In 2017, the Scottish Government consulted on proposals to improve energy efficiency in Scotland's private rented sector and subsequently has stated intention to develop minimum energy efficiency standards from April 2020.
These standards would essentially consist of a requirement that private landlords ensure that their propoerties are upgraded to at least EPC Band E when their tenancies change after April 2021 and up to at least EPC Band D when their tenancies change after April 2022.
Our consultation strongly disagrees with the concept of EPCs in the first place - as detailed in our policy paper Just Warmth - and calls for the creation of a Nation Energy Service to serve as a co-ordination and data hub for the required upgrades.
The response is strongly of the view that the Scottish Government has significantly under-estimated the financial, resource and time costs involved in using EPCs as a basic measure of energy efficiency.
The response is also of the view that proposed financial penalties to be levied on landlords who fail to meet required energy standards are far too low and are unlikely to force the changes required - particularly with absentee landlords or those with large portfolios. As a minimum, the penalties should reflect the costs of any upgrades plus the additional costs of tenants not making them (and thus paying higher fuel bills). Revenue from fines should be ringfenced for other energy efficiency projects and/or recycling and fuel poverty services.
Landlords should be prohibited from acquiring new rental properties and tenants until all of their stock meets the new standards.