9. EE in PRS and HEETSA - Report
Renfrewshire Council · 19 August 2025
Back to Communities and Housing Policy Board — 19 August 2025 and its agenda
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To: Communities and Housing Policy Board On: 19 August 2025 Report by: Director of Environment, Housing and Infrastructure Heading: Scottish Government Consultations on the Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations and the Draft Scope for a Heat & Energy Efficiency Technical Suitability Assessment 1. Summary 1.1 The Scottish Government is currently consulting on draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations and a proposal setting out the scope of a Heat & Energy Efficiency Technical Suitability Assessment (HEETSA). 1.2 The draft energy efficiency regulations propose a Minimum Energy Efficiency Standard for the private rented sector, requiring all such properties to meet an Energy Performance Certificate Heat Retention Rating of band C. It is proposed this standard will apply to new tenancies from 2028 and to all privately rented properties by 2033. 1.3 The Scottish Government are currently reforming the Energy Performance Certificate framework, with the intention the new certification will be introduced in 2026 (subject to the UK Government timetable for development of the Home Energy Model) and features new Heat Retention Ratings, Energy Cost Ratings and Heating System Rating. 1.4 The HEETSA is intended to provide assurance for building owners when choosing measures to improve energy efficiency and change heating systems. This provides mechanisms to ensure the most appropriate measures are implemented. The intention is this will be underpinned by legislation and updating the current Energy Performance Certification scheme. 1.5 Both consultations objectives aim to improve energy efficiency, reducing emissions from buildings and support the Scottish Government’s Net Zero and fuel poverty reduction commitments.
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1.6 The consultations will close on 29 August 2025 and Officers have prepared responses which broadly support the introduction of both the Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations and a HEETSA. If approved, by this Board, these will be submitted prior to the consultation closing date. 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Approves the draft responses to both consultations, and 2.2 Authorises the Director of Environment, Housing and Infrastructure to submit the responses prior to the closing date of 29 August 2025. 3. Background 3.1 The Scottish Government is consulting on two areas aimed at improving energy efficiency and reducing emissions from buildings to ensure that these fall in line with the net zero target date of 2045. The proposals further aim to achieve a good level of energy efficiency, in a way that is fair and which reduces fuel poverty. The first consultation relates to proposed Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations, with the second consultation seeking views on the scope of a potential HEETSA. The Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations 3.2 The Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations propose to make provision for the introduction and enforcement of minimum standards of energy efficiency (MEES) within the domestic privately rented sector. This will address the least energy-efficient properties and propose that all private rented properties meet Heat Retention Rating (HRR) band C within the Energy Performance Certificate. Landlords will be prohibited from letting properties which fall below this minimum standard until they have made any relevant energy efficiency improvements which apply to the property. 3.3 It is proposed this standard will apply to new tenancies from 2028 and to all privately rented properties by 2033. 3.4 The Scottish Government are currently reforming the Energy Performance Certificate framework so that they have a clearer focus on the energy efficiency of the building fabric and give better information on the emissions and efficiency of the heating system. The new certification will be introduced in 2026 (subject to the UK Government timetable for development of the Home Energy Model), introducing a new Heat Retention Rating which focuses on the fabric of the building and will directly measure how well it retains heat to maintain a comfortable internal temperature, so it would not be affected by changes to the heating system.
