Memorandum submitted by the Association
for the Conservation of Energy
INTRODUCTION
The Association for the Conservation of Energy
is a lobbying, campaigning and policy research organisation, and
has worked in the field of energy efficiency since 1981. Our lobbying
and campaigning work represents the interests of our membership:
major manufacturers and distributors of energy saving equipment
in the United Kingdom. Our policy research is funded independently,
and is focused on four key themes: policies and programmes to
encourage increased energy efficiency; the environmental benefits
of increased energy efficiency; the social impacts of energy use
and of investment in energy efficiency measures; and organisational
roles in the process of implementing energy efficiency policy.
ACE welcomes this inquiry into existing housing
stock and climate change. Tackling the existing housing stock
is a critical issue as 27% of the UK's carbon emissions come from
the domestic sector. This is a big opportunity to reduce carbon
emissions and to tackle fuel poverty.
ACE believes that current measures to adapt
existing housing have had limited success and that more needs
to be done. We will be examining this issue in more detail in
our response to the individual questions below. Furthermore, the
respective roles of homeowners, central and local government and
the energy suppliers need to be rebalanced, as currently a disproportionate
burden falls upon the suppliers and, as a consequence of increased
fuel bills, upon householders (irrespective of income). ACE recommends
that Government follows the examples of other countries, like
Germany, and make available greater sums of Government money with
which to tackle both its household energy efficiency and fuel
poverty obligations.
Heating in the home is by far the largest source
of carbon emissions. Space and water heating account for 41% of
an average individual's annual carbon emissions, whereas lighting,
appliances and cooking together account for under one fifth. It
is therefore critical to tackle heating in the home as the top
priority. The key issue should be dealing with the fabric of buildings
(ie the building itself). Cavity and solid wall insulation, loft
insulation, double glazing and boiler replacement should be the
first measures implemented while lighting and appliances should
be secondary. However this does not always happen as programmes
tend to concentrate on the cheapest and easiest measures first.
A "whole house" approach is critical
to the delivery of optimal energy efficiency. Currently the way
programmes are structured means that households are approached
in a piecemeal fashion. Low income homes can even have one measure
installed by one programme and another measure installed at a
later date by another programme. This type of approach is much
more costly and time consuming. ACE advocates a systematic, integrated
and coordinated approach in terms of the whole house and in terms
of location. Programmes in France and Germany use a whole house
approach and the UK could benefit from following their lead.
The housing stock is being increased, not only
by new build, but by the subdivision of existing properties. This
is increasing the proportion of households living in properties
that may not be governed by current Building Regulations. By tackling
existing stock an increasing proportion of households will be
targeted.
It is vital that the carbon emissions from the
existing housing stock are tackled and that all existing homes
have sufficient energy efficiency improvements in order to prevent
energy waste, reduce heating bills and help the UK reach its carbon
emissions reduction targets.
1. How can Improvements be Achieved?
It is clear that existing approaches are not
generating sufficient levels of demand from householders to meet
UK household energy efficiency targets. In England the average
SAP rating is around 54, in Scotland 58 and in Wales 52. ACE believes
that fiscal measures can make a significant contribution to delivering
the household portion of the Government's climate change targets.
It must be a priority of Government to implement further complementary
measures, which specifically include fiscal incentives as part
of an overall package, in order to encourage consumers to save
energy. There has been very slow progress towards introducing
any substantial new economic instruments to improve households'
energy efficiency—and ACE hopes that this inquiry will add
a new impetus to transforming economic incentives. There are insufficient
policies and standards that relate to existing buildings in the
UK, and these need to be strengthened.
When faced with a UK building stock that is,
from an energy efficiency standpoint, in very poor condition,
activities targeting the householder (rather than the house, such
as via the Energy Efficiency Commitment Priority Group) is effectively
pock-marking the stock with improved homes, rendering the remaining
stock unchanged and costly to identify and treat in the future.
This effect is compounded as EEC effectively forces suppliers
to compete with each other to install measures at least cost.
This leads to myopic behaviour, precluding a more integrated,
systematic stock-based approach, as suppliers are concentrating
on reaching their targets with the cheapest approach instead of
looking at the wider picture.
