Questionnaire

To what extent do you support the use of a fabric efficiency rating, based on heat demand, in the SHNZS?

Strongly support

The NIA supports the use of a fabric efficiency rating that goes beyond EPCs to focus solely on the building fabric and how well it retains heat and mitigates unwanted heat gains. A well-insulated and airtight building fabric is critical for maximising the efficiency of heating systems and minimising energy bills for residents. By prioritising fabric efficiency, the standard can better ensure that tenants benefit from clean heating systems, particularly for heat pump systems, which can perform exceptionally well in tightly sealed and well-insulated environments, further enhancing the efficiency and reducing the overall energy consumption of homes.

Of the options presented for the fabric efficiency rating, which one do you support for the new SHNZS?

Option 2
The NIA supports a fabric energy efficiency rating based on space heating demand only, to reduce external influences on the rating such as consumer behaviour. Meeting the fabric efficiency rating is essential to ensure social housing across Scotland is ready for the transition to clean heat. The NIA supports providing a target range to account for harder to treat property types. Option 2 mitigates the obvious issue of social housing providers aiming for the lower end of the range by providing an additional target to reach 71 kWh m2/year or better by 2040. That said, staggering this requirement by allowing a further 7 years to achieve the fabric efficiency rating will negatively impact tenants and cause further disruption, including some who may be living within vulnerable circumstances. The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach reduces the risk that having a target range will disincentivising a best-practice, whole house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.

Are there additional options for the fabric efficiency rating that you think should be included? If yes, please describe these here.

The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach reduces the risk that having a target range will disincentivising a best-practice, whole house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.

What, if any, are your views on how performance against the fabric efficiency rating should be measured?

The NIA advocates for a robust process to measure whether the fabric of homes actually meets its target design efficiency under real-world occupancy to protect residents and ensure that properties are ready for the transition to clean heat. Mandatory and accurate real-world performance monitoring (through sampling) is one way of reducing risk. Social housing providers could also make use of innovative technologies to measure performance which consider user behaviour and occupancy to determine actual energy performance. This will also incentivise high quality retrofit and ensure that residents reap the true benefits of retrofit measures in practice. Social housing providers should engage with tenants as early as possible during the retrofit process to effectively manage and implement this.

What are your views, if any, on the proposal for a minimum fabric efficiency standard?

The Scottish Government have recently consulted on EPC reform, therefore we expect the accuracy of EPCs will improve after the introduction of the new metrics that more accurately reflect the fabric efficiency of a home and support the transition to net zero. This will be further strengthened by the introduction of the Home Energy Model which will result in significantly more accurate and effective EPCs. EPCs take into account the individual property characteristics, whereas using a ‘one size fits all’ list that doesn’t consider property-specific characteristics creates a risk that the list of measures will become a ‘tick-box’ exercise that is irrelevant for certain property types.

It must be recognised and considered that properties have differing energy needs, and it is critical to ensure that residents have access to high quality, accessible advice to make sure that they can make informed choices about which measures are the most suitable for their property.

Should the Scottish Government proceed with a list of measures, we believe that solid wall insulation (IWI and EWI) should also be included on it. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.

The proposed requirements reflect a commitment to providing warmer homes and lower bills for residents. However, they must also be accompanied by funding and support to enable social landlords to meet them. Therefore, the NIA recommends the implementation of additional support, resource and guidance to effectively deliver the proposed measures.

What, if any, are your views on whether homes should not be relet if they cannot meet a minimum fabric efficiency standard?

The proposal that social housing cannot be relet if the minimum standard is not met by 2028 does incentivise landlords to make the required changes, however the impact of this exacerbating housing shortages must be taken into account.

The proposed exemptions in Section 3.5 do mitigate this issue somewhat, however more could be done to ensure that a higher proportion of hard-to-treat properties receive much-needed energy efficiency measures. For example, rather than exempting properties in circumstances where social landlords share buildings with other tenures – if mixed tenure properties are unwilling or unable to contribute – funding streams, such as the Social Housing Net Zero Heat Fund, could include a percentage of funding allocated for ‘in-fill’ properties to mitigate this. This supports an area-based approach, allowing for economies of scale and addresses communities collectively.

What, if any, are your views on whether ventilation and monitoring strategies should be required where MVHR is not installed?

The NIA supports the proposition that landlords should be required to devise a ventilation and monitoring strategy to accompany energy efficiency interventions in cases where mechanical ventilation isn’t installed.

In particular, there should be a focus on monitoring to provide essential data to identify potential risks and ensure that air quality meets required standards under real-world occupancy – contributing to the well-being, comfort and health of tenants. Effective ventilation, backed up by stringent monitoring, will protect social housing tenants from health risks associated with damp and mould. The PAS 2035 process sets out clear ventilation requirements, hence it is vital that social housing retrofit is carried out by qualified installers subject to PAS standards. This is integral to an effective ventilation strategy.

Enforcing a mandatory ventilation and monitoring strategy would help to mitigate unintended consequences. There should be a clear process in place to ensure regulations are consistent and guidance and support should be put in place to assist landlords with implementing this.

To what extent do you support the need for landlords to have an element of discretion to ensure measures are cost effective and in the best interest of tenants?

Strongly support

The measures installed should always be in the best interest of tenants, and landlords should ensure that appropriate advice and guidance is provided to make sure that tenants are not in any way negatively impacted by measures, particularly financially. This includes considering disruption to tenants. Early and ongoing engagement throughout the retrofit process is crucial to achieve this.

A report issued by BEIS (now DESNZ) highlighted that tenant behaviour and lack of education and advice is a major barrier to social housing retrofit.1 Landlord discretion must be regulated and monitored to ensure the outcome is best for the tenants.

What, if any, are your views on whether targets should be varied by guidance from the Scottish Government in specific circumstances?

The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach mitigates the risk of the target range disincentivising a best-practice, whole-house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.

For the minimum fabric efficiency standard, The NIA supports including solid wall insulation in the list of proposed measures. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that they will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without. Insulating solid wall homes will ensure that residents experience lower bills and higher levels of thermal comfort. It will also ensures that all of Scotland’s social housing sector is ready for the transition to clean heat. Further time could be given to insulate solid wall properties given the additional costs and complexities.

1 Department for Business, Energy and Industrial Strategy (2018). What are the Barriers to Retrofit in Social Housing? Available at: Barriers to retrofit in social housing (publishing.service.gov.uk)

To what extent do you agree that the new SHNZS should apply to mixed tenure properties?

