Consultation Document on:
(1) Introduction of an Energy Performance Certificate lodgement transaction fee, upon the creation of a database for Non-Domestic Buildings; and
(2) Introduction of a transaction fee for the lodgement of Energy Performance Certificates for Dwellings on the Home Energy Efficiency Database (HEED)
1.1 This consultation seeks your views on two fee-related issues. Firstly, the proposal to include a fee for the lodgement of Energy Performance Certificates (EPCs) once a database for non-domestic buildings is created. Such a resource would be mainly to collect the certificates and the information they contain, but also to support other Government initiatives. And secondly, to introduce a fee for lodging domestic EPCs on the domestic register, which is currently hosted on the Home Energy Efficiency Database (HEED).
2.1 As part of the original implementation of the EU Directive on the Energy Performance of Buildings (EPBD), Scottish Government engaged with the Energy Saving Trust. To support EPBD implementation, the home energy efficiency database is used for storing data generated by EPCs. The database was developed by Energy Saving Trust (EST) on behalf of Government and is used to record energy efficiency installations, as well as survey data on a property-by-property basis. The development of this database has been funded by a number of UK Government Departments, including the Scottish Government.
2.2 A key benefit of the database is that it holds data from a wide variety of sources including energy suppliers, government scheme managing agents, local authorities and Energy Saving Trust programmes. It is purposely designed to:
- build up a picture of progress on energy efficiency over time and by area and
- facilitate the planning and efficient targeting of energy efficiency, low carbon and fuel poverty initiatives.
2.3 The database has been developed to accept and store both EPCs as well as the underlying data used to produce to them via EPC software. The database is managed on a Scottish basis by EST who have been appointed by Scottish Ministers as 'Keeper of the Register' as outlined in the Energy Performance of Buildings (Scotland) Regulations 2008. To date over ½ a million EPCs have been lodged on the database and it can be considered to be a success and a good example of working with external partners.
2.4 However, there is no equivalent Scottish database for non-domestic properties and this can be viewed as a missed opportunity in terms of EPBD implementation.
3. Database for non-domestic Buildings
3.1 The Sullivan Report, 'A Low Carbon Buildings Standards Strategy for Scotland', published in 2007 identified the need for an electronic register/database for non-domestic properties.
3.2 As part of the Scottish Government's implementation of the Climate Change (Scotland) Act 2009, Green Deal and improved EPBD procedures, a national database which will collect the information that underpins the EPC calculation for non-domestic buildings is now being developed. Our initial intention is that the database will hold:
- EPCs and associated data for both existing buildings and new buildings
- Assessments, recommendations and Action Plans for existing non-domestic buildings, under Section 63 of the Climate Change (Scotland) Act (when introduced)
- Operational ratings/assessments (when introduced under Section 63) and
- Green Deal Assessment files and/or reports (when introduced).
3.3 The build cost of the database will be funded by Scottish Government. However, a lodgement fee will be needed to ensure that future development and maintenance costs are met.
3.4 It is intended that the fee will be raised in the following way. When an assessor lodges a certificate for a property a fee would be incurred. This would be collected on a quarterly basis via the Approved Organisations. Fees would only be paid by those lodging EPCs onto the database. The introduction of a lodgement fee means that only these users will contribute towards the future development and maintenance costs. It is considered that this approach is equitable. If funding were to be provided centrally by Government, the result would be that the public purse (and in effect everyone) would bear the burden.
3.5 The introduction of a database for non-domestic properties in Scotland will provide a number of benefits. It will enable data to be used not only to inform on progress on Scottish Government policies, but also to show the UK Government and Europe how Scotland is performing with regard to CO 2 emissions reduction targets. It will also provide us with reliable information to assist in developing future targets and standards.
3.6 The database will provide interested parties with an efficient service and the ability to retrieve certificates electronically. This however needs to be balanced and have the necessary controls to prevent misuse of the database and the information it contains. Local authorities will also be able to access the database to support their enforcement role.
3.7 The database will be built, developed and maintained through working with EST. This will provide continuity to the successful partnership already forged (see 4.3 below).
4. Database for domestic buildings (HEED)
4.1 The introduction of UK Government policies such as Green Deal will require significant IT adjustment to the existing domestic database. Because of this and as a result of the growing need for information capture and storage we consider it prudent, at this time, to make changes to the domestic database to bring it broadly into line with the proposals for the non-domestic database.
4.2 There will however be differences between the two databases. Our intention is that the revised database will hold:
- EPCs and associated data for both existing buildings and new buildings (EPCs for new buildings are currently not registered centrally)
- Green Deal Assessment files and/or reports (when introduced) and
- Assessments, recommendations and Action Plans for existing dwellings, under Section 64 of the Climate Change (Scotland) Act (when introduced).
4.3 To ensure funding is available to make the development changes we now need to introduce a lodgement fee. The register in England is operated by a commercial company. Again we are proposing to continue working with EST, an organisation funded by Government to deliver our requirements. We consider that this is the best option for Scotland firstly because of the expertise already in place within EST and secondly they are a not for profit organisation. The introduction of a lodgement fee will ensure that ongoing support costs are met and the database will be self-funding. It is intended that the fee will be raised in the following way. When an assessor lodges a certificate for a property a fee would be incurred. This would be collected on a quarterly basis via the Approved Organisations. This means that only those lodging EPCs onto the database pay to maintain the service they are using.
5. Combined Database
5.1 Having identified the need for a non-domestic database and significant adjustments to the existing domestic database we consider the best way to deliver this is through the creation of a single database. This would store information for both domestic and non-domestic buildings. And will offer savings in terms of support and future development costs with the added benefit from the streamlining that a shared platform will offer.
6. Lodgement Fees
6.1 A fee was introduced for EPC lodgement (for both dwellings and non- domestic buildings) in other parts of the UK on the initial implementation of the EPBD in 2008.
6.2 The current lodgement fee in England is £1.15 for dwellings and £5.36 for non-domestic buildings (both exclusive of VAT). The rate of the levy has been defined in legislation. To ensure parity it is proposed that the same rates are introduced in Scotland.
6.3 The introduction of a lodgement fee for the databases is not designed to make a profit. Where surplus funds are generated the lodgement fee will be reassessed.
7. Associated Government Policies
7.1 There are a number of Scottish, UK and European policies which could benefit from these proposals and some have already been mentioned elsewhere in this consultation document. These are:
- EPBD (Recast)
- Home Report
- Section 63 Climate Change (Scotland) Act 2009 (the introduction of S64 will also require to use the data collected to support it's implementation)
- Feed in Tariffs (FITS)
- Renewable Heat Incentive (RHI)
- UK Energy Bill - Green Deal
Further details relating to these policies are outlined in Annex A.
7.2 In drafting this consultation, we have worked with colleagues across Scottish Government, and with EST and the Carbon Trust.
8.1 From the beginning of April 2012 all non-domestic EPCs created will be required to be lodged on the non-domestic database. The fee for this will be initially set at £5.36 per EPC (exclusive of VAT).
8.2 From the beginning of April 2012 a lodgement fee will be initially set at £1.15 per EPC (exclusive of VAT) will be introduced for EPCs being registered on the Home Energy Efficiency Database (HEED).