To mitigate this risk—and reduce transaction
costs associated with the potential for multiple agencies supporting
any given household (EEC, Warm Front/Warm Deal/Home Energy Efficiency
Scheme, Low Carbon Buildings Programme, Local Authority support)—we
strongly recommend area-based co-ordination where possible. In
this way those in fuel poverty—as well as the able-to-pay
and the entire building stock—can be addressed systematically
and at least cost. This co-ordination could be done directly by
Home Energy Conservation Authorities (district, borough and unitary
councils), or by an external company, working for each HECA council
under contract. Local knowledge could then be combined with external
money to enable a systematic, targeted approach to improving the
local housing stock, an example being the various Healthy Homes
programmes being carried out in various forms in Cornwall, Westminster,
Kensington and Chelsea, Eastbourne, Lewes and Rother.
An area-based approach can also save time and
reduce costs. Some seven million homes have cavity walls that
have not been insulated. Many of these houses will be semi-detached
or terraced. If a road of houses is tackled together, more can
be done in a shorter period, which reduces the costs and complexity
of installation.
With regard to EEC, the depth of the loft insulation
installed by Government programmes in the 1970s—when most
was introduced—is inadequate by modern standards (one to
two inches). There is also no guarantee that after 30 years this
insulation has not been rendered far less effective by being moved
or compressed by storage. ACE supports counting these lofts as
effectively "virgin", as this will help bring these
lofts up to modern standards.
Currently energy saving measures are not installed
where one more or occupant is ineligible for funding. ACE recommends
that this be changed so that all those eligible for funding are
reached and are not penalised just because they live with others
who do not qualify.
ACE welcomes the Government's commitment, as
set out in the 2007 Budget, that by the end of the next decade
all householders will have been offered help to introduce energy
efficiency measures with the aim that all homes will have achieved
their cost-effective energy efficiency potential. The Budget Report
outlines the following programmes and measures in order to achieve
this aim: EEC, Warm Front and Decent Homes Programmes, Energy
Performance Certificates, improvements to billing information,
the roll-out of smart metering and visual display units over the
next decade and improved energy advice and information.
However, these programmes and measures as they
stand will not be enough to reach this aim. Warm Front and Decent
Homes only concentrate on vulnerable groups with the rest of householders
not being targeted. In the current phase of EEC, 50% of the energy
saving target has to be achieved via measures installed in low
income households. In the next phase of the programme—from
2008 to 2011—the Government proposes that the Priority Group
should still account for 40% of total energy savings. Meanwhile,
the majority of the measures outlined in the Budget revolve around
creating greater awareness and information on energy use, but
unless these are coupled with actual financial incentives, the
take-up of these measures will be minimal. ACE believes that consumers
need direct help to install energy saving measures and that there
is still considerable scope for the introduction of further fiscal
and economic measures. Additional incentives targeting landlords,
homeowners and energy suppliers are needed to encourage the uptake
of energy improvements to homes.
The Budget announced that from 1 October all
new zero-carbon homes will pay no stamp duty or receive a reduction
in stamp duty of £15,000. While ACE welcomes this proposal,
the number of houses affected will be minimal. We therefore strongly
support a stamp duty rebate for house purchasers who make energy
efficiency improvements to their home within a set time period,
say six months to a year. Owner-occupiers account for 70% of the
UK's householders. Very few of these households are taking steps
to improve the energy efficiency performance of their properties.
People are most likely to act at the time of selling or purchasing
a house, and therefore this behaviour should be incentivised at
the appropriate time. A rebate could be readily linked to Energy
Performance Certificates.
Currently a reduced rate of VAT to 5% is offered
for the supply and installation of certain energy efficient products
or materials in non-grant schemes when householders employ contractors.
ACE recommends that this should be extended to all measures and
that the Government should intensify its calls for a change in
EU VAT legislation to allow the reduced rate to apply when householders
install the measures themselves. This will prevent discrimination
against low income households who are more likely to install energy
saving measures themselves than pay someone else to do it.
ACE welcomed the introduction in Budget 2004
of the Landlord's Energy Saving Allowance, which allows private
landlords to claim investment in energy saving materials against
profits. We also welcomed the extension of the allowance in the
most recent Budget, so that it is now available to landlords per
property, rather than per building—ensuring that landlords
of smaller properties have access to the full allowance. However,
we recommend that the amount of capital relief should be raised
and that the range of technologies for which the allowance is
available should be extended to the full range of energy saving
technologies. ACE supports a requirement for domestic landlords
to make energy performance improvements under landlord and tenant
legislation at the termination or surrender of a lease.
