Memorandum by the Housing Corporation
1. INTRODUCTION
2. Climate change is now acknowledged as
a pressing and critical global challenge with implications not
only for future generations but individuals and communities today.
3. In England government has set an ambitious
national target of achieving a 60% reduction in carbon dioxide
emissions by 2050 compared with 1990 levels.
4. While much attention has been placed
on the emissions from transportation, a key part in realising
this ambition will be reducing energy use in buildings. Energy
use in buildings accounts for around 50% of carbon emissions.
A significant proportion of this comes from the fuels we use (primarily
for water and space heating) in our homes. The focus of this enquiry
on existing housing stock is therefore timely and welcome.
5. Important measures are already being
taken. In addition to toughening building standards, the Government
has announced a target for all new homes to be zero carbon by
2016. Regulatory requirements to deliver this are being accompanied
and supported by initiatives to drive change in the housing market
such as the Code for Sustainable Homes.
6. However, while measures have been put
in place to improve the energy performance of new homes, around
two thirds of the homes that will be standing in 2050 will have
been built before 2005. Most of these homes were built to standards
(or indeed, were built before standards) that are significantly
lower than what we would require of our new housing stock. These
existing homes account not only for a greater number of buildings,
but are also likely to account for a higher proportion of carbon
emissions.
7. There are currently around 26 million
homes in the UK, with the vast majority of these in England. These
homes vary dramatically in age, size, condition, tenure and in
their energy efficiency. Notably, 38% of these existing homes
are over 60 years old, with 55% of them constructed before thermal
regulations.
8. Unlike many other European countries,
where there is a strong preference for private rental properties,
a significant proportion of English housing stock can be found
in the social sector. Around 18% of English housing stock is social
or affordable housing, owned and managed either by housing associations,
local authorities or their management agents (ALMOs).
9. The environmental performance of this
social housing stock is therefore of particular interest and significance.
In looking at how the social housing sector compares with other
sectors we can see that it is better on average than other sectors
(owner occupied and private rented). Since 1996 the average SAP
rating across all stock in the social sector has risen from 47
to 57, with stock in the private sector only rising from 41 to
46[217].
Many social landlords have also already undertaken core energy
efficiency measures (such as loft and cavity wall insulation)
both independently and as part of Decent Homes programmes. Today,
almost all social sector housing (96%) has a rating of more than
30.
10. Yet, despite the important strides that
have been made, the environmental performance of social housing,
as with other existing homes, will require ongoing attention if
government ambitions to reduce carbon emissions are to be realised.
11. As the government's national affordable
housing agency, the Housing Corporation is responsible for both
investment in new affordable homes and the regulation of 2 million
housing association properties. We therefore play an instrumental
role in not only ensuring that new affordable homes meet and exceed
current sustainable building requirements but also that housing
associations manage their existing stock efficiently and effectively—including
steps to improve environmental performance.
12. Looking ahead, our successor agency,
the new Homes and Communities Agency, announced by the government
in February 2006, will have a key role to play in promoting and
ensuring environmental sustainability in English housing. This
is particularly the case with new homes, as it will deliver one
in every three new homes in meeting the affordable housing targets
set out in the recent Housing Green Paper. It will also play a
key role in improving existing homes, notably as it exercises
its likely remit around estate regeneration and transformation.
13. Government is also currently considering
the regulatory future of social housing. Any new regulatory model
will also have a distinct contribution to make around the sustainability
of both new and existing homes.
14. DECENT HOMES
PROGRAMME
15. 70% of the homes that will exist in
2050 are already built. The Housing Corporation is well placed
to contribute to the improvement of existing affordable housing,
using experience and knowledge gained from implementation of the
Decent Homes programme in the social housing sector.
16. In 2000 the Government made a commitment
to bring the fabric of all public sector homes up to a minimum
standard by December 2010. The Decent Home Standard was established
as this minimum standard. The Housing Corporation is responsible
for ensuring that housing associations meet the standard within
the required timescale.
17. The Housing Corporation monitors and
has researched housing association asset management performance
in monitoring the sector's progress towards meeting the Decent
Home Standard in 2010. We are currently extending the criteria
we use to assess associations' performance (Housing Corporation
Assessments or HCAs) to place greater emphasis on asset management.
18. Housing associations, without exception,
report that they will meet the 2010 deadline. More significantly,
housing associations have made commitments to their tenants to
meet the target.
19. The total Decent Homes Standard failures
reported in the sector fell by 46,860 in 2006 to a total of 293,556,
which is 5.5% of total stock. It is important to note that a number
of variables other than stock condition affect both the total
number and the percentage of Decent Homes Standard failures and
make it difficult to monitor year-on-year trends. These include
changes in the total stock number which can be affected by new
stock transfer associations bringing more properties into the
housing association sector, new development completions, sales
to tenants, disposals on the open market and demolitions.
