Response ID ANON-21GM-FAAD-3

Transcription

1 Response ID ANON-21GM-FAAD-3 Submitted to Energy efficiency and condition standards in private rented housing: A Scotland s Energy Efficiency Programme Consultation Submitted on :53:41 Part 1 energy efficiency standards 1.1 Do you think that only tenancies covered by the repairing standard should have to meet minimum energy efficiency standards? Don't know If not, what other privately rented tenancies do you think should be included? : in reality, any property where the occupier is required to pay the energy bill, should fall into line with the scope of the regulations. The government needs to consider whether listed buildings are part of the regulations, and also if they are required to have an EPC by law when sold or rented. At present, the guidance, in the various administrations is varied and hard to understand. Listed buildings 1.2 We propose to link the minimum energy efficiency standard to the energy performance certificate as we think this is the most suitable mechanism. Comments: RdSAP is a recognised standardised methodology that lends itself well to measuring a dwelling against a standard. RdSAP is being used in E&W for the MEES regulations. 1.3 (a) Do you think there are elements of the energy performance certificate assessment that would need to be altered to support a minimum energy efficiency standard? No If so, what areas do you think would need to be changed and what evidence can you offer to support your view?: No however, please consider the audit of EPCs. Whenever a minimum rating is required, there is a risk that the EPC could be manipulated to achieve the rating. Schemes are currently creating a smart audit process which can be altered if industry uses the EPC in such a way as MEES/SEEP. This should provide a deterrent and also increase confidence in the report. 1.4 Do you think that the minimum energy efficiency standard for private rented properties should be set at an energy efficiency rating of E in the first instance? it provides an achievable starting point for the regulations to work from, and would see the worst performing dwellings brought up to a standard whilst balancing the cost of achieving the standard. Stroma feels that setting the standard higher, would provide a barrier that would be hard to overcome in the early stages of the regulations, and would result in more exemptions from the process. 1.5 Do you think that the minimum energy efficiency standard should first of all apply only to those properties where there is a change in tenancy, and after that to all private rented properties? it provides a sensible mechanism in line with the EPBD requirements to ensure the standard is achieved at the point of tenancy change (transaction). By then setting a back stop date, there would be a more comfortable transition to the regulations. 1.6 Do you think that 1 April 2019 is the right date to start applying the minimum standard of E when there is a change in tenancy? it gives enough notice to all involved in the rental sector (agents, landlords and tenants). It also gives those involved a year to see how similar regulations are applied in E&W. 1.7 Do you think that 31 March 2022 is the right date by which all privately rented properties would need to meet the minimum standard? this is a reasonable time period to allow all landlords and letting agents/managing agents/ factors to prepare and improve properties. 1.8 Where a property has an EPC of F or G at the point of rental:

2 Please explain your answers. : (a) do you think that we should require the owner to carry out a minimum standards assessment before renting the property out? otherwise the occupant will be incurring higher bills in a less comfortable home, and also be disrupted by remedial works. The void period is always the best time to do any works to the property. (b) do you think that we should allow a period of six months from the date of the minimum standards assessment to carry out the improvement identified by the assessment? if enough time/notice is given to landlords and the industry, then work should be done prior to the implementation date. Adding any extensions carte blanche will ensure that most landlords will take this extra time. Extensions to the time period should be means tested based on exceptions. (c) do you think that the owner should have to provide a post-improvement EPC to prove that the necessary improvements have been made?, definitely. This would ensure that the most up to date information was available on the register and would also give any prospective interested party (new tenant etc) confidence in the efficiency of the property. The DEA would gather evidence as part of the visit to show that work had taken place. 1.9 We think that all privately rented properties should have to meet the minimum standard by 31 March Where a property does not have an EPC of E: Please explain your answers. : (a) do you think that we should require the owner to carry out a minimum standards assessment by 30 September 2021 (the backstop assessment date)? this way all properties in the PRS sector will have a valid, up to date EPC and this data will have uses for future policy direction. All tenants will have up to date information on the property they are/will be renting and can make informed decisions. The date gives landlords 6 months to complete the recommendations to meet the minimum standard. (b) do you think that we should allow a period of six months from the backstop assessment date to carry out the improvement identified by the minimum standards assessment? this would be a reasonable time to allow for landlords to compete the works. Even if demand is great, six months should be sufficient. (c) do you think that the owner should have to provide a post-improvement EPC to prove that the necessary improvements have been made?, definitely. This would ensure that the most up to date information was available on the register and would also give any prospective interested party (new tenant etc) confidence in the efficiency of the property. The DEA would gather evidence as part of the visit to show that work had taken place We are proposing that there should be a new minimum standards assessment based on the EPC methodology that will tell an owner how to bring their property up to standard. Please tell us your views on the following elements of that proposal: It would be logical for both aspects to be based on the same methodology (RdSAP) to avoid confusion in the reporting. Using an occupancy assessment would mean a more accurate savings figure (if the full range of data were available), however the occupancy of rental properties tends to change quite regularly so introducing a methodology like Occupancy Assessment seems illogical. However a GDA is more knowledgeable and better able to deal with in-property interactions required when putting together packages of suitable measures. The RdSAP methodology is applied by qualified DEAs. Unfortunately, the DEA qualification doesn t cover when a measure is unsuitable/appropriate. It is