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Alongside this rating, the EPC would also show the efficiency and running costs of its heating system, and the cost of energy to run the home to standardised conditions. 3.5 Basing a minimum energy efficiency standard on this new rating will allow a more accurate assessment of the direct impact of poor energy efficiency on fuel poverty than the current cost-based EPC rating. Given the importance of also being able to understand how much it costs to heat a home, the existing cost- based rating will be retained on the EPC and renamed as the ‘Energy Cost Rating’. This will allow the EPC to support fuel poverty policy by continuing to provide a rating for the cost of energy, whilst enhancing this through a direct measure of the fabric energy efficiency of a property. The EPC will also include a Heating System Rating (HSR) which will show whether the installed heating system is polluting, hybrid or clean, and its emissions and efficiency. 3.6 Under the draft regulations for the minimum energy efficiency standard proposals, a number of exemptions would apply to the requirements to meet it. No landlords will be required to install measures which are technically unsuitable for the type of property they own, for which they cannot attain the required consent from tenants, neighbours or planning authorities, or which would be prohibitively expensive. A cost cap exemption of £10,000 is proposed within the draft regulations. It is anticipated that a landlord will require to evidence the requirement for an exemption and where successful in obtaining the exemption, it will have a finite lifespan. Short Term lettings will be specifically excluded from the scheme. 3.7 It is being proposed that local authorities will carry out enforcement and compliance duties however, Officers are of the opinion that the scheme would be more appropriately regulated through the landlord registration regime and can be enforced in such a way that a landlord will not be given a registration if they do not meet the standard. Enforcement of the regulations would, in Officers’ opinion be most appropriate through the Housing and Property Chamber, First Tier Tribunal for Scotland, as is currently the case where landlords are failing to comply with their duties under Repairing Standard. There are a range of financial penalties for non-compliance with the proposed regulations, ranging from £600 to £3,000. 3.8 The consultation also seeks views on changes to the Energy Act 2011, ensuring consistency in powers across the UK. This will future proof Scottish Ministers powers to make further regulatory changes and will not impact the fine proposals within this current consultation, as mentioned at 3.7 above. 3.9 The Scottish Government established a PRS Landlord Loan Scheme in 2020 providing financial support for landlords to make energy efficiency improvements and install clean heating systems The consultation is seeking views on whether this scheme is appropriate to support the proposed regulations. Heat & Energy Efficiency Technical Suitability Assessment (HEETSA) – Scoping Consultation 3.10 In parallel with the consultation on the Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations, the Scottish Government is also consulting on the scope of a potential HEETSA.
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3.11 The proposal establishes a framework for assessing retrofit suitability of energy efficiency and clean heating measures, offering tailored advice beyond EPCs, especially for complex buildings like tenements and traditional properties. 3.12 The HEETSA intends to provide safeguards for consumers by ensuring that retrofit measures are technically appropriate for individual buildings; avoid unintended consequences, such as damp, mould, or ineffective heating, that can result from installing unsuitable measures and to complement EPCs, which are standardised and limited in scope, by offering a more detailed, building-specific assessment. 3.13 The retrofit assessment market has seen significant growth in recent years, driven by a combination of commercial, professional, and governmental influences. Installers have played a key role in promoting clean heating systems and insulation products, while professional bodies such as RICS and AECB have introduced new standards like the Residential Retrofit Standard and the EnerPHit Standard. Government responses to past programme failures—such as the Green Deal—have also shaped the market, leading to the creation of the TrustMark scheme and the development of standards like PAS 2035, PAS 2038, and more recently, BS40104. independent reports published in 2019 and again in 2025 have recommended that the Scottish Government take a more active role in overseeing this emerging market. These recommendations reflect a growing recognition of the need for consistent quality assurance and consumer protection as the demand for retrofit services increases. The evolution of the market is seen as a positive step toward improving the technical accuracy and relevance of retrofit advice provided to homeowners and landlords. 3.14 However, there is a recognised risk that commercial interests—particularly from businesses promoting specific products or systems—could compromise the impartiality of assessments. Ensuring that retrofit advice remains independent and technically sound is essential to maintaining public trust and delivering effective outcomes. As the market continues to grow, there is a clear need for robust oversight and governance to manage potential conflicts of interest and support the delivery of high-quality, unbiased retrofit assessments. 3.15 The Scottish Government are seeking stakeholder views on establishing government-led approval of methodologies of assessment, approval of professional standards relating to assessor skills and qualifications to undertake this, specification of the format for certification / reporting results of the assessment and the specification of circumstances in which an assessment is required. 3.16 Powers available under Part 10 of the Energy Act 2023, provide a legal basis for regulations covering the production of Energy Performance Certificates and the assessment methodology and assessor skills requirements which underpin them. These powers could also be used to specify the circumstances in which a Heat & Energy Efficiency Technical Suitability Assessment is required and the Scottish Government is seeking stakeholder views on what, if any, legal basis is needed to establish a HEETSA, along with views on the potential impacts of it being a statutory or non-statutory process.
