This week the Scottish Property Federation submitted comments to the Scottish Government questioning their proposals for a new assessment of carbon and energy performance that would be imposed on some 200,000 commercial properties in Scotland.

SPF are concerned with the proposals for ACEPs to require 'cost-effective'  mandatory improvements by property owners.  This is against a backdrop of existing legislation bringing forward the need for Energy Performance Certificates for the sale or letting of commercial properties from 4th January and a new draft Energy Performance of Buildings Directive at the EU level.

Other issues raised include:

• the need for an operational rating approach to be adopted by the Scottish Government
• differences between methodologies between England & Wales and Scottish EPCs
• the need for the government to understand the landlord-tenant relationship
• making use of BPF's Landlord Energy Statement-Tenant Energy review toolkit   

The full SPF response may be viewed here.