3 therefore necessary to consider some form of upskill training to cover this aspect of the Assessment. This would mean that all DEAs would have the opportunity to partake in the new assessment; at a low fee (the DEA scheme underwent a similar upskill in 2012 for RdSAP 9.91 and it cost around 80 for the exam). Alternatively, GDAs already possess the skills and knowledge to build packages of appropriate measures, and understand the Golden Rule. These would seem to be applicable to the proposed assessment, and these assessors are already trained. If the rating of D is being set for a future date, then it would be logical to set this in the plan as a stretch target, therefore, giving the landlord an opportunity to do the work once and therefore potentially save money with in the package of measures. Landlords would not take kindly to achieving the minimum standard and then three years later, told that they need to do more work. Similarly, lenders may want properties to achieve the future minimum standard so that they have certainty when lending. An EPC should be calculated AND lodged on the register. Without doing this (I.e. just a calculation) would result in a number of issues the register would allow proof that the landlord knew that their property had not achieved the minimum standard and then rented it anyway (for example). The most up to date methodology should be used (9.92 or more recent) as older methodologies are difficult to compare with. It is also fair to state that older EPCs are more likely to contain old, out of date information. No alternatives considered The market will naturally dictate the price; however the time associated in doing the assessment should be reflected in the fee. If an EPC is required plus the assessment then this should be reflected in the fee Do you think that the assessment should only recommend a package of measures which improves both the energy efficiency and the environmental impact scores of the property? Given that most EPC measures do affect both, then it would seem logical to only allow measures that improve both scores. There is little point in trying to achieve one without the other We propose to develop a new role of minimum standards assessor. The role seems to be different to that of a DEA as per the answer given in 1.10b; The RdSAP methodology is applied by qualified DEAs. Unfortunately, the DEA qualification doesn t cover when a measure is unsuitable/appropriate plus the provision of advice on what the package should be. It is therefore necessary to consider some form of upskill training to cover this aspect of the Assessment. This would mean that all DEAs would have the opportunity to partake in the new assessment; at a low fee (the DEA scheme underwent a similar upskill in 2012 for RdSAP 9.91 and it cost around 80 for the exam). Alternatively, GDAs already possess the skills and knowledge to build packages of appropriate measures, and understand the Golden Rule. These would seem to be applicable to the proposed assessment, and these assessors are already trained. Stroma would like to see GDAs considered as suitable for the role, but also allow DEAs to upskill if a suitable gap analysis can be performed to highlight the areas of training required. In reality, it appears that the ability to give advice on suitable applicable measures, identifying low cost measure and those measure that meet the Golden Rule, in that they pay for themselves etc. Software would also be considered, and therefore the training on this platform would seem necessary as part of the new skill set. This could happen fairly quickly, and certainly before Once the scope of the role is known, then a set of learning criteria could be created. This would be based on the gap between the current skill set of DEA and what would be required. Alternatively, if GDA is chosen as the qualification/level of knowledge and skill, then these assessors could be made ready once guidance documents and any software needed was in place. The current EPC register keeper (EST) could be the logical choice.