Strongly agree

The NIA agrees the SHNZS should apply to mixed tenure properties and that more should be done to ensure that a higher proportion of mixed tenure properties are included. For example, rather than exempting properties in circumstances where social landlords share buildings with other tenures – if mixed tenure properties are unwilling or unable to contribute, funding streams, such as the Social Housing Net Zero Heat Fund, could include a percentage of funding allocated for ‘in-fill’ properties to mitigate this. This supports an area-based approach, allowing for economies of scale and addresses communities collectively.

To what extent do you agree that the new SHNZS should apply to Gypsy/traveller sites?

The NIA recognise that Gypsy/travellers have poorer outcomes than the settled population across a range of outcomes. These homes have been notoriously hard to treat within government funding streams due to a lack of clear guidance. To protect the most vulnerable residents, a solution must be found to include Gypsy/traveller sites in the SHNZS and further consultation should be sought on this.

What are your views on the timetable for introducing the new SHNZS?

Ensuring the required advice, guidance and support is in place in advance of standards being implemented is crucial to success. Therefore, the NIA accept the timetable for introducing the new SHNZS, to provide adequate time to consider enforcement, build resources and guidance and sufficiently consult and engage with a range of stakeholders. Timelines are already very tight, with minimum fabric efficiency standards due to come into force in 2028. Hence, it is critical that the Scottish Government implements the SHNZS as soon as possible to give social housing providers and the retrofit supply chain sufficient time to meet the regulations. Delays to this timeline would cause significant impact and hinder progress towards crucial net zero targets.

Summary – Scottish Government Heat in Buildings Proposals

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Questionnaire

Question 1
To what extent do you support our proposal to prohibit the use of polluting heating systems in all buildings after 2045?

☒ Strongly support 

The NIA supports the prohibition of polluting systems in all buildings after 2045, as decarbonising Scotland’s buildings is essential for it meet its 2045 net zero target. This is supported by the proposed minimum energy efficiency standards (MEES), which will ensure that the majority of Scottish homes achieve a good level of fabric energy efficiency. However, the standards do not include more expensive measures such as solid wall insulation, which risks leaving some households behind.

A fabric first approach is vital to ensure that properties are ready for the transition to low-carbon heat. If heat pumps (or other low carbon heating systems) are installed in properties with inadequate insulation, there is a risk that those heat pumps will have overly expensive running costs, as heat pumps are most effective in properties with a high thermal efficiency. Making sure that a home has adequate insulation prior to installing a heat pump is essential to safeguard consumers from potential energy bill increases.

To improve information and advice, the NIA supports the development of an assessment tool to help building owners understand which types of clean heating system are most suitable for their building.

Question 2
To what extent do you agree that we should introduce a minimum energy efficiency standard to be met by private sector landlords by the end of 2028 (even if they are already using clean heating)?

☒ Strongly support 

The NIA supports the introduction MEES for private sector landlords by 2028, as private rented homes typically have a poorer standard of energy efficiency. The Scottish House Condition Survey published in May 2023 found that 30% of private rented sector households are fuel poor, in comparison, only 9% of those with a mortgage and 14% of those who own outright are assessed to be fuel poor – highlighting that private rented homes should be urgently addressed to protect tenants.

This said, there must be support in place to support landlords through the transition. A recent report by British Gas found that one of the main barriers for landlords looking to upgrade their properties is a lack of knowledge around EPC standards, with 44% of landlords not knowing the EPC rating of their properties. In addition, over half of landlords don’t know enough about the grants available to them to make improvements. Government and industry must work together to tackle the lack of knowledge and financial support to incentivise landlords to make changes to properties.

It is also important that private landlords are given sufficient notice before MEES come into force, so that they have time to upgrade their properties. Therefore, we would like to see the Scottish Government finalise MEES regulations and embed them into law as quickly as possible. This would provide much-needed clarity to landlords and the retrofit industry, which is important for targets to be deliverable. If MEES are implemented too close to the date they are set to come into force, it may be impossible to feasibly meet them. For instance, there may be a risk of supply chain bottlenecks if thousands of private landlords are trying to install energy efficiency measures at the same time.

The NIA agrees that MEES should still be met even if the property has clean heating installed. A fabric-first approach, in line with PAS 2035, should be followed and is essential to reduce overall energy demand and to improve the comfort and well-being of tenants.

(1 Scottish Government (2023). Scottish House Condition Survey: 2021 Key Findings. Available at: Fuel Poverty – Scottish House Condition Survey: 2021 Key Findings – gov.scot (www.gov.scot), 2 British Gas (2023). Greening the Private Rental Sector. Available at: british-gas-greening-the-prs-report.pdf (centrica.com)

Question 3
To what extent do you agree that we should introduce a minimum energy efficiency standard to be met in owner occupied homes (which still have a polluting heating system) by the end of 2033?

☒ Somewhat support 

The NIA supports the introduction of a MEES to be met in owner occupied homes by the end of 2033.

However, and especially without an initial legal requirement to do so, advice and support for owner occupiers must be improved to incentivise residents to make the necessary improvements to their homes. The proposal does state ‘there will be very strong incentives for homeowners to invest in energy efficiency’ however these are not fully realised within this consultation. We urge the Scottish Government to roll out these strong incentives as soon as possible, as these will be vital to encourage homeowners to meet MEES and to reduce the financial burden of doing so.

The NIA disagrees with the proposal that owner-occupied homes that have ended their use of polluting heating by 2033 will not be required to meet the MEES. Whilst we understand the need to protect homeowners from financial burden, it is vital to treat the fabric of the home first, in line with PAS 2035, to maximise efficiency of low carbon heat and to ensure measures deliver the intended outcomes. A fabric-first approach according to PAS 2035 is of critical importance for the following reasons:

• To protect residents from high energy prices. Low carbon heating system replacements are expected to be dominated by electrified options like heat pumps. The high electricity to gas price ratio (3.86 to 1 as of the January 2024 price cap level) means that without significant energy demand reduction measures, residents with electrified heating will be exposed to high energy bills. Therefore, we believe that households who have replaced polluting heating systems should still be subject to MEES. This is particularly important given the current cost-of-living and energy crises, with electricity prices expected to remain well above pre-crisis levels for the rest of the decade. MEES for all households, regardless of heating system, will protect them from the risk of sustained high energy bills in the long term.
• To increase the efficiency and reduce the running costs of heat pumps. The efficiency of heat pumps is linked to the fabric efficiency of homes. MEES for homes installing heat pumps are important because a higher fabric efficiency will increase the efficiency of heat pumps and reduce the cost they incur to run. Higher insulation standards should allow a smaller, cheaper heat pump to be installed that will have lower operating costs for residents. As such, MEES for all homes will result in more efficient and cheaper-to-run heating systems.
• To reduce the cost of electricity network expansion. If the majority of homes are to replace gas with electric heating, a huge expansion of the electricity grid will be required. There is a huge capital cost associated with building more renewable generation capacity and expanding the electricity network. According to Ofgem and the UK Government, £170bn – £210bn will need to be invested in the UK grid by 2050 to achieve our net zero targets. Therefore, it is imperative that homes consume as little electricity as possible because the cheapest energy is the energy we don’t use. Ambitious MEES which reduce the energy demand of new homes will reduce the scale by which the electricity network and additional renewable capacity will need to be expanded by, thus saving billions of pounds in capital costs for residents and government.

