― 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.

― In principle, Common Weal supports mandatory improvements for houses owned by owner-occupiers and private landlords however we note a number of problems with the proposals covered by this consultation.

― We object to energy efficiency being measuring using Energy Performance Certificates due to the severe shortfalls in the methodology used to determine them.

― 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.