst responds to the consultation on the Scottish EPC Register

Elmhurst has responded to the consultation on the Scottish EPC register.

The headline in the consultation is that the statutory lodgement fees for lodging data onto the Scottish Register are proposed to rise by 126%!  If agreed by Scottish Government the proposed fee increase would be as below: 

Certificate Type

Current Charge

Proposed Charge

Increase

% rise

Dwellings

£1.15

£2.60

£1.45

126%

Non Dwellings

£5.35

£12.10

£6.74

126%

Elmhurst and its members in unison, express surprise and concern at this proposed increase. The increases to fees are extremely excessive and are in no way aligned with any normal inflationary increases.

Elmhurst’s welcome member’s feedback

We notified all Scottish assessors about the consultation, and indeed last week, we publicised our draft response to the Consultation questions. We were pleased to receive lots of great feedback from members agreeing with the sentiments and adding their professional thoughts and ideas to the consultation response. We trust we have captured the essence of all of these into our considered response.

Elmhurst Comment

Stuart Fairlie, Technical Director of Elmhurst commented:

"We thank the members who took the time to let us know their thoughts on this. We campaign hard for energy assessors and we think that the consultation is a little too one sided. It very much concentrates on the fees associated with lodgements of energy certificates, and doesn’t cater for the huge benefits that the data means to Scotland and the Scottish Government in terms of policy direction, now and in the future. We also want to see clear analysis of the breakdown of costs associated to the Register, to ensure that a fair balance is consulted on in terms of costs as well as anticipated revenues.

We strongly believe that the fee increase is out of line with any inflationary measures, and many of our members will find it a tough financial burden to take. We hope that Government reflect on our suggestion and share the cost of the register, as well as rigorously look at cost saving efficiencies on the provision of the register itself.

Moreover, we feel that reducing the EPC lifetime to 3 years will not only improve lodgement numbers, and increase revenue for the Register; but will also provide more accurate data to allow Scottish Families and Government to make better informed decisions regarding  warmer and cheaper to run homes and businesses, moving forward. Overall, Making Energy Certificates valid and up-to-date will encourage them to be used to drive energy efficiency in Scotland.

We continue to work well with Scottish Government and we look forward to the response of this consultation.” 

Conclusion

On behalf of all energy assessors we at Elmhurst will continue to express our views to Scottish Government on this proposed price hike. We continue to encourage assessors to respond to this important consultation and there is still time for assessors to respond to the consultation (deadline on 19/06/17). We have made our detailed views and opinions available to each question (below).

Official Consultation Response

There are 3 consultation Questions and Elmhurst have answered as below:

Question 1

Do you support the continuation of the funding approach introduced in 2012 - that the operation of the SEPCR be self-financing, supported primarily by the statutory fee levied on each lodgement of energy performance data?

No, we at Elmhurst want to see the benefits to the wider audience who are storing EPC data onto Scottish Register. A plethora of policies and engagements are used when the basis of an EPC is created. Yet these industries do not pay for the data set. We all agree that it is fair for the energy assessor to pay for some of the register functionally – but not its entirety. The benefits of the Register are also stated in the consultation where it states;

“The SEPCR now provides a rich source of data on the energy performance of our existing building stock. The Scottish Government has designated energy efficiency as a National Infrastructure Priority, the cornerstone of which will be Scotland’s Energy Efficiency Programme (SEEP) – a 15 to 20 year programme. The Programme for Government commits to investing more than half a billion pounds to SEEP over the next four years, setting out a clear commitment to develop this programme with substantial annual funding.

By 2035, SEEP will have transformed the energy efficiency and heating of Scotland’s buildings so that, wherever technically feasible, and practical, buildings are near zero carbon. An effective and well-resourced register of energy performance data is integral to that process – helping to target improvements as well as tracking progress”.

Government has also been able to provide platforms for a myriad of different policies in the built environment and lists the Home Report, the Energy Efficiency Standards for Social Housing, Section 63 of the Climate Change Act, Green Deal, Feed in Tariff, Renewable Heat Incentive, Energy Company Obligation, and Minimum standards of energy efficiency in the private sector. All of these policies are not possible without an EPC, therefore we believe that they could play their part in funding mechanism, not just solely the energy assessor.

We are extremely disappointed with the level of fee rises being proposed. We would also ask, have the predicted increase in EPCs (which all the new policies require) been catered for in the projection of EPC lodgement revenue?

Question 2

Do you support the intent to review the lodgement fee on an annual basis to ensure that charges are set at the minimum level needed to cover operational costs?

As above, we feel it should not be solely the energy assessors who pay for the register. If the lodgement fee is to be reviewed annually in an effort to stop enormous hike in fees, this may be a good idea. Business models can be better adapted with more certainty. Sensible contributors would prefer this approach, as long as there was a long lead in time, and all the numbers and projections were made more accessible.

We would also ask that a breakdown for the costs of operating the register were provided during the consultation, in order for both the costs and revenues to be consulted on together. This will provide further assurance that the costs were being analysed with the necessary vigour, rather than being disregarded in favour of a prise rise to energy assessors alone.

We would also like to see competition in the Register provision so that they provide the service at the best cost and quality.

Question 3

Please use this question to provide any other commentary or observations you have on the current funding of the Scottish Energy Performance Certificate Register. Where practical, please provide examples or evidence to support the issues you raise.

1. EPCs life spans should be moved immediately to 3 years not 10. The EPC is not a useful document unless it is up to date. Reducing the validation period of an EPC will yield plenty of benefits:

  • The register will see more lodgements, hence becoming more profitable
  • Energy assessors can effectively communicate information about energy efficiency to members of the public, through homeowners and tenants
  • Landlords and business owners will have documents that they can rely on to make better choices.

This recommendation should be considered irrespective of this consultation.

2. The Register at its heart is a data repository, with KPI reporting functions. There are currently three EPC registers in operation accross the UK (England & Wales, Northern Ireland and Scotland), each providing similar, if not, identical functionality. The infrastructure spent on three separate registers could be cheaper if consolidated. The ‘data’ can be ring fenced so that Scotland and the other regions can be kept separate for political reasons, but the cost savings alone would make the register significantly cheaper to run.

3. The Register provider needs to be in a competitive world. Elmhurst has competition, assessors have competition, but the register doesn’t appear to. Assessors currently have no choice but to lodge through this central register. This is not a good model to ensure a level playing field. We advocate that if the revenues are to be part of a consultation, then the associated costs must be fairly outlined so that value can be ascertained and indeed consulted on. 

4. Elmhurst also received many responses from energy assessors all over Scotland and the overriding response was one of shock and a consistent message that the price rises will mean that they will find it hard to continue providing EPCs. The costs of producing these documents linked to the extremely low market price for them, and with this impending price rise, will put many people out of this business. These warnings need very careful consideration by Government, as we all want to increase the value of EPCs not decrease them.

Many individuals, as well as small and medium sized companies will be hit hard by this. As described the volume of EPCs is falling, therefore the revenue for these hard working assessors is similarly falling. They will also be signed into contracts over the longer term, effectively locking them into the fee rise, which they will just have to absorb. 


Full Consultation:

https://consult.scotland.gov.uk/local-government-and-communities/scottish-energy-performance-certificate-register/

Deadline for Responses: Monday 19th June 2017

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