CAS welcomes the ambition of the Scottish Government to bring every owner-occupied home in Scotland to Energy Performance Certificate (EPC) band C. This will not only increase the energy efficiency of Scotland’s housing stock, but also reduce carbon emissions and alleviate fuel poverty. We believe a warm, dry, energy efficient home that is affordable to heat should be the standard in Scotland, not a privilege.
To this end, we cautiously support mandatory regulation for all owner occupiers. This is likely to be a crucial part of national efforts to reduce harmful greenhouse gas emissions, in line with the Scottish Government's commitment to reach 'net zero' by 2045. However, regulation works best when it works with people. Any mandatory standard should therefore be accompanied by:
- an energetic campaign of energy efficiency education
- clear information that is easy to access
- a robust consumer protection framework
- an enforcement body with teeth
We believe that the mandatory standard should be implemented in 2030, not 2024, so that the above have time to be developed and implemented across Scotland. However, homeowners should be educated, supported and incentivised to upgrade their property in advance of this deadline, and the Scottish Government should make their goals clear so homeowners can plan their investment efficiently.
Mandating the standard before consumer protection frameworks are fully developed and awareness is widespread will make the standards difficult to enforce and is likely to cause consumers more harm than good. Any mandatory standard should be enforced by local authorities, who should be adequately staffed and resourced to do so.
Lastly, the cost of upgrading every home in Scotland to EPC band C will be incredibly high. The poorest and most vulnerable should not shoulder the burden; low income households already spend 6% more of total household expenditure on energy (National Energy Agency (2017). The Scottish Government should cover 100% of the cost to EPC band C for the fuel poor and offer a wide range of financial incentives for those able to pay.