Elmhurst Draft Response to Consultation on the Scottish EPC Register

Inside this recent consultation by Scottish Government, there is disappointing news that the statutory lodgement fees for lodging data onto the Scottish Register are proposed to rise by 126%!  The proposed fee Increase breakdown: 

Certificate Type

Current Charge

Proposed Charge


% rise






Non Dwellings





Elmhurst wishes to express its surprise and concern at this proposed increase and that we will respond appropriately on this matter on our members behalf. Not only are the increases to fees extremely excessive, Elmhurst does not believe these rate changes are in line with any normal inflationary increases.

Ultimately Scottish Government know that Energy Assessors have only one national Register in which to lodge i.e. a monopoly, and therefore have no alternative. We at Elmhurst are extremely disappointed to hear this proposed  fee scales.

Reason’s for the increase

The consultation highlights that the revenues received in income for the ‘not for profit’ register do not meet the costs. The Government have produced the following table, which indicates that the operation of the register has been losing money over the past 3 years:

The income has also been hampered by the reduced number of lodgements going into the Register:“Annual EPC lodgement for the past three years has fallen by approximately 27% for domestic buildings and 9% for non-domestic buildings.

Scottish government have also provided the following comments to support their decision to increase the Register Fees:

  • The statutory fee remains a small component in the overall cost of an EPC assessment;
  • Scottish building owners were not charged a lodgement fee prior to October 2012, fees have remained the same or lower than the rest of the UK since that date; and
  • The current Keeper of the Scottish Register is a social enterprise and the register is run on a not for profit.

Elmhurst’s Draft Response to Consultation

The main issue is that the energy assessors themselves are funding lots of activity on behalf of the Government and policy direction; and whilst we all back that Energy Certificates should be the backbone of sensible choices and benchmarking; the benefits that the register bring to the Government and policy moving forward are not catered for.

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.

There are 3 consultation Questions and Elmhurst have attempted to answer these at a high level to allow assessors to use these as appropriate responses (if they wish).

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 of the Scottish Register storing EPC data are adequately catered for. 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. 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. This will have a threefold benefit, the register will see more lodgements, hence becoming more profitable, and energy assessors will get out there communicated to members of the public about energy efficiency, through homeowners and tenants. Landlords and business owners will have documents that they can rely on to make better choices. This move should be irrespective of this consultation.
  2. The Register at its heart is a data repository, with KPI reporting functions. There is currently a duplicated register in England & Wales, Northern Ireland as well as Scotland. The infrastructure spent of 3 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. It needs to be clear that they need to be more efficient and make similar savings to the hard working energy assessors that have no other choice than to lodge into it. Elmhurst has competition, assessors have competition, but the register doesn’t appear to. 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 consulting on.
  4. Elmhurst also received over 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.

Next Steps

On behalf of all energy assessors we at Elmhurst will continue to express our views to Scottish Government on this proposed price hike. We strongly encourage assessors to respond to this important consultation. We have made our more detailed views and opinions available to each question and next week we will publish our final response; we hope this helps likeminded individuals and business to respond appropriately.

We have already received some great feedback from our members this week and we welcome any more thoughts from our members; to help we have created a form for which you can continue to send your consultation response feedback or suggestions to us.


Full Consultation:


Deadline for Responses: Monday 19th June 2017

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