Energy Performance Certificate


Dr Keith Baker

Take a deep breath, I am about to say some nice things about the Scottish Government, Buildings Standards, and Energy Performance Certificates. 

(Although, I hasten to add, the kudos here is due to the Building Standards Division, who seem to be free to do useful work thanks to a hands-off First Minister and a Minister for Net Zero who hasn’t attended cabinet in over a year and is more focussed on ‘other things’).

I should also add that, at the moment, none of this good news is set in stone, months of discussion lie ahead, it won’t please everyone, and we can expect the mass build lobby to kick back hard. However, this is the first time in over 10 years when I’ve felt that genuine progress is being made on issues that I’ve spent much of my academic life working on. 

Right now, we are looking at no fewer that four areas of policy where joint work between Common Weal, my research centre at Glasgow Caledonian University, and others may be taken up in legislation.

First of all, we have the Passivhaus Bill (now renamed the Domestic Building Environmental Standards (Scotland) Bill), which Alex Rowley MSP has worked so hard on. It seems unlikely that the Scottish Government will adopt Passivhaus standard directly off the peg, as this would lock us to a commercial standard but, in practice, there could end up being hardly any differences between the standard and a Scottish ‘equivalent’. Without getting into the technical details, there are some areas where it may well make sense to see some divergence without, necessarily, watering down the overall stringency of the standard.

Secondly, and this is a big one for us that was sprung on me at a workshop, we understand that BSD are minded to adopt the EnerPHit standard for assessing retrofits, which could ultimately replace the much-criticised Standard Assessment Procedure (SAP). Both the Passivhaus and EnerPHit standards make use of the Passivhaus Planning Package (PHPP) methodology, an alternative to SAP which, unlike SAP, has been extensively verified in practice. Whilst no model can ever be one hundred percent perfect, there is simply no comparison between the accuracy of PHPP compared to SAP. PHPP is also cheap to licence, and comes as an Excel spreadsheet where it is easy to see and trace every calculation. The spreadsheet can also be modified easily enough, making a Scottish equivalent simple to implement and roll out.

Another advantage of EnerPHit, in common with the LEED standard used in the USA, is that it’s a relative standard that takes into account the maximum energy performance that any retrofitted building could be expected to achieve. It’s not perfect, and the degree of tinkering it will need before adoption will no doubt be the subject of some heated discussions, but it would be a massive step forward – easily the most significant step forward since Scotland secured responsibility for our Building Standards.

Then we have the incorporation of embodied energy, something Common Weal has lobbied for for many years, and which we first got wind was on the cards last November. I’ll skoosh over this one as there are some potential issues with integrating it with the other legislation and it probably merits an article on its own, but we know it’s coming.

And finally, we have the reforms to Energy Performance Certificates. You may remember that the Scottish Government consulted on reforming EPCs back in 2021, and we absolutely trashed the proposals. But our joint response to this year’s consultation (which closes on October 10th, in case any of you want to get submissions in) is considerably more positive.  

However, from engaging with the Scottish Government over the last few months, we are aware that the reforms now being considered go much wider than the proposals in the current consultation. But before we get to that, I have been assured that I won’t have to wait another ten years to see EPCs incorporating real energy consumption data. (For now, we’ll politely ignore the forthcoming report on this from Changeworks, as this work is being done by non-experts and we’ll respond to that matter in due course). Also, we are getting traction with our proposal for EPCs to include some suitably anonymised household information to enable potential owners and tenants to better understand how their energy costs may differ from that of the existing occupants. The latter change would be helpful, but the former would be a game-changer that would mean I’ll be able to retire knowing that my PhD wasn’t a complete waste of time.

(I should also note that, whilst all this is going on, the European Union is busy revising its Energy Performance of Buildings Directive, which how EPCs came about in the first place, and the Scottish Government will need to decide how much, if at all, it will diverge from any changes made to it).

This brings us on to why EPCs were introduced in the first place, and potentially the biggest game-changer of the lot. EPCs were originally intended to encourage people to place a premium on energy efficient buildings, and to help building owners make the right choices about energy efficiency upgrades. They have barely been effective at the former and have been a significant problem for the latter.

Now, imagine if we took all this back to the drawing board. What if, when buying or renting a new property, you were given a manual with everything you needed to know about how it works, how to make it work efficiently, and how best to upgrade it? That manual, let’s call it a Building Passport, would still include an EPC, but that EPC would be restricted to measures of performance, and (either in the EPC or elsewhere in the passport) those measures would be extended to things like water usage and how easy it is to maintain minimum internal temperatures (aligned to those used for determining fuel poverty). The recommendations would still be in the manual, but would be caveated with a note to say that none other than the most basic should be implemented without consulting a suitably qualified professional, along with links to lists of chartered surveyors and other useful experts. They would also be filtered to remove the ridiculous ones – so no more recommendations for installing micro-wind turbines on listed buildings in urban areas and World Heritage Sites.

For the sake of costs, you’d need to access that manual online but, if designed right, that would mean the passport could be updated in real time to ensure its contents remain up to date. It would also mean that the data from that passport could be linked to that held in public portals such as the Scottish EPC Register, which would ensure that they are sufficiently populated, and save the Energy Saving Trust a lot of work on a task that they seem to have struggled with. Even better, the Scottish Government could bring that work in-house and save public money by not having to pay the EST’s overhead charges.  

Does this sound like a different world to you? Because it does to me. We could, at long last, be on the verge of seeing the sorts of changes many of us have been arguing for for years. But we still have over a year left and a lot more lobbying ahead until we know what the final picture will look like.

It’s scary just thinking how much work has gone into getting this far – how many times papers and reports have gone largely ignored, how many late nights have gone into writing them, and how many times my head has hit my desk over the excuses given for not adopting perfectly sensible and achievable proposals. We don’t know what’s happened behind the scenes, but the Building Standards Division deserve a lot of credit for the work they’re now doing, and for engaging us with it.

And, of course, we couldn’t do all this without your support, so please keep those letters going in to your MSPs and MPs, and please consider throwing Common Weal a few beans. I’m lucky that my day job pays me to do this and my research centre’s relationship with Common Weal is a mutually beneficial one, but we need to keep Craig supplied with chocolate biscuits and Haribo.

Dr Keith Baker FRSA is a Research Fellow in Fuel Poverty and Energy Policy at the Built Environment Asset Management (BEAM) Centre, Glasgow Caledonian University, and a Director and Convenor of the Energy Working Group at Common Weal               

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