There is an urgent need to understand the highly significant uncertainties around both the ratings and the appropriateness of the improvements recommended by EPC assessments. The alternative approach is based on the fundamental principle of maximising the use of real data in order to provide buyers and tenants with accurate, robust, relevant, and useful information.
― The aims of the European Union’s Energy Performance of Buildings Directive (EPBD), which requires EPCs to be produced for all new buildings and those being sold or rented out, are fundamentally sound and should serve to drive improvements in energy performance. However, in Scotland and the UK, the method by which EPCs are produced are fundamentally flawed. In particular, this is due to the reliance on using modelled energy consumption data rather than actual (measured) data.
― In light of the increasing reliance on using EPC ratings as a key driver for Scottish Government policies on energy efficiency and fuel poverty, including proposals to mandate home and building owners to upgrade their properties to achieve higher ratings, there is an urgent need to understand the highly significant uncertainties around both the ratings and the appropriateness of the improvements recommended by EPC assessments. Then if the Scottish Government seeks to persist in using EPCs as a policy driver it should develop an alternative method for producing them which both more accurately reflects actual energy consumption and includes a more realistic and appropriate list of recommended improvements. Doing so is entirely within its devolved powers, and such an alternative approach would be more aligned to the EPBD’s guidance for producing EPCs.
― This policy paper sets out such an alternative approach, and how it would achieve greater alignment with the EPBD. The approach is based on the fundamental principle of maximising the use of real data in order to provide buyers and tenants with accurate, robust, relevant, and useful information. The approach is also designed to maximise the use of data already being collected by the Scottish Government and public bodies in order to be cost effective. We present this approach as an answer to the frequently asked question of ‘if not EPCs, then what?’, and would welcome comments from other experts and stakeholders as to how it could be refined further.
Energy Performance Certificates as they stand are not a valid driver for policy. What should replace them? Through a deconstruction of the legislation and the modelling that underpins EPCs we have shown both the limitations and implications of using EPCs in their current form as a policy driver, and 12 Common Weal Energy Performance Certificates: An alternative approach have presented an alternative approach which meets all the necessary legislative requirements and which can be implemented directly under currently devolved powers. Although this work is focussed on domestic EPCs we have set out how it can be applied directly to non-domestic EPCs through harmonisation with the future development of the Scottish Sustainability Label.
This alternative approach not only directly addresses the requirements of the Energy Performance of Buildings Directive, it is a better way of implementing those requirements, and serves to counter the potential for damage to social welfare under non-ideal circumstances. Furthermore, the costs of adopting the alternative approach, even without offsetting against the wider economic savings, are far from the scale of the only two viable alternatives, whilst also reducing the need for and costs of modelling.
We present this alternative approach for further discussion and as a step towards the formalisation and implementation of a more accurate, robust, realistic, appropriate and workable method for producing EPCs, and look forward to further engagement with the Scottish Government, stakeholders and experts to resolve the problems caused by the current approach.