The National Insulation Association (NIA) published its response to the Scottish Government's Energy Performance Certificate reform consultation on 18 October 2023, two days after the consultation closed on 16 October 20231. The association describes itself as representing the insulation industry in Scotland and across the UK, with members drawn from installers, system certificate holders and manufacturers1.
On the domestic proposals, the NIA said it agrees with the set of metrics the Scottish Government proposes to display on the reformed EPC, and welcomed a separate fabric rating as a headline metric1. It argued that the fabric rating should not include domestic hot water heat demand, on the grounds that this risks making the metric more complex and could dilute the focus on fabric measures1. It also said the new fabric rating scale should be aligned with the current EER rating system, so that continuity is kept with policy commitments and targets based on EER bands, in particular Band C1.
The association supported reducing EPC validity from 10 years to five, saying it agreed in principle, and noted the Scottish Government has set a target for all homes to reach EPC C by 20331. It warned that the change would require more skilled energy assessors, and pointed to the Home Decarbonisation Skills Training Competition in England, now in its second phase, as a model it would like replicated in Scotland1. It also backed giving more prominence to energy efficiency features such as loft insulation depth, a webpage format for EPCs, and including the EPC register in an application programming interface so stakeholders can access historical data through the year1.
On non-domestic EPCs, the NIA disagreed with the proposed metric set, calling for fabric rating to be added as a headline metric there too1. It cited the Climate Change Committee's 2023 Annual Progress Report to Parliament, which it said highlighted non-residential buildings as an area of concern1.
"There is a large and increasingly concerning policy gap relating to non-residential buildings."
On installer choice, the NIA said the requirement for installers to be Green Deal certified can be a barrier, and that customers accessing HES funding should be allowed to use a Green Deal, Trustmark or NIA registered installer1. It also agreed in principle with proposed changes to the auditing process, saying smart auditing would allow automatic triggers for EPCs meeting certain criteria, and agreed with the proposed timeline on the grounds that it gives stakeholders and homeowners a grace period1.
| Proposal | NIA position |
|---|---|
| Domestic EPC metric set | Agrees1 |
| Fabric Rating including hot water heat demand | Does not agree1 |
| Fabric Rating scale aligned to EER bands | Supports1 |
| Non-domestic EPCs including fabric rating | Calls for it to be added1 |
| EPC validity cut from 10 to five years | Agrees in principle1 |
| EPC register API access | Supports1 |
| HES funding installer options | Wants Green Deal, Trustmark or NIA registered installers1 |
Why it matters for households
A fabric rating shown separately on an EPC would tell a householder how well insulated the property is, distinct from how it is heated or what it costs to run. The NIA's argument is that keeping hot water demand out of that figure keeps the measure focused on the building shell, which is the part of a home's performance that fabric measures such as loft, wall and floor insulation change. For a home's energy independence, that distinction matters: a well-insulated shell reduces how much energy is needed in the first place, whatever the heating source.
Shortening EPC validity from 10 years to five would mean ratings reflect the current state of a property more often, which affects homeowners, buyers and anyone planning work. The NIA's caveat is that this depends on there being enough trained assessors to carry out the extra surveys, and it says no equivalent to the English skills funding exists in Scotland1. The call on HES funding would widen which registered installers a householder can use for grant-funded work, which the NIA links to more options and better value for money1.
What happens next
The consultation closed on 16 October 20231. No date for the Scottish Government's response to the consultation, or for any resulting legislation, has been reported1.