ACE also supports a Council Tax rebate for householders
installing energy saving measures. This is a way of reaching households
who are not moving or taking out a new mortgage. It therefore
has the potential to reach more households more quickly than a
stamp duty rebate. In conjunction with British Gas, 16 local authorities
have already committed to offer one-off rebates to their residents.
There is enthusiasm for this scheme among other local authorities.
Homes that meet some sort of sustainability
criteria should be eligible for Mortgage Interest Relief. This
would effectively be a restoration of mortgage interest relief
at source for sustainable homes and could be linked to Energy
Performance Certificates and green mortgages. The relief could
be given to homeowners when they move house and/or to those who
are remortgaging their house but not moving.
ACE supports a Green Mortgage scheme. Three
lenders already offer this to encourage their clients to be more
energy efficient. However there needs to be a much more concerted
effort by the major mortgage lenders to stimulate a serious focus
on energy efficiency and environmental issues in general. As noted
above, green mortgages can be a route into mortgage interest relief
for sustainable homes.
ACE supports a reform of Winter Fuel Payments
to create incentives to invest in energy efficiency measures.
The relationship between winter fuel payments and energy efficiency
should be reviewed and practical ways of ensuring that a growing
proportion of the WFP expenditure is invested in energy efficiency
should be developed.
Interest-free loans offered to homeowners who
install energy efficiency measures in their homes would encourage
uptake, especially for the more expensive technologies such as
external wall insulation. This has certainly been the experience
for SMEs benefiting from similar programmes.
Currently a boiler is only replaced if it breaks
and is costly to repair. Many older boilers are inefficient and
would benefit from replacement. Incentives such as interest-free
loans, reduced VAT or Council Tax discounts need to be in place
for replacing obsolete boilers.
2. Existing Housing Performance compared
with New Build
There are significant differences between the
energy performance of existing housing and new build with older
properties generally having a much lower energy performance. In
principle buildings constructed since 2006 are typically 40% more
energy efficient than those built in 1996, largely due to changes
in Building Regulations.[38]
Over 40% of properties built before 1919 have a SAP rating of
less than 41, whereas 60% of properties built since 1990 have
SAP ratings above 70.[39]
If the UK is to reach its target of reducing emissions by 60%
by 2050 then the existing housing stock will need to be made much
more energy efficient. In 2050, 60% of buildings will still predate
the last revision to Part L of Building Regulations, and 40% will
predate the introduction of Part L in 1985.
Existing housing stock represents 98-99% of
building stock at any one time and new build rates are very low
with new buildings adding 1%-1.5% of building stock each year.
Although the Government has set a target that all new houses will
be zero carbon by 2016, new build will only account for 1% of
homes in 2016.
3. Roles of Residents, Homeowners, Landlords,
Local Government, Central Government, Energy Industry
There is a need to strike the right balance
between all stakeholders. As things stand, the principal policy
mechanism to ensure greater energy efficiency in households is
the Energy Efficiency Commitment (to be called the Carbon Emissions
Reduction Target—CERT—from 2008), which requires energy
suppliers to achieve targets for saving energy in the household
sector. Furthermore, the Energy Efficiency Commitment—as
opposed to the Government-funded Warm Front and Decent Homes Programmes—is
the only programme that targets the able-to-pay sector.
In terms of comparative expenditure, the most
recent figures show that the annual cost of EEC (borne by energy
suppliers and ultimately, via increased fuel bills, the householder)
is in the order of £384 million, whereas the Government's
latest estimates of the combined cost to them of the Warm Front
and Decent Homes Programmes is £450 million per year. In
other words, 46% of the total spend on the UK's three principal
household energy efficiency programmes is borne by the energy
suppliers (and UK householders). This level of private sector
expenditure is proportionately higher than anywhere else in Europe.
Given that reducing household energy consumption is a public policy
aim, surely it is right that proportionately greater sums of public
money be spent on delivering it.
3.1 Role of central government
The Home Energy Conservation Act 1995, which
came into force on the 1 April 1996, placed a requirement on local
housing authorities, to be known as Energy Conservation Authorities
(ECAs), to reach a 30% energy efficiency improvement in domestic
housing stock over the 15 year period from 1996 to 2011.
The Department of Environment, Food and Rural
Affairs has recently published the HECA figures for 2005-06. This
reveals that only 41.2% of ECAs have reached their (proportional)
target of achieving a 20% improvement in energy efficiency. The
majority of ECAs who have not yet reached a 20% improvement will
need to improve by more than 2% a year for the next five years
in order to reach their 30% target.
