Supplementary Memorandum by National Energy
Action (NEA) (DEC 09 (a))
THE DEFINITION
The definition is intended to provide a measures-based
proxy for affordable warmth and constitutes the main approach
to tackling fuel poverty in social housing. This approach has
been adopted because assessing fuel poverty using the agreed formula
of "needed spend" is complex and intrusive. For the
Thermal Comfort criterion to be acceptable it would have to be
much more rigorous. The ODPM recognises that the Decent Homes
Standard won't eliminate fuel poverty and, by implication, sees
increased household income as the solution.
NEA Recommended Standard for Thermal Comfort
| Controllable central heating[10]
| Insulation standard |
| Gas | 250 mm loft[11] insulation and cavity wall insulation
|
| Oil | 250 mm loft insulation and cavity wall insulation
|
| Controllable central heating |
|
| Electric storage heating | 250 mm loft insulation and cavity wall insulation
|
| Solid fuel | 250 mm loft insulation and cavity wall insulation
|
| Liquid petroleum gas | 250 mm loft insulation and cavity wall insulation
|
| |
Revised Building Regulations will require that, from April
2005, central heating boilers should be highly efficient (A or
B rated). Yet the current guidance to social landlords endorses
A—C rated boilers as the standard to be achieved—another
short-term option.
Loft insulation by tenure and insulation depth
| None |
50mm or less | 75mm
| 100mm | 150mm |
More than
150mm |
| | |
| | |
|
| Owner occupied | 939,000
(6.7%)
| 2,351,000
(16.9%) | 1,907,000
(13.7%)
| 5,713,000
(41.0%) | 1,717,000
(12.3%)
| 282,000
(2.0%) |
Private
rented | 289,000
(14.5%)
| 259,000
(13.0%) | 183,000
(9.2%)
| 511,000
(25.6%) | 111,000
(5.6%)
| 20,000
(1.0%) |
| Local authority | 36,000
(1.4%)
| 417,000
(12.0%) | 398,000
(11.5%)
| 989,000
(28.5%) | 358,000
(10.3%)
| 88,000
(2.5%) |
| RSL | 13,00
(1.4%) | 64,000
(6l.8%)
| 84,000
(8.9%) | 312,000
(33.1%)
| 172,000
(18.3%) | 14,00
(1.5%)
|
| |
| | | |
|
Cavity wall insulation by tenure
| Insulated | Uninsulated
|
| Owner occupied | 1,935,000 (13.9%)
| 7,202,000 (51.7%) |
| Private rented | 102,000 (5.1%)
| 700,000 (35.0%) |
| Local authority | 591,000 (17.1%)
| 2,019,000 (58.2%) |
| RSL | 145,000 (15.5%) | 531,000 (56.5%)
|
| |
|
Feasibility of Changing the Definition
The ODPM Select Committee raised the issue of how feasible
it might be to change the Decent Homes definition. The UK Fuel
Poverty Strategy emphasises that "it is not necessarily the
final statement on how the Government intends to tackle fuel poverty,
since knowledge will develop in the light of experience".
It may be embarrassing to revise a standard almost as soon as
it has begun to be implemented but this is a better option than
persevering with an ill-advised policy.
The case for changing the definition is, in our view, compelling.
Housing qualty standards evolve and improve naturally over time.
The quality of the existing housing stock can be defined in terms
of proximity to the Buildng Regulations of the period. The energy
efficiency component of the Building Regulations is regularly
amended and we would expect the Decent Homes Standard to aspire
to those specifications. It should be noted that the Thermal Comfort
criterion will be amended when Building Regulations are revised
in 2005 to require the installation of highly efficient central
heating boilers (SEDBNUK A or B).[12]
If the perceived problem is that some progress has already
been made towards meeting the existing standard and any revisions
will set back the objective of Decent Homes for all social sector
tenants by 2010 this is not insurmountable. A revised standard
can be applied to future work with those properties already improved
being revisited subsequently. The UK Fuel Poverty Strategy requires
the problem of fuel-poor households to have been resolved by 2016
and it would certainly be preferable for the timescale to be extended
than for this opportunity to be missed.
If the problem is one of resources then this too must be
resolved. The Warm Homes and Energy Conservation Act 2000 requires
fuel poverty to be eradicated "as far as is reasonably practicable"
by 2016; there is no provision for failure on the basis of inadequate
funding.
10
This standard would require full house central heating to all
main living areas, including bedrooms and a modern efficient boiler.
A or B rated condensing boilers will be required from 2005 but
the ODPM guidance endorses C rated boilers. Back
11
The loft insulation specification for Warm Front was increased
in October to 250 mm. The Building Regulations were amended in
1975 to specify loft insulation at a level of 50-60 mm. Back
12
Seasonal Efficiency of Domestic Boilers in the United Kingdom. Back
|