4 1.13 What are your views on the existing advice and information provision provided by Scottish Government for landlords and tenants? What changes, if any, do you think are required? What are your views on the existing advice and information provision provided by Scottish Government for landlords and tenants? What changes, if any, do you think are required? : Stroma has no views at this time, only that the guidance needs to be clear, timely and easy to locate and distribute. When new guidance is available then this should be highlighted to interested parties What financial or fiscal incentives support such as grant and loans, tax or otherwise - would you find most useful to help to accelerate the installation of energy efficiency measures and help landlords meet any proposed standards? What financial or fiscal incentives support such as grant and loans, tax or otherwise - would you find most useful to help to accelerate the installation of energy efficiency measures and help landlords meet any proposed standards?: It would seem a logical argument that an improved, more energy efficient property will be worth more, and be easier to rent, possible at a higher rental fee. Stroma do not consider financial incentives as the best way forward for this sector. However, Scotland are leading the way in improvements to home energy efficiency, and schemes like the Home Energy Scotland Loan look to be a positive way to help current landlords and homeowners (who could be landlords in the future) What impact do you think the introduction of minimum standards would have on local supply chains for energy efficiency works? What impact do you think the introduction of minimum standards would have on local supply chains for energy efficiency works?: It will increase demand on the supply chain, but in the early stages, the demand wont be significant as the number of sub-e rated properties is not great. However, the demand for specific skill on historic buildings may be higher than the current experienced workforce can supply. However Stroma has no evidence that can support either of these hypothesises Do you think it would be helpful for assessors and installers to have a traditional buildings qualification that raises awareness and understanding of energy efficiency measures for older, traditional or vulnerable buildings built prior to 1919? From an assessor perspective, this should be incorporated into any upskill process. Whilst a separate qualification is desirable, it would limit the pool of assessors initially and would prove a financial blocker for a prospective assessor Do you think there are additional consumer protection safeguards the Scottish Government should consider for the private rented sector? Stroma are mindful that landlords should not be encouraged to evict tenants if they are not willing to achieve the minimum standard. Doing so would cause unnecessary hardship to tenants who are currently occupying these properties. Where the property is vacant and not achieving the minimum standard, then Stroma suggest that the property cannot be rented out until the property is brought up to the standard. This should help protect any potential tenant. In addition, it would be sensible to require that the Minimum Standards Report is QA d to ensure that it has be completed correctly, impartially, is accurate and appropriate. The quality of installed work should be regularly checked. A PAS 2030 accreditation for installers would seem to be a sensible standard to enforce, which brings QA and consumer protection with it Do you think that local authorities should be responsible for enforcing the standard? If not, why not, and what alternative would you suggest?: In E&W the Local Weights and Measures Authority is being made responsible for MEES enforcement. Stroma can see the logic in this as they are already charged with enforcing the EPC. As described in the consultation document, if the local authority currently has powers of enforcement in the PRS then this is a logical conclusion. As long as the responsible body or department can make the necessary checks at the enforceable trigger points (i.e. they know when a tenancy changes etc), then they should be able to enforce the standards Do you think that the penalty for not complying with the standard should be a civil fine against the owner?

