Energy Systems Catapult submitted its response to the Scottish Government's consultation on Energy Performance Certificate reform on Monday 16 October 20231. The response was prepared by Fay Holland, Senior Energy Policy Advisor at the Catapult1.
The Catapult said it agrees that the current EPC system needs reform to drive the changes needed in the buildings sector to reach Net Zero1. It proposed an alternative set of outcome-focused primary metrics: Energy Efficiency, Climate Impact and Energy Cost, which it said would better support householders' decision-making and allow policy makers to target their interventions1.
"We have concerns about the Heating System Type metric dampening innovation in the development of low carbon heating technology as it would not distinguish between the most and least efficient models within a 'type'."
The Catapult also said it supports proposals to move towards a digital and accessible EPC register, and that in the long term it would like to see a "live" EPC, updated whenever changes are made to the fabric or heating system1. It encouraged the Scottish Government to further explore the development of Green Building Passports1.
The submission followed a separate response from the Catapult on proposed amendments to the Boiler Upgrade Scheme regulations, submitted to government on Thursday 12 October 20232. That response, drafted by Fay Holland and Katrina Young, Practice Manager for Heat and Local Energy Policy, addressed proposed changes by the Department for Energy Security and Net Zero2. The Catapult said the proposal to enable government to differentiate grant levels for different types of property or property owners is sensible, as it would allow the scheme to be adjusted to changes in the heat pump market as it develops2. On insulation, it said that encouraging property owners to invest in insulation is important, but that on balance the requirement not to have outstanding EPC recommendations for loft or cavity wall insulation could be removed without risking the installed heat pumps being ineffective2.
Why it matters for households
EPCs are the documents that record how a home performs and, increasingly, the benchmark that government schemes and lenders use to judge a property. The metrics an EPC reports therefore shape what a householder is told about their home and what work is treated as worthwhile. The Catapult's argument is that scoring a home on the type of heating system it has, rather than on how that system performs, would not separate the best and worst models within a category1. Its proposed metrics, Energy Efficiency, Climate Impact and Energy Cost, would report outcomes rather than categories1. For a household considering a heat pump or other low carbon heating, the difference is between a certificate that describes the equipment installed and one that describes what it costs to run and what it emits. The Catapult's support for a digital register and, eventually, a live EPC updated when fabric or heating changes, points to a record that tracks a home as it is improved rather than a snapshot that ages1. The separate Boiler Upgrade Scheme response concerns grant conditions in England, Wales and Scotland, where the Catapult backed removing the requirement for no outstanding loft or cavity wall insulation recommendations2. How the Scottish Government will weigh the responses has not been reported.
What happens next
The Scottish Government consultation closed to responses on 16 October 20231. No date for publication of the government's response or for any resulting changes to the EPC system has been reported1.