Memorandum submitted by the Chartered
Institute of Housing
1. INTRODUCTION
1.1 The Chartered Institute of Housing is
the professional organisation for people who work in housing.
Its purpose is to maximise the contribution housing professionals
make to the wellbeing of communities. The Chartered Institute
has over 20,000 members across the UK and the Asian Pacific working
in a range of organisations—including housing associations,
local authorities, arms length management organisations, the private
sector and educational institutions.
1.2 Whilst the current government emphasis
to increase the environmental performance of new built is laudable,
it is in danger of neglecting the biggest problem facing us—emissions
from existing homes. We therefore welcome this inquiry with its
focus on tackling emissions from the existing housing stock, which
is pivotal in stemming global warming and moving towards the UK
government's target to reduce emission by 60% compared to 1990
levels by 2050. Since new build accounts for only 1% annually,
tackling the existing stock is crucial if significant carbon emission
reductions are to be achieved. The issue becomes even more pressing
given the fact that the vast majority (around three quarters)
of current homes will still be in use by 2050.
2. HOME ENERGY
EFFICIENCY PROGRAMME
2.1 It is recognised that the costs of significantly
reducing the carbon footprint of existing homes are substantial.
However, the threat of global warming does not leave much room
for manoeuvre and we believe that there needs to be a comprehensive
government programme in place, along similar lines of inner city
renewal programmes in the 1980s. The current "piecemeal"
approach does not address the scale of the problem. Such a programme
should be devised within the next three years. Given the considerable
cost implications, we would like to see an allocation of resources
in the spending review, building up to significant allocation
in successive reviews, as the programme develops.
2.2 As part of this programme, government
should set similar ambitious targets / standards to improve the
carbon footprint of the existing stock as it has done with new
build, ie introducing a Code for Sustainable Homes for Existing
Stock. This should be accompanied by a clear timetable and
milestones (for example retro-fitting cost effective measure first).
The Passivhaus concept could be adopted as a possible standard,
since it has been shown that Passivhaus principles can
be applied effectively and more importantly economically to existing
housing[3].
2.3 The focus should be on those properties
first which can be retrofitted cost effectively (for example there
are still approximately seven million unfilled cavity walls).
By doing this an estimated 4MtC/yr could potentially be saved,
reducing the overall emissions from the domestic sector to just
over 24%[4].
Government should publish a timetable when this is to be achieved.
This should be done on an area by area basis in order to streamline
the process and to make use of economies of scale. In the context
of 2050 almost all existing housing and a significant proportion
of "new" housing built up to 2016 will need to be upgraded,
albeit only insulating external walls. Insulation upgrades should
be to the optimum standard for 50 degrees-60 degrees North in
one go. The aforementioned inner city renewal programmes could
act as a blueprint for a potential home energy efficiency programme.
2.4 Whilst a great number of properties
can be made energy efficient at relatively modest costs (ie cavity
and loft insulation), a significant proportion falls into the
"hard-to-treat" category, with a hefty price tag attached
to potential energy efficiency upgrades. Such homes can have any
or a combination of the following characteristics: solid walls,
inaccessible loft space and not connected to the gas grid. For
instance, in England alone there are 2.5 million pre-1919 terraced
houses, which fall in this category. Building on the work carried
out by the Centre for Sustainable Energy in mapping hotspots of
hart to treat homes[5]
there needs to be a detailed audit of the housing stock at the
neighbourhood level that identifies those dwellings that (currently)
cannot be treated cost effectively. Tackling hard to treat properties
will not only cut carbon emissions but will have significant impact
on reducing fuel poverty numbers, since half of all fuel poor
households occupy such homes[6].
2.5 Fundamentally, residents / homeowners
are responsible for their behaviour and the cost of fuel will
have an influence over that. However, this does not necessarily
translate into behaviour changes or an increase in the take-up
of grants for loft / cavity wall insulation and minor / DIY energy
efficiency improvements such as hot water tank insulation and
draught proofing. The Energy Efficiency Partnership for Homes
(EEPH) for example found that people's perception on the costs
of cavity wall insulation is rather skewed (ie £1,000-3,000).
