Memorandum submitted by PLUS Housing Group
This submission attempts to address in succinct
form (as requested) the key questions being addressed by the Inquiry
into Existing Housing Stock and Climate Change. We would be happy
to provide more detail on any issue as required by the Committee.
1. The significance of existing housing compared
to new build and the different levels of performance each display
The table below indicates the differences in
three property types—mid terrace, semi-detached and new
build, of applying energy performance improvements, such as double
glazing and improved insulation, to each type. These performance
figures are based on actual properties of comparable size within
each category. For the flat category a comparison with a new build
example is also given.
| Dwelling | Config
| Status | SAP |
CO2 tonnes pa | Ave Running £ pa
|
| Geraint St | Mid Terrace |
Improved | 63 | 4.22
| £500 |
| Mid Terrace | Unimproved
| 41 | 7.34 | £824
|
| Warham Road | Semi Detached
| Improved | 74 | 4.25
| £533 |
| Semi Detached | Unimproved
| 46 | 6.96 | £734
|
| Flat | New Build
| 102 | 2.24 | £337
|
| Pinehurst | Flat | Improved
| 88 | 2.33 | £361
|
| Flat | Unimproved
| 67 | 3.53 | £439
|
2. The respective roles of residents, homeowners, landlords,
local government, central government and the energy industry in
promoting and delivering greater energy efficiency
PLUS Housing Group has a comprehensive Affordable Warmth
Strategy that aims to reduce fuel poverty across our portfolio
as far as possible. This strategy is directly linked to our Asset
Management Strategy and is influential in the development of our
annual investment programmes. However, there are many pressures
on our ability to deliver across various agendas (including the
Decent Homes Standard) and we consider that there is currently
little real incentive for Housing Associations to prioritise investment
into energy related works.
The Government has placed great emphasis on increasing energy
performance standards for new build through the introduction of
the Code for Sustainable Homes and the requirement that all NAHP
funded programmes should reach Code Level 3 from 2008. However,
welcome as this is, in order for private developers and the energy
industry to rise to this challenge effectively, the Code Level
3 should be mandatory for all developments via both Building Regulations
and through planning requirements—not just for grant supported
affordable housing.
3. Energy Performance Certificates (EPC)
PLUS Housing Group is one of the selected Housing Associations
in the UK to have been awarded the maximum available grant funding
to participate in CLG's pilot project for the introduction of
EPC's across the rented sector housing stock in October 2008.
We are currently preparing nearly 800 individual EPC's across
our stock.
We welcome the introduction of EPCs and are well placed to
generate the certificates in-house and to use their findings to
influence letting and investment decisions. Alongside our annual
stock condition and energy surveys, we are confident that the
EPCs will assist in the targeting of energy related investment
to those properties and neighbourhoods in greatest need.
4. The provision of information for households and prospective
house buyers, including energy performance certificates
Again, we welcome the transparency of the incoming EPC regime,
allowing incoming tenants to assess the energy performance characteristics
of the property that is being offered. It is our opinion that
this can only help to isolate the poorer performing properties
and increase the urgency for improvement works to take place.
We firmly believe that a significant proportion of residents who
are informed about the energy performance of their properties
and their own appliances (televisions, kettles etc) will actively
seek to reduce their own fuel bills wherever possible.
5. Government efforts to reduce carbon emissions from
existing housing stock whether in private or public ownership
and other rented programmes including Decent Homes
The Decent Homes Standard is a basic minimum standard that
seeks to ensure that heating systems and insulation levels within
a property are effective and efficient. However, it is not prescriptive
in that all properties must necessarily be fully centrally heated,
double glazed or exceed minimum levels of roof or cavity wall
insulation. In itself, the Decent Homes Standard will does not
directly tackle issues to reduce carbon emissions, increase SAP
ratings or lower fuel bills. However, we do use the Decent Homes
Standard as "part of the jigsaw" when determining investment
programmes to ensure that we integrate work packages, based on
financial, technical and social considerations together. In summary,
reduction of carbon emissions can be a by-product of Decent Homes,
if the Housing Association chooses to prioritise and integrate
those works with specific energy related programmes.
We would recommend that Government considers replacing the
Decent Homes Standard with a Green Standard for all existing housing
stock which uses EPCs as a measure of effectiveness and offers
incentives for higher performance. We would also recommend that
housing investment is targeted towards investment in the quality
of the existing housing stock (as well as producing new homes)
with particular emphasis on measures to reduce carbon emissions
and increase the use of renewables. The government could support
this programme via grants.
6. The technologies available to reduce emissions and
the Government's role in facilitating relevant further technological
development
Carbon emission reducing technologies for existing buildings
appears to be far less available than for new build. We would
welcome greater emphasis on research for such technologies; the
vast proportion of public sector housing is existing stock rather
than new build. Due to restrictive planning issues, it is simply
not practical to apply new build technological solutions to existing
stock in many instances.
Pilot funding should be made available for energy providers
and Housing Associations to examine and monitor the introduction
of new products and technologies into the existing housing stock.
7. 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
As discussed above, there is current little incentive for
Housing Associations to actively spend a considerable proportion
of available investment primarily on carbon emission reducing
works. Whilst we support the Government's ambitions in this respect
and aim to deliver our own fuel poverty ambitions through our
asset management and affordable warmth strategies, the conflicting
financial and technical demands on annual investment budgets means
that such works can be classified as lower priority. We consider
that adding some form of financial assistance or incentivisation
for the public sector would assist greatly in ensuring such works
are prioritised.
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