Memorandum submitted by WWF—UK
INTRODUCTION
WWF welcomes the opportunity to respond to the
above enquiry. WWF has extensive experience and knowledge of the
housing sector, formerly through the work of our One Million Sustainable
Homes (OMSH) campaign and recently through our One Planet Homes
campaign, and our work to deliver exemplary "One Planet Living[197]"
Communities across the globe with our partners BioRegional.
After extensive work to improve the performance
of new build housing over the last five years, WWF has been turning
its attention towards existing homes. As part of this we have
commissioned a study from the Centre for Sustainable Energy and
the Association for the Conservation of Energy to try and understand
in more detail both the cuts in carbon emissions that are possible
from the UK's existing housing stock—from "cost effective"
and more expensive measures—and what kind of policy and
support mechanisms would be necessary to achieve this. This report
will be completed by November 2007 and we would like to submit
it to this enquiry once it is published.
WWF has also commissioned a study—with
RSPB and IPPR—to assess what may be required to move the
UK to a low carbon economy by 2050. This will build on and reinforce
WWF's major asks on the UK Climate Change Bill, namely to ensure
cuts of at least 80 % in carbon emissions by 2050, and to ensure
the inclusion of emissions from aviation and shipping in this
process. The housing sector's contribution to this low carbon
trajectory is vital and essential policy requirements relating
to the housing sector will be drawn out from this report. This
report will be completed by November 2007 and we would like to
submit it to this enquiry once it is launched.
WWF's work on ecological footprint and One Planet
Living has demonstrated that it is not only vital to tackle the
direct impacts of our homes, such as energy used for heating and
lighting. The home can also be the major starting point for wider
environmental awareness and enabling greener lifestyle choices.
For example if homes are within walking access of public transport
nodes, local food markets and recycling facilities it makes it
much easier for residents to choose more sustainable lifestyle
options and dramatically reduce their overall ecological footprint.
The home is where people are most likely to
experience direct financial benefits of environmental action,
such as reduced fuel and water bills, or incentives such as reductions
in council tax as per the British Gas and Braintree flagship scheme.[198]
Improved resource use in the home will also
be vital if we are to address some of the key challenges of adapting
to climate change, most notably improved water efficiency.
(i) The significance of existing housing
compared to new build and the different levels of performance
each display:
There is no debate on the importance of addressing
existing stock in terms of tackling the UK's carbon emissions.
As stated in the introductory paragraph of the call for evidence,
housing accounts for around a quarter of all carbon emissions
in the UK. It also highlights that even with increased house building,
"homes built after 2007 are unlikely to account for more
than a third of total housing stock by 2050".[199]
WWF has consistently argued that while it is
vitally important that we address the performance of new build,
to ensure that it does not add to the high carbon emissions levels
already generated by housing, it is more important to tackle existing
stock which represents around 99% of the UK's housing stock.
A typical SAP (Standard Assessment Procedure)
rating for an average house in England is about 45 (using SAP
2005, where 1 is very poor and 100 is excellent). In contrast,
a SAP 2005 rating on a house built to current Part L building
regulations would be closer to 80 or more.[200]
This demonstrates that new build (as long as it complies with
Building Regulations) is significantly more energy efficient than
most existing homes.
Furthermore, energy demand in the housing sector
grew 17.5% from 1990 to 2003—higher than the 7.5% growth
for the economy as a whole during the same period. According to
the Environmental Change Institute, since 1970, energy use per
household has changed very little but because of a 30%[201]
growth in household numbers (due to, for example, an increase
in single person households) overall energy consumption has increased
by 32%.
The main areas of energy demand are space heating,
accounting for 60% of energy use, followed by hot water heating
(25%) and lighting and appliances (15%). In the last thirty years
gains in energy efficiency have been offset by an increase in
thermal comfort levels and an increase in electricity use for
lights and appliances.[202]
(ii) The respective roles of residents,
homeowners, landlords, local government, central government and
the energy industry in promoting and delivering greater energy
efficiency:
In order to tackle emissions arising from homes,
it is clear that action by all of the above parties is crucial.