However, even when presented with the actual costs (around £400)
those "able to pay" were still reluctant to pay for
such measures. The big challenge will be to find ways to compel
homeowners to improve the energy efficiency performance of their
buildings. One possibility would be to operate EPCs in a more
MOT-like manner, required on an annual or bi-annual basis, with
comparable penalties. Such a system would however only work if
accompanied by significant levels of grants and other government
support for people on low and moderate incomes.
2.6 Government should overhaul the Low
Carbon Buildings programme by setting up special loan facilities
for energy efficiency measures, which could compel those homeowners
to act who are "able to pay". We would like to draw
the attention to a programme the German government is running,
which could be a potential model for a scheme in the UK. The CO2
Gebäudesanierungsprogramm[7]
was established in 2006 and provides low interest loans to homeowners
for energy efficiency improvements. Loans are administered through
the government owned KfW Bank[8].
So far the programme increased the energy efficiency of around
265,000 dwellings and achieved estimated carbon savings of 900,000
tonnes. Furthermore, the programme supports economic growth and
employment. For every €1 billion invested into the existing
stock, it is estimated that around 25,000 new jobs are created.
2.7 Measures to increase uptake of energy
efficiency measures might include:
— Council tax rebates on energy efficient
properties.
— Low interest loans for energy efficiency
improvements, such as the German CO2 Gebaudesanierungsprogramm.
— A significant reduction (or even
abolishment) in VAT on micro-renewables and refurbishment work.
— Equity release products to facilitate
energy efficiency improvements.
— Allowing microgeneration measures
under EEC Warm Front.
— Obligation on energy suppliers to
provide smart meters.
— Feed-in tariff (see below).
2.8 EPCs are an important tool in increasing
both energy efficiency and reducing emissions form the existing
stock. In particular EPCs help with a number of important issues:
— Raising general awareness of domestic
energy efficiency.
As the majority of homeowners will not be aware
of their dwellings' energy use and carbon footprint, the proposed
white goods type labelling will help with clarification.
— Increasing consumer demand for more
sustainable homes.
With awareness of the environmental impact of
housing likely to increase, EPCs can help to create consumer demand
for more sustainable homes. Over time we hope that energy efficiency
and carbon considerations would guide the buying process in the
same way as say the locational factors do at present.
— Identifying homeowners eligible for
financial assistance.
The latest 2006 estimates suggest that the number
of owner occupier households in fuel poverty has doubled since
2004, putting the figure at 1.6 million. EPCs will help to identify
those fuel-poor owners who have not yet sought assistance under
one of the current schemes.
2.9 EPCs should be made mandatory for all
homes and produced periodically, with additional information for
more transparency (for example they should include figures of
the actual annual fuel consumption and associated costs). EPCs
could be operated in a similar manner to the MOT for vehicles,
with obligations put on homeowners to implement any recommendations
as set out. As mentioned earlier, in order for such a system to
be fair and equitable, there needs to be a comprehensive grant
and loan system in place.
2.10 It is important to make EPCs available
to local authorities (LAs), so that they can build a comprehensive
picture of the energy (in)-efficiency of the stock in their area.
This will help in identifying those households who are eligible
for grant assistance under one of the government's fuel poverty
schemes, as well as money available through EEC and the successor
CERT. It will also support investment and strategic decisions
of a prospective government programme. Any potential data protection
issues which may arise from this need to be resolved swiftly.
3. DISTRIBUTED
ENERGY GENERATION
3.1 Local and central government must also
co-ordinate distribution services for heat and power to make more
efficient power generation (eg from combined heat and power and
photovoltaic) cost effective and functionally efficient. The co-ordination
needs to address the appalling inefficiencies of energy utility
infrastructure provision.
3.2 The energy companies need to solve the
technical problems of distributing electrical power from distributed
generators, since the current system does not work. This is an
urgent priority, and a pre-requisite for a feed-in tariff system.
Government may need to legislate to force energy utilities to
accommodate power from distributed generators.
3.3 Government should explain that the cost
of electricity generation is only about one third of the cost
of electricity delivered to end users. The balance covers the
cost of distribution and administration. These costs do not change
if electricity is exported. Thus, under the current system, building
owners and occupiers will never be able to sell electricity for
the same price that they buy it.