20. Importantly though, the Decent Homes
Standard is a trigger for action, not an aspirational standard,
as such it is therefore a minimum standard, and social landlords
are expected to carry out work in excess of the standard.
21. Under the 4th Decent Homes criteria,
social landlords must ensure that properties meet minimum standards
of thermal comfort. Associations have programmes of installing
roof and cavity wall insulation, often funded by utility companies
under EEC and Warm Front. The Housing Corporation is also working
closely with utility companies to increase take up of this.
22. Upgrading insulation is the most effective
thing that social landlords can do with existing stock to reduce
carbon emissions; much of this work is underway. We are aware
of the challenges faced in improving the thermal efficiency of
properties without cavity walls: there is a need to develop solutions
such as internal or external wall insulation for these.
23. ECOHOMES
XB
24. Under our 2003 Sustainable Development
Strategy the Housing Corporation commissioned the Building Research
Establishment (BRE) to develop an environmental assessment methodology
for existing stock. The BRE produced the Ecohomes XB (eXisting
Buildings) resource in 2006.
25. This product enables social landlords
to assess the current performance of the stock, plan the most
effective interventions to improve the worst cases and on the
back of actions taken measure the improvements made.
26. EcoHomes XB recognises that existing
stock includes a wide range of property ages and types. It will
help housing associations and local authorities to identify the
best score that can realistically be achieved by their particular
stock—the XB Goal and to track their progress towards it.
27. Following a successful pilot programme
and evaluation, Ecohomes XB has now been made freely available
to all social landlords.
28. The Housing Corporation ensured that
Ecohomes XB is aligned with housing association business practices
and objectives. We believe that it is a tool that will assist
associations to build improvement of environmental performance
of their existing stock into their business practices.
29. The following are the aspects of housing
association planned maintenance practice that are relevant to
Ecohomes XB:
30. Work to improve environmental performance
falls into two categories:
(a) Work that associations are carrying out
under their planned maintenance programmes. This has to comply
with Building Regulations and therefore new boilers must be A
rated condensing models, new windows must be double glazed with
low e glass.
(b) Improvement work such as installation
of renewables, eg CHP, Photo Voltaics, solar panels. These incur
additional cost and currently involve a degree of technical research
and feasibility studies.
31. Housing association maintenance is funded
from rental income and social Landlords are under pressure to
keep rents down. It also does not make economic sense to carry
out improvements randomly or over short term. Properties are occupied
and it is necessary to keep disruption to residents to reasonable
level. For these reasons work must be built into planned maintenance
programmes, characteristically over 30 year periods.
32. Because of these factors, it is important
to consider all aspects of climate change together in asset management
strategies—adaptation and mitigation, energy, water and
waste.
33. Ecohomes XB has been well received in
sector and its take up continues to be positive. It is suitable
for Local Authorities as well as housing associations and local
authorities were involved in piloting it. In addition to the core
resource, we have also commissioned Sustainable Homes to prepare
practitioner focused Good Practice Guidance.
34. ENERGY PERFORMANCE
CERTIFICATES
35. The introduction of Energy Performance
Certificates is currently being phased in and will be required
when homes are built, sold or rented. They provide homeowners
with significant information about the energy performance of the
home they are intending to occupy and provide advice on how they
can make cost effective changes to improve its performance. As
such they are an important tool in improving the environmental
impact of existing properties.
36. The Housing Corporation has advised
Communities and Local Government about the implementation of EPCs
in the social rented sector. We recently commissioned Interim
Guidance for housing associations on the introduction of EPCs
on letting in October 2008.
37. The implementation of EPCs in social
housing does present some particular challenges. Notably, there
is a risk that production of certificates when properties are
offered for viewing may extend void periods and slow down turnaround
of re-letting properties. The Housing Corporation and Communities
and Local Government are currently running a pilot programme for
housing associations to produce EPCs with lessons from this used
to inform and improve the wider roll out of EPCs in 2008.
38. An intention of EPCs is to create market
pressure by educating people to demand energy efficient properties.
The shortage of social housing makes this slightly less effective
in this sector but Energy Performance Certificates will still
play an important role in increasing awareness among tenants.
39. SUPPORTING
RESIDENT CHOICE
40. The Housing Corporation has worked with
the Energy Saving Trust to produce a toolkit for residents to
learn about climate change and to disseminate information among
neighbours and communities.
41. Tenant satisfaction is also a key measure
of housing associations' performance. A recent Housing Corporation
survey of our Existing Tenants' Panel on environmental issues
revealed significant levels of awareness and concern about energy
efficiency. Demand from tenants will therefore be an important
driver for improving environmental performance of existing stock.