5 If not, why not, and what alternative would you suggest?: This would a logical penalty to the person(s) responsible for the property We have proposed the following fines: The fines are far higher in E&W, but if enforced fully, then they would be deterrent to avoidance of the standards, in a staged way. However, both fines should be the same, otherwise not having an assessments (which is key to the process) would be seen as an easier way out. If the government is suggesting that the EPC fine can also be levied at the point of the fine for not having a MS Assessment, then this would be line with the 1000 fine We have proposed some specific situations where owners should have longer than six months to bring their properties up to the minimum standard. Do you have any comments on these proposed situations in relation to: Please explain your answers.: (a) the proposed reasons? None - the reasons outline/suggested seem comprehensive enough. (b) what evidence you think the landlord would need to provide for each? Technical = A chartered surveyors report or report from the expert that states why a measure cannot be installed following detailed/invasive inspection. Legal = Signed disclaimers showing that permission has not been granted with a particular stakeholder (Tenant, Superior Landlord, Lender etc) Excessive cost = A written and signed statement from an installer stating that a measure or package of measures exceed the 5000 cap for each EPC band. Stroma strongly advises that all cost effective measures are installed even if the property cannot achieve the minimum standard. (c) should there be other situations, such as the completion of condition works? This is not within Stroma s competency to answer We have proposed some situations where we think owners should not be penalised for not carrying out the full improvement identified by the minimum standards assessment. Do you have any comments in these in relation to: Please explain your answers.: Only to repeat that Stroma strongly advises that all cost effective, permissible and legitimate measures are installed even if the property cannot achieve the minimum standard. However, Scottish Government should be mindful of any overly inflated process that may come about as a result of this cap inflating the price to a point where the packages become cost prohibitive, in order to exempt the standard from being met should be challenged. In this example Stroma suggests that at least 3 quotes are obtained to prove such an eventuality. (d) the proposal that this would remain valid for a period of not more than 5 years? The five year period proposed is a reasonable time frame that balances the likelihood of the exemption situation changing (new tenants, new technologies, costs of measures changing), with a mechanism that allows fairness for the Landlord. It means that a property may be required to improve to the relevant standard in the future For local authorities to be able to enforce and monitor the proposed minimum standards: Please explain your answers.: This is not within Stroma s competency to answer, however there definitely needs to be a mechanism in place for the local authority to be notified when a tenancy agreement is renewed. Currently Stroma is not aware of how this can work in practice. When a new tenant takes tenancy of a dwelling, the property will have been marketed, and a checked for the EPC would need to be made. However, it is not immediately obvious how the process would work for renewals. If this problem wasnt resolved, the we could see existing tenants continuing to rent properties that dont meet the minimum standard - up until the backstop date, when all properties must meet the standard. Again, there would need to be sufficient information on an accurate and up to date database of all private rented properties to ensure that compliance is checked and enforcement is fair, thorough and effective. See above

6 1.24 What opportunities do you think there are to combine enforcement of minimum energy efficiency standards with other action in the private rented sector? This is not within Stroma s competency to answer 1.25 Do you think that we should set out now the minimum energy efficiency standard after 2022? This would create certainty within the sector and would allow Landlords and other stakeholder to plan in advance. Likewise, properties can be brought up to the next standard at the same time as achieving the initial E standard, which can save landlord the cost of doing two sets of improvements and save tenants unnecessary disruption Do you think that the next standard should be to meet an EPC of D at point of rental from 1 April 2022, and in all privately rented properties by 31 March 2025? A C band rating would be a large step and would face strong resistance from Landlords. The expense of moving from an E to a D is far less and in theory properties can be brought straight up to a D rating, without incorporating the higher cost measure in many circumstance When increasing the standard to EPC D, we propose that the cost cap will be 5000 for properties with an EPC of E, and 10,000 for properties with an EPC of F or G (which would include any spend made to improve the property previously following a minimum standards assessment). Please tell us your views about this proposed cap. When increasing the standard to EPC D, we propose that the cost cap will be 5000 for properties with an EPC of E, and 10,000 for properties with an EPC of F or G (which would include any spend made to improve the property previously following a minimum standards assessment). Please tell us your views about this proposed cap. : In E&W, measures are considered individually. This methodology seems to limit the work to the low cost, high savings measures only. This in turn would make achieving the minimum standard difficult in some cases. Setting a cap for the package of measures seems far easier to understand for all stakeholders, and would be easier to implement and enforce. However, Scottish Government should be mindful of any overly inflated process that may come about as a result of this cap inflating the price to a point where the packages become cost prohibitive, in order to exempt the standard from being met should be challenged. In this example Stroma suggests that at least 3 quotes are obtained to prove such an eventuality What are your views on the provisions in general for exceptions to the D standard, including that a property which has an exception from meeting E should not automatically be excepted from meeting D? A previously exempt property should always be assessed against to see if it is exempt from achieving the minimum standard, even if that standard has increased. Again, Stroma would like Scottish Government to ensure that property is brought up to the highest possible standard, even if the property cannot achieve the minimum standard. With the cost of measures coming down over time (economies of scale, cost of materials) then it is possible that a measure that was cost prohibitive in 2019 would not necessarily be so in What do you think the main benefits would be of introducing a minimum standard higher than D? A greater ability for the landlord to rent (or sell) the property. If the landlord were to sell the property after achieving a higher than D standard, then lenders may be more willing to lend full amounts to the new buyer, as the lender would consider this a wiser investment (in that it can be rented in the future, even if the standards were to increase again). We are seeing similar impacts in E&W as MEES approaches. In terms of the tenant, they would definitely benefit from warmer, easier to heat accommodation, and a reduction in fuel poverty in most cases. We would also see a increase in the use of renewable (in order to achieve higher standards). This would result in driving economies of scale in the production and installation of such technologies in the same way FIT achieved for PV, which in theory will reduce install costs, and therefore making higher ratings more achievable We think that any increase in the standard beyond D would bring new challenges in the form of cost, technical considerations and alignment with the Climate Change Plan. Please explain your answers.: (b) How do you think we could address these challenges if we raised the minimum standard beyond energy efficiency rating of D? Making it easy for Landlords to access the various funding mechanisms available to them - ECO, Home loans, FIT, RHI etc. This can be achieved by working with

