Scottish Government consultation on energy efficiency and repairs in the PRS Shelter Scotland response

The private rented sector has almost tripled since 1999 and has increasingly become the home of families, as more are priced out of home ownership and as social housing demand exceeds supply, even with the increase in supply pledged 2016-21. Whilst many in the private rented sector are happy and there out of choice, for others there are issues of unaffordable rents, poor conditions and unresponsive landlords coupled with a lack of real choice meaning private tenants are unable to vote with their feet and move, and their consumer voice is
limited. Over half of all clients coming to Shelter Scotland in 2016-17 were from people in the private rented sector, with one of the top 3 reasons being for conditions.

The passing of legislation to implement the new model tenancy, alongside changes to the dispute resolution process through the introduction of the Housing and Property Chamber of the First Tier Tribunal will help to strengthen the position of private tenants. Shelter Scotland supports the broad principles of the current proposal to regulate for a minimum energy efficiency standard in the private rented sector, as well as to amend the repairing standard, as a means to further level the playing field between private tenants and their counterparts, and as a step towards ensuring everyone in Scotland, no matter what sector they live in, is entitled to a warm, safe and affordable home.

111,000 households in the private rented sector live in fuel poverty in Scotland, i.e. need to spend over 10% of their household income on energy costs to maintain a satisfactory heating regime, equivalent to 33% of the sector. Housing quality varies across the sector, and private tenants live in the most inefficient homes with 9% of properties in the private rented sector in the two lowest energy efficiency bands. By comparison, in the social rented sector, where registered social landlords and local authorities are working towards statutory targets for energy efficiency, just 2% of their stock has the lowest EPC ratings. Regulation, when accompanied with sufficient scrutiny, enforcement and support, is both necessary and effective to achieve the aims set out, and the private rented sector has demonstrated over the last 15 years that regulation is no barrier to growth.