Therefore, the NIA believes that MEES should apply to all homes, including those with a non-polluting heating system. This should be accompanied by greater support for residents to improve the energy efficiency of their homes.

(3 Ofgem (2024). Energy price cap. Available at: Energy price cap | Ofgem, 4 Jillian Ambrose (2023). ‘Higher energy bills forecast for UK households next year’, The Guardian. Available at: Higher energy bills forecast for UK households next year | Energy bills | The Guardian, 5 Regen. Building a GB electricity network ready for net zero. Available at: Building a GB electricity network for net zero (regen.co.uk)

Question 4
Do you agree with our proposal to set a minimum energy efficiency standard that can be met by either installing a straightforward list of measures, or showing a good level of energy efficiency based on a reformed EPC fabric efficiency metric?

☒ Somewhat support 

The Scottish Government has recently consulted on EPC reform, therefore we expect the accuracy of EPCs will improve after the introduction of the new metrics that more accurately reflect the fabric efficiency of a home and support the transition to net zero. This will be further strengthened by the introduction of the Home Energy Model which will result in significantly more accurate and effective EPCs. EPCs take into account the individual property characteristics, whereas using a ‘one size fits all’ list that doesn’t consider property-specific characteristics creates a risk that the list of measures will become a ‘tick-box’ exercise that is irrelevant for certain property types.

It must be recognised and considered that properties have differing energy needs, and it is critical to ensure that residents have access to high quality, accessible advice to make sure that they can make informed choices about which measures are the most suitable for their property. The focus of the minimum energy efficiency standard must be to ensure that each property can benefit from the most suitable energy efficiency measures tailored to its individual needs.

Should the Scottish Government decide to use a list of measures to demonstrate compliance with the MEES, we believe that solid wall insulation (IWI and EWI) should also be included. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.

The proposed requirements reflect a commitment to providing warmer homes and lower bills for residents. However, the practicalities for homeowners and landlords must be considered. Meeting the standards may involve a significant financial contribution, particularly in harder to treat properties which require complex measures. To alleviate this, the NIA recommends the implementation of additional support, funding and guidance to effectively deliver the proposed measures.

Question 5
What is your view on the initial proposed list of measures to meet the minimum energy efficiency standard?

☒ Somewhat oppose

We believe that solid wall insulation (IWI and EWI) should also be included on the proposed list of measures. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.

Nearly a quarter of homes in Scotland have solid walls and of these, only 16% had insulated walls as of 2022. Hence, there is an urgent need for more targeted support for solid wall homes, particularly because 45% of a home’s heat can be lost through uninsulated solid walls. We recognise that installing solid wall insulation across all of the homes that need it will be a challenge and therefore we would be open to a later compliance date for solid wall properties. However, it is vital that solid wall properties are not disregarded altogether from MEES. This would leave residents of solid wall homes colder and worse off in the long-term. Therefore, solid wall insulation (IWI and EWI) installed in line with PAS 2030/2035 as part of a fabric first approach, should be included on the list of measures for any MEES. According to Energy Saving Trust, this could save a typical detached home £660 per year on their energy bills.

Early engagement with residents is also essential to demonstrate the benefits of such measures. Including higher cost measures in the list alongside providing high-quality advice will help residents to make informed choices. Where necessary, additional time and financial support to complete higher cost measures should be granted.

(6 Scottish Government (2024). Scottish House Condition Survey: 2022 Key Findings. Available at: Supporting documents – Scottish House Condition Survey: 2022 Key Findings – gov.scot (www.gov.scot), 7 Emma Spencer (2024). ‘Save energy with solid wall insulation’, Money Supermarket. Available at: Solid Wall Insulation | MoneySuperMarket, 8 Energy Saving Trust (2024). Solid wall insulation. Available at: Advice on insulating your solid walls – Energy Saving Trust)

Question 6
Do you think that properties for which most or all of the measures on the initial proposed list are not relevant should be required to meet an equivalent minimum energy efficiency standard?

☒ NO – these properties should be considered compliant once they have installed all the measures that are appropriate for their building type, even if this is few or no measures.
☒ YES – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), and they should be required to install all of these where feasible.
☒ YES – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), but they should only be required to install some of these where feasible and cost effective.
☒ YES – they should be required to meet the standard and additional measures should be included on the list (such as solid wall insulation, solid floor insulation and flat roof insulation), but they should only be required to install some of these where feasible, and they should be allowed additional time to do so.

Question 7
Do you think that properties for which most or all of the measures on the initial proposed list are not relevant should be required to meet an equivalent minimum energy efficiency standard?

☒ DON’T KNOW – The NIA believe that both the worst first and fabric first approach should be followed to address the need for investment in existing homes. MEES across housing tenures are a key regulatory lever that will drive progress towards more energy efficient housing.

However, the enforcement of private sector MEES and incentivising owner occupier MEES must be considered to ensure residents and landlords are motivated to make energy efficiency improvements. Measures must remain affordable, fair and feasible for homeowners and landlords and the Scottish Government should ensure that advice and financial support is accessible.

In terms of approach, the standard suggests that evidence including invoices or photographs could be used to show that a property has installed all of the measures (or as many as are feasible) for it to meet the standard. However, reformed EPCs will also include all the information that is required to show that an owner has met the standard. The NIA strongly advocates for robust evaluation and quality control of measures installed under MEES (such as through in-use performance testing) to avoid exposing residents to property damage and health risks, such as damp and mould, resulting from poor quality installations. High quality, PAS-compliant installs must be promoted to ensure that the benefits of measures are delivered as intended.

Question 9
To what extent do you support the requirement to end the use of polluting heating following a property purchase?

