The Scottish Government’s plan for new Environmental Performance Certificates (EPCs) may, in some types of property, be impossible to achieve.

That's according to Scottish property portal ESPC, which called for exemptions for certain types of property to the ban on direct emissions heating systems.

In the current system of EPCs, the most prominent metric is the Energy Efficiency Rating (EER) for the dwelling. This provides a banded rating from A (the most efficient) to G (the least efficient) and a one to 100 rating based on the cost to run the dwelling; normalised to the floor area.

The Scottish Government intends to change that, creating three new headline metrics for EPCs: a fabric rating, cost rating and a heating system type.

Following the proposed changes to EPCs, the government also intends to bring in a wider Heat in Buildings Bill, which would require all homes to meet a minimum fabric energy efficiency standard equivalent to EPC rating C by 2033 and to prohibit the use of direct emissions heating systems - like gas boilers - in domestic and non-domestic buildings by 2045.

For context, there are 2,610 properties currently for sale on ESPC's website. Of those, only 1,192 - or 46% - currently have an EPC rating of C or better.

For many properties and householders achieving this rating or better will be difficult for both logistical and financial reasons.

The ESPC has therefore proposed the possibility for exemptions from the ban on direct emissions heating systems for certain types of buildings - for example some tenement flats and some properties in conservation areas or heritage sites.

It also called for greater financial support to help purchase and install heat pumps, as well as discussion on a wider suite of options to help move Scotland’s varied housing stock closer to net zero.

Paul Hilton, chief executive of ESPC, said he broadly supported the government proposals, as the new EPCs will make it easier for buyers to evaluate how much they’ll be likely to spend on heating, while the move toward zero direct emissions heating systems will help reduce carbon emissions.

“However, we need to be more aware of the unintended consequences of the proposals.

“The installation of ground or air source heat pumps will be expensive and logistically difficult in many properties - in some tenement flats, for instance, it will be practically impossible.“

Hilton continued: “To take Edinburgh as an example, around two thirds of the city’s housing stock is flats, and many of those will be in one of the city’s two UNESCO World Heritage Sites, which in many cases will make it even harder for people to convert their heating systems.

“That, in turn, means that the C rating the government wants all properties to reach will be unachievable in many cases, with potentially severe implications for people wishing to sell those homes.”

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