REEPS 7/4
Stakeholder Engagement
Stakeholder Engagement
1. Introduction
The last wider context meeting on 27 May considered proposals on how we engage
with stakeholders who may have an interest in energy efficiency and regulation,
reflecting REEPS’ view that the communications plan should be a two way process.
The wider context subgroup agreed that we should use the summer period to seek
views on the practicalities and process of how regulation would work such as
enforcement and trigger points for regulation.
This paper is to inform REEPS of how we plan to engage with stakeholders over the
summer period, what we plan to discuss with them, and how and when we plan to
use the material to inform the work of REEPS and the subgroups. It also seeks
REEPS’ views on any additional stakeholders we should speak to and what would
be useful to feed into discussions on the design of both regulations and consultation.
2. Purpose of stakeholder engagement
To raise awareness of the forthcoming consultation
 We can tell stakeholders that consultation on regulations for minimum
standards for energy efficiency will be in spring 2015
 The consultation will ask about a date for implementing regulations
 Standards are likely to be on an EPC basis
To seek feedback on general attitudes to and awareness of energy efficiency and
potential regulation
 What could we do to promote take up of energy efficiency measures and raise
awareness of regulation?
 How do they think plans for minimum standards will affect their
group/interests?
 What is the current attitude to energy efficiency in their group/interests?
To seek views on how the process might work and help inform REEPS’ discussion
on non-modelling elements of the proposals
 Trigger points, and how processes for sale and rental currently work
 Where responsibility would sit, eg with the buyer or seller
 How standards could be enforced
 Views on EPCs and their processes
3. How will Stakeholder Engagement fit with REEPS?
We plan to use stakeholder engagement:
(a) To inform the design of the consultation
Discussions over the summer will help to inform the proposed brainstorm at the
September meeting of the wider context subgroup, around how to design the
consultation. This in turn will feed into the October meeting of REEPS.
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REEPS 7/4
Stakeholder Engagement
(b) To provide more thinking on options for trigger points
The discussion on trigger points will build on subgroups’ discussion of trigger points
and customer journeys, to come back to REEPS in August to feed into scenarios
identification.
Trigger points from the ISM literature review were discussed at wider context and
technical subgroups:
 Moving home – eg sale or rental
 Refurbishment or renovation
 Replacing heating systems
Other trigger points were also suggested:
 Consequential improvements
 Area based improvement schemes
We would propose to explore with stakeholders how sale and rental processes
currently work; how they might be used as trigger points for regulation; and also to
identify whether there are other trigger points where action could be encouraged to
be taken.
(c) To explore enforcement routes
The subgroups have only discussed enforcement briefly so far. We will explore this
with the organisations who may be involved in enforcing regulation and who have
experience of enforcing current obligations such as the repairing standard and house
condition. We will use this to inform our discussions at future REEPS meetings on
enforcement routes for minimum standards.
Some of the issues we plan to explore around enforcement routes are:
 How could minimum standards be enforced at point of sale or rental (or other
emerging trigger points)
 Can the obligation to meet minimum standards be passed on to the buyer? If
so, how will this be enforced?
 How similar obligations currently are enforced, for example the repairing
standard and house condition.
 What are the problems with enforcement and how can we overcome them for
REEPS?
 How are similar obligations enforced at conveyancing?
(d) To discuss the role of and awareness of EPCs
The technical and wider context subgroups have both considered how EPCs could
be improved to support regulation. Discussions with stakeholders will look at:


awareness of EPCs both for them and their client groups.
How can EPCs be used to support energy efficiency
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REEPS 7/4
Stakeholder Engagement
4. Impact Assessments
We will use the stakeholder discussions to support evidence gathering for the BRIA
and EQIA processes. The draft impact assessments will be published along with the
consultation.
5. Timetable
Meetings with stakeholders will be on-going from the end of June to allow us to
feedback to REEPS and the subgroups from August.
6. Engaging with owner occupiers and tenants
We recognise that owner occupiers and tenants as groups are missing from our
plans for stakeholder engagement. We will speak to groups such as Age Scotland
and Shelter as a proxy for some groups of owners and tenants, but recognise that
these organisations represent only a limited section of these groups. We will also
explore the possibility of working with Citizens Advice Scotland (CAS) to identify
owners concerns from focus groups. The consultation will seek views from individual
owners and tenants.
7. Questions for REEPS
a) Do you agree that these are the right issues to discuss with stakeholders and
that they will help to contribute to the design of the consultation and
regulations?
b) Are there any further key messages or issues we should be exploring with
stakeholder groups?
c) The interests we plan to cover are: Enforcement (eg COSLA and the Law
Society); Buyers and Sellers (eg estate agents, SPCs); Landlords and Letting
Agents (eg SLE, SAL ARLA) and owners and tenants (Age Scotland, CAS
and Shelter). Are there other stakeholder groups we should speak to?
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