For landlords the deadline is now 2028 and for homeowners it is 2033 which at least allows some more time to assess the viability and affordability of this scheme.

But within this consultation there remains the constant refrain of threat and coercion rather than conciliation and encouragement. For example, we are told that: “Private landlords would be subject to civil penalties if they don’t meet the minimum energy efficiency standard after 2028.” Not enough encouragement for the private rented sector (PRS) or concern over the affordability or timescale but simply an edict that this must be done by this date or else.

Homeowners are told that: “if it becomes evident that not enough properties are complying with the Standard, we may think about other tools to help us achieve this, including wider civil penalties.” Some of there may include higher council taxes or changes to the land and building transaction tax (LBTT) but this remains under review.

Mortgages or home insurance may become dependent on EPC ratings (Picture: stock.adobe.com)

But happily, the consultation paper goes on to state that: “We do not propose to prohibit the sale of properties which do not meet the minimum energy standard by, or after, the backstop dates.” Well, that’s good!

In a paper where the words prohibit and prohibited appear 13 times and penalties eight times this doesn’t sound like much of a consultation but more of an edict.

With house prices likely to be affected by a policy which states that new heating systems will have to be installed in as short a period as two years after a property is sold and that they are consulting with the finance sector on whether mortgages or home insurance may be dependent on suitable EPC ratings this sounds more stick than carrot.

But it is also the lack of detail on cost, implementation, and delivery that is of greater concern. While much is made of the availability of grants there is £1.8bn available against an anticipated £32bn of costs so most homeowners will be paying the full price of this work.

David Alexander is CEO of DJ Alexander Scotland Ltd (Picture: Laurence Winram)

There is also considerable ambiguity on how this proposal is to be implemented as the consultation admits that “certain types of properties may have limited options for clean heating systems in the near term. This includes, for example, flats, homes that aren’t suitable for certain energy efficiency upgrades, or properties in areas that don’t have sufficient electrical grid capacity.”

Given that tenements comprise around 40 per cent of total housing stock in Scotland it would surely make more sense to have a consultation which reflected the true make-up of property in Scotland with appropriate options. Instead, we seem to have a one-size-fits all-offering which will satisfy few and may frustrate many more.

We have a proposal that sets a later date for achievement but little detail on how we get there. What we need is a proper review of the Scottish housing stock and what systems would be suitable to make it more environmentally friendly. We need this to be an appropriate consultation across the sector to examine the financing of these proposals, the achievability of the timescale, and a full explanation of the benefits to individuals and business owners. What this policy needs is encouragement rather than punishment.

Too often there seems to be recourse to threats rather than explanation. Most people will be in agreement with the principles but will question the implementation. We need more reaching out to homeowners and landlords rather than this constant cajoling and badgering and excessive use of words like prohibit and penalty.

David Alexander is CEO of DJ Alexander Scotland Ltd

Boiler consultation needs a more conciliatory tone - David Alexander

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