Residents
WWF understands residents to mean rental tenants
in this context, and have answered on that basis. Residents suffer
from the consequences of energy inefficient homes, through high
bills and reduced thermal comfort, and a potentially unhealthy
environment. Residents have little or no incentive to invest in
energy efficiency measures (particularly those relating to building
fabric) when they do not own the property and may live there for
a relatively short period of time.
However, arguably the most significant impact
residents can have on home energy efficiency is through their
actions and behaviour within the home. It may be the case that
without energy efficiency awareness, residents' behaviour may
reduce or undermine efficiency improvements—for example
through "comfort taking" (when residents turn up the
heating to live in a warmer home after efficiency installations,
but pay the same energy costs as they were paying for a leaky,
colder house before).
Widespread action is needed to ensure the provision
of better home energy information to residents. The rollout of
Energy Performance Certificates (EPCs) to the private rented sector
will be a welcome start, and should be completed as soon as possible,
but greater efforts are needed to ensure communication of these
messages to tenants. Inclusion of EPCs in tenant's handbooks and
contracts should be mandatory.
Landlords
There is clearly very little incentive for landlords
to spend money on energy efficiency when they will not get the
direct benefits through energy bills as tenants usually pay these.
It is hoped that landlords will be more likely to act when they
are required to produce an EPC, as prospective tenants may be
able to negotiate reduced rental payments on the basis of predicted
energy bills. However, WWF's anecdotal experience suggests that
not enough people currently know about the EPCs for this to have
a significant impact on the rental market. As stated above, WWF
believes Government should invest in energy efficiency awareness
campaigns for both landlords and tenants in order to remedy this,
and also calls for mandatory inclusion of EPCs in rental packs.
Homeowners
Homeowners suffer from the direct negative impacts
of an inefficient home, and therefore the direct benefits of improvements,
through improved thermal comfort and reduced bills. However; this
alone does not seem to have prompted significant take-up of even
the most cost effective measures like cavity wall insulation so
far. Around 11 million cavity walls remain uninsulated even though
undertaking this measure makes very good financial sense (with
a payback time of one to three years) and with limited disruption
during installation.
Clearly then it is important to understand why
homeowners do not act. Possible reasons include a lack of understanding
of which measures should be installed, and their benefits. Furthermore,
the "hassle factor" related to finding an installer
and living with the, often perceived, disruption of installation,
and a lack of prioritisation of environmental issues in busy lives.
Again it is hoped that the EPC will help to
make people more aware of the efficiency of their own home when
they come to put it on the market, or when they're buying a new
property. For the first time people will have this information
in a clear and concise way which is a very significant step forward.
What remains to be seen is whether buyers act on the advice of
the EPC, and install cost effective improvements.
Government should monitor the impacts of the
EPCs on energy efficiency closely. Furthermore, those homes outside
the sale/letting process will remain unaffected by the EPCs. WWF
believes the Government needs to drive people to use the EPC to
better understand the environmental performance of their home
throughout its lifetime, not just at point of sale, to enable
appropriate energy efficiency improvements and the consequent
reduced fuel bills.
Again, the lifestyle and behavioural choices
of homeowners are equally as important as the fabric of the home.
Simple actions like turning off appliances, and making best and
most efficient use of heating/cooling systems can have significant
impacts on energy consumption. It is therefore vital that behavioural
issues are considered, and of course that all appliances are as
energy efficient as possible (WWF notes that this enquiry is not
considering appliances).
Local Government
The local council is usually the first place
where many people turn to ask for advice about home energy efficiency.
If the local authority (LA) is not adequately informed or motivated
to offer practical help this may be a wasted opportunity for positive
intervention. LAs have the optimal interface with local people,
and can provide help, advice and information. The LA should also
offer fiscal incentives, such as reduced rates of council tax
(see footnote 2). This should be supported through increased central
government funding.
There has been a great deal of publicity about
LAs fining "unsustainable" behaviour (such as failure
to recycle, or raising parking fees), but hardly any about financially
rewarding sustainable actions. More widespread council tax rebates
would provide a simple opportunity to change this, and help change
the perception that environmental action is somehow "painful".