Under Section 4(3) of the Sustainable Energy
Act 2003 the Secretary of State may exercise a power to give an
"energy efficiency direction" to all or some of these
authorities. Authorities must then comply with this direction.
To date this power has not been used. The use of this power would
compel the worst performing authorities to do better. An energy
efficiency direction—as well as more financial support for
councils, where appropriate—will ensure that more authorities
get on track to meet their HECA target by 2011.
Government is not on course to meet its statutory
target under the Warm Homes and Energy Conservation Act 2000 to
alleviate fuel poverty in vulnerable households by 2010. ACE believes
that more funding and resources need to be put into alleviating
fuel poverty. ACE has informed the Secretary of State for Environment,
Food and Rural Affairs that, if the 2010 target is not met, the
Government may be subject to judicial review.
Furthermore, the reporting requirements—on
fuel poverty and climate change targets under the Sustainable
Energy Act 2003 and on the targets set in the Housing Act under
the Climate Change and Sustainable Energy Act 2006—have
not been properly carried out by the Government. Under the latter,
the Secretary of State is required to publish an annual progress
report on achieving the target for the energy efficiency of residential
accommodation in England as set out in the Housing Act 2004, namely
that by 2010 the general level of energy efficiency of residential
accommodation in England has increased by at least 20% compared
with the general level of such energy efficiency in 2000. It is
vital that these reports are published to order to gauge whether
the targets are likely to be met, and if not, what needs to be
done in order to meet them.
The largest proportion of applications for planning
permission are for residential extensions. The last revisions
to Part L of the Building Regulations were originally intended
to include a requirement that when an extension was agreed for
a building, it would give rise to consequential improvements to
the original building in order to minimise its overall carbon
footprint. However, immediately before the revisions were announced
in September 2005, last-minute changes were made which limited
this requirement to larger commercial buildings over 1,000 square
metres.
The Government's draft regulatory impact assessment
on these improvements to Part L concluded that introducing such
a requirement would be extremely cost-effective and 81% of respondents
to the (then ODPM's) original 2004 consultation agreed with the
concept. It has been estimated that improvements forgone could
have delivered up to 500,000 tonnes of carbon saving, which would
have made up 19% of the residential sector 2010 targets adopted
in the 2004 Housing Act. ACE recommends that the 1,000 square
metre restriction be removed and that the requirement for consequential
improvements should be applicable to all buildings.
The reduction (or abolition) of yet another
1000 square metre threshold would yield substantial further energy
savings in the household sector. Under Article 6 of the 2003 Energy
Performance of Buildings Directive, all buildings over 1,000 square
metres have to be upgraded to meet minimum energy performance
requirements whenever they undergo major renovation. ACE strongly
welcomes the proposal by the European Commission to "lower
significantly" (in 2009) the 1000 square metre threshold
to include "the majority of existing buildings". We
have calculated that, if the threshold were abolished completely,
the amount of carbon dioxide savings expected to flow from the
Directive would roughly double. The abolition of the threshold
would mean that the whole of the residential sector would be covered
by Article 6. ACE therefore urges the Government to support in
the strongest possible terms the Commission's proposal to reduce
the threshold in 2009. Furthermore, we believe that they should
be pressing for a complete abolition of the threshold.
There are currently limited policies and standards
in the UK that relate to existing buildings, with the majority
of emphasis being on new buildings. ACE supports energy refurbishing
requirements and requirements for upgrading energy performance
when buildings undergo renovation to be included in Building Regulations
and planning policy. ACE believes that local planning authorities
should be given the power to specify in their local development
plans higher energy efficiency standards for new developments—both
residential and commercial—than those required by Building
Regulations.
3.2 Landlords
The standards of social housing have been raised
by the Decent Homes Standard, but privately rented homes have
been largely neglected. Although the private rented sector is
relatively small, it contains a very high proportion of energy
inefficient properties, and improvements to homes rented out by
private landlords need to be undertaken.
The main barrier to energy efficiency improvements
in the private rented sector is split incentives. A situation
where the landlord pays the capital cost of energy efficiency
measures and the tenant benefits through lower bills means that
landlords currently have no incentive to install efficiency measures
as they do not pay the heating bills.
