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Scottish Government publishes analysis of domestic EPC reform consultation

The Scottish Government has published its analysis of responses to a 2021 consultation on reforming domestic Energy Performance Certificates, with broad support for new ratings on cost, carbon and energy use.

A newspaper on a kitchen table beside a model of rules and regulation

The Scottish Government published the analysis summary report of its domestic Energy Performance Certificate reform consultation on 24 August 2022. The consultation ran from July to October 2021 and set out proposals intended to enable EPCs to support planned regulations under the 2021 Heat in Buildings Strategy1.

The central proposal was to add a new metric of energy efficiency based on the amount of energy a dwelling uses, to be called an Energy Use Rating. This would sit alongside the existing Energy Efficiency Rating, which the government proposed to rename an Energy Cost Rating to reflect that it is based on running cost. The Environmental Impact Rating would be retained and renamed a Carbon Emissions Rating1.

The report sets out the current and proposed metrics as follows1:

Current metricsBasisProposed metricsBasis
Energy Efficiency Rating (£)Running cost (£ per m2)Energy Cost RatingRunning cost (£ per m2)
Environmental Impact RatingEmissions (kg CO2e per m2)Carbon Emissions RatingEmissions (kg CO2e per m2)
Energy Use RatingDelivered energy (kWh per m2)

The report states that respondents broadly agreed with the proposals, with strong support for a new metric reporting energy efficiency based on energy use. Some respondents suggested a metric based on demand, rather than use, would be more appropriate. Respondents supported renaming the existing metrics, but stressed the need for EPCs to provide clear, simple and useful information, and noted that issues in the underlying methodologies needed to be addressed. The government said it would take these concerns into account as it develops detailed proposals1.

"Respondents broadly agreed with our proposals. There was strong support for the introduction of a new metric to report energy efficiency based on energy use."
Scottish Government, Heat in Buildings strategy - domestic EPC reform consultation: analysis summary report1

Why it matters for households

An EPC is the document that records how a home performs, and it is the reference point for regulations that set minimum standards. The proposed split into three separate ratings would change what a certificate tells a householder: cost, carbon and energy use would each be reported on their own scale rather than through the single Energy Efficiency Rating in use now1. For a home's energy independence, the Energy Use Rating is the notable addition, because it would report delivered energy in kWh per m2 rather than running cost in pounds, separating how much energy a property consumes from what that energy costs1. The report does not set out how the ratings would be calculated in detail, and the underlying methodology questions raised by respondents have not been resolved1. The EPC Regulations and the Reform of Energy Performance Certificates guide covers the wider reform programme, and Scotland's Housing Stock and EPC Ratings sets out the profile of Scottish homes these ratings apply to. Energy and buildings policy is devolved, as explained in Energy and Buildings Policy in Scotland: Devolved Powers Explained.

What happens next

An updated policy proposal will be set out in a further consultation on the proposed regulatory framework for heat and energy efficiency outlined in the Heat in Buildings Strategy. The report states that this consultation is due to be published within the next year1. No date has been reported.

Sources1 cited
  1. Heat in Buildings strategy - domestic EPC reform consultation: analysis summary report - gov.scot, gov.scot