☒ Neither support nor oppose – The NIA agree that to ensure we reach climate change targets, we should consider other options to influence homeowners, landlords and businesses to make the change to clean heating systems before 2045.

The cost of upgrades to meet requirements will be a significant challenge for homeowners, especially for first-time buyers – and would significantly impact the housing market; affecting property values and impacting the buying/selling process. Lower-income homeowners are likely to be impacted the most, and this could create disparities in housing options.

Importantly, whilst the requirement to end the use of polluting heating is necessary, it is vital to ensure that properties are first ready for the transition to low-carbon heat. If heat pumps (or other low carbon heating systems) are installed in properties with inadequate insulation, there is a risk that those heat pumps will have overly expensive running costs, as heat pumps are most effective in properties with a high thermal efficiency. Making sure that a home has adequate insulation prior to installing a heat pump is essential to safeguard consumers from potential energy bill increases.

The NIA agrees that a grace period should be implemented to allow homeowners to make required changes. In order for the requirement to be fair, the Scottish Government would need to ensure:

• There are robust enforcement procedures in place to monitor and verify that upgrades have been installed to a high standard
• There is a significant range of finance products/ public funding to support people and businesses to make the required upgrades, including those who might not currently be able to access standard forms of private finance, such as mortgages.
• Homeowners have access to comprehensive advice and information services
• That the impact on the housing market is minimised as much as possible – for example providing an exemption for first-time buyers

Question 11
To what extent do you support our proposal to apply a cost-cap where people are required to end their use of polluting heating following a property purchase?

☒ Neither support nor oppose – The NIA understands the rationale for implementing a cost-cap to ensure homeowners do not pay unreasonable costs and that financing options can be determined.

However, introducing a cost-cap can be problematic as it could lead to unintended consequences such as compromising quality and market distortion. A strict cost-cap may influence selection of measures based solely on cost, rather than considering the most effective and sustainable solution – this could also discourage innovation in the sector. For instance, a low cost cap may exclude measures like solid wall insulation which are higher cost but which have significant benefits in terms of energy bill savings and thermal comfort.

If a cost-cap is implemented, the NIA recommends that the cap is flexible and adaptable to account for factors such as inflation, changing market rates and harder to treat properties.

Question 12
To what extent do you support our proposal to apply a cost-cap where people are required to end their use of polluting heating following a property purchase?

☒ Another, please suggest below – The three options proposed each have disadvantages which have been highlighted in the consultation. If a cost-cap is implemented, the NIA recommends that the cap is flexible and adaptable to account for factors such as inflation, changing market rates and harder to treat properties. To provide flexibility and fairness, cost-caps should take a range of variables into account, including building type, wall type, EPC rating, heating type etc, as seen with other energy efficiency schemes. Every property is different and there are many factors that can affect the cost of upgrading to a reasonable level of energy efficiency. Therefore, it is important that any cost cap reflects the heterogenous nature of Scotland’s housing stock and does not exclude harder to treat properties from important energy efficiency standards.

Question 18
We will need to have a way to monitor if people are meeting the Heat in Buildings Standard, and discussed two options for this. Which do you support?

☒ A combination of the two  – The NIA supports using a combination of both EPCs and sampling to monitor and enforce the proposed requirements.

The NIA also strongly advocates for evaluation and quality control of measures installed, to avoid exposing residents to property damage and health risks, such as damp and mould, resulting from poor quality installations. Monitoring must take into account the quality of installs to ensure that the intended consequences are delivered. These further checks could be completed as part of the sampling process.

Question 19
We will need to have a way to enforce the Heat in Buildings Standard. We discussed possible options to help achieve compliance. What are your views on these ideas?

☒ I support a mixture of the above options – The NIA believes the most effective way to enforce the Heat in Buildings Standard is through proactive reinforcement; offering comprehensive information and advice alongside a range of different financing options. The Scottish Government’s priority must be to provide residents with financial support and generous incentives to help them comply with MEES, with penalties a last resort.

The NIA agrees with proposing that private landlords should be subject to civil penalties if they refuse to meet the MEES. However, a recent report by British Gas shows that lack of information and costs are the main barriers for landlords when considering upgrades to properties. Therefore, it is important that appropriate support is available to help landlords comply and to avoid the need for penalties wherever possible.

For homeowners, the NIA agrees with the Scottish Government’s decision to avoid wider civil penalties, at least for the initial stages of the standard – particularly as the main barrier is the cost of measures. Homeowners should be engaged as early as possible to achieve targets. Information and support around eligible funding streams must be improved to incentivise homeowners to implement measures.

In addition, it is likely that enforcement bodies will experience gaps and inconsistencies with the quality of EPC data, hindering the identification of target properties. The Scottish Government should facilitate cross-team working for example between landlords, local authorities, Historic Environment Scotland, building control and trading standards to share intelligence and coordinate enforcement activity.

(9 British Gas (2023). Greening the Private Rental Sector. Available at: british-gas-greening-the-prs-report.pdf (centrica.com), 10 Centre for Sustainable Energy (2022). Compliance & Enforcement of the Minimum Energy Efficiency Standard (MEES) in the Private Rented Sector. Available at: Compliance & Enforcement of the Minimum Energy Efficiency Standard (MEES) in the Private Rented Sector (centreforsustainableenergy.ams3.digitaloceanspaces.com)

Question 20
To what extent do you support our proposals to modify the Standard or exempt certain people from the need to meet the Heat in Buildings Standard?

☒ Somewhat support – The NIA accepts that individual circumstances, and our homes and buildings, vary significantly, and therefore any enforcement should be fair and should protect vulnerable residents. Exemptions should be treated on a case-by-case basis where possible to allow for the greatest flexibility.

As full exemption from standards would hinder the pace we reduce carbon emissions, this should only be provided in a very limited set of circumstances where it is not possible for standards to be met. Instead, additional time and support should be offered for properties where it is more difficult to meet standards. For instance, we would support giving solid wall homes a later date to comply with MEES. This recognises the challenges associated with insulating Scotland’s solid wall housing stock, without excluding them from standards altogether, which would leave residents of solid wall homes colder and worse off.

Question 22
To what extent do you support our proposals to give certain people extra time to meet the Heat in Buildings Standard?

☒ Somewhat support – The NIA accepts that individual circumstances, and our homes and buildings, vary significantly, and therefore any enforcement should be fair and should protect vulnerable residents.

The NIA also agrees that extra time may be required for those living in properties where clean heating options are limited – in this case residents should focus on improving the fabric of the building to reduce energy demand and to ensure the property is ready for clean heat once suitable options become available.

