The Scottish Government’s announcement of a long term strategy for energy efficiency has been broadly welcomed by rural housing providers but caution has been urged in the plan’s implementation.

Scottish Land & Estates, whose members are the leading suppliers of rental homes in the countryside, said it was important that the unintended consequences of new energy standards – especially in terms of rural homes - were fully considered and understood.

For the private rented sector, the Scottish Government intends that where there is a change in tenancy after 1 April 2020, the property will need to meet EPC band E, extending to all private rented properties to be EPC E by 31 March 2022.

Where there is a change in tenancy after 1 April 2022 the property will need to be EPC band D, extending to all privately rented properties to be EPC D by 31 March 2025. The Scottish Government is also consulting on a proposal for private rented properties to reach EPC C by 2030.

There is also an added complication with households in fuel poverty being given a separate more ambitious target.

Katy Dickson, head of policy at Scottish Land & Estates, said: “Everyone recognises the importance of energy efficiency and shares the desire for each and every individual or family to live in warm homes which can be heated affordably.

“Our members firmly support the move towards better energy standards but there is also a vital need for the Scottish Government to give due consideration to the unintended consequences of the standards.

“The rural private rented sector has a lot to do in terms of improving energy efficiency and must not shy away from the challenge. However, those managing traditional, detached properties which are off the gas grid with long term tenants, will be apprehensive at the thought of having to reach an EPC E, let alone EPC D or even C. For landlords of listed properties then these apprehensions will be even greater.

“We are pleased to see Scottish Government’s partial business and regulatory impact assessment recognises that not all properties will meet these standards. Details of exemptions and abeyances, as well as how the programme will be funded, are still to be confirmed. Retrofitting energy efficiency measures must be cost effective and technically feasible.

“Improvements to energy performance measurement and reporting are also required and we welcome the further work Scottish Government has committed to regarding this.”

Scottish Land & Estates said that improving energy efficiency in homes should not be a standalone action and that other factors also had to be considered.

Ms Dickson added: “We would firmly advocate a ‘whole house approach’ rather than a tick box exercise. There is little point installing insulation if the property is in disrepair or issues such as ventilation have not been considered. We have seen many instances where volume standard approaches to improving energy efficiency have caused long term problems in traditional properties.

“If costs and burdens are prohibitive there is a risk that landlords will consider removing properties from the rented sector. These minimum standards must be viewed alongside the other recent changes in the sector which have failed to be rural-proofed. To continue to let properties, very often at affordable rents, there is a requirement for regulation to be practical, and landlords to be supported. In current times when the need for rural housing is high, we cannot risk the erosion of the current supply.

“Scottish Land & Estates looks forward to working with Scottish Government to ensure the programme is implemented and then regularly reviewed in a manner which improves the energy efficiency of homes without risking the health of occupants, the building or the rural private rented sector.”