42. Residents' play a significant role in
two other ways: their co-operation is needed in giving access
for works to be carried out and in submitting to the disruption
that they entail. We also know that individual behaviour is critically
important in achieving carbon reductions and maximum environmental
performance. The Energy Saving Trust estimates that 25% of target
carbon reductions may be achieved through behaviour change. In
this, it is equally important that technical measures are accompanied
by support for resident education.
43. GOLD AWARD
44. Our 2006 "Gold Award" theme
last year was Environmental performance. The Gold Award is made
to housing associations who achieve outstanding practice in the
field. It rewards and encourages associations, and the award is
followed by a programme of dissemination where winners share the
learning. The audience for this includes local authorities and
house-builders, as well as other housing associations.
45. Drum Housing Association was one of
the Gold winners in 2006. It has improved central heating and
insulation in 95% of its existing homes during the past ten years,
targeting the most polluting homes where solid fuel systems are
replaced with renewables. The average SAP rating of its stock
is now 70. Low water demand appliances are fitted in all its new
homes and in the refurbishment of existing homes.
46. The association is also developing methods
of reducing carbon emissions in existing housing with the Energy
Saving Trust through one of a long list of partnerships it has
established to deliver its sustainability strategy. Other partners
include local authorities, the World Wildlife Fund, housing associations,
government agencies, the Hampshire Sustainable Business Partnership,
utility companies and the association's own customers.
47. The association established and co-ordinates
SHREC— the Sustainable Housing Renewable Energy Consortia—which
has more than 50 members and works to reduce the costs of renewables
through bulk purchasing deals. With Kingston University it has
created a Sustainable Asset Management Index, which it uses to
gauge and track the sustainability of all its homes. Through its
Affordable Warmth Strategy it is targeting technical and benefit
advice to tenants living in fuel poverty.
48. In a similar vein, a mixture of innovation
in construction, resident involvement and a commitment to sustainability
secured a Gold award for Greenoak Housing Association and produced
warm homes and affordable energy bills for its 258 customers.
Greenoak's existing houses and flats have a whole-stock average
SAP energy efficiency rating of 92 (the UK average is 51). New
homes built by the association have overall CO2 emissions
as low as 13kg/m2/yr—way below the UK Building Regulations
requirement of 57 kg/m2/yr. Greenoak has also forged links with
local authorities and is a member of the 12-strong Small Housing
Associations Pursuing Excellence (SHAPE) group.
49. One of the largest housing associations,
Places for People, was also a Gold winner. Places for People (PfP)
has successfully moved environmental sustainability from the margins
to the mainstream of its business with a sophisticated sustainable
development matrix created to identify key targets for each business
area in the group's seven companies. It also runs a large programme
of research and innovation to support and inform the group's work.
50. Its approach to partnership work has
also yielded benefits for PfP's 58,625 customers. During the past
four years the Group has spent more than £3 million on energy
savings improvements to existing homes, producing a whole-stock
average SAP rating of 73. Its Affordable Warmth Strategy delivers
an average annual energy savings of £200 a customer, and
the group is now working with National Energy Action on the development
of fuel-poverty proofing.
51. RESEARCH
AND DEVELOPMENT
52. We are aware of increasing interest
from developers, landlords and tenants in improving the sustainability
of both new and existing stock. We are also aware however of uncertainty
about how best this can be achieved—both in terms of new
and existing technologies that can be adopted and those that will
provide best value for money, and in terms of facilitating cultural
change amongst consumers. This technological complexity represents
a risk for social landlords of adopting potentially costly and
inappropriate measures.
53. We have therefore commissioned a research
study into the most effective technologies and practices that
social landlords should consider in developing their asset management
strategies and maintenance programmes. These present particular
challenges: it is significantly more complex to improve the environmental
performance of existing, occupied homes.
54. We will use this research to moderate
the risk that landlords may undertake in implementing technologies
which are inappropriate or insufficiently developed, or simply
inappropriately adopted, because of a lack of knowledge. We will
be looking to promote this research beyond the social housing
sector and will work with the Local Government Association, the
House Builders Federation, the Audit Commission and Communities
and Local Government to promote the findings.
55. CONCLUSION
56. The Housing Corporation is committed
to championing and seeking to improve the ability of social landlords
to improve the environmental performance of existing social housing
stock.
57. In this we will continue to work closely
with Communities and Local Government, local authorities, residents
and communities, the Audit Commission, CABE, the Energy Savings
Trust, and affordable housing providers.
58. Work is currently underway planning
the activities of the new Housing and Communities Agency and,
potentially, a new regulatory body following implementation of
the Cave Review recommendations. In addition to delivering on
our current work in this area, we are also supporting the development
of environmental objectives as a key part of transition thinking.
217 SAP methodology was revised by BRE in 1998, 2001
and 2005 affecting comparability between years. However there
is a clear trend towards improvement and conclusions about comparability
between the sectors are valid. Back
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