A start has been made to address this with the
Landlords Energy Saving Allowance which was introduced to provide
an incentive for private landlords to improve the energy efficiency
performance of homes that they let. However, this is very little
used and only offers up to £1,500 for capital expenditure
and only applies to certain technologies. Considering that many
technologies can cost significantly more than £1,500, ACE
believes that this amount of capital relief is insufficient and
should be raised. We also believe that the range of technologies
for which the allowance is available should be extended to the
full range of energy saving technologies.
3.3 Role of the energy industry
The principal policy mechanism used by the Government
to ensure greater energy efficiency in households is the Energy
Efficiency Commitment. Currently suppliers are required to choose
from a range of measures which means that programmes generally
seek to concentrate on the "low hanging fruit", ie the
cheapest and easiest measures. Consequently there is limited scope
for these programmes. EEC 1 focused heavily on offering householders
compact fluorescent lightbulbs, as lighting presents few barriers
and is the most cost-effective measure. Other common energy saving
measures are cavity wall insulation and loft insulation as these
are also among the cheapest and easiest.
Because programmes focus on the cheapest measures
first, they have limited scope. This will soon have to change
as upgrading the housing stock will become more expensive once
the cheapest measures have been undertaken. There need to be enough
resources made available for this eventuality.
Under current installation rates for Warm Front
and the EEC Priority Group it would take over 1,000 years to install
external insulation in all applicable properties[40].
Ignoring solid wall insulation will only magnify the problem as
still more expensive measures will be needed. In light of the
number of homes with low SAP levels which have solid walls, it
remains vital that the improvements in insulating technology for
such walls be monitored, and that this be accompanied by sufficient
flexibility to encourage take-up. Solid wall insulation has an
important role to play and investment in this will be worthwhile
so availability of funding is essential.
The major setback of EEC is that it does not
carry out a whole house approach. Because the cheapest measures
are carried out first, programmes may then have to return to the
same home at a later date to install another measure. This piecemeal
approach is costly and time consuming. ACE recommends that a whole
house approach be adopted by energy suppliers via incentives.
4. Energy Performance Certificates
ACE welcomes the introduction of Energy Performance
Certificates. We believe that it is vital that local councils
receive the information provided on the energy performance of
homes in order to improve knowledge of the state of their housing
stock and also to enable them to carry out their statutory obligations
more effectively. We do not think it appropriate that certificate
information be placed on the public record for use by commercial
entities. The EPCs should include information on the benefits
homes could enjoy had they received a higher rating. A high energy
performance will add value to the property as prospective buyers
will be willing to pay more for a home that has low energy bills.[41]
5. Provision of Information for Households
and House Buyers including EPCS
To facilitate behavioural change, householders
need accessible, immediate and informative information about their
energy use. Smart metering/real time displays can provide this.
There needs to be a commitment from Ofgem to a national rollout
of meters sufficiently "smart" to allow householders
to measure and compare their immediate and historical electricity
consumption in monetary, carbon and kWh terms.
Until such time that smart meters are installed
widely, informative billing can play an important role. Intelligible,
frequent and accurate fuel bills can play a valuable role in encouraging
households to reduce their energy consumption.
Article 13 of the Energy End-use & Energy
Services Directive requires Governments to ensure that by May
2008 all energy bills are provided frequently, are based on actual,
rather than estimated consumption, and are easily comprehensible.
The bill should enable consumers to compare their energy use by
providing information on past consumption levels as well as compare
energy use with comparable premises. These bills must also provide
contact details for energy efficiency advice and services. The
Department for Business, Enterprise and Regulatory Reform is currently
conducting a consultation on energy billing and metering and ACE
recommends that there should be full and early implementation
of this Directive.
6. Government efforts to Reduce Emissions
from existing Housing Stock and Other Programmes including Decent
Homes
More than half of fuel poor households live
in homes that pass the Decent Homes Standard so in theory they
have access to affordable warmth, but in practice they are still
fuel poor. The Standard provides very little assurance to housing
providers that a home is "fuel poverty proof". ACE recommends
that higher energy efficiency standards need to be incorporated
within the Standard and it needs to be re-specified to incorporate
more stringent standards of thermal comfort so that more of these
homes are captured by it. The same standard should be applicable
to Houses in Multiple Occupation as it is to all other areas of
the housing stock in England. Risks associated with damp and mould
are considered to be much more likely in Houses in Multiple Occupation.
