Scottish energy efficiency policy must be inclusive, says OFTEC in consultation response
Proposals outlined in the government document include the introduction of a legally binding standard to ensure all homes in Scotland meet Energy Performance Certificate (EPC) rating C at point of sale or major renovation, from 2024.
If a seller is unable to bring their home up to standard before sale, the responsibility would fall on the buyer to do so within a specific timeframe, proposed to be 12 months, or face a fine.
Whilst OFTEC fully supports the consultation's aim to improve home energy efficiency and believes a legally binding standard could be introduced at a future point, the trade association fears the timeframe is premature and could lead to financial hardship and difficulty for many homeowners.
Commenting on the proposals, OFTEC CEO Paul Rose says: "OFTEC strongly backs a 'fabric first' approach to energy efficiency and agrees that EPC Band C is a realistic target for most properties. However, those homes with the lowest EPC ratings, many of which are in rural off-gas grid areas, would need considerable investment to bring them up to the proposed standard.
"A deep retrofit of this kind could easily cost anywhere between £20,000 to £60,000. So, when you consider that the least efficient homes are often owned by those on low to middle incomes with little or no savings to draw on, it's difficult to see how these households could possibly meet the expected costs.
"More time is needed before a binding target is introduced, and more robust support measures put in place, to prevent many rural homeowners being unfairly penalised by these measures."
OFTEC is also concerned that using point of sale as a trigger point to meet the proposed standard could lead sellers to adopt the lowest cost rather than best solution, just to achieve a sale. As a result, standards could be undermined.
Passing responsibility to the buyer in cases where the seller is unwilling or unable to pay for improvement work could also stall the housing market and encourage 'gaming' where purchasers try to acquire homes for unreasonably low prices.
OFTEC's consultation submission also outlines how decarbonisation progress continues to be threatened by the lack of affordable, practical low carbon heating solutions currently available to consumers.
According to Energy Savings Trust, heat pumps, which are among government's favoured options for rural homes in particular, cost between £6,000 to £18,000 to install. Without significant support, these figures fall well beyond the financial capabilities of most households.
To help address the glaring gap, OFTEC is working with industry partners to introduce a sustainable low carbon liquid fuel to replace heating oil. The simple solution would enable existing high efficiency boilers to be retained and so greatly reduce the capital investment involved.
Paul Rose concludes: "Extensive independent research shows that changing the fuel rather than changing the appliance is the most cost-effective way for both consumers and government to decarbonise heat from oil using homes. We are confident that with the right policy support, a 100% fossil-free liquid fuel could be in use by 2035, ten years ahead of Scotland's net zero target.
"Scottish Housing Minister Kevin Stewart has said that government wants “all our homes to be warmer, greener and more efficient”. For this to be achieved, it's crucial that the next round of policy does not leave whole sectors of society behind. But without some modifications to current proposals, this could be exactly what happens.
"We are keen to continue working with government to ensure consumers have access to the affordable, practical low carbon heating solutions they need to really get behind the decarbonisation process and push for net zero."
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