Next steps in reforming EPCs

At the end of 2022, the Scottish Government published the outcomes of their 2021 consultation on the reform of domestic Energy Performance Certificates (EPCs), including adding a new metric and renaming the scheme.  Forming part of the Scottish Heat in Buildings Strategy, the consultation built on the principle that high-quality advice and information are critical for guiding householders' decisions to improve the energy performance of their homes.

·         The Energy Efficiency Rating (EER) is based on both delivered energy and fuel prices, to provide an energy efficiency rating of a property.

·         The Environmental Impact Rating (EIR) is based on carbon emissions and is a measure of the home's impact on the environment in terms of carbon dioxide emissions.

The consultation proposed to add a third measure, the Energy Use Rating, which would provide additional information and can be assessed using information already collected in the EPC assessment process.

The new measure is proposed because the inclusion of fuel prices in the EER could mean that installing a zero-emissions system could lead to a worsening of the rating, e.g. mains gas heating systems may achieve a better EER than a zero emissions heating system in an equivalent building. As such, the current EPC framework is not compatible with incentivising the uptake of zero emissions heating. The consultation also proposed to rename the EIR as the Carbon Emission Rating to provide greater clarity on its meaning.

Retaining information about the impact of potential improvements to the property on energy consumption was also proposed and asked how the data in an EPC should be presented.

Responses to the consultation were broadly supportive of the proposals, with the new measure of energy use well received. However, some respondents favoured a metric based on energy demand, rather than use.

A consensus about the need for EPCs to provide clear, simple, and useful information to users is paramount, and some technical issues with the measurement methods were also raised.

The Scottish Government initially advised there would be three stages of consultation on EPCs. Following a review of consultation responses, further research, and a wider consideration of heat in buildings policy, the structure of the Scottish Government's planned consultation has been modified. Stages two and three of the EPC consultation, and the Scottish Government's policy position will be provided in a planned consultation on a proposed regulatory framework for heat and energy efficiency. This consultation is due to be published sometime in 2023.