Elmhurst Draft Response to Scotland's Energy Efficiency Programme Consultation

The Scottish Government is currently consulting on the two aspects of private rented housing in Scotland; firstly the ‘energy efficiency’ and secondly the ‘condition’ of the homes.

Elmhurst is delighted to see the consultation on the energy efficiency of private rented homes in Scotland. We are the largest accreditation scheme for domestic energy assessors in Scotland, and we will be backing our members to produce the necessary information to help support Scottish tenants and landlords to live in warmer and more efficient homes. We are fully behind the Scottish Government in this consultation and will continue our excellent working relationship with the Government to ensure that the least efficient (coldest) homes in Scotland are adequately improved.

Scottish Government Overview

Kelvin Stewart, Minister for Local Government and Housing sums up the consultation as follows:

“Most private landlords are delivering homes to modern standards and many have voluntarily improved the energy efficiency of their tenants’ homes. They understand the need to keep their property in good condition, both for their investment and for the benefit of their tenants. However, it is entirely unfair that there are tenants living in some of the least energy efficient homes in Scotland, who therefore face higher energy bills and are at greater risk of being pushed into fuel poverty.

We are therefore seeking views on introducing a standard for the private rented sector. This will mean that tenants in the least efficient properties will, over time, be able to enjoy the same standard of accommodation as other tenants, making homes warmer and more affordable to heat. Our aspiration is to remove inadequate energy efficiency in properties as a driver of fuel poverty, and these minimum standards of energy efficiency will not only play an important role in helping deliver on our continued commitment to tackle fuel poverty, but also help meet Scotland’s world leading climate change targets.”

 Consultation Headlines

  • The standard will be an EPC band ‘E’ initially (affecting 30,000 properties), and will be raised to a band ‘D’ over time (affecting a further 65,000 properties). With views of further increasing the standard over time
  • Meeting the initial standard of E: the standard will initially apply to properties where there is a change in tenancy after 1 April 2019.
  • Where the EPC shows a band of F or G, the owner will need to have ‘a minimum standards assessment’ carried out and lodged on the EPC register before renting out the property. The owner will have six months from the date of the assessment to carry out the work.
  • Backstop date: all properties covered by the repairing standard would need to meet the energy efficiency standard by 31 March 2022 (the “backstop date”).
  • Raising the standard to EPC D at a later date: similarly properties covered by the repairing standard would meet the higher standard at a change in tenancy after 1 April 2022
  • Doing the work: the owner of the property will be responsible for getting the improvements required by the minimum standards assessment done.
  • Fines: local authorities will have the power to issue civil fines of up to £1,500 against any owner who does not comply with the standard.
  • Exceptions: there will be some situations where an owner is not required to do all the improvements identified in the assessment, or will have a longer time to do so. There will be a cost cap of £5000, and we are seeking views on the existing incentives available to improve the energy efficiency of privately rented properties.

Elmhurst provide a high level response

On behalf of all our members Elmhurst will continue to express its views to Scottish Government on this exciting consultation. We strongly encourage our members to respond to this strategically vital  consultation.

To help form an opinion we have made our high level views available in summary form below as well as a draft response to each consultation question 



  • Elmhurst backs the policy target of stopping families living in ‘F’ and ‘G’ rated private rental homes
  • Elmhurst welcomes the opportunity to involve experiences local energy assessors in giving appropriate advice to improve these cold homes via the EPC and a ‘minimum standards assessment’
  • The Government must build upon the current infrastructures in place, not re-invent the wheel, in order to make the EPC the ‘base’ position, to make informed decisions in terms of the correct measures to be installed on behalf of the family (tenant) and Landlord.
  • The ‘Regulations’ (stick), the ‘Incentives’ (carrot) and the Communication (noise) need to be aligned, clear and easy to understand, with every stakeholder participating at the correct level.
  • The benefits for all need to be communicated well. This is something that Elmhurst have campaigned hard for over 20 years – the EPC is just the start of the journey, the true ‘measure’ of success is bringing families out of fuel poverty and living in warmer, healthier and cheaper to run homes.


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

In order to continue to be open, honest and, vitally independent; we will post our full and final response before the deadline (30th June 2017). We hope that likeminded individuals and businesses respond accordingly.


Stuart Fairlie – Technical Director at Elmhurst Energy concludes; “Elmhurst is delighted to see this consultation and is currently working on its final response, We have high hopes that this is excellent news for the energy assessment industry and it is vital, like all consultations, that we listen to our members and campaign on their behalf.

We believe that this is a vital first step to ensure that all homes in Scotland are warmer and use less energy. The social sector has played its part for over a decade with various standards; but this is a great first step into the private lettings sector.

It is essential that we encourage landlords to do this, by not just hitting them with a ‘stick’ (the regulations), but helping explain that better homes combined with healthier and happier tenants, with lower fuel bills are understood as a mutual benefit. We want to surround the policy with the ‘carrots’, appropriate incentives and funding mechanisms, as well as the ‘noise’ which is often the missing piece in the jigsaw; where all stakeholders disseminate and discuss the relevant information in order to make this a success. This policy is already in action in England and Wales and is making a difference; we welcome the Scottish approach and back our members to provide a great service for families and landlords in Scotland”

Elmhurst's Full Draft response (Q&As)

Link to Full Consultation


Deadline for Responses: Friday 30th June 2017


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