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3.17 There is a timeline setting out the development of Heat & Energy Efficiency Technical Suitability Assessment within the consultation document, which seeks to have the guidance or regulations being in force from the beginning of 2028, which aligns with (and supports) the timeline for the proposed minimum energy efficiency standard in the private rented sector being introduced. 3.18 The consultations will close on 29 August 2025 and Officers have prepared responses which broadly support the introduction of both the Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations and a HEETSA. Implications of the Report 1. Financial – none. 2. HR & Organisational Development – none. 3. Community Planning Our Renfrewshire is safe – the introduction of regulations and technical assessment of home energy efficiency improvements will improve the living standards of tenants within the private rented sector, reducing fuel poverty and providing warm homes free of condensation and dampness. Creating a sustainable Renfrewshire for all to enjoy- the introduction of HEETSA will work toward Net Zero targets for emissions from homes and whilst this is in part designed to align with improvements in the private rented sector, it will be more widely available for all property owners to ensure they are provided with sound technical advice on energy efficiency improvements to their homes. 4. Legal – none. 5. Property/Assets – none. 6. Information Technology – none. 7. Equality & Human Rights - The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report 8. Health & Safety – where staff are required to visit premises, all risk assessments and safe working procedures have been developed. 9. Procurement – none. 10. Risk – none. 11. Privacy Impact – none. 12. CoSLA Policy Position – None.
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13. Children’s Rights – None. 14. Climate Risk- The proposed regulations align with local climate related targets, through minimising energy demand and maximising energy efficiency, thus contributing to reduced emissions and limiting climate related impacts. List of Background Papers None. Author: Colin Hunter, Environmental Health and Community Safety Manager e-mail: colin.hunter@renfrewshire.gov.uk
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Appendix 1 – Proposed Response to Consultation on Draft Energy Efficiency (Domestic Private Rented Property) (Scotland) Regulations Questionnaire Question 1 Do you agree that the PRS MEES should be EPC HRR band C? X Yes No Don’t Know Please give reasons for your answer. Question 2 Do you agree that only new reformed EPCs should be used as a basis for the proposed MEES? X Yes No Don’t Know Please give reasons for your answer. For the reasons detailed within the consultation document, it is necessary for all private rented properties to have a sufficient standard of EPC/HRR for both carbon reduction for climate change and for improving standards in properties with the aims of better health and reducing fuel poverty. Band C represents a standard which landlords should generally be able to meet, ensuring rental properties provide tenants with a basic level of comfort. This includes reducing issues with mould and condensation, which are common problems in many homes within the private rented sector. The new EPC/HRR will modernise the certificates and bands and would make older certificates obsolete. A single way of compliance should support all stakeholders including property owners and those responsible for monitoring and enforcement.
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Question 3 Do you agree that the backstop date for all PRS homes to comply with MEES should be 2033? Yes X No Don’t Know Please give reasons for your answer. Question 4 Do you agree that the MEES should apply to properties being let to new tenants from 2028? X Yes No Don’t Know Please give reasons for your answer. Question 5 Do you agree that, regardless of changes to the repairing standard, that crofters, small landholders and agricultural holdings should be excluded from PRS MEES? Yes No X Don’t Know Renfrewshire Council is of the opinion this process should be linked with the landlord registration regime. As part of renewing their registration as a private landlord, they require to confirm that they are meeting certain standards by completing the prescribed information, relating to having up to date gas safety certificate, Electrical Installation Condition Report, property meets housing standards, etc. This should be added to the prescribed information with landlords having to confirm that they meet these standards when they renew. As renewal is every 3 years, all landlords would need to confirm their compliance with this between 2028 and 2031. Renfrewshire Council supports this proposal. It is reasonable that all new tenants from 2028 should have a property that meets EPC/HRR band C
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Please give reasons for your answer. Question 6 Do you agree that the regulations should exclude short-term holiday lets from the PRS MEES? Yes X No Please give reasons for your answer. Question 7 Do you agree with the proposed exemptions covering consent, the fabric requirements of the home and temporary exemptions? X Yes No Don’t Know Please give reasons for your answer. Renfrewshire Council supports this proposal. Given that the standard will prohibit the letting of a property where the standard is not met, and meeting this standard would not be appropriate for the nature of many of these tenancy agreements, which can be lifelong, intergenerational or legally required, it appears reasonable for the proposed types of property to be exempt from the requirements. While the issues of fuel poverty will not be a concern for tenants within the Short Term Let sector, there will still be an impact on carbon reduction/climate change if this was rolled out to such property. In addition to this, landlords may see it as a further incentive to convert their property into a Short Term Let rather than keeping it within the PRS further reducing the availability of housing. Renfrewshire Council supports this proposal. These are valid reasons where an exemption would be appropriate. However, it will be necessary to have appropriate checks in place for landlords to verify any exemption. With regards to communal repairs that are required to comply with the Repairing Standard, landlords have looked to quickly use a lack of consent as a reason to not carry out works and be compliant, and there will need to be a robust process in place for landlords to be able to show that they have made sufficient efforts to gain consent before an exemption should be granted/accepted.
