Local Government Association
INTRODUCTION
The Local Government Association represents
local authorities in England and Wales, promoting the interests
of around 500 local authorities which represent around 50 million
people and spend around £74 billion a year on local services.
The government acknowledges that local authorities
have specific potential to help deliver the step-change in reducing
greenhouse gas emissions that national policies require. Recognising
this, the LGA has a dedicated programme of work on sustainable
energy and climate change, in partnership with the Energy Saving
Trust, and assists local authorities in joining up their environmental
work through its "greening communities" campaign and
support for the Joint Environmental Prospectus launched this year
with Defra.
The LGA also recognises that action needs to
be taken more urgently in all sectors including local government
and therefore established in March 2007 a Climate Change Commission
to consider how local government can respond more effectively
to both reduce greenhouse gas emissions and deal with the impact
of climate change.
The objectives of the LGA Climate Change Commission
are to:
— review and evaluate critically local
government's track record on climate change, and identify the
factors which have contributed to and hampered local government's
effectiveness;
— make recommendations for local government,
central government and other stakeholders on how the local government
response could be improved; and
— raise the profile of climate change
and the local government role in responding to it, to local government,
central government and the public.
Tackling emissions from existing housing stock
has been a key theme for Commission investigation. The Commission
plans to report later this year with recommendations to international,
national and local government to which the LGA will be responding
over the following months in consultation with its membership.
SUMMARY
Tackling existing housing stock must be an immediate
priority for national and local programmes of action to reduce
emissions of greenhouse gases.
With home energy use accounting for 27% of UK
CO2 emissions and over two thirds of existing housing
stock likely to be still in existence in 2050, it is vital that
our current homes are brought up to the higher standards we are
expecting homes of the future to meet.
With domestic emissions dependent not only on
the condition of the fabric of homes, but also on fuel choices
and behavioural decisions by millions of householders, no one
approach will fully deliver the cuts in emissions that are needed
from this sector. Rather we need a range of approaches joined
together under a holistic strategy to enable maximum use is made
of the myriad of individual opportunities to raise energy efficiency
standards and increase the use of low carbon fuel sources.
Local authorities (Las) have a pivotal role
to play in helping to meet national objectives on climate change,
not least in the household sector where action can range from
those of direct impact, such as improving energy efficiency in
council owned stock, to less direct influencing and community
leadership approaches.
Key approaches which the LGA believes could
help to deliver emissions reductions from our homes further and
faster include:
— Adopting a holistic approach at national
level to feed through the higher standards of Building Regulations
introduced from 2006 onwards to systematically address the improvement
of the fabric of homes built prior to 2006.
— Using the focus of the carbon budgets
approach of the Climate Change Bill to establish ambitions for
the existing homes sector nationally.
— Enabling local authorities to develop
and articulate a set of objectives for emissions from housing
stock in their own areas, building on the basis of the Home Energy
Conservation Act 2005 within the broader framework of climate
change outcomes in the new Performance Framework for councils.
— Developing the synergies with other
council agendas on fuel poverty, environmental quality, social
inclusion, cost efficiency, economic growth and regeneration,
to drive council action most effectively—for example through
a higher thermal comfort requirement for Decent Homes in a Decent
Homes Plus standard, and requiring all homes owned by social landlords
to achieve SAP 65 or more.
— Integrating local authorities more
closely with delivery of energy efficiency programmes such as
Energy Efficiency Commitment/Carbon Emissions Reduction Target
(EEC/CERT), through improved liaison with the Energy Supply Industry
as a starting point.
— Giving local authorities access to
key data such as that collected for Energy Performance Certificates
(EPCs) to enable them to target energy efficiency programmes effectively.
— Establishing a national strategy
to deliver the necessary skills and training for all aspects of
sustainable construction and refurbishment at sufficient levels
to meet the needs of higher standards for new build and to enable
wide scale upgrading of existing buildings.
— While raising the bar nationally,
retaining local flexibility to apply local planning policies to
require higher standards for new homes ahead of the national Code
for Sustainable Homes timetable and maximize local opportunities
for renewables, where appropriate.
