New EPC Regulations and Holiday Homes – Guest Post by Fiona Campbell

Individual holiday homes, which are rented out in their entirety as specific properties to groups of people now require an Energy Performance Certificate in Scotland, contrary to advice prior to January 2017. By law, the EPC rating must be displayed in every advertisement, whether on or off line.

EPCs are designed to help and protect consumer choice. However, the vast majority of self-catering or short-term rental is now sold, like hotel rooms and bed and breakfast establishments, as inclusive of electricity and heat and so the EPC rating does not impact on the consumer’s choice in booking the accommodation.

Whilst the Association of Scotland’s Self-Caterers welcomes measures to reduce carbon emissions and promote energy efficiency, we consider that the use of EPCs in self-catering properties is unlikely to show any real material benefit to holidaymakers or owners.

We consider that there are already measures in place, which promote and encourage energy efficiency: VisitScotland’s Quality Assurance Scheme requires members to meet a list of twelve environmental standards; and membership of the Green Tourism Business Scheme obliges businesses to possess advanced levels of energy efficiency as a requirement of obtaining an award.

Several European countries have introduced exemptions for holiday let properties to be required to have EPCs, including Italy, Denmark, Germany and Sweden. In England, if a property does not charge for electricity or heat, an EPC is not required. These exemptions have been sanctioned by the European Commission.

“We believe it is only reasonable that the Scottish Government takes the same supportive approach, especially given the considerable economic benefit the sector brings to the tourism economy.”

The ASSC’s recent Economic Impact Study indicates that there are 16,949 self-catering holiday let properties in Scotland, representing 3.4million visitor nights per year and an annual £723.3 million direct visitor spend. Scottish self-catering supports 10,725 direct FTE jobs.

We consider that it is unfair to penalise businesses operating in old heritage properties, which may be constrained by planning regulations from attracting a sufficiently high EPC rating.

The critical issue is not with the EPCs themselves, nor even with the difficulties of displaying the rating on every advertisement, but with the coming minimum standards: in 2018, any property being rented out must achieve a minimum rating of E, rising to a D or even a C in 2020. Many older properties will simply not be able to achieve this, and will have to be withdrawn from the market.

The ASSC considers the requirement of EPCs for self-catering properties to be yet another regulatory burden on a sector which faces significant and growing cost pressures.

We also consider that the introduction of EPCs to self-catering appears to run contrary to the principles of the Scottish Government’s Better Regulation agenda, particularly in relation to proportionality and targeting.

Overall, we consider the notion of EPCs on short-term holiday lets is unnecessary, impractical and potentially damaging to tourism businesses. The ASSC has urged the Scottish Government to introduce an exemption to EPC requirement to provide a level playing field with our European neighbours.

Fiona Campbell is the CEO Association of Scottish Self-Caterers (ASSC). 

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