As full exemption from standards would hinder the pace we reduce carbon emissions – additional time and support should instead be offered, where reasonable and feasible, to do so.

Heat strategy for Wales | GOV.WALES

Closing Date: 8 November 2023
Response submitted by: National Insulation Association
For more information, please contact: info@nia-uk.org

About the National Insulation Association

The National Insulation Association (NIA) represents the insulation industry in the UK with a member base comprised of installers, system certificate holders, and manufacturers who provide a wide range of insulation solutions for homes and buildings. The NIA and its members are fully committed to maintaining and raising standards within the insulation industry.

Yes, we agree with the Welsh Government’s vision.

Yes, we agree with the six areas identified by the Welsh Government.

Yes, PAS 2035/2030 standards are crucial to ensure a high-quality, whole-building approach to retrofit. The NIA is committed to maintaining and improving quality across the insulation sector so that the true benefits of the installed measures are realised, and the customer and their home are fully protected at all times. We believe that PAS 2035/2030 is a helpful standard which promotes high-quality retrofit and reduces the risk of retrofit projects. Hence, we welcome the plans set out by the Welsh Government to use PAS 2035/2030 standards in all of its retrofit programmes.

PAS 2035/2030 is an industry-led quality standard that provides best practice for retrofit, taking a whole house approach. This provides customers with confidence in the work being carried out, and also prevents poor delivery of measures and costly damage to properties. New PAS standards were brought in after the Each Homes Counts review to safeguard against the damaging consequences of sub-standard installations. Since then, they have been instrumental in improving the quality of installation and customer service across the industry. PAS 2035/2030 focusses on a fabric first approach to home decarbonisation which prioritises vital insulation upgrades as a first step to whole house decarbonisation. It puts whole house retrofit at its heart and sets out a clear platform for sensible, logical retrofit.

Nonetheless, even with the recent revisions which should make the PAS process more streamlined, we recognise that PAS compliance can be costly, especially for small businesses. Therefore, it is important that the Welsh Government supports businesses with these costs and helps them to carry out high-quality, PAS-compliant retrofit. This could include providing more funding within its programmes to cover the costs of PAS compliance. Training and qualifications are another vital element of the PAS framework; hence it is important that the Welsh Government provides support for local businesses so that they are adequately skilled and qualified to carry out PAS-compliant retrofit projects. By providing more support to businesses working towards PAS compliance, this will enable PAS-compliant retrofits to become commonplace across Wales.

Yes, we agree that the Welsh Government has a key role to play in supporting the development of the necessary skills for heat decarbonisation. Modelling carried out by the Construction Industry Training Board (CITB) suggests that an additional 12,000 full-time equivalent (FTE) construction jobs will be required in Wales by 2028, the majority to deliver improvements to reduce energy demand in existing buildings. This represents both a challenge and an opportunity for Wales. The retrofit sector in Wales, and the insulation sector more specifically, will need to attract and train new entrants to deliver the volume of installs required to meet net zero. It will also require large-scale training and upskilling of the existing workforce. Retrofit training will demand significant investment from devolved government. Therefore, the NIA would like to see the Welsh Government work with retrofit employers and training providers to widen the provision of retrofit training across the country. This could involve helping employers and training providers to offer subsidised training courses, particularly for roles where there is a shortage, such as Retrofit Coordinators and Retrofit Assessors.

We are pleased to see that the Welsh Government is committed to exploring opportunities for early years and young people to enter the heat decarbonisation sector. There is a clear need for this – according to research by the recruitment brand Reed, current rates of retrofit recruitment will need to triple if Wales and the rest of the UK are to meet our shared net zero 2050 target.1 It is important that industry and government to work together to attract new entrants into the sector. This is something that the NIA is keen to support the Welsh Government with.

The Welsh Government has a key role to play in support the development of the necessary skills for heat decarbonisation in Wales. Targeted investment in retrofit skills will have the added benefit of creating thousands of high-quality and sustainable jobs in communities across Wales. A report published in 2021 by the Future Generations Commissioner for Wales estimated that 26,500 new jobs could be created by 2030 as part of a long-term strategy to decarbonise housing in Wales. The localised nature of most energy efficiency work means that many of these jobs will be created locally within Wales. Hence, Wales can retain the job and growth opportunities offered by the net zero transition.

Yes, we agree with the Welsh Government’s plans to rebalance the levies on electricity bills. This is essential to kickstart the transition to low-carbon heat and make sure that it is affordable for consumers.

However, the Welsh Government should also prioritise increased investment in insulation measures as the most effective way to fairly distribute the costs of the transition to low carbon heat. Insulation can significantly decrease the heat demand of a property and cut heating costs. According to research by the Energy & Climate Intelligence Unit, raising the EPC of a property by one SAP band from D to C can reduce space heating demand by 20%.2 Insulation is the most effective way to make home heating affordable because it reduces energy demand and energy bills.

Taking a fabric-first approach is especially important when it comes to the installation of low-carbon heating systems, such as heat pumps. Heat pump efficiency is dependent on the flow temperature at which it operates, running at higher efficiencies when the flow temperature is lower. However, a property can only be adequately heated at low flow temperatures if it has a high thermal efficiency. Therefore, the installation of fabric efficiency measures prior to, or alongside, heat pump installation means a smaller, cheaper heat pump can be installed which will then operate at higher efficiencies over its system lifetime. If low-carbon heating is installed and then insulation added afterwards, consumers may be left with a heating system that is not proportionate with the property’s reduced space heating demand and therefore has capital and running costs that are unnecessarily high. It is vital that properties are as insulated as much possible before installing low-carbon heating systems to ensure they are sized correctly and cost less to run.

The most effective way to ensure that the public can afford the switch to decarbonised heating is by following a fabric-first approach. Insulation will safeguard consumers from increased heating costs, thereby ensuring a just transition to low-carbon heat, especially for those vulnerable groups most at risk of falling into fuel poverty due to energy bill increases.

