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Proposals on improving the energy performance of existing non-domestic buildings in Scotland

Follow the link for our response to the Scottish Government’s consultation on Improving the Energy Performance of Existing Non-Domestic Buildings.

In summary we welcome the Government’s consultation on this crucial issue, and are broadly supportive of the proposals set out in the consultation document. In particular, we welcome the implicit acknowledgements that neither ‘business as usual’ nor voluntary measures alone will deliver the emissions cuts required.

However, we would like to see where emissions cuts from the non-domestic sector sit within a wider energy saving strategy for Scotland. Setting the outlined measures in a wider context of energy efficiency and microgeneration is, in our view essential. We have already seen dissonance in approaches between the domestic and non-domestic sectors, for example in a consultation on permitted development rights for microgeneration in the domestic sector only. In our view this betrays the lack of a strategic approach to energy saving from the Scottish Government which is disappointing.

Finally, it is in our view essential that clear signals are sent from Government to industry in order to allow them to invest with confidence. Such clear signals can best be sent, in our view, through setting sectoral targets into the face of primary legislation, ideally the forthcoming Climate Change Bill. If Government is serious about delivering the emissions cuts that it says are needed, then these statutory sectoral targets are essential.

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