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Question 8 Do you agree that HEETSA should be available as an option to evidence potential negative impacts on the fabric of a property and to support an exemption? X Yes No Don’t Know Please give reasons for your answer. Question 9 Do you agree that the cost cap level should be £10,000? X Yes No Don’t Know Please give reasons for your answer Question 10 Do you agree with the proposed 12 month lead in time period for works to contribute to the total cost cap? X Yes No Don’t Know Renfrewshire Council supports this proposal. HEETSA will help to establish and define where any works may not be beneficial or even detrimental and would therefore, be a valuable assessment tool. Renfrewshire Council supports this proposal. An appropriate value requires to be set and £10000 appears reasonable. The consultation makes reference to further planned analysis which is welcomed to further inform the most suitable and realistic cost cap. Information provided to Local Authorities requires to be sufficiently robust to demonstrate (and be verifiable) that the cost of any works exceed the cost cap. It is Renfrewshire Council’s position that the cost cap should be exclusive of Value Added Tax as in most cases landlords will be in a position to reclaim VAT paid on goods and services purchased for use in their business. Another option of setting a limit to the cap would be linking this to the value of rent paid monthly or the value of the property; this would perhaps be fairer, but may be difficult to establish/enforce.
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Please give reasons for your answer Question 11 Do you agree that that all actual costs, and the cost of an EPC, should count towards the cost cap? X Yes No Don’t Know Please give reasons for your answer Question 12 Do you agree that landlords should receive Scottish Government support to make the required changes? X Yes No Don’t Know Please give reasons for your answer Renfrewshire Council supports this proposal. It is reasonable for works done (in advance of any regulations being amended) to be considered as it would not be fair on landlords who are proactive and trying to improve the energy efficiency earlier than they are legally required to. Without such a lead-in period, the regulations could act as a deterrent for landlords to be proactive. Renfrewshire Council supports this proposal for landlords who currently hold an EPC and will require a new certificate, post any improvement works undertaken. this additional cost is unlikely to significantly influence landlords reaching the cost cap level of £10,000. Renfrewshire Council supports this proposal on the basis that providing support will encourage landlords to be more accepting of the changes and will increase the likelihood of compliance with the regulations
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Question 13 Do you agree that this should be in the form of a loan? X Yes No Don’t Know Please give reasons for your answer Question 14 Do you agree that Local Authorities should be responsible for monitoring and compliance of these regulations? If no, please provide details of an alternative with your reason(s) as to how this would support the delivery of these regulations. Yes X No Don’t Know Renfrewshire Council supports this proposal. While support should be available, it’s not appropriate for money to be given as a grant to landlords to improve their private properties. Therefore, a loan system would be most suitable where landlords can use their profits from the rent of the property to pay for the repairs over an appropriate period of time. Renfrewshire Council is concerned that this will place additional burden on Services responsible for enforcement work, without the provision of funding to support this. The proposed scheme would be more appropriately regulated through the landlord registration regime and can be enforced in such a way that a landlord will not be given a registration if they do not meet the standard. However, any complaints from tenants or decisions regarding exemptions would be better provided by the Housing and Property Chamber who already enforce the Repairing Standards and other issues such as deposits. The suggested proposal would not have any impact of programmes such as Area Based Schemes which can continue to encourage landlord engagement to deliver improvements within mixed tenure blocks.
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Question 15 Do you agree with the proposed level of financial penalties to support compliance with the regulations? If no, please provide detail on suggested amendments that should be made, outlining how the changes would increase the impact of penalties to achieving compliance with the Regulations. X Yes No Don’t Know Please give reasons for your answer Question 16 Do you agree that the Scottish Government should seek to amend the Energy Act 2011 to increase in maximum financial penalties that could be imposed up to £30,000 in future, should this be deemed necessary? X Yes No Don’t Know Please give reasons for your answer Renfrewshire Council supports the proposed levels of financial penalties which should act as a deterrent for landlords to disregard their legal obligations under the legislation. Renfrewshire Council notes that the level of fines imposed for non-compliance would be for the Courts to determine but having the financial penalty up to £30,000 would act as a significant deterrent for landlords to disregard their legal obligations under the legislation.