Yes, the NIA agree that stronger regulation can support uptake of low carbon heat and energy efficiency measures. This is particularly true for Minimum Energy Efficiency Standards (MEES) which require homes to be above a certain EPC. Having higher MEES will encourage more homeowners to invest in the energy efficiency of their properties. MEES are an integral part of improving conditions in the Private Rented Sector whereby tenants are reliant on landlords to invest in energy efficiency measures that will reduce their energy bills and improve their thermal comfort. The UK Government had proposed several amendments to MEES in its 2020 consultation on ‘Improving the energy performance of privately rented homes’. Although it has since abandoned these commitments, as signalled by the Prime Minister’s speech in September 2023, the NIA would like to see the Welsh Government commit to adopting these proposals in Wales. These would improve energy efficiency standards in the private rented sector and improve thermal comfort for private tenants. These proposals include:

• The minimum EPC rating increasing from an E to a C, which would require investments to be made to reach the standard before a property can be rented out. EPC C would need to be reached by 2025 for new tenancies and 2028 for existing tenancies.
• The increase in the cost cap from £3,000 to £10,000 per property, which would allow for investment into measures that have a real impact on the thermal comfort of the property.
• The integration of the fabric first approach, which requires investment in the fabric of the building (lost, cavity or external wall insulation, double windows and doors) prior to other improvements such as heating system upgrades.

Most regulations and targets in the energy efficiency sector are based on EPCs. These underpin our understanding of the efficiency of properties in the UK therefore, they need to be as accurate as possible. The NIA believe that important reforms to EPCs are needed to ensure that households get reliable advice on how to improve their properties. We would support the introduction of similar EPC reforms to the ones currently being proposed by the Scottish Government. These proposed reforms include:

• A separate fabric rating alongside existing metrics to draw attention to the energy efficiency of the property specifically. This supports the fabric first approach.
• A metric for the type of heating system in the property. This will support the transition to low carbon heat as it will highlight the carbon intensity of the heating system as well as the running costs. This enables informed decision making for consumers as we transition towards net zero.
• Improving the explanation of the recommendations given to the consumer to ensure they understand why measures have been suggested and what benefit they offer.

By introducing similar reforms, the Welsh Government could ensure that EPCs more effectively support Wales’ heat decarbonisation pathway by incentivising investment in low carbon heating systems and energy efficiency measures.

Along with this, it will be important for government schemes to target the worst performing or hardest to treat homes first as they may incur the highest cost to the homeowner and be the most dangerous to live in. The effects of exposure to cold homes include poor mental and physical health due to inadequate indoor air temperatures (too cold or too hot), high humidity levels which can lead to mould, high noise and poor air quality. It is estimated that the NHS spend over £540 million each year treating people affected by living in the worst performing properties in England. However, this is a solvable problem, the BRE Group in its’ 2023 report on the Cost of Poor Housing in England by Tenure estimated that of the homes in the PRS experiencing excess cold the average cost to mitigate this is £6,835, which if the MEES reforms were actioned would be under the maximum spend for landlords of £10,000. There are similar average mitigation costs for excess cold across owner occupiers (£6,690) and social homes £3,800). The NIA believe that the worst performing homes need to be supported to improve across all housing tenures and no household should suffer with the effects of poorly performing homes.

Yes, a holistic approach to fuel poverty which simultaneously supports both energy efficiency improvements and the transition to low carbon heat is crucial. This should revolve around a whole-house, fabric-first approach to heat decarbonisation.

When upgrading or decarbonising a property’s heating system, it is important to assess and upgrade (where necessary) the property’s energy efficiency. As discussed in our response to Question 8, improving a property’s fabric performance will facilitate the installation of a more efficient and cost-effective heating system, thus making the transition to low-carbon heat smoother and more affordable for residents.

A holistic, fabric-first approach is particularly important when it comes to those in fuel poverty, as it ensures that the transition to low carbon heat is affordable. Taking a whole house approach that installs insulation improvements in conjunction with a low carbon heating system will make sure that those in fuel poverty will not see any increase in their heating costs when they transition to a low carbon heating system. As such, a holistic fabric first approach to heat decarbonisation is the best way to ensure that the transition does not place a cost burden on fuel poor households.

Yes, we would welcome demonstration projects for historic and traditional building retrofit. These buildings are often avoided as they are perceived as too difficult to retrofit, however this means that they are excluded from the benefits of energy efficiency measures. There is also a significant skills and knowledge gap when it comes to retrofitting traditional and historic buildings. The Retrofit Academy have recently released a new qualification targeted at historic and traditional buildings which is a good step towards addressing this skills gap. The introduction of demonstration projects would be another very useful step as they would encourage new, innovative approaches and the sharing of best practice around hard to treat buildings.

It can be very difficult to get planning permission for retrofit projects on historic and traditional buildings. Thus, it is important that the Welsh Government adopts a joined up approach to retrofitting them which involves Local Authority planning departments in the process. This should help to streamline the process for retrofitting historic and traditional buildings and also make sure that retrofits are compliant with all the requisite planning requirements.

Yes, we agree that this is a sensible approach.

Energy Performance Certificate reform consultation – Scottish Government consultations – Citizen Space Closing Date: 16 October 2023

Response submitted by: National Insulation Association
For more information, please contact: info@nia-uk.org

About the National Insulation Association
The National Insulation Association (NIA) represents the insulation industry in Scotland and across the UK with a member base comprised of installers, system certificate holders, and manufacturers who provide a wide range of insulation solutions for homes and buildings. The NIA and its members are fully committed to maintaining and raising standards within the insulation industry.

The NIA agrees with the set of metrics that the Scottish Government proposes to display on the reformed EPC.

The new set of metrics support the need to reduce direct heating emissions, the need to lower residents’ energy bills and tackle fuel poverty, and the need to ensure that the building fabric is as efficient as possible. The proposals provide consumers with a more detailed information breakdown on the performance of different aspects of their home, which will help them to make informed decisions about the best route to improving the energy efficiency of their homes.

It is encouraging to see a separate fabric rating included as one of the headline metrics. A fabric first approach is industry best practice when it comes to whole-house retrofit. It also helps to make the transition to low carbon heat as affordable as possible for consumers. Therefore, it is critically important that the fabric efficiency of homes is clearly displayed on EPCs. This will give consumers a clear of idea of their property’s current fabric performance and how this can be improved, as well as highlighting the importance of adequate insulation to residents. The inclusion and adding weighting given to fabric efficiency on EPCs should help to facilitate muchneeded insulation upgrades to Scottish homes.

The inclusion of a metric for heating system type is also welcome. This means EPCs will more effectively support the transition to low carbon heat. There is very little incentive to install low carbon heating systems within the current EPC framework. Since the EER on current EPCs is based on modelled running costs, cheaper heating systems receive a better rating, regardless of their carbon emissions. Hence, changing EPCs to better incentivise low carbon heating measures, such as heat pumps, is vital if they are to be fit for a net zero future.

No, we agree with the metrics included.