7 the sector, Landlords associations and letting agents so that all options are clearly sign posted Please tell us about any potential economic or regulatory impacts, either positive or negative, that you feel the legislative proposals in Part 1 of this consultation document may have, particularly on businesses (including landlords). Please tell us about any potential economic or regulatory impacts, either positive or negative, that you feel the legislative proposals in Part 1 of this consultation document may have, particularly on businesses (including landlords)?: 1.32 In relation to the interim Equality Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 1 of this consultation document may have on any groups of people with protected characteristics. We would particularly welcome comments from representative organisations and charities that work with groups of people with protected characteristics. In relation to the interim Equality Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 1 of this consultation document may have on any groups of people with protected characteristics? We would particularly welcome comments from representative organisations and charities that work with groups of people with protected characteristics. : This is not with Stroma s competency to answer To help inform the development of the Child Rights and Wellbeing Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 1 of this consultation document may have on children s rights and welfare? We would particularly welcome comments from groups or charities that work with young people. In relation to the Child Rights and Wellbeing Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 1 of this consultation document may have on children s rights and welfare? We would particularly welcome comments from groups or charities that work with young people. : This is not with Stroma s competency to answer Do you have any suggestions for the monitoring and review framework? Do you have any suggestions for the monitoring and review framework?: Both frameworks look reasonable and sensible 1.35 Do you have any other comments on the proposals set out in Part 1 of this consultation? Do you have any other comments on the proposals set out in Part 1 of this consultation?: Stroma would like to thank the Scottish Government for giving industry stakeholders the opportunity to be consulted and feedback thoughts and opinions on this subject. The priority here is for the process to be made a simple as possible to; a) Understand b) Implement c) Enforce The costs should also be kept low for landlords and protection must be given to tenants to avoid them being the victim of landlords who are not willing to improve properties, but also protect landlords from being taken advantage of by installers, due to the requirement to improve their investments. Stroma looks forward to being part of the process of making the standards a reality. Part 2 Condition standards 2.1 Do you think that ensuring a house complies with the tolerable standard should be part of a private landlord s duties under the repairing standard? 2.2 Do you think that private rented housing should meet a minimum standard for safe kitchens? 2.3 If this is introduced, what exceptions (if any) do you think would be needed? If this is introduced, what exceptions (if any) do you think would be needed?: 2.4 Do you think that private rented housing should have a minimum standard for food storage space? 2.5 If this is introduced, what exceptions (if any) do you think would be needed?

