― According to the latest figures, 26.5% (or around 649,000) of Scottish households live in fuel poverty while 7.5% of households (183,000) live in extreme fuel poverty. This is unacceptable in contemporary Scotland.

― The Scottish Government should abandon its staged approach to housing energy efficiency improves as it creates ongoing (rather than one-time) upheaval for construction companies and adds to the problem of retrofitting existing buildings to the most efficient standards.

― The aims of the European Union’s Energy Performance of Buildings Directive (EPBD), which requires EPCs to be produced for all new buildings and those being sold or rented out, are fundamentally sound and should serve to drive improvements in energy performance. However, in Scotland and the UK, the method by which EPCs are produced are fundamentally flawed. In particular, this is due to the reliance on using modelled energy consumption data rather than actual (measured) data.

― The response is strongly of the view that the Scottish Government has significantly under-estimated the financial, resource and time costs involved in using Energy Performance Ccertificates as a basic measure of energy efficiency.