Currently the Thermal Comfort element consists
of two main elements: controllable gas, oil, or LPG central heating
or electric storage heating and cavity wall insulation and/or
loft insulation. The latter recommendation is inadequate. ACE
supports cavity wall insulation as well as loft insulation. The
acceptable minimum for the loft insulation is set at 50mm which
we believe should be raised to 250mm as this is the standard measure
used by Warm Front: otherwise these homes will need to be revisited
later.
7. Available Technologies for Reducing Emissions
and the Government's Role in facilitating Further Development
There is the potential to reduce consumption
from the average household by at least one quarter, using established
technologies. Incentives are needed to give these technologies
(eg solar water heaters, micro-wind turbines, ground source heat
pumps, biomass stoves and boilers and micro-CHP) the boost that
they need and to create the economies of scale that will enable
them to become more affordable.
Micro-generation and other low carbon technologies
have the potential to greatly reduce carbon emissions from homes.
However these technologies are expensive to install. The implementation
of feed-in tariffs would facilitate and encourage homeowners to
install these technologies. This would reduce dependence on electricity
from the grid which has a high carbon footprint. Feed-in tariffs
were introduced in Germany in 1991. This has been extremely successful
and has been responsible for a dramatic increase in growth in
their renewable energy market. In five years the quantity of electricity
fed into the grid from eligible sources doubled. At present, feed-in
regulations for renewable energy exist in over 40 countries, states
or provinces internationally.
8. Costs associated, who should meet those
Costs (in particular in respect of Low-Income Households), Interaction
between Emissions Reductions and Reducing Poverty
Poverty reduction and reducing carbon emissions
must be tackled together; it must not be seen as either-or. The
imbalance between the proportion of costs falling onto Government
and energy suppliers needs to be addressed. Currently a very small
proportion of costs fall onto Government—the money it spends
on household energy efficiency consists of the Warm Front Programme,
the money it gives to local councils for Decent Homes and the
money it forgoes by means of VAT reductions and allowances. In
contrast, between 2003 and 2007 Government VAT receipts on fuel
consumption have increased by £500 million per annum as a
result of higher fuel prices. The majority of costs fall on to
the energy suppliers, which in turn falls onto the customer via
higher fuel bills.
ACE commends the German government programme
which makes €2.4 billion euros available each year to stimulate
investment in improving existing buildings. In contrast, UK Government
spending is low. ACE recommends that more Government funding is
made available. As noted above, as a result of the increased fuel
prices since 2003, the Treasury is now raising an extra £500
million each year. ACE believes that this money should be spent
on energy saving measures and tackling fuel poverty.
ACE is concerned that current policies aimed
at reducing fuel poverty are poorly integrated, leading to duplication
and unnecessarily high transaction costs. Programmes and standards
for reducing fuel poverty and upgrading existing housing stock
need to be more coordinated. The eligibility for financial and
grant assistance needs to be re assessed, as many households do
not qualify.
The Fuel Poverty Advisory Group Fifth Annual
Report of 2006 recommended that energy efficiency standards for
social housing need to be increased either by an improvement in
the Decent Homes Standard or by a duty on landlords to provide
minimum SAP ratings by say 2016. The report also identified that
Government programmes lack co-ordination and that the responsibility
for fuel poverty is dispersed across many different Government
departments. The report recommended that the roles of all Government
departments need to be clearly defined and that a significant
contribution on fuel poverty could be made by a high profile cross-Departmental
commitment.
9. Challenges in Relation to Housing of Special
Architectural and Historical Interest
There are many barriers to installing energy
efficiency in this sector of houses. The fabric of an existing
building may present barriers to the adoption of some energy efficiency
measures. For example, there are high costs in updating traditional
sash windows with double-glazing. Some measures could change the
building's appearance which may need to be preserved for listed
buildings. However these buildings can not be ignored as historical
buildings may be the least efficient.
38 Royal Institute of Chartered Surveyors, Transforming
Existing Buildings: The Green Challenge Final Report, March 2007. Back
39
Department of Communities and Local Government, Review of Sustainability
of Existing Buildings, The Energy Efficiency of Dwellings-Initial
Analysis, November 2006. Back
40
Fuel poverty-Mapping the Next Decade, The cost of alleviating
fuel poverty in England and in managed housing, Association for
the Conservation of Energy, March 2007. Back
41
The Desirability of Sustainable Homes Research Study, Sponge Sustainability
Network, January 2007. Back
| 
