The Scottish Government has published the Energy Efficiency Scotland Route Map. The policy statement shows the direction of travel up to 2040. The part of the route map relevant to commercial property states:
Energy efficiency in non-domestic buildings
There are approximately 200,000 non-domestic buildings in Scotland, and these vary widely in terms of construction, size, and in particular their use, whether it's as shops, offices, factories, warehouses, or hotels. The diverse nature of non-domestic buildings means we know less about their energy performance compared with those in the domestic sector. As of July 2017 there were around 30,000 non-domestic buildings with an EPC assessment.
Energy efficiency standards in the non-domestic sector
Given the wide variety of building size and use in the non-domestic sector, we are proposing to move to a benchmarking system for assessing energy efficiency and are seeking views on this in the Energy Efficient Scotland consultation.
We are also proposing to build on the current Non-Domestic Energy Efficiency (NDEE) regulations under the Climate Change (Scotland) Act. These currently only apply to buildings over 1,000m2, and buildings can defer improvement by reporting their energy use. By 2040 we aim to have extended the regulations to all non-domestic buildings, and for them to be improved to the extent that this is technically feasible and cost effective. We will phase in the regulations so that they are extended to progressively smaller buildings over time.
We will consult further on our plans for the non-domestic sector in 2019 and set out our proposals for this sector by 2020, ahead of new regulations commencing in 2021.
EPCA Commentary - What does it all this mean?
Section 63 Action Plans were introduced in 2016, and required Building Owners to make energy efficiency improvements to existing buildings for the first time. The Scottish Government made it clear at the time that this was a first step on the road to meeting the overall improvement required by 2040.
At the moment, Section 63 Action Plans apply to buildings over 1,000 sqm, and actions can be deferred. The new Route Map now states that by 2040 Section 63 Action Plan will be required for all buildings, with no deferment of actions. By 2021 we will have updated regulations setting out the interim stages to get us to 2040. Our guess would be that Section 63 Action Plans will be required for buildings over 500 sqm from 2021, with provision in the regulations for a further drop in the minimum area to 250 sqm by the mid-late 2020's. We would anticipate the option to defer will also be curtailed in 2021.
Interestingly, the Scottish Government is also open to benchmarking EPC's against use class, bringing the Scottish system more into line with EPC practice in England & Wales.