New Proposals to Enhance Energy Efficiency

The Scottish Government has been working for over a decade to establish a minimum energy efficiency standard for properties in the private rented sector (PRS). While previous proposals have undergone changes, we can now confirm that the requirement for PRS properties to achieve an EPC rating of C by 2025 and reach the same standard by 2028 is no longer under consideration. This update will be welcomed by those operating in the sector.

However, there have been recent developments. The Scottish Government has released a consultation outlining new proposals to enhance the energy efficiency of all properties in Scotland, including residential and non-residential buildings. Here are the key proposals:

1. Private landlords must adhere to a new minimum energy efficiency standard by the end of 2028, with social housing landlords already obligated to comply with a similar standard.

2. Owner occupiers must meet the same minimum energy efficiency standard by the end of 2033, unless they have discontinued the use of environmentally harmful heating.

3. Prospective property buyers will be prohibited from using environmentally harmful heating within a specific timeframe following the completion of the sale. The exact timeline is yet to be determined but is anticipated to be within 2-5 years.

4. By the end of 2045, all building owners must cease using environmentally harmful heating.

To achieve the proposed minimum energy efficiency standard, the government has identified a prioritised list of measures with the greatest impact and minimal cost and disruption. This list includes loft insulation, cavity wall insulation, draught-proofing, heating controls, hot water cylinder insulation, and suspended floor insulation. It does not include more expensive or disruptive measures like solid wall insulation. The government acknowledges that compliance will vary based on each property type.

Regarding polluting heating systems, such as gas boilers, oil boilers, and LPG boilers, they must be replaced with clean heating systems like heat pumps, heat networks, electric storage heaters, and other emission-free electric heating technologies. Local authorities are required to produce a strategy report by the end of 2023, focusing on areas with high housing density, to identify heat network opportunities that can supply 17-34% of Scotland's heat demand. The prohibition on polluting heating applies only to the main heating system(s) of a property. The full consultation paper can be accessed here.

The government is inviting views on these proposals, and feedback can be submitted online until March 8th, 2024. You can participate here.

For more than ten years, the Scottish Government has been formulating plans to establish a minimum energy efficiency standard for properties within the private rented sector (PRS). Throughout this period, the proposed plans and dates for introduction have undergone multiple changes.  We can confirm that previous proposals requiring PRS properties to achieve an EPC rating of C at the change of tenancy by 2025, with all PRS properties reaching the same standard by 2028, are no longer under consideration, which we are sure will be welcomed from those operating in the sector.

In a recent development however, the Scottish Government has released a consultation outlining fresh proposals aimed at enhancing the energy efficiency of all properties in Scotland, encompassing both residential and non-residential buildings. The key proposals are:

Private landlords will be required to adhere to a new minimum energy efficiency standard by the end of 2028, with social housing landlords already obligated to comply with a similar standard.

Owner occupiers must meet the same minimum energy efficiency standard by the end of 2033 unless they have discontinued the use of environmentally harmful heating.

Prospective property buyers must, at a date yet to be determined, comply with the prohibition on environmentally harmful heating within a specified timeframe following the completion of the sale (anticipated to be 2-5 years).

By the end of 2045, all building owners must cease the use of environmentally harmful heating.

The proposed minimum energy efficiency standard is envisioned by the government to be achievable through the implementation of a straightforward set of measures. This prioritised list of measures aims to have the greatest impact on homes with minimal cost and disruption. The proposed list includes:

• 270 mm loft insulation
• Cavity wall insulation
• Draught-proofing
• Heating controls
• 80 mm hot water cylinder insulation
• Suspended floor insulation

Notably, more expensive or potentially disruptive measures, such as solid wall insulation, are not included. The government recognises that certain properties may not be applicable to all measures on the list, and compliance would be tailored to the relevant measures for each property type.

Regarding polluting heating systems, which include gas boilers, oil boilers, and liquid petroleum gas (LPG) boilers, these must be replaced by clean heating systems like heat pumps, heat networks, electric storage heaters, and other emission-free electric heating technologies. Local authorities are mandated to produce a strategy report by the end of 2023 identifying heat network opportunities, with an estimated capacity to supply 17-34% of Scotland's heat demand, focusing on areas with high housing density. The prohibition on polluting heating applies solely to the main heating system(s) of a property.

The Full consultation paper can be found here.