Memorandum submitted by the Riverside
Group
1. INTRODUCTION
The Riverside Group (TRG) is one of the largest
social housing and regeneration organisations in England owning
or managing around 50,000 properties across England. We have recently
merged with English Churches Housing Group and now employ around
2,600 people and have a turnover of £180 million. TRG is
the parent body for eight housing associations including the new
ECHG subsidiary which manages all of our sheltered and supported
housing.
We have been engaged in sustainable regeneration
and renting homes for a social purpose for almost 80 years. Our
commitment to neighbourhoods can be seen in the millions of pounds
we invest in community projects each year, and in the hundreds
of new homes we build annually for shared ownership, rent and
outright sale. We aim to be the partner of choice for major regeneration
projects.
2. In response to the call for evidence
we would like to make the following points:
a. The significance of existing housing compared
to new build and the different levels of performance each display
Within the Housing Corporation Approved Development
Programme TRG builds up to 400 new homes in the North West and
Midlands each year. Given that we own or manage over 50,000 units
it is clear that the carbon impact of existing stock is of a much
higher order than that of the new build programme.
However, this is not to underemphasise the impact
that newly built properties can have on climate change. We understand
that hhousing in general contributes to 25% of carbon emissions
and by 2050 one third of all properties built will have been built
since 2006. This means that across the board housing providers
can have a direct impact on approximately 8% of carbon emissions
through improving the carbon performance of houses we build from
this point forward.
Mindful of the impact of existing stock, TRG
has made a significant investment in energy efficiency within
its asset management programme. Over the next five years we estimate
that we will spend some £37 million on upgrades which support
energy efficiency eg double glazing, boilers and insulation.
b. The respective roles of residents, homeowners,
landlords, local government, central government and the energy
industry in promoting and delivering greater energy efficiency
We welcome the introduction of the EcoHomes
XB assessment method for existing housing. This will allow us
to assess and monitor the environmental performance of our housing
stock and we are currently working on the implementation of this
tool across the Riverside Group.
We will propose below (see paragraph f) that
government should revisit the rent restructuring regime to encourage
landlords to adopt an innovative and enthusiastic approach to
improving environmental standards.
In our opinion residents can play a key role
in helping to reduce carbon emissions and social landlords could
play an effective part in helping to change behaviours. Registered
Social Landlords (RSLs) could do more in terms of pro-active campaigns
to encourage tenants to use their homes more efficiently and support
from government (perhaps in the form of funding for pilot projects
for the setting up of energy advice services) would be welcomed.
This approach would also link in to other policy objectives such
as anti-poverty and financial inclusion.
It is clear that our residents see energy efficiency
as a priority. Our recent STATUS survey results confirm that over
a quarter (27%) see new/upgraded boilers as a priority for investment
whilst 17% see insulation as a priority.
c. Energy performance certificates
These are a good concept if the consistency
and quality of certificates produced for existing properties can
be guaranteed without becoming costly and difficulty to produce.
However it does beg the question on what a resident can do if
the home they are considering moving into has a poor rating. Social
housing residents may not have the option to decline a property
for this reason and access to practical advice on energy management
therefore becomes more important.
d. The provision of information for households
and prospective house buyers, including energy performance certificates
The Government is currently out to consultation
on making a rating against the Code for Sustainable Homes (CfSH)
mandatory. Both the CfSH and energy performance certificates should
be made mandatory in order to provide objective criteria to judge
the quality of houses. In our view the same standards should be
applied to the private sector to ensure a consistent approach,
fuel an innovative approach to technological development and drive
down costs.
e. The technologies available to reduce emissions
and the Government's role in facilitating relevant further technological
development
These are in existence but are still relatively
"young" technologies for the mass market and are still
to be tested and proven, as a consequence both cost and quality
are not necessarily at the standard required long-term. This is
not helped by the requirement for all properties part funded by
government money to be of a higher quality (at least level 3 in
the Code for Sustainable Homes) but for less grant. We estimate
that it will cost an additional £8,000 per property to achieve
the necessary water and energy standards to achieve Level 3 in
the CfSH and a further £8,000 to achieve level 4. To meet
Level 6 this could cost around £35,000 per property above
our current standards.
As mentioned above it is crucial that the same
standards are applied to the private sector to help minimise costs
and promote innovation benefiting both new and existing housing
provision.
f. The costs associated with reducing carbon
emissions from existing housing, who should meet those costs and
particularly, in respect of low-income households, interaction
between carbon emission reductions and the Government's ambitions
to reduce poverty
There are limited measures we can implement
to improve the thermal performance of our existing stock but relatively
low-cost strategies such as double glazing and roof insulation)
can create a significant benefit to the wider picture.
At the moment we do not specify any upgrade
in relation to environmental sustainability for our empty properties
which are awaiting relet (voids) other than increasing the level
of roof insulation where necessary to 200 mm. This is also picked
up in our "decent homes plus" standard for planned maintenance.
Practically the kinds of upgrades we could
carry out would be:
— Replacement of boilers with Combination/Condensing
boilers as part of a fully programmable heating system (approx.
£4,000).
— The filling of external cavity walls
(where present) with insulating material or the dry lining of
solid walls (approx. cost £3,000).
Lower cost options would include upgrading levels
of roof insulation to 400 mm and fitting low energy fitments throughout
(around £500 per property). These measures would have a direct
benefit for our tenants in terms of comfort and running costs
although minimal payback for the landlord.
Whilst newer technology is available (such as
photovoltaic cells and solar pumps costing around £13,000
and £3,000 respectively per property) we doubt whether it
would be practical or cost effective to consider this for most
of our existing stock. There would not be enough payback in terms
of reduced maintenance or liveability to justify expenditure on
the majority of properties. Some of the units may be vulnerable
to vandalism and misuse or inconsistent with property layout.
However it occurs to us that for some of our larger schemes (for
example sheltered and supported schemes) it may be cost effective
due to the increased surface area to add photovoltaic production
for preheating water for heating systems and so on.
The environmental features which make a property
more expensive to build or refurbish do have a corresponding effect
on fuel and water bills for the person living in the property.
There is nothing that we are aware of in Housing Corporation guidance
on rent restructuring which permits social landlords to charge
a higher rent for environmentally efficient properties other than
the possibility that the property valuation may arguably be higher
for enhanced properties. However the effect of any uplift in the
valuation on target rents is diluted by it being used in only
30% of the rent calculation (the other 70% being earnings related).
We suggest that there is a case for government to look again at
rent restructuring to see whether more can be done to incentivise
social landlords by enabling them to achieve some payback for
their capital investment via the rental stream. An increase of
£2 per week on a property could generate sufficient income
to pay for improved standards of glazing, heating or insulation
(depending of course on property type and specification).
Within the Fusion [22]
consortium environmental considerations are a key part in terms
of product choice and the selection of our supply chain. Our evidence
supports the view that bulk procurement can significantly reduce
initial cost and create an environment for continuous improvement
and focused research and development.
RSLs developing remote rural schemes may wish
to look at waste treatment systems which are not linked to mains
but which involve reed based filtration ponds which will minimise
energy use and create habitat.
22 TRG is a partner in Fusion21, a procurement consortium
which was set up on Merseyside in 2002. Its mission is to maximise
efficiency, provide training and employment opportunities and
develop systems which increase both performance and environmental
awareness. Back
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