Elmhurst responds to one of Scottish Government's most important consultations to date

8 FEATURE

www.elmhurstenergy.co.uk

Jonathan Bourke, Scotland Business Development Manager

In the year that Glasgow prepares to welcome delegates from around the world to the COP26 UN Summit on Climate Change, February saw the publication of The Scottish Government’s Draft Heat in Buildings Strategy (Consultation). This set out the ambition to achieve Net Zero emissions from our buildings by 2045, take steps to eradicate the scourge of fuel poverty from our society, and the discuss the mechanism for delivering on these goals as part of the Country’s post-COVID recovery...

At 185 pages there’s a lot of reading! Elmhurst supports the pathway detailed and its overall intentions to reduce carbon emissions, and published our formal response here: https://www.elmhurstenergy.co. uk/uploads/Heat_in_Buildings_ Strategy_Scotland.pdf

Part of moving forward to a greener future must involve actively improving occupiers’ knowledge. Usage of a building creates a massive variable in its true efficiency, therefore, the greater the occupiers’ understanding of how to use energy in their homes and businesses in the most efficient way, the greater the chance of overall emissions savings.

Retrofit and PAS 2035

Critically, as most carbon reduction will come from retrofitted improvements of existing buildings, great consideration needs to be made to the retrofit process as a whole and ensure what’s done is right for both the property and the occupant.

A systematic approach (as found, for example, by ascertaining client ‘Intended Outcomes’ within the PAS 2035 process) must be undertaken and measures should be installed at a time and in a sequence which maximises appropriate recommendations.

A fundamental aspect to this involves reducing the risk of unintended consequences, such as poor air quality or those which perpetuate the performance gap between what was planned and what was installed.

EPC trigger points

Funding models must be consistent with the principles of PAS 2035 which means a breakaway from the traditional measure-led approach and taking a step further - Energy Performance Certificate (EPC) trigger points should also be revised. For example, when a material change has occurred in the building which will impact its energy efficiency, property owners and dutyholders should be obliged to commission accurate and measured records which will not only be specific to their own property but allow metadata to be extracted for ongoing analysis.

As well as this, reducing the EPC’s validity period from 10 years to 3 years will promote proactive actions from homeowners and landlords to improve their

buildings and overcome some of the complacency observed.

Reforms to the EPC metric

Amending the metric for EPCs will be required (as noted in the Consultation), with the Scottish Government echoing our view that they “want these reforms to remove anomalie... which at present in some circumstances can disincentivise installation of zero emissions heating systems.”

Currently, due to the use of electricity and its associated higher unit price (in cost calculations), EPCs may not actually demonstrate an improvement in SAP score (or EPC Band rating) and this may result in a less favourable rating overall - particularly where insulating the building envelope either can’t or won’t be done fully. What’s worse, the EPC may not recommend a move away from fossil fuels as a heating source at all and this would inevitably lead to a detrimental impact on rolling out strategies to promote a shift away from fossil fuel heating systems. completed for a homeowner or landlord which provides recommendations to make savings not only on bills but also reductions in carbon emissions. It is imperative that funding for recommended improvements is given careful consideration as often they can be unaffordable to many - especially those most in need.

This must work in tandem with investment in training and development to gain the full benefits to the economy particularly in upskilling Retrofit Installers, Assessors, and Coordinators.