Fair and accurate energy efficiency tests for housing are essential

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Helping homeowners to reduce environmental impacts and continue the fight against climate change must be at the core of new owner-occupied housing standards says Scottish Land & Estates (SLE), the organisation which represents landowners and rural businesses.

In its response to the Scottish Government’s consultation on “Improving Energy Efficiency in Owner Occupied Homes”, SLE has said that the disparity between Energy Performance Certificates (EPCs) and lowering carbon emissions is a barrier to homeowners implementing the required energy efficiency changes which can help Scotland achieve net-zero emissions by 2045.

Stephen Young, Head of Policy at Scottish Land & Estates said: “Our members are fully supportive of the Scottish Government’s aim to improve Scotland’s housing stock and keen to continue to play their part. 

“EPCs were originally created to give a quick, simple and relatively cheap method of reporting energy efficiency levels of houses to the European Commission. However, the methodology used to generate the Energy Efficiency Rating (EER) of EPCs is simply not fit for purpose, especially regarding traditional rural buildings and rural housing with off-grid heating. 

“We believe that the continued use of the EER as the primary measurement is problematic if we want to increase energy efficiency whilst simultaneously decreasing environmental impacts. We recommend that consideration is given to using the Environmental Impact Rating (EIR) as the main measurement, as it refers specifically to carbon dioxide emissions, and using the EER as the secondary. This will be crucial to Scotland’s ability to meeting the net-zero target for 2045. 

“In order to know what is achievable and how we can make progress, it is essential that we have an accurate picture of the energy efficiency levels of homes across Scotland. Many houses in Scotland will currently be below an EPC Level E. Expecting these properties to reach EPC Level C, without significant invest in both the property and the construction industry, is unrealistic and unaffordable. 

SLE is also calling for a more realistic timeframe for implementing these changes. A significant amount of work is required for the proposed changes to be successfully rolled out, and the four-year window could make the process rushed and lacking in critical oversight. 

Read SLE’s full consultation response online