The Scottish Government has significantly under-estimated the financial, resource and time costs involved in using Energy Performance Certificates as a basic measure of energy efficiency. The financial penalties are far too low and are unlikely to force the changes required.
― The response is strongly of the view that the Scottish Government has significantly under-estimated the financial, resource and time costs involved in using Energy Performance Ccertificates as a basic measure of energy efficiency.
― The response is also of the view that proposed financial penalties to be levied on landlords who fail to meet required energy standards are far too low and are unlikely to force the changes required – particularly with absentee landlords or those with large portfolios. As a minimum, the penalties should reflect the costs of any upgrades plus the additional costs of tenants not making them (and thus paying higher fuel bills). Revenue from fines should be ringfenced for other energy efficiency projects and/or recycling and fuel poverty services.
― Landlords should be prohibited from acquiring new rental properties and tenants until all of their stock meets the new standards.
― Common Weal strongly opposes the use of Energy Performance Certificates as a measure of energy efficiency and has published a more appropriate replacement model based on actual measured energy performance.