1. TACKLING EXISTING
HOUSING STOCK
AND CLIMATE
CHANGE—THE
CHALLENGE
1.1 Home energy use accounts for 27% of
UK CO2 emissions. The domestic sector is clearly a
major priority area for action if national greenhouse gas emissions
reductions objectives are to be met. However this is not a homogenous
sector and, with over 25 million dwellings in the UK, it is only
through galvanising millions of individuals to take action that
significant progress can be made in tackling emissions from our
homes.
1.2 The statistics demonstrate the contribution
to be made from even modest percentage reductions in emissions
from each household, when replicated across millions of dwellings.
1.3 Each UK household emits around 6.6 tonnes
of CO2 from electricity and direct fuel use in the
home, with an additional 2.2 tonnes attributable to household
appliances (1). Total emissions attributable to households, including
activity such as personal transport, are around 20 tonnes. Nationally
this means some 144 million tonnes of carbon equivalent is attributable
to the domestic end user (2). The average household could save
two tonnes of CO2 per year by implementing standard
energy efficiency measures to improve the fabric of their home
and energy use within it.
1.4 Clearly there are cost effective benefits
to be had from tackling this key sector but no one approach or
policy lever can be adopted to translate this potential into results
overnight. This is partially because there are a number of routes
to achieve emissions reductions, but a more important factor is
the variety in approaches needed to persuade 25 million people
to go down these routes.
2. KEY ROUTES
TO TACKLING
THE CHALLENGE
2.1 In outline, the key routes for reducing
greenhouse gas emissions from existing homes can be categorised
as:
a) Raising energy efficiency standards, eg:
— upgrading insulation in walls and
lofts, improving emissivity of windows/glass areas, reducing air
leakage and draughts.
b) Changing behaviour in energy use in homes
particularly:
— heating and cooling; and
c) Increasing use of low carbon energy by
householders:
— contracting for green energy;
— installing household microgeneration
(CHP, micro wind, ground source heat pumps, solar thermal and
solar PV); and
— linking up to district scale renewable
generation (CHP, renewable sources).
2.2 The main focus of much council activity
is related to (a), raising energy efficiency in the fabric of
homes, given the direct role for councils in this arena through
their roles as landlords, as partners with other social and private
sector housing landlords and their more indirect roles in supporting
and influencing the owner occupied sector.
2.3 However behaviour change is also an
area for council action. There has been a significant increase
in the number and usage of electrical home appliances (as set
out in recent Energy Saving Trust reports [*3]). The Energy Saving
Trust estimates that around £1 billion worth of electricity
is wasted by leaving appliances on standby. This equates to around
10TWh, or about 10% of the electricity consumption of the household
sector. It is important to tackle these broader issues in parallel
with fabric issues not only to maximise carbon reduction at least
cost but also to reinforce the need for individuals to take ownership
of their carbon emissions and tackle them proactively and holistically.
2.4 The LGA is fully supportive of the concept
of a hierarchy of approaches, whereby demand reduction needs to
be seen as a top priority ahead of lower carbon energy supply
and this is particularly true of the household sector. However,
allied to demand reduction is the need to utilize lower carbon
energy sources more widely, where appropriate, and there are gains
to be made from taking action to ramp up household use of lower
carbon energy supplies.
2.5 This includes household level micro
generation, national grid supplied renewable energy and locally
provided decentralised energy supplies. Lead times for infrastructure
and technological implementation means that some of the most cost
effective gains are to be had further down the road but, without
falling into the trap of promoting technological fixes such a
household micro generation beyond their actual potential to deliver,
we need to maximise this approach at an early stage.
2.6 This requires a strategic approach to
ensure delivery can match up to technological promise, addressing
issues such as:
— supply chain readiness;
— quality assurance, from advice on
selection of technology through yo installation and maintenance;
and
— regulatory, fiscal and behavioural
barriers.
3. MEETING THE
CHALLENGE—A HOLISTIC
RESPONSE
3.1 Government policies are pro-active in
raising the bar for new homes and these are welcomed. For example
Building Regulations introduced in April 2006 have dramatically
raised the carbon performance required of new homes. A new house
built to today's standards is 40% more efficient than one built
before 2002. But with replacement of old homes with new running
at only 1-2% per year this leaves a huge challenge for existing
stock. Even with the higher targets recently announced for new
homes, those built after 2007 are unlikely to account for more
than around 30% of total housing stock in 2050 which means that
two thirds of all homes in 2050 are likely to have been built
to building standards with lower requirements on carbon emissions.
