Memorandum submitted by the Black Country
Housing Group Ltd
The significance of existing housing compared
to new build and the different levels of performance each display
1. Existing housing is statistically much
more significant than new build.
2. 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.
3. Insulation upgrades should be to the
optimum standard for 50 degrees -60 degrees North in one go and
neither the economic thickness nor a series of top-ups as in the
past. (The problem with the economic thickness of insulation is
that it is predicated on the cost of fuel (oil prices) and the
cost of money (interests rates). If the costs fall the economic
thickness falls).
4. The underlying data behind Home Energy
Conservation Act reports is a good indicator of relative performance.
Actual fuel bills would also be useful. There is no reason why
Energy Performance Certificates should not publish actual fuel
bills.
The respective roles of residents, homeowners,
landlords, local government, central government and the energy
industry in promoting and delivering greater energy efficiency
1. Residents are responsible for their behaviour
and the cost of fuel will have an influence over that. Fines and
incentives could also influence behaviour.
2. Building owners must be compelled to
improve the performance of their buildings in the same way car
owners are.
3. Local and central government can tax
and hypothecate through penalties and incentives and can operate
EPCs in a more MOT-like manner.
4. Local and central government must also
co-ordinate distribution services for heat and power to make more
efficient power generation, eg combined heat and power and generation
by alternative technologies, eg solar photovoltaic panels cost
effective and functionally efficient. The co-ordination needs
to address the appalling inefficiencies of energy utility infrastructure
provision and the tension between highways, road users and competing
energy utility and other utility organisations, e.g. water and
telecommunications.
5. The energy utility companies need to
solve the technical problems of distributing electrical power
from distributed generators. The current system does not work.
This is an urgent priority.
6. Central government may need to legislate
to force energy utilities to accommodate power from distributed
generators.
7. Central government should explain that
the cost of electricity generation is only about one third of
the cost of electricity delivered to users. The balance coves
the cost of distribution and administration. These costs do not
change if you export electricity and therefore building owners/occupiers
will never be able to sell electricity for the same price that
they buy it.
Energy performance certificates
1. These should be mandatory, annual and
should be against the 2050 target.
2. They should include actual annual fuel
consumed.
3. They should operate in a similar manner
to the MOT for vehicles with comparable penalties.
The provision of information for households and
prospective house buyers, including energy performance certificates
1. They should include actual annual fuel
consumed.
Government efforts to reduce carbon emissions
from existing housing stock whether in private or public ownership
and other related programmes including Decent Homes
1. The Decent Homes Standard should be repositioned
as the lowest acceptable performance standard not a target that
is aspired to.
2. There needs to be an audit of the housing
stock that identifies those dwellings that cannot be treated and
therefore have to be replaced.
3. There needs to be a schedule for replacement.
The technologies available to reduce emissions
and the Government's role in facilitating relevant further technological
development
1. Central government should commission
R&D for insulation products that are an order of magnitude
better than current products—especially for external walls.
2. Central government must facilitate solving
the problem of distributing electricity from distributed generators.
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
1. The tax-payer will have to pay for this.
2. Where the tax payer improves their own
building tax can be waived.
3. Sufficient tax must be levied to hypothecate
to low-income households so that the cost of reducing carbon emissions
does not worsen poverty.
The specific challenges which may arise in relation
to housing of special architectural or historical interest
1. Central government needs to identify
how many museum pieces are required and which they are.
2. There are huge swathes of older property
that have no architectural merit but that are a key part of their
urban fabric.
3. A new aesthetic would be just as valid
as the existing appearance in the majority of older housing stock
and could accommodate external insulation where internal insulation
is not practical.
4. Some museum pieces will no longer be
suitable as dwellings, but would be suitable for other uses, eg
storage or office use.
This inquiry will focus on functions which are
integral or semi-integral to housing fabric such as heating and
lighting. The Committee will not examine the environmental performance
of individual household appliances
1. This is a mistake. Electrical power must
be considered. We are developing low-power distribution and appliances
concepts.
2. Half of electrical power in many devices
is wasted in transformer heat losses and fan-cooling. If devices
only need low power they should be supplied with low power.
3. A new low-power standard for devices
would demand a separate circuit built into the home and appliances
designed to work from it.
4. The study should also consider the implications
for future cooling of dwellings.
5. Central government should sponsor R&D
into phase change materials that obviate the need for air conditioning.
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