En­ergy ef­fi­ciency stan­dards for pri­vate land­lords should be 'more am­bi­tious but with longer lead time' - CIH Scot­land


The Char­tered In­sti­tute of Hous­ing in Scot­land has re­sponded to a Scot­tish Gov­ern­ment con­sul­ta­tion propos­ing new min­i­mum en­ergy ef­fi­ciency stan­dards for the pri­vate rented sec­tor (PRS) by join­ing calls for these stan­dards to be made more am­bi­tious. At the same time, it is also rec­om­mend­ing that pri­vate land­lords be given a longer lead time to com­ply with the new stan­dards and that ad­vice, in­for­ma­tion and fi­nan­cial in­cen­tives are made avail­able to help sup­port im­prove­ments. It has un­der­taken a con­sul­ta­tion en­ti­tled, ‘En­ergy ef­fi­ciency and con­di­tion stan­dards in pri­vate rented hous­ing: A Scot­land’s En­ergy Ef­fi­ciency Pro­gramme Con­sul­ta­tion.’ The Scot­tish Gov­ern­ment is con­sult­ing on pro­pos­als that, by 2019, all pri­vate rented homes in Scot­land should achieve an En­ergy Per­for­mance Cer­tifi­cate (EPC) rat­ing of band E or bet­ter at point of rent. By 2022, all PRS prop­er­ties are ex­pected to achieve an EPC rat­ing of band D or bet­ter when there is a change of ten­ancy with this re­quire­ment then ex­tend­ing to all prop­er­ties in the pri­vate rented sec­tor by 2025. It is an­tic­i­pated that the re­quire­ment to meet a min­i­mum stan­dard of EPC band E will af­fect around 30,000 prop­er­ties with a fur­ther 65,000 prop­er­ties af­fected by the re­quire­ment to achieve band D or bet­ter. In its sub­mis­sion to the Scot­tish Gov­ern­ment con­sul­ta­tion, CIH Scot­land ar­gues that, rel­a­tive to the ad­di­tional cost and ad­min­is­tra­tive bur­den of com­pli­ance, the in­terim re­quire­ment to achieve EPC band E will have a rel­a­tively low im­pact on im­prov­ing over­all en­ergy stan­dards within the sec­tor. Ar­gu­ing for en­ergy ef­fi­ciency stan­dards for the pri­vate rented sec­tor that are both re­al­is­tic and achiev­able, it sug­gests re­mov­ing the re­quire­ment to achieve an ini­tial min­i­mum stan­dard of EPC band E and in­stead re­quir­ing prop­er­ties to achieve at least EPC band D from 2021 at change of lease, ex­tend­ing to all PRS prop­er­ties by 2024. CIH Scot­land is also urg­ing the Scot­tish Gov­ern­ment to set a clearer tra­jec­tory for higher en­ergy ef­fi­ciency stan­dards be­yond that time pe­riod. Its pro­posal is that, with ef­fect from 2027, the min­i­mum stan­dard be in­creased to EPC band C at change of lease, ex­tend­ing to all PRS prop­er­ties in Scot­land by 2030. Com­ment­ing on the Scot­tish Gov­ern­ment con­sul­ta­tion and CIH Scot­land’s re­sponse, CIH Scot­land Ex­ec­u­tive Di­rec­tor An­nie Mauger said: ‘ In re­spond­ing to this con­sul­ta­tion, our pri­or­ity is to en­sure that min­i­mum en­ergy ef­fi­ciency stan­dards for the pri­vate rented sec­tor are suit­ably strate­gic and am­bi­tious while also be­ing re­al­is­tic and achiev­able for land­lords. By re­mov­ing the in­terim tar­get, our in­ten­tion is to give land­lords a longer lead time to adapt their prop­er­ties to meet a suit­ably am­bi­tious stan­dard. We are also mak­ing the case for a longer term tar­get for all prop­er­ties in Scot­land’s pri­vate rented sec­tor to achieve EPC band C or bet­ter by 2030. We think giv­ing the sec­tor a clearer in­di­ca­tion of the long term am­bi­tion will make it eas­ier for land­lords to plan and adapt ac­cord­ingly.’

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