3.2 There is therefore a need for a holistic
approach to feed through these higher standards into existing
stock and this requires a set of joined up policies to systematically
address the improvement of the fabric of homes built prior to
2007.
3.3 Arguably government policy on addressing
domestic emissions has focussed disproportionately on the challenge
of new build—understandably perhaps because there is the
potential within existing approaches for regulatory standards
to be set for building fabric standards where these relate to
new homes which is not present in relation to existing buildings.
3.4 While wishing to endorse this vigorous
approach to raise the bar nationally, LGA would also wish to see
the potential for local flexibility to be maintained so that local
authorities can apply local planning policies requiring higher
Code for Sustainable Homes standards ahead of the national timetable,
and maximize local opportunities for renewables, where locally
appropriate.
3.5 Additionally a similarly vigorous and
holistic government framework for existing buildings to be upgraded
both in terms of energy efficiency of the fabric and access to
low carbon energy supplies needs to be promoted through joined
up cross government policies, spearheaded by CLG and Defra. The
current public and political focus on carbon budgets via the Climate
Change Bill provides a unique opportunity to provide cohesion
to approaches on existing buildings. It is imperative that targets,
budgets and trajectories build in factors for existing buildings
as ambitiously as the aims for new build. Clearly the zero carbon
agenda is not currently achievable to the same extent as for new
build, given the range of age, types and construction methods
in the homes we have inherited across our towns and countryside
today, but there is a need for political leadership and vision
on this issue at EU, national and local level.
4. MEETING THE
CHALLENGE—THE
LOCAL AUTHORITY
ROLE
4.1 Tackling home emissions of greenhouse
gases requires joined up action across a large range of players—from
individual householders/tenants to energy supply companies and
from international policy makers to local decision takers. The
role of the EU and national frameworks in setting the context
for local and individual action needs to be recognised while enabling
locally appropriate approaches to tackling the specific housing
circumstances of local areas.
4.2 An articulated set of aims, trajectories
and targets at national level will be an invaluable starting point
for each sector/set of actors to refine their own role in meeting
national carbon objectives. For LAs this means developing and
articulating a set of objectives around the role each LA can play
at local level in addressing housing stock emissions. This is
not new since under existing frameworks LAs have specific direct
roles and duties, and beyond this have wider influencing and place
shaping roles, but a clearer articulation against specific sectoral
aims is needed.
Current Key Drivers on Local Authorities
4.3 Synergies with a wide range of council
agendas mean that there is scope to weave climate change objectives
into existing priorities such as:
— tackling fuel poverty and social
inclusion;
— transport provision to address air
quality and congestion problems;
— economic and regeneration programmes;
and
— waste collection and disposal.
Example
Birmingham City Council has been pro-active in addressing the energy efficiency and climate change agenda in the private housing sector, through the Affordable Warmth and Fuel Poverty programme. Focussing on four deprived wards, pilots provided a platform for new working relationships with the private sector to deliver area-wide energy efficiency improvements for vulnerable and low income households.
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4.4 Broad policy drivers on councils include:
— Power of securing environmental, social and economic
well-being (Local Government Act 2000);
— role of champions (elected member/officer);
— public pressure/local priorities; and
— Local Strategic Partnerships and sustainable community
strategies.
4.5 The principle specific drivers for LA action on tackling
emissions from existing housing currently in place can be summarised
as:
— Home Energy Conservation Act 2005 (HECA).
— CPA/Comprehensive Area Assessment performance
indicators (proposed new framework announced in the Local Government
White Paper 2006) and Local Area Agreements/Multi Area Agreements.
— Home Health and Safety Rating System.
— Climate Change and Sustainable Energy Act 2006.
— Schemes including warm front and Energy Efficiency
Commitment/CERT.
— Energy Performance Certificates (Energy Performance
of Buildings Directive).
