Elmhurst Responds to Scotland's Energy Efficiency Programme Consultation

Elmhurst has today responded to the Scottish Government’s consultation on private rented housing. The consultation is aimed around the two aspects; firstly the ‘energy efficiency’ and secondly the ‘condition’ of the private rented homes.

As mentioned over the past few weeks 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 worst (coldest) energy inefficient homes in Scotland are adequately improved.

Consultation Headlines

The Government wish to set the following standards for private rented homes in Scotland:

  • 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 Summary of Response:

  • Elmhurst backs the policy target of stopping families live in ‘F’ and ‘G’ rated private rental homes
  • Elmhurst welcome the opportunity to involve professional 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 good 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, healthy and cheaper to run homes.


We have received some great feedback from energy assessors and we thank those who took the time to respond to us; we have attempted to include the sentiments of all the feedback into our official response. Allthough the deadline to respond is today (Friday 30th June) we still encourage assessors to respond to the consultation.

In order to continue to be open, honest and vitally independent; we have posted our full and final response below.


Stuart Fairlie – Technical Director at Elmhurst Energy concludes; “Elmhurst are delighted to see this consultation and, 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 world.

It is essential that we encourage landlords to do this, but 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”


Link to Full Consultation:


Deadline for Responses:  Friday 30th June 2017

Link to Elmhursts Full Response:



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