Scotland’s Energy Efficiency Programme Consultation
The Scottish Government have issued a consultation on the ‘Energy efficiency and condition standards in private rented housing’
The Scottish Government are 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 energy efficient (coldest) homes in Scotland are adequately improved.
Scottish Government Overview:
Kelvin Stewart, Minister for Local Government and Housing states:
“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.”
In Part 1, The Scottish Government state the following intentions through the consultation:
- The standard will apply to privately rented properties covered by the repairing standard.
- The standard will be based on the energy efficiency rating on the Energy Performance Certificate (EPC). 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). We are also seeking views on raising the standard further.
- Point of rental and backstop date: the standard will initially apply to properties where there is a change in tenancy, and then to all properties (known as the “backstop date”).
- 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”). Where a property has an EPC of F or G (and has not already complied with the energy efficiency standard at a change in tenancy), the owner would need to have a minimum standards assessment carried out by 30 September 2021, allowing a six-month period to carry out the required improvements ahead of 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 if they have an EPC energy efficiency rating of D, and this standard would apply to all properties by 31 March 2025. The application of the standard of D at change in tenancy and by the backstop date would work in the same way as for the initial standard of E. Any increase in the standard from 2025 would be considered following future review of the implementation of the initial minimum standards.
- 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 will respond
On behalf of all our members we at Elmhurst will continue to express our views to Scottish Government on this exciting consultation. We strongly encourage assessors to respond to this strategically vital consultation. We will also make our more detailed views and opinions available to assessors over the next few week, to aid industry responses.
We welcome any feedback from assessors, and have created a form for which you can send your consultation response feedback or suggestions to us (click here for feedback/suggestion form).
In order to continue to be open, honest and vitally independent; we will post a considered response in the next week or two, and will also post our full and final response before the deadline (30th June 2017).
Stuart Fairlie – Technical Director at Elmhurst Energy concludes; “Elmhurst are delighted to see the consultation and are currently digesting all of the information it presents. We would encourage assessors to respond to the consultation, and we will be keeping everyone informed of our expert thoughts over the next couple of weeks."
“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 world of the private sector.”
“We need to encourage landlords, not just by hitting them with a ‘stick’ (the regulations), but helping explain that better homes combined with healthier and happier tenants, with lower fuel bills can result in mutual benefit. We want to surround the policy with ‘carrots’ (appropriate incentives and funding mechanisms), as well as the ‘noise’, 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”
Deadline for Responses: Friday 30th June 2017