Scottish Government consultation on Heat In Buildings Bill - Which? response

Which? supports consumers to make sustainable choices through our information and advice, and our engagement with Governments and business. As we are not an environmental organisation we are not able to take a position on the merits of some of the targets that are proposed in this consultation, however we have made recommendations in relation to the design of the requirements and the support that households will require if the regulations are introduced. 

1. Consistent long term targets. Consumers benefit from long term and well publicised targets that give households clarity about the changes that are required. Targets should be aligned with a coherent set of policies that support and create incentives for consumers. This is also important for businesses that need to invest in production and training.
2. Consumers will need support including information and advice, and support with upfront costs. We recognise the progress that Scotland has made in these areas and the need to continually improve delivery. The Scottish Government should also support a requirement for all installers to belong to an approved certification scheme in order to provide consumers with protection from poor quality work and rogue traders.
3. The private rental sector has high levels of fuel poverty and presents particular challenges due to the split incentives between landlords and tenants. This is likely to frustrate progress in improving energy efficiency. Therefore we support the introduction of a minimum energy efficiency standard, alongside protections for tenants and support for small scale landlords.
4. Products and costs. The Scottish Government should take action to ensure that suitable products are available for different homes and that the HIB standard does not lead to higher energy bills for consumers. This includes working with the UK government to rebalance the levies between gas and electricity prices. It should also consider setting efficiency standards for clean heating systems to promote efficient systems with low running costs, and ensure support is available so that efficient systems are affordable for low income households.
5. Flexibility. We encourage the Scottish Government to allow exemptions, modifications and grace periods that take account of the differences between building types and household’s circumstances. Whilst not all circumstances can be predicted, where possible there should be clear eligibility criteria and a straightforward system for applications to minimise confusion.
6. Monitoring and enforcement. We are concerned that producing a straightforward set of measures that households can install to meet the minimum energy efficiency standard may be more complex in practice and therefore suggest further consultation and maintaining the option of using an EPC. In relation to enforcement, in the early years the government should seek to understand why households are not meeting requirements before instigating enforcement measures, and recognise that regulation is likely to drive the right changes over time.