No, the NIA does not think that the Fabric Rating should include hot water heat demand. This risks making the metric more complex and potentially confusing for consumers. It could also dilute the focus on fabric measures.

The rationale for including a fabric rating metric is to give residents a clear idea of how well insulated their home is and to drive insulation improvements. By including hot water heat demand (a non-fabric factor), this could detract from the metric’s primary goal – to improve fabric efficiency. While we recognise the importance of limiting heat loss from hot water systems through measures such as insulating the hot water cylinder, it is vital that the fabric rating is not influenced by nonfabric elements, such as type of hot water system. This would detract from the overall efficacy of the fabric rating.

As current policy commitments and targets are based upon EER bands (in particular Band C), the new fabric rating scale should be aligned with the current EER rating system. This is important to allow for continuity and consistency between different versions of EPCs. It will minimise any confusion that might be caused for businesses and consumers by changes to the EPC framework.

Yes, we agree with this proposal. Including unambiguous information about the dwelling’s specific energy efficiency features should give residents much-needed clarity. This should help them understand the current fabric performance of their home and allow them to make informed decisions about which measures to take in order to upgrade the property’s energy efficiency.

No, we believe that non-domestic EPCs should also include fabric rating as an additional headline metric, as is being proposed for domestic EPCs.

A fabric first approach is the most effective method to carry out whole-building retrofit. This is true regardless of the building’s use. A high level of thermal efficiency is equally important for non-domestic buildings as it is for domestic ones. Adequate insulation could save businesses a significant amount of money on their overhead costs, especially with energy bills at their current high level. Therefore, fabric rating should be clearly displayed on non-domestic EPCs so that building owners are fully aware of their building’s fabric efficiency and what steps they can take to improve it.

The fabric efficiency of non-domestic buildings is also important to ensure that they have a correctly sized heating system. This is particularly important when buildings are installing a new low carbon heating system. For instance, If a heat pump is installed followed by insulation, the building’s heating system output may not be proportionate with its reduced space heating demand and therefore have capital and running costs that are unnecessarily high. The installation of fabric efficiency measures prior to, or alongside, the installation of a low carbon heating system means a smaller, cheaper system can be installed. This is especially important in non-domestic buildings, which often have a significantly larger space heating demand and floor area than domestic dwellings.

In their 2023 Annual Progress Report to Parliament, the Climate Change Committee (CCC) highlighted non-residential buildings as an area of concern, nothing that, “There is a large and increasingly concerning policy gap relating to non-residential buildings.” Hence, it is crucial that the Scottish Government gives the same attention to the fabric efficiency of non-domestic buildings as it does for domestic ones. The best way to reduce the energy use and carbon emissions of non-domestic buildings is to make sure that they are adequately insulated. Thus, a fabric rating should be included on non-domestic EPCs, so that businesses as well as residents are incentivised to improve the fabric efficiency of their buildings.

As set out in our response to Question 6, we believe that non-domestic EPCs should include fabric rating as an additional headline metric.

A fabric first approach is the most effective method to carry out whole-building retrofit. This is true regardless of the building’s use. A high level of thermal efficiency is equally important for non-domestic buildings as it is for domestic ones. Adequate insulation could save businesses a significant amount of money on their overhead costs, especially with energy bills at their current high level. Therefore, fabric rating should be clearly displayed on non-domestic EPCs so that building owners are fully aware of their building’s fabric efficiency and what steps they can take to improve it.

The fabric efficiency of non-domestic buildings is also important to ensure that they have a correctly sized heating system. This is particularly important when buildings are installing a new low carbon heating system. For instance, If a heat pump is installed followed by insulation, the building’s heating system output may not be proportionate with its reduced space heating demand and therefore have capital and running costs that are unnecessarily high. The installation of fabric efficiency measures prior to, or alongside, the installation of a low carbon heating system means a smaller, cheaper system can be installed. This is especially important in non-domestic buildings, which often have a significantly larger space heating demand and floor area than domestic dwellings.

In their 2023 Annual Progress Report to Parliament, the Climate Change Committee (CCC) highlighted non-residential buildings as an area of concern, nothing that, “There is a large and increasingly concerning policy gap relating to non-residential buildings.” Hence, it is crucial that the Scottish Government gives the same attention to the fabric efficiency of non-domestic buildings as it does for domestic ones. The best way to reduce the energy use and carbon emissions of non-domestic buildings is to make sure that they are adequately insulated. Therefore, a fabric rating should be included on non-domestic EPCs, so that businesses as well as residents are incentivised to improve the fabric efficiency of their buildings.

Yes, we agree.

Yes, we agree with this in principle. The energy efficiency landscape is constantly changing as new policies and targets are introduced to drive the transition. The Scottish Government has set a target for all homes to reach EPC C by 2033.1 With the current validity period of 10 years, this means that an EPC carried out today would be still valid in 2033, even though the energy efficiency landscape will look drastically different by then.

Reducing the validity period to 5 years would allow a more up-to-date and greater coverage of EPC data across the housing stock. It would also provide a more accurate picture of the UK housing stock and its energy performance for policymakers, businesses and consumers. The Government.

However, if the Scottish Government is to proceed with this proposal, it must support industry to train new energy assessors and upskill existing workers, as it will be necessary to increase the number of skilled energy assessors to meet the increased demand for EPC assessments. This would also improve the accuracy of EPCs and thereby increase consumer confidence in the reliability of the EPC framework.

This represents a significant challenge for industry and government. Therefore, the NIA would like to see the Scottish Government work with retrofit employers and training providers to widen the provision of retrofit training across the country. The Home Decarbonisation Skills Training Competition has been very successful in England and is now in its second phase.2 When we signposted members towards this latest pot of skills funding, we had interest from Scottish members who enquired about whether Home Decarbonisation Skills Competition funding was available in Scotland (which unfortunately it is not).

There is clearly a demand and need for more subsidised skills funding in Scotland. Therefore, we would urge the Scottish Government to consider introducing a similar scheme to the Home Decarbonisation Skills Training Competition in Scotland, which would enable Scottish retrofit businesses to access subsidised training courses to train existing and new employees, and ultimately grow their businesses. Without more investment in training, we have concerns that there will be severe shortages in energy assessors and other roles key to the decarbonisation of homes. This could limit the practical viability of reducing the validity of EPCs to 5 years, and potentially hinder Scotland from reaching its wider energy efficiency targets.

