Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by the Association for the Conservation of Energy (DHB 11)


  1.1  We welcome the Housing Bill: there is much in it that will increase the standard of housing for very many people. We also welcome the opportunity to comment on the draft Bill: and would emphasize that our focus on some shortcomings should not detract from those earlier words.

  1.2  This response is confined to the parts of the draft Housing Bill that are relevant for those interested in fuel poverty and domestic energy efficiency. These are explained below.


    —  A specific provision enabling an HMO licence to include energy efficiency standards.

    —  A specific provision enabling the selective licences for other residential property to include energy efficiency standards.

    —  A specific requirement for the home information packs to include details of the energy efficiency of the heating system in the property.

    —  A specific requirement for the home information packs to include energy efficiency advice relating specifically to the property concerned.


  3.1  Clause 65(3) lists the five conditions that licenses may impose on a landlord. The relevant provision is:

    "(3) The provisions of a license may, in particular

    (a)  . . .

    (b)  impose conditions relating to the condition of the house or its contents or the amenities available to its occupants or persons visiting it".

  3.2  From the point of view of energy efficiency and fuel poverty this is unsatisfactory. Historically "conditions of the house" has not included energy efficiency. It is crucial from a policy point of view that this point is clarified because of the large numbers of fuel poor living in private rented accommodation and the CO2 effects of the poor standard of thermal insulation in much of this sector. It is also crucial from a legal point of view: any lack of clarity could lead to challenges as to the meaning of "conditions' and whether it can extend to energy efficiency.

  3.3  Suggested Amendment.

  In view of the fact that the Government, during the passage of the Home Energy Conservation Bill in the last session, both accepted and indeed tabled amendments to that Bill at Committee Stage enabling conditions to be set for energy efficiency we strongly recommend that the best (and presumably completely uncontroversial) way of clarifying this matter is for an additional paragraph to be inserted in the Housing Bill, based on the wording of the Government's own amendment to the Home Energy Conservation Bill. The clause tabled by the Minister, the Rt Hon Michael Meacher for the Committee Stage of that Bill, and which was agreed by the Committee read:

  "The standards that may be prescribed in the regulations include . . . (b) energy efficiency standards"

  Thus the suggested amendment to the Housing Bill would be:

  Page 30* clause 65 line 38 at end insert:

    (c)  impose energy efficiency standards"

  (* That is page 30 of the draft Bill. This appears on page 71 of the consultation document).


  4.1  For the same reason as above, namely the number of people in fuel poverty in the private rented sector, the energy inefficiency of private rented housing and resulting CO2 emissions and legal clarity we recommend that such licences should also be able to include an energy efficiency provision.

  4.2  Suggested Amendment.

  Page 42* clause 86 line 11 at end insert:

    (c)  impose energy efficiency standards"

  (* That is page 42 of the draft Bill. This appears on page 83 of the consultation document).


  5.1  In clause 144(5) "the energy efficiency of the property" is made a requirement of the packs. This is welcome. However, we suggest a specific provision relating to the heating system in the property, for two reasons:

    —  Because it is not clear whether the existing provision extends to the heating system; but more importantly, even if it is meant to so do a specific requirement is important because;

    —  It is essential, from a CO2 reduction point of view that every effort is made to draw buyers' attention to the importance in terms of both energy and monetary saving of efficiency or inefficiency of heating systems because this is the one decision that purchasers may take that cannot easily or cheaply be changed. For instance, a purchaser may decide not to install cavity wall insulation immediately but change his/her mind in a year or two with little extra cost or inconvenience (beyond that of not having enjoyed the benefits). In the case of a heating system this is not the case—and society will be left with the CO2 implications for 15 years. We must, therefore make every reasonable attempt to draw this issue to the attention of purchasers.

  5.2  Suggested Amendment.

  Page 70* clause 144 line 30 at end insert:

    (c)  the energy efficiency of any heating system present in the property"

  (* That is page 70 of the draft Bill. This appears on page 111 of the consultation document).

  5.3  In addition we believe that it is not just important to require the provision of energy efficiency information, but also the provision of energy efficiency advice (eg in terms of energy and monetary savings and "pay-back" periods etc)—in order to increase the effective installation of energy efficiency measures. The experience of the very effective Energy Efficiency Advice Centres (as highlighted by the National Audit Office) shows the importance of such advice in increasing the installation of measures.

  5.4  Suggested Amendment.

  Page 70* clause 144 line 37 at end insert:

    (b)  energy efficiency advice related to the property; and"

  (* That is page 70 of the draft Bill. This appears on page 111 of the consultation document).

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2003
Prepared 12 June 2003