Letter to Minister re EPC and traditional buildings

Further to a Scottish Government consultation on energy efficiency and the private rented sector this joint letter flags issues around the use of energy performance certificates and traditional buildings

Wednesday 10 January 2018

The undersigned have written to Kevin Stewart MSP, Minister for Local Governmnet and Housing to raise our concerns over current government proposals intended to improve the energy performance of Scotland’s private rented housing stock – specifically the potential impact the use of the Energy Performance Certificate will have on Scotland’s stock of traditionally built homes. We are a group of heritage professionals, responsible for assessing, planning and executing the maintenance and improvement of Scotland’s built heritage.

As a group, we strongly support the drive to improve the energy performance of Scotland’s homes, including traditionally-built properties. The continued use of historic properties is the best guarantee of their survival. These properties form a fifth of Scotland’s overall housing stock and they are a prominent part of Scotland’s heritage, shaping the character of our towns and villages. These properties are also a disproportionately important part of rural housing stock.

However, adverse or incorrect adaptations of traditionally-built properties can fail to improve their energy performance, and by limiting air circulation may degrade both occupants’ health and the building fabric. We are also concerned that, if the phasing or cost estimates are not aligned with what is actually feasible, then housing stock will be taken out of rental use and may instead go to holiday home use, or fall out of use altogether. This would have the greatest impact on rural areas in Scotland, where there are already pressures on housing availability.

In relation to the government’s current proposals for minimum energy requirements in private-rented properties (and their potential extension to privately-owned properties) we have identified the following issues:

Real-world baselines – the current EPC baselines for traditionally-built, stone-walled buildings do not reflect their real-world performance. There is therefore a risk of making unneeded interventions based on inaccurate data.

Availability of assessor skills – to implement the proposals will require an adequate supply of assessors trained in how traditional buildings perform and how they can best be improved.

Availability of installation skills and suitable materials – similarly, we will need to have suitably trained professionals and trades able to carry out the adaptations, and a supply chain to meet the demand. This can be developed, particularly if there is a strong market signal from government, from assessors and from owners, but may need time to grow.

The government’s regulator, Historic Environment Scotland, has previously raised concerns over the lack of professional and trades skills available to support the traditional building sector, including the capacity to meet the Government’s commitments under the Climate Change (Scotland) Act 2009.[1]

Realistic timeframe – if the timeframe is too short for the assessor and installer skills to be developed and applied, we risk damaging interventions or stock being taken out of use.

This is all entirely avoidable. With the correct policy prescription in place, traditional buildings are amongst the most sustainable of all building types, with embodied energy, durable materials, and capable of being adapted to a variety of uses.

We believe that these problems can be avoided through:

  • Updating the EPC baselines with more accurate data on the actual environmental performance of Scottish traditional buildings.
  • Assessing the availability of assessor and installer skills against the likely demand for resources, and estimate how these can best be developed, and how quickly this can be done.
  • Developing and applying a timeframe for upgrade that respects these limits.

We note that other jurisdictions, including England and Germany, have recognised these issues and provided specific remedies for these types of homes.

The inadequacies of the Energy Performance Certificate in relation to traditional buildings have recently been raised by heritage professionals in England with the Secretary of State for Business, Energy and Industrial Strategy.

We would be happy to meet with you and your colleagues to discuss how we can find the best resolution that maintains the integrity of Scotland’s traditional buildings, that keeps them as wind, water tight and warm homes, and that meets Scotland’s ambitious climate change goals.

Yours sincerely,

Martin Robertson, Chair, Architectural Heritage Society of Scotland

Euan Leitch, Director, Built Environment Forum Scotland

Rebecca Thompson, President, Chartered Institute of Building

Earl of Hopetoun, Chair, Historic Houses Association Scotland

Sean O’Reilly, Director, Institute of Historic Building Conservation

Simon Skinner, Chief Executive, National Trust for Scotland

Karen Stevenson, Acting Secretary, Royal Incorporation of Architects in Scotland

Gail Hunter, Regional Director – Scotland, Royal Institution of Chartered Surveyors

Colin Maclean, Chair, Scottish Civic Trust

John McKinney, Convener, Scottish Traditional Building Forum

[1] Historic Scotland (2011) Traditional Building Skills: A strategy for sustaining and developing traditional building skills in Scotland