Based on feedback from our membership, the requirement for installers to be Green Deal certified can represent a barrier to businesses and consumers. There are several reasons why an installer may not be Green Deal certified. For instance, some installers cannot use pre-existing “systems” because they a lot of their business is either architect-specified or needs bespoke solutions for installers. For these installers, it often doesn’t make sense to be Green Deal certified.

However, these businesses often miss out on business unfairly because of difficulty with customers accessing HES funding. Hence, we believe customers accessing HES funding should be allowed to use a Green Deal, Trustmark or NIA registered installer. This would give customers more options as well as ensuring better value for money for homeowners and taxpayers.

Yes, the NIA support this proposal as it will encourage EPCs to be used more and therefore will support its intended use as a guidance document for investment in home retrofit. The proposed changes will improve the accessibility of the document for readers. Enabling residents to view their EPC on a mobile device will allow EPCs to be viewed by a wider group of people. It will also enable people to view EPCs when they are on-the-go or away from their laptop. It will also allow for a more efficient system of updating the documents as the webpage can be updated with new data more frequently than pdf formats. As stated in the consultation, a webpage format will also reduce additional verification steps making the document more useable for those trying to access information about the properties they live in. The NIA support this proposal as it contributes to making EPCs more accessible and user-friendly.

As well as the format being easier to access, having the EPC on web page format will allow for additional links to be included helping readers to understand the content of the EPCs in greater detail. This is currently a barrier for consumers as the information on EPCs can be hard to follow without additional knowledge. In their letter to Lee Rowley MP, Parliamentary Under Secretary of State for the Department of Levelling up, Housing and Communities, ‘Reform of domestic EPC rating metrics to support delivery of Net Zero’ , the Climate Change Committee (CCC) list several factors that contribute to EPCs being unfit for purpose including the 1-100 rating scale, which does not provide useful information on what steps the consumer should take to improve the efficiency of their home.3 If EPCs were moved to webpage format as proposed, the advice provided can be accompanied by additional links enabling the reader to access supporting information to help them understand the content.

However, these businesses often miss out on business unfairly because of difficulty with customers accessing HES funding. Hence, we believe customers accessing HES funding should be allowed to use a Green Deal, Trustmark or NIA registered installer. This would give customers more options as well as ensuring better value for money for homeowners and taxpayers.

Yes. As mentioned above, being able to link readers to external information will support informed decision making on how they should invest in their homes. By directing readers towards existing support, such as existing energy efficiency and retrofit schemes in Scotland, they can see whether they are eligible for financial support, which according to the Energy Saving Trust (EST) is amongst the most common barriers for investing in home retrofit, alongside access to advice and information.4 The NIA support this proposal as this will add an extra layer of support provided through EPCs and will encourage engagement with existing schemes, helping to support the Scottish Government’s target of reducing emissions in homes by 68% from 2020 levels by 2030. Rather than the EPC being a standalone document, it can be used to link readers to information and existing support to help them to realise the retrofit work they are interested in, benefit from the results of an improved EPC rating and contribute to the decarbonisation of the housing sector.

However, it is important that readers understand that whilst EPCs offer advice, they should still get a full survey and retrofit assessment from a reputable installer before getting any work done to their home. This will ensure that they are choosing the right measure for their property and that they understand what is involved including time and cost.

To this end, we would recommend that, as well as linking to EST and HES, EPCs should also signpost customers to where they can find reputable, Trustmark-registered local installers. This is important as for many residents, the next step after having an EPC done is to install retrofit measures. It can be challenging for consumers to know where to start and sometimes speaking to local installers can clarify what work is available and at what cost. Consumers should be encouraged through the advice on their EPC to receive multiple quotations on the cost of the work where possible. By signposting to a trusted site this can help to simplify the retrofit process for consumers and help them take the next step to upgrading their home.

By directing consumers to a site where they can find high-quality, local installers, it would also reduce some of the burden on advice services, thus reducing the risk that a bottleneck could be created through massed calls to EST and HES, for example. For customers looking to install energy efficiency measures of the back of an EPC, it might be helpful to direct them directly towards businesses who can install the measures they want.

Yes, the NIA support this proposal as it will allow new homeowners to view and understand previous EPC ratings allocated to the property and any historical retrofit works that have taken place at the property to get to the current EPC. This proposal will also help local authorities to understand the common issues and solutions in housing in their local area. The effective use of data is vital to give local authorities an in-depth and detailed picture of their housing stock. This will allow them to plan more effectively for council-led retrofit programmes and create local decarbonisation strategies that are tailored to the local housing stock.

This data may also be useful for understanding local skills gaps through the identification of the most common work needed in homes in the area and the availability of local installation companies. The NIA works closely with contractors, suppliers and installers to identify ways to address the UK wide green skills gap with localised solutions being at the forefront of overcoming this issue in order to reach Net Zero.

Yes, the NIA support the proposal to include the EPC register in an Application Programme Interface (API) to allow for key stakeholders to access historical EPC data throughout the year. These key stakeholders could include homeowners, local authorities, industry representatives, research organisations and policymakers. The NIA believe this kind of data transparency can support key stakeholders in understanding how to improve the EPC rating of homes through access to information, which will ultimately support the transition to Net Zero.

Having accurate EPCs is fundamental to the decarbonisation of the housing sector as they are often the starting point from which consumers make decisions on what retrofit works to carry out on their properties. On principle the NIA agree with the proposed changes to the auditing process as smart auditing would allow for automatic triggers for EPCs meeting certain criteria, thereby enabling homes to be highlighted where urgent improvements are needed. This would be particularly useful for identifying the hardest to treat and worst performing homes. However, there are some questions on how this would work in practice in terms of informing homeowners and arranging assessors to visit the properties in question if this is to be part of the process.

The NIA believe prioritising energy efficiency improvements to the building fabric are the most effective ways of increasing thermal comfort, reducing energy loss from properties and reducing energy consumption as properties require less energy for space heating. Therefore, EPCs should advise households to invest first in insulation measures before moving to heating system upgrades according to a fabric-first approach. More widely, following the fabric-first approach has the highest benefits for decarbonisation of the housing sector as insulation measures help to reduce energy consumption and enable an affordable switch to using low-carbon heating systems such as heat pumps.

The NIA agree with the timeline proposed as it allows a grace period for stakeholders and homeowners to become familiar with the changes. The time period aligns with the introduction of other regulations in Scotland including the Energy Performance of Buildings Regulations. However, there is also an urgency to the introduction of policy changes that will serve to encourage investment in the decarbonisation of the housing sector, which these changes are likely to do, therefore we encourage the Scottish government to implement the reforms as quickly as possible.