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Question 17 In what way could these regulations have a specific or different impact, positive or negative, on a particular group of people? This could be based on protected characteristics, such as age or disability, or geography, such as island communities. Please provide further views or information A large number of properties in the PRS within Renfrewshire Council are pre-1919 tenement buildings with poor energy performance and heat retention. The tenants in these buildings are generally on low income and living in, or near, fuel poverty. Having a home that retains heat more efficiently will ensure tenants are more likely to use their heating, providing warmer and healthier environments, where issues such as condensation and mould will be less likely. RC welcome the proposed refresh of impact assessments to support delivery of the proposed regulations and to identify any potential impacts on protected characteristic groups.
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Appendix 1 – Proposed Response to Heat and Energy Efficiency Technical Suitability Assessment (HEETSA) Scoping Consultation Consultation Questions: Summary 1. To what extent to you agree or disagree that it would be valuable for the Scottish Government to develop a HEETSA (a government-led approval and accreditation mechanism to provide oversight and standardisation of the retrofit assessment market)? Strongly agree Mostly agree Neither agree nor disagree Mostly disagree Strongly disagree Don’t know Please give reasons for your view. 2. If the Scottish Government develops a HEETSA, which of the following should it cover (select all that apply): Retrofit assessment (i.e. identifying whether measures are present or can be installed) Retrofit design (identifying the types of measures (e.g. loft insulation) that can be installed) Retrofit specification (identifying the products or materials (e.g. mineral wool) that can be installed) Installation (identifying the relevant installation standards) Renfrewshire Council welcome the proposal to develop a Scottish Government-led HEETSA. Such a framework should help to ensure the consistent and effective delivery of retrofit measures for building owners, thus supporting wider national and local objectives relating to reducing carbon emissions from homes and buildings, consumer protection, fuel poverty and energy efficiency. Consumers / building owners in many cases will require technical expertise and support to identify and install the most effective and technically suitable improvement measures to avoid any unnecessary or unforeseen implications. A standardised and consistent approach to this through HEETSA should support this requirement. The limitations of current Energy Performance Certifications (EPCS) are recognised, and therefore the reformation of EPCs due later this year is welcomed alongside the proposed introduction of HEETSA. HEETSA will also provide timely support to property owners who may require to take action as part of the proposed Private Rented Sector Minimum Energy Efficiency Standard (PRS MEES).
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Evaluation (planning an approach to evaluating the impact of measures) Occupancy (including factors related to the building’s current occupancy in assessment of suitable measures) Other – please specify Please give reasons for your view. 3. Which delivery model do you think would be most appropriate for HEETSA? Direct Government accreditation of assessors Government accreditation of assessor organisations who in turn accredit assessors HEETSA as guidance only without Government accreditation of assessors Other – specify Please give reasons for your view. 4. What methodologies would be needed to meet the requirements of a HEETSA? Please name existing methodologies that could be used and highlight any gaps that you think should be filled with new methodologies. 5. There are a range of ways that identified gaps could be filled – by the market, or by the Scottish Government procuring and developing methodologies to do this. What do you think is the best approach to filling identified gaps in the methodologies required for HEETSA? Renfrewshire Council recommends that all aspects listed are covered as part of a HEETSA to provide consumers/building owners with as much information and guidance as possible as part of a full and robust assessment. Renfrewshire Council propose a structure in which Scottish Government accredits assessor organisations who in turn accredit assessors. This ensures quality assurance and allows for scalability and local delivery. The potential role of local authorities in the process should be considered and any potential resource implications, given our statutory role in housing and energy planning. Existing methodologies such as those listed in the consultation including PAS: 2030, PAS:2035, PAS:2038 and BS40104 should be most suitable. However, the Scottish Government may wish to consider any identified gaps or challenges associated with existing methodologies including the assessment of hard-to-treat properties (e.g. older buildings, stone buildings, tenements) and any local contexts.
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Please give reasons for your view. 6. What skills and qualifications should be required to undertake a HEETSA? Please name existing qualifications that would be relevant and highlight any gaps that you think should be filled by new skills or qualification requirements. 7. Which of the following statements comes closest to your view: It is feasible for an individual assessor to have sufficient skills and knowledge to complete a HEETSA A HEETSA would require input from multiple specialists and could not be completed by an individual Don’t know Other - please specify Please provide reasons for your view. There may be some instances in which an individual assessor may have sufficient skills and knowledge to complete a HEETSA. However, we believe multidisciplinary teams will often be required to deliver full HEETSA, especially in large or complex projects. In these instances, multiple specialist inputs may be required such as surveyors, ventilation experts etc. Renfrewshire Council recommend that the Scottish Government invest in developing or adapting methodologies to address any gaps, in collaboration with key stakeholders including local authorities, market leaders and academic institutions. This should ensure a collaborative and consistent approach to developing and implementing methodologies. HEETSA assessors should have qualifications aligned with the methodologies previously outlined including PAS:2030/PAS:2035 Retrofit Coordinator and Domestic Energy Assessor Standards (required for EPC Assessors). The Scottish Government may wish to consider additional training in relation to building typologies and fuel poverty.