However, council tax rebates should not be seen
as some form of panacea. Despite the rebates, most environmental
home improvements entail some level of capital expenditure by
the home-owner/tenant, and it is essential not to restrict the
assistance to the "able-to-pays". If council tax rebates
are provided, this will mean that the people most able to afford
improvements (and by implication, most able to afford to pay their
council tax) will get the rebates. To balance this, a much more
sophisticated grant system than that presently utilised is required,
to ensure the equity of installation and rebate.
Central Government
Central Government has a very significant role
to play in terms of setting the aspirations for addressing existing
housing, and putting in place the national policy to deliver against
these aspirations, and providing funding for awareness and support
programmes.
WWF welcomed the commitment in the Housing Act
2004 that by 2010 the general level of energy efficiency of residential
accommodation in England would be increased by at least 20% compared
with the general level of such energy efficiency in 2000. We further
welcomed the Government's recent commitment that all homes should
be "low carbon" within 10 years. We feel this is setting
a challenging but realistic target for greater energy efficiency
in this sector. However, unlike in Germany, where the Chancellor
has committed that 5% of the housing stock be improved year on
year, and set in place policy measures and committed the necessary
finance to enable it[203],
the UK Government has not yet outlined how it intends to achieve
the goal.
WWF was deeply disappointed that during the
last review of the building regulations (Part L), the Government
withdrew a proposal for "consequential improvements"
to be required in existing homes when people increased the carbon
footprint of their home (for example by building a conservatory).
This was in spite of the fact that the majority of respondents
were in favour of the measure. WWF would urge Government to reinstate
this proposal in the next review of Part L, and implement it in
2010. This is a vital measure to rein in future incremental growth
of the carbon footprint of our existing stock, and will help close
a blatant environmental loophole.
As well as regulatory measures, WWF thinks that
central Government must also offer national fiscal incentives
and support LAs in the delivery of local rebates. For example,
the recent stamp duty land tax exemption for new zero carbon homes
could be extended to existing homes when people undertake to improve
on their home's EPC within a certain time after moving in. However;
it should be noted that the zero carbon definition being employed
for this exemption for new homes is unnecessarily restrictive
and should be aligned with more realistic targets, as set out
in the Code for Sustainable Homes. WWF has responded separately
to the Treasury's informal consultation on the zero carbon stamp
duty land tax relief. A copy of our response can be made available
to the Committee if requested.
Other financial incentives should include the
provision of long-term loans attached to a home, to be paid back
over a period of say, 25 years, to enable extensive renovation
work to be undertaken. This could be provided in partnership with
mortgage companies.
Central Government should also invest more in
greater support services for energy efficiency. Currently, Energy
Efficiency Advice Centres are available but not many people know
about them, and anecdotal evidence suggests that some information
provided by them can be too generalised (ie not house specific).
The Government needs to better understand the factors which motivate
people to take environmental actions.
Government needs to build on the awareness of
the issues that people already have and drive action in these
areas. In doing so, government must understand that the motivation
for action is different for different people: a sense of responsibility,
providing a better future for their children, fostering community
spirit, personal gain, monetary savings etc. Furthermore, it is
essential to recognise that national policy without local action
and implementation is meaningless. Although short term wins are
possible in changing behaviour patterns, it is crucially important
to focus attention on the way people behave in the long-term,
and not just about changing actions in the short term. This type
of behaviour change happens best when people take action together—thus,
more support for collective action is needed, and not a constant
reliance on isolated, individual behaviour change.
The Government should also invest heavily in
extending the Low Carbon Buildings Programme to offer grants for
appropriate community and household renewable energy technologies.
Attempts by government to defend claims to be supportive of the
microgeneration industry are futile without this massive uplift
in investment. Furthermore, Government needs to roll out an information
service relating to this Programme to bolster public awareness
and confidence in the scheme.
Energy industry
The UK energy industry has several minimum regulatory
measures to work within which aim to reduce the negative environmental
impacts of certain parts of the industry. These include the Renewables
Obigation (RO), the Carbon Emissions Reduction Target (CERT) and
then from 2011-2020 the Government has committed to some form
of Supplier Obligation (SO)—a cap and trade scheme coupled
with a reduction in the amount of energy supplied to households,
in an effort to reduce energy demand and carbon emissions.