8 If this is introduced, what exceptions (if any) do you think would be needed?: 2.6 Do you think that private rented housing should have a fixed heating system? 2.7 If this is introduced, what exceptions (if any) do you think would be needed? If this is introduced, what exceptions (if any) do you think would be needed?: 2.8 Do you think that private rented housing should be free of lead pipes from the boundary stopcock to the kitchen tap? 2.9 If it is not possible to establish whether or not there are any lead pipes from the boundary stopcock to the kitchen tap, do you think a water quality test should be carried out before the tenancy commences? 2.10 Do you think that private rented housing should meet a minimum standard for (a) safe access and (b) safe use of common facilities provided with the tenancy? 2.11 If this is introduced, what exceptions (if any) do you think would be needed? If this is introduced, what exceptions (if any) do you think would be needed?: 2.12 Do you think that private rented housing should meet a minimum standard for safe and secure common doors? 2.13 Do you think that baths and bidets in private rented housing should be fitted with thermostatic mixing valves (or similar measures)? 2.14 Do you think that electrical installations in private rented housing should be fitted with residual current devices? 2.15 A qualified specialist must be employed for any work that involves removing or disturbing asbestos. Asbestos surveys ensure that a landlord knows when a qualified specialist must be used Do you think that the repairing standard should be amended to include a duty on landlords of private rented properties with a private water supply, covering (a) risk assessment of the supply, and (b) annual water quality testing? 2.17 Do you think that the repairing standard should be amended to include capacity for a fridge/freezer in order to ensure people are able to store food? 2.18 Do you think that private landlords should be required to provide cookers, fridges and freezers? 2.19 Do you think that the repairing standard should be amended to include a specific reference to safety of heating systems using other fuels in addition to gas and electricity? 2.20 Do you think that the repairing standard should be amended to include flooring materials to reduce sound transmitted to other homes? 2.21 What (if any) other measures to reduce sound transmission should be considered?

9 What (if any) other measures to reduce sound transmission should be considered?: 2.22 Do you think anything else should be added to the repairing standard? Do you think anything else should be added to the repairing standard?: 2.23 Do you think that agricultural tenancies, rented crofts and small landholdings should be subject to the repairing standard? 2.24 Do you think that we need to clarify whether holiday lets (or certain types of holiday lets) should be subject to the repairing standard? 2.25 Do you think that there should be a lead-in time of at least 5 years for landlords to comply with any changes to the repairing standard? 2.26 Do you think that different lead-in times for different measures would cause any difficulties for (a) landlords or (b) tenants? Please tell us what difficulties you think could be caused. Do you think that different lead-in times for different measures would cause any difficulties for (a) landlords or (b) tenants? Please tell us what difficulties you think could be caused.: 2.27 Do you think that the timetable for changes should be linked to wider government milestones on climate change? 2.28 Are the current enforcement routes via the housing tribunal appropriate for the proposed new measures in the repairing standard? 2.29 Do you think that rules on exceptional circumstances (where landlords are not required to comply with the repairing standard) should be revised to ensure situations such as technically infeasible work, unreasonable costs and withheld consents are covered? 2.30 Do you have any other views on the measures proposed in relation to: Do you have any other views on the measures proposed in relation to:: 2.31 Please tell us about any potential economic or regulatory impacts, either positive or negative, that you feel the legislative proposals in Part 2 of this consultation document may have, particularly on businesses. Please tell us about any potential economic or regulatory impacts, either positive or negative, that you feel the legislative proposals in Part 2 of this consultation document may have, particularly on businesses?: 2.32 In relation to the interim Equality Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 2 of this consultation document may have on any groups of people with protected characteristics. We would particularly welcome comments from representative organisations and charities that work with groups of people with protected characteristics. In relation to the Equality Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 2 of this consultation document may have on any groups of people with protected characteristics? We would particularly welcome comments from representative organisations and charities that work with groups of people with protected characteristics. : 2.33 To help inform the development of the Child Rights and Wellbeing Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 2 of this consultation document may have on children s rights and welfare. We would particularly welcome comments from groups or charities that work with young people. In relation to the Child Rights and Wellbeing Impact Assessment, please tell us about any potential impacts, either positive or negative, that you feel the proposals in Part 2 of this consultation document may have on children s rights and welfare? We would particularly welcome comments from groups or charities that work with young people. : About You What is your name?

10 Name: Andrew Parkin What is your address? Are you responding as an individual or an organisation? Organisation What is your organisation? Organisation: Stroma Certification Ltd The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference: Publish response only (without name) We will share your response internally with other Scottish Government policy teams who may be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for Scottish Government to contact you again in relation to this consultation exercise? Evaluation Please help us improve our consultations by answering the questions below. (Responses to the evaluation will not be published.) Matrix 1 - How satisfied were you with this consultation?: Slightly satisfied Please enter comments here.: It was probably too long. It would have been easier if the sections were released periodically to those who has signed up as an interested party. Matrix 1 - How would you rate your satisfaction with using this platform (Citizen Space) to respond to this consultation?: Very satisfied Please enter comments here.: