ESPC says Scottish Government’s EPC ratings plan “practically impossible”

Paul Hilton (ESPC)

ESPC fears the Scottish Government’s plans for new Environmental Performance Certificates (EPCs), whilst well intentioned, may in some types of property be impossible to achieve.

In the current system of Environmental Performance Certificates (EPCs) the most prominent metric is the Energy Efficiency Rating for the dwelling. The EER provides a banded rating from A (the  most efficient) to G (the least efficient) and a 1-100 rating based on the cost to run the dwelling (normalised to the floor area).

The Scottish Government intends to change that, creating three new headline metrics for EPCs:

  • Fabric Rating
  • Cost Rating
  • Heating System Type

(More information is available in the notes to editors below.)

Following the proposed changes to EPCs the government intends to bring in a wider Heat in Buildings Bill, which would require all homes to meet a minimum fabric energy efficiency standard equivalent to EPC C by 2033 and to prohibit the use of direct emissions heating systems (like gas boilers) in domestic and non-domestic buildings by 2045. 

For context, there are 2,610 properties currently for sale on 1,192 (46%) currently have an EPC rating of “C” or better.

For many properties and householders achieving the “C” rating or better will be difficult for both logistical and financial reasons. ESPC would like the government to work with the industry on a number of issues:

  • The possibility for exemptions from the ban on direct emissions heating systems for certain types of buildings, for example some tenement flats and some properties in conservation areas or in heritage sites.
  • Greater financial support to help purchase and install heat pumps.
  • Discussion of a wider suite of options to help move Edinburgh and Scotland’s varied housing stock closer to net zero.

Paul Hilton, CEO of ESPC, said: 

“We are in agreement with much of what the Government is proposing.

“The new EPCs will make it easier for buyers to evaluate how much they’ll be likely to spend on heating the home they’re thinking of buying, and we agree that the move toward zero direct emissions heating systems will help reduce carbon emissions.

“However, we need to be more aware of the unintended consequences of the proposals. The installation of ground or air source heat pumps will be expensive and logistically difficult in many properties. In some tenement flats, for instance,  it will be practically impossible. 

To take Edinburgh as an example, around two-thirds of the city’s housing stock is flats, and many of those will be in one of the city’s two UNESCO World Heritage Sites, which in many cases will make it even harder for people to convert their heating systems.

“That, in turn, means that the C rating the Government wants all properties to reach will be unachievable in many cases, with potentially severe implications for people wishing to sell those homes.”

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