The aim of the SO is to encourage; a new relationship
between energy suppliers and customers; the decoupling of profits
and units of energy supplied; and the development of new energy
services companies, so that the present energy supply market is
transformed.
Energy companies should take a lead by exploring
and committing to a number of new proposals to help them in the
transition to a low-carbon economy. These could include; increasing
investment in large and smaller-scale renewables, trialling new
and innovative energy and carbon saving measures in households,
such as attractive loans, installing solar thermal and smarter
metering, and seriously considering the carbon benefits of introducing
a new increasing block tariff type of structure in the bills to
households.
WWF has recently published a report—Waste
Not, Want Not, Water and Energy Tariffs for Sustainability—outlining
new pricing structures for household energy and water that will
help to address the increasing environmental impact of rising
demand. WWF has included this report[204]
as part of our response to this enquiry.
(iii) EPCs and the provision of information
to households/buyers:
See above.
(iv) Government efforts so far through
public/private sector, including Decent Homes:
WWF congratulates the Government for leading
the way on energy efficiency through the public sector. In the
new build sector the Government has led the way by committing
to the Code for Sustainable Homes level 3, and for existing public
housing stock, many homes that were previously in dire states
of repair have been ameliorated by the Decent Homes programme.
However, from a thermal efficiency perspective,
the Decent Homes programme does not go beyond the very minimum
acceptable standards for thermal comfort, and the Government has
not made enough resources available to fund greater improvements.
Arguably it would have been preferable for this refurbishment
programme, which has been extensive, to invest in greater efficiency
from the start rather than having to retrofit those houses again
to bring them up to better SAP standards.
WWF believes that over the medium-term, Government
should require that all publicly-owned existing housing stock
be assessed against the EcoHomes for Existing Buildings standards,
developed by BRE and the Housing Corporation, with targets set
for improvements, and Central Government financial support for
councils and housing associations to enable this. This will not
only provide significant environmental savings, it will also help
to lower residents' water and energy bills and protect them against
future price increases.
WWF suggests that the Government should use
existing public sector stock to demonstrate how improvements should
be made, providing best practice exemplar schemes to complement
the "eco-towns" which will demonstrate best practice
in new build.
Government efforts to tackle the private sector
have amounted to very little so far. The Government has made very
few interventions and indeed, as stated they actively backed away
from imposing further requirements for energy efficiency in existing
homes through Part L. WWF believes this was a significant missed
opportunity to make massive cuts in carbon emissions.
We therefore strongly recommend that the Government
commits to a "Germany-style" programme to address the
energy efficiency of our existing homes with fiscal incentives
in place to enable it.
(v) The technologies available to reduce
emissions:
There are a number of challenges in the existing
stock which require innovative solutions. Perhaps first amongst
these is insulation for solid walls. WWF understands from the
current BERR consultation, Draft Strategy for Sustainable Construction,
that work is being carried out to research options for solid wall
insulation, and we look forward to the results.
WWF also welcomed the recent easing of planning
restrictions for both community and individual building renewables.
However, it is essential that residents undertake efficiency measures
first to ensure optimum use of renewable energy, and it must be
ensured that appropriate renewables are being installed. It would
be counter-productive for there to be a backlash against badly
sold and installed renewable technologies because they fail to
meet expectations of energy supply.
New and innovative technical solutions are needed
like a switch which turns off all non-essential plugs (for example
at night or during holidays, to prevent appliances wasting electricity
and make it easier for residents) should also be examined and
perhaps incorporated into future revisions of Building Regulations.
(vi) The costs associate with reducing
carbon emissions from existing housing:
WWF believes it is a false economy to take a
short-term view of cost when it comes to energy efficiency. Many
measures such as energy efficient light bulbs and insulation will
require upfront capital costs, however the pay back time for these
measures is very short and the carbon savings are significant.
Using the right technologies and measures means that saving carbon
and cutting bills can go hand in hand.
We're carrying out research, as outlined above
in the introduction, on the costs associated with slashing the
carbon emissions from the UK's existing stock. This report will
be completed by November 2007 and we would like to submit it to
this enquiry.
(vii) Specific challenges which may
arise in relation to housing of special architectural or historical
interest:
WWF has no expertise in this area.
