This is CAS’s response to the Energy Efficiency (Private Rented Property) Regulations 2019. We welcome mandatory standards of energy efficiency in the private rented sector, provided that:
There are no rent increases above the cost of the energy efficiency measure per month over the lifetime of the measure. o Landlords that cannot retrofit their property to EPC C are still required to install all improvements that fall within the £5000 cap, to ensure that all properties are as efficient as possible. o There are technical, cost, and compassionate exemptions for tenants that are too vulnerable to cope with renovations in their home. The compassionate exemption should be attached to the tenant, not the property. o There is a continuation of interest free loans for landlords seeking to make improvements.
We believe that the best trigger point for regulation is landlord registration. As we outlined in our consultation response to Energy Efficient Scotland (March 2019), we believe that point of new tenancy is an opportunity for advice, signposting, and support, not regulation.
The program should be supported by an in-depth program of public information and guidance that encourages and supports early engagement with the regulations.