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8. To what extent do you agree or disagree that non-personal data gathered through a HEETSA should be stored to form part of a ‘building logbook’ or ‘green building passport’? Strongly agree Mostly agree Neither agree nor disagree Mostly disagree Strongly disagree Don’t know Please give reasons for your view. 9. To what extent do you agree or disagree that the HEETSA assessor should be required to be independent of the outcome of the assessment? E.g. they could not financially gain from the outcome if a measure is stated as technically suitable. Strongly agree Mostly agree Neither agree nor disagree Mostly disagree Strongly disagree Don’t know Renfrewshire Council strongly support the creation of a digital ‘green building passport’ or logbook which captures comprehensive building information, a bespoke plan for renovation guidance and key supporting information for energy efficiency improvements. This is especially important when required improvements are more complex or larger in scale. The introduction of a GBP or logbook would support improved continuity of information across tenures and ownership changes and provide supporting evidence for adhering to required standards or targeting public funding. It will be important to provide clear distinction on personal data and property data, who has ownership of the data and who should have access. This will support robust data governance and protection and good practice. Suitable pathways and processes for data being shared or made publicly available should also be considered.
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Please give reasons for your view. 10. Thinking about the relationship between the EPC and HEETSA, which of the following statements comes closest to your view: The results of a HEETSA should result in the production of a revised EPC as part of its output The results of a HEETSA should be made available to inform the production of a revised EPC and should be considered acceptable ‘documentary evidence’ to override default values. The results of a HEETSA should not have any influence on the EPC and its ratings Don’t know Other – please specify Please provide reasons for your view. 11. Thinking about presenting the results of a HEETSA, please give your view on: (a) HEETSA should result in a standardised certificate or report? Strongly agree Mostly agree Neither agree nor disagree Mostly disagree Strongly disagree Don’t know Assessors should require to be independent of the outcome of the assessment to avoid any potential conflicts of interest and to ensure consumer trust and confidence in the outcome of the assessment. It is important that the results of a HEETSA closely align and link to the EPC of a property. This ensures a full, detailed technical assessment which provides precise property related data, that an EPC may not provide. Therefore, a revised EPC should provide more detailed and robust recommendations for improvements in energy efficiency supported by a technical assessment.
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(b) What information should be included when presenting the results? Please provide reasons for your view. 12. Please provide details of any circumstances in which you think a HEETSA should be required, and the reasons for your view. Please provide reasons for your view 13. Do you think it is necessary to develop a legal basis for HEETSA (i.e. should HEETSA be underpinned by regulations in a similar manner to EPCs)? Yes Don’t know No A standardised certificate or report should include: An overview of the property a summary of the assessment including the date, it’s purpose and the outcome (current energy performance, recommended/identified suitable measures based on technical findings). Details of the accredited assessor Supporting documentation This captures the relevant detail within a consistent format for all completed assessments. HEETSAs should be required in some instances as part of an application for public funding to ensure it is being invested in the most suitable and effective measures. However, it is worth noting that some application processes have short timescales for providing extensive information to support an application, and this additional step may prove challenging to potential applicants. HEETSAs may be required prior to the commencement of major retrofit projects or programmes and for complex or hard to treat buildings, ensuring the most effective and suitable measures are identified for those building types.
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Please give reasons for your view. Introducing a legal basis for HEETSA may be necessary for some specific, targeted circumstances to protect consumers and support other regulation adherence and compliance. However, the potential challenges and implications of doing so must be carefully considered. Introducing a legal requirement for assessments could place additional pressure on households and landlords which risks resistance or non-compliance. Developing and enforcing new regulations requires significant resource, both at national and local government level. There may also be initial challenges relating to the quantity of accredited assessors and identifying the most appropriate approach for complex or unique buildings or projects. Therefore, the Scottish Government may wish to consider a phased approach to regulation with a focus on priority areas initially.