The Scottish Government’s proposed new minimum energy efficiency standards for the private rented sector (PRS) should be more ambitious, the Chartered Institute of Housing in Scotland has said.

In its response to a Scottish Government consultation closing today, CIH Scotland also recommended that private landlords be given a longer lead time to comply with the new standards and that advice, information and financial incentives are made available to help support improvements.

The Scottish Government is consulting on proposals that, by 2019, all private rented homes in Scotland should achieve an Energy Performance Certificate (EPC) rating of band E or better at point of rent. By 2022, all PRS properties are expected to achieve an EPC rating of band D or better when there is a change of tenancy with this requirement then extending to all properties in the private rented sector by 2025.

It is anticipated that the requirement to meet a minimum standard of EPC band E will affect around 30,000 properties with a further 65,000 properties affected by the requirement to achieve band D or better.

In its submission, CIH Scotland argues that, relative to the additional cost and administrative burden of compliance, the interim requirement to achieve EPC band E will have a relatively low impact on improving overall energy standards within the sector.

Arguing for energy efficiency standards for the private rented sector that are both realistic and achievable, it suggests removing the requirement to achieve an initial minimum standard of EPC band E and instead requiring properties to achieve at least EPC band D from 2021 at change of lease, extending to all PRS properties by 2024. CIH Scotland is also urging the Scottish Government to set a clearer trajectory for higher energy efficiency standards beyond that time period. Its proposal is that, with effect from 2027, the minimum standard be increased to EPC band C at change of lease, extending to all PRS properties in Scotland by 2030.

Annie Mauger, executive director of CIH Scotland, said: “In responding to this consultation, our priority is to ensure that minimum energy efficiency standards for the private rented sector are suitably strategic and ambitious while also being realistic and achievable for landlords. By removing the interim target, our intention is to give landlords a longer lead time to adapt their properties to meet a suitably ambitious standard. We are also making the case for a longer term target for all properties in Scotland’s private rented sector to achieve EPC band C or better by 2030. We think giving the sector a clearer indication of the long term ambition will make it easier for landlords to plan and adapt accordingly.”