Memorandum by the Energy Saving Trust
(EST) (DHB 15)
The Energy Saving Trust is the lead organisation
for promoting energy efficiency to households within the UK. Energy
efficiency has social benefits (alleviating fuel poverty), environmental
benefits (tackling climate change) and economic benefits (saving
money for the householder, and for the nation as a whole). We
are therefore happy to see legislation that will lead to an improvement
in the energy performance of housing. From this perspective, our
views on the draft Housing Bill are as follows:
Overall: The Housing Bill has the potential
to lead to significant improvements in domestic energy efficiency,
with the Home Information Pack in particular leading to a massive
increase in energy efficiency activity. We therefore support the
intentions of the Bill, and look forward to its being enacted
with its major provisions intact.
Part 1 Housing Conditions: We support the introduction
of a Housing Health and Safety Rating System (HHSRS), that will
more accurately reflect the quality of a home than did the fitness
standard. Cold, damp accommodation constitutes one of the highest
health and safety risks for a householder (as reflected in the
HHSRS)—It contributes to an excess winter mortality within
the UK of some 40,000 per annum, and many more illnesses and home
accidents (falls, etc.). We hope that the new HHSRS system will
lead to better management of the problem.
Parts 2-4 Licensing: We support the attempt
to license HMOs, and to allow the licensing of private sector
landlords where appropriate. Such accommodation accounts for some
of the worst performing housing within the UK, in energy terms—Some
11% of the UK's four million or so fuel poor are housed in these
sectors. Yet, owing to issues relating to property management
and ownership, these very people are the most difficult to reach
with energy efficiency grants, advice, and other forms of assistance.
It is therefore important that the energy performance
of the property is taken into account in licensing schemes. Unfortunately,
the draft Bill does not provide reassurance on this point. It
refers to "home condition," but in the past—and
indeed, later on in the Bill and in ODPM's associated consultation
on the Home Information Pack—the term "home condition"
has been deemed not to include energy efficiency. We therefore
propose the following addition on the scope of licensing:
Clause 65 line 38: insert c) impose energy efficiency
requirements
Clause 86 line 11: insert c) impose energy efficiency
requirements
Part 5 Home Information Packs: We support the
introduction of mandatory home information packs as part of the
home purchase process. Government, the Energy Saving Trust, energy
suppliers, and others currently go to great effort to reach people
with the energy efficiency message, and to direct them to the
best course of action. The EST's network of Energy Efficiency
Advice Centres alone services over half a million households a
year with consumer-friendly, personalised advice, that is proven
to be highly effective. The Home Information Pack could make this
job a lot easier; home purchase is one of the major trigger points
for home improvement, and some three million homes are sold annually.
Therefore, an energy efficiency report within the pack—as
set out in the draft Bill—has the potential massively to
accelerate activity under the UK's climate change and fuel poverty
programmes.
The ODPM consultation on the contents of the
Home Information Pack and the associated energy efficiency assessment
suggests the consideration of the full energy efficiency performance
of the property (including insulation and heating), and the provision
of tailored advice (rather than less effective standardised information).
Nevertheless, EST would be reassured if the legislation itself
explicitly required these measures, i.e:
Clause 144 line 30, insert: c) … the energy
efficiency of the property, including building services, and property-specific
advice for improvements
Finally, the Energy Saving Trust has developed,
on behalf of Government, a Homes Energy Efficiency Database (HEED),
in which information on energy efficiency measures is compiled
from a variety of sources (energy suppliers, EEACs, etc.). HEED
will help build up a picture of progress on energy efficiency
over time and by area; help local authorities with their reporting
under the Home Energy Conservation Act (HECA); and enable efficient
targeting of energy efficiency initiatives. The systematic provision
of energy efficiency information from the Home Condition Report
databank to HEED would be very useful to further these objectives.
It would be helpful if the Housing Bill could ensure that Data
Protection issues do not prevent the provision of energy efficiency
information to HEED.
It is very important for the cause of energy
efficiency that the Housing Bill is enacted on this basis. European
legislation (the Energy Performance in Buildings Directive) requires
the UK Government to introduce energy efficiency assessments upon
purchase, by 2005. If the current opportunity is foregone, there
is every likelihood that the process for complying with the Directive
will be rushed and inadequately implemented, with households,
industry, and the environment all losing out.
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