3.4 However, electricity generated from
micro renewables can make an important contribution to the overall
energy mix. Furthermore, a system, which properly incentivises
the export of electricity, has the potential to significantly
expand the uptake of micro-renewables and reduce carbon emissions
at the same time. The most effective way to do this is through
the introduction of a feed-in tariff. Probably the most successful
example is Germany. Under the Energy Sources Act electricity from
micro-renewables exported to the grid is rewarded with four-time
the market rate over a 20 year period (up to 64.4ct/kWh, approx
35p/kWh). This makes for a very attractive investment with pay-back
periods of less than 10 years and with a return of 8-9%. Between
2000 and 2004, electricity generated from photovoltaic systems
has seen a nine-fold increase. Germany currently boasts a solar
power capacity of 200 times that of Britain. Increased take-up
also leads to economies of scale, with a typical domestic photovoltaic
system selling now for less than £10,000, compared to around
£17,000 in Britain. It is expected that costs for systems
in Germany will halve within the next decade. The feed-in tariff
is financed by all electricity customers, who are charged a premium
on their bills[9].
4. SOCIAL HOUSING
SECTOR
4.1 The social housing sector has been at
the forefront of the sustainability agenda for quite some time
and is responsible for some of the most eco-friendly developments
in the country and has also made significant inroads to increase
the energy efficiency of its existing stock. Social homes are
on the whole more energy efficient then their privately owned
counterparts, with an average SAP rating of 57 and 46 respectively.
The sector will also be two years ahead of the private sector
in adopting the new Code for Sustainable Homes. Since the majority
of our members work in the local authority and housing association
sector, we do have a particular interest in the environmental
performance of the sectors' housing stock. Moreover, given that
the social housing sector makes up almost one-fifth of the UK
housing stock, the potential carbon savings are quite significant.
4.2 Despite the inroads made, there is no
room for complacency, since the threat of irreversible climate
change is here to stay for the foreseeable future. It is also
important to notice that the overall picture in terms of adopting
high environmental standards and more importantly seeing environmental
sustainability as a core business objective rather than an add
on is quite patchy. What we certainly don't need are any more
exemplar developments! We believe it is high time for the "green"
agenda to become mainstream across the sector. Over the coming
months we will be consulting with the sector on the most effective
support structures to achieve this goal.
4.4 The Decent Homes Standard should be
repositioned as the lowest acceptable performance standard (ie
in terms of thermal comfort component) and not a target that is
aspired to. Any potential post-2010 standard needs to be more
explicit on energy efficiency.
5. ADDITIONAL
ISSUES
5.1 The terms of reference of the Committee
state that
"this inquiry will focus on functions which
are integral or semi-integral to housing fabric such as heating
and lighting" and " . . . will not examine the environmental
performance of individual household appliances".
We believe that this is a missed opportunity,
since the carbon emission potential due to consumer electronics
and gadgets is immense. Although significant energy efficiency
gains have been achieved with cold appliances, they have been
largely offset due to the exponential increase of consumer electronics,
such as digital boxes and plasma screen TVs[10].
5.2 Equally, electrical power must be considered.
The environmental sustainability consultancy arm e2S of Black
Country Housing Group is developing low-power distribution and
appliances concepts. Half of electrical power in many devices
is wasted in transformer heat losses and fan-cooling. If devices
only need low power than there is no reason why they should not
be supplied with low power. A new low-power standard for devices
would demand a separate circuit built into the home and appliances
designed to work from it. We would be pleased to supply the Committee
with more information on this if required.
5.3 The study should also consider the implications
for future cooling of dwellings. Adapting to climate change is
an important task, since we can expect the summer heat waves,
which gripped Europe in the past years to become more commonplace
in the future. The use of energy intensive conditioning units
is, for obvious reason, not an answer. Thus, central government
should sponsor research and development work into phase change
materials that obviate the need for air conditioning systems.
3 http://www.passiv.de/ Back
4
http://www.communities.gov.uk/documents/planningandbuilding/pdf/154500 Back
5
http://www.eeph.org.uk/uploads/documents/partnership/HTTH%20Mapping%20Research%20Mar%2006.pdf Back
6
http://www.eeph.org.uk/sector/hardtotreat/ Back
7
http://www.energie-fuer-morgen.de/ Back
8
http://www.kfw.de/EN_Home/index.jsp Back
9
For a typical three-person households, this amounts to around
€2 per month (approx £1.30). Back
10
http://www.eci.ox.ac.uk/research/energy/40house.php Back
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