CLIMATE CHANGE
ADAPTATION: WATER
EFFICIENCY
WWF maintains that however successful we are
in reducing carbon emissions, the UK needs a comprehensive strategy
for adapting to the effects of climate change, some of which we
have already experienced. Among the most significant predicted
impacts of climate change in the UK will be reductions in precipitation
in certain regions, and this will place increased pressure on
our already stretched domestic water supplies. Significant progress
has been made in considering improved water efficiency in new
housing. The challenge now lies in reducing water use in the existing
housing stock.
The UK lags significantly behind other European
countries in addressing water efficiency. In the UK, each person
uses on average 150-180 litres per day. However, as a result of
determined action, countries such as Germany have been able to
reduce this to 125. We must follow their example.
In 2006, WWF was part of a coalition of organisations
(between them representing over 6 million people) who published
the Blueprint for Water.[205]
The Blueprint set out a clear plan to achieve sustainable water
management in England and Wales. Among these were steps to address
water efficiency in existing housing.
WWF believes the Government should publish plans
to install a water meter in every home. The WWF report,[206]
included as part of this response, has made a strong case for
the installation of water meters. More than 90 studies of international
experience and UK trials have unambiguously demonstrated that
introducing metering and increasing block tariffs would lead to
a sustained reduction in demand of at least 10%, with reductions
of up to 30% in peak (summer) demand, when water availability
is at its lowest. Meters can be accompanied by tariffs that protect
vulnerable customers and penalise wasteful use.
WWF recommends that DCLG should introduce mandatory
high water-efficient standards for fixtures and fittings to be
installed in existing homes. The Government must also give strong
guidance to OFWAT to approve water company investment in fitting
water-efficient devices and appliances into existing homes. WWF
understands that consumers must be empowered and incentivised
to use water more efficiently by a combination of standards set
by the Government and corresponding services and products provided
by businesses and the water industry.
197 One Planet Living® is a joint initiative of
WWF and BioRegional based on 10 guiding principles of sustainability.
The vision of One Planet Living is a world in which people everywhere
can lead happy, healthy lives within their fair share of the Earth's
resources. Back
198
British Gas worked first with Braintree council and has extended
the scheme to 58 councils to offer council tax rebates to people
who install energy efficiency measures. Each household who invests
in home insulation from British Gas under this scheme will receive
a rebate of up to £100 from their local authority and could
see energy savings of around £200 a year through installing
loft and cavity wall insulation. http://www.britishgas.co.uk/energy-efficiency/products/home-insulation/council-tax.html Back
199
CLG, 2007, New Inquiry and Call for Evidence, Existing Housing
Stock and Climate Change. Back
200
NHER, 2007, http://www.nher.co.uk/pages/consumer_centre/energy_ratings.php Back
201
CLG, 2007, Eco-towns Prospectus. Back
202
Environmental Change Institute, 2007, http://www.40percent.org.uk/40-percent-research/introduction/ Back
203
According to the Environmental Audit Committee "The German
Government has said it intends to quadruple the annual budget
for encouraging energy efficiency from €360 million (£240
million) a year to €1.5 billion (£1 billion) a year.
Interestingly, it has also switched from financing loans to funding
direct subsidies because it believes that direct fiscal incentives
are more likely to have an impact. The German approach to fiscal
incentives contrasts sharply with the lacklustre way in which
ODPM, DEFRA and the Treasury have responded to the question of
fiscal incentives, which not only speaks volumes about the real
level of importance and commitment afforded to this issue, but
also paints a very depressing picture of complacency and apathy
which we believe is all too evident in these departments."-March,
2006, http://www.publications.parliament.uk/pa/cm200506/cmselect/cmenvaud/779/77907.htm Back
204
http://www.wwf.org.uk/filelibrary/pdf/energy_water_summary_final.pdf,
http://www.wwf.org.uk/filelibrary/pdf/water_tariffs_report01.pdf,
http://www.wwf.org.uk/filelibrary/pdf/energy_tariffs_report.pdf Back
205
www.blueprintforwater.org.uk Back
206
Waste Not, Want Not-Sustainable Water Tariffs-http://www.wwf.org.uk/filelibrary/pdf/water_tariffs_report01.pdf Back
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