4.6 Of these drivers, the single key specific driver
impacting most directly on current LA work is HECA. Local authorities
with housing responsibilities are required to identify measures
to improve the energy efficiency of all residential accommodation
in their area by 30% between 1995 and 2005-10 and to report on
progress made in implementing the measures. In the future, performance
frameworks outcomes on community emissions promises to embed this
HECA driver more holistically since it will be important for councils
to address housing stock energy efficiency as a cornerstone of
their performance management relating to community climate change
outcomes.
4.7 Crucially a community emissions outcome as part of
a honed down set of key performance indicators will give LAs a
strong focus in not only addressing energy efficiency in their
own housing stock but also in other socially owned stock and in
the private rented and owner occupied sectors. The LGA believes
that this will provide a powerful driver for councils to deliver
at local level on national climate change objectives, particularly
in extending the work of local partnerships, through Local Strategic
Partnerships and Local Area Agreements, on emissions reductions
for local areas. The domestic sector is key to delivery on the
performance framework, not simply due to the importance of tackling
a sector which is responsible for over a quarter of emissions
by end user, but also because LAs have potentially significant
traction to bring to minimising household energy usage.
Responding to the Drivers
4.8 LA action in response to these drivers ranges from
actions under council direct control such as installing measures
in council owned stock to far more indirect actions such as influencing
consumer behaviour and choices. The broad categories for LA action
relate to:
— Social housing (work with Registered Social Landlords)
Example
Kirklees has set up an authority wide Warm Zone bringing every resident the opportunity to improve the energy efficiency of their home through a £15 million, three year programme. Pro-actively contacting every householder to offer insulation, advice and deals on boilers and solar panels, the scheme is one of the biggest and most comprehensive in the UK.
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Council roles involve promoting action through:
— promotion of measures through direct council incentives
or advice services; and
— provision of measures through council run schemes.
Example
London Borough of Lewisham has adopted a small scale, highly focussed programme to increase energy efficiency and the use of renewables while reducing costs and fuel poverty in Energy Action Zones. Installing insulation, for example, in selected households will lead to carbon emission reductions of around 27,000 tonnes (over the lifetime of the measures)
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— signposting to funding/incentives from other bodies
for measures; and
— promotion of behaviour change through direct/indirect
campaigns.
Example
Cornwall advice services run by the Energy Saving Trust, working with the Cornish District Councils, referred around 10,000 households for energy efficiency and insulation grants in 2006-07.
This would lead to around 21,000 tonnes of carbon saved per annum over the lifetime of the products.
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Key Programmes
4.9 Government policy focusses on carbon savings through
a number of signficant programmes such as the Energy Efficiency
Commitment (EEC/CERT) with further consultations underway around
a future supplier obligation[*4] as set out in the Energy White
Paper 2007. In conjunction are a number of key policies connected
to government policies for addressing fuel poverty. Defra's Energy
Efficiency Action Plan 2007 sets out that broadly the EEC/CERT/Supplier
Obligation approach is expected to yield 5.4 million tonnes of
carbon reductions per annum by 2020—plus another 0.4 MtC
associated with fuel poverty programmes. In addition the new build
approaches such as Building Regulations 2002 (England) and Building
a Greener Future will lead to around 1.9 MtC per annum by 2020.
4.10 This underlines the key role of non government funded
approaches, particularly funding from householders channelled
via the energy supply industry, in delivering carbon reductions
and the importance of ensuring that such programmes deliver in
the most effective way holistically on national carbon reduction
aims.
4.11 Defra's Energy Efficiency Action Plan 2007 *[5]
summarises the overall government approach to the existing household
sector.
To improve the energy efficiency of existing homes, we:
— will continue to strengthen the Energy Efficiency Commitment, with the third phase of the scheme from 2008-11, to be known as the Carbon Emissions Reduction Target, potentially saving 1.1 MtC per annum by 2010;
— will drive further energy efficiency improvements in the home through a continued obligation on energy suppliers until at least 2020;
— have set minimum requirements for efficient heating and thermal comfort for social landlords using the Decent Homes Standard, and other mechanisms in the devolved administrations;
— are continuing to improve energy efficiency of the homes of vulnerable groups by tackling fuel poverty, through the Decent Homes Standard in social housing, and Warm Front and other programmes elsewhere; and
— have introduced various financial measures to incentivise energy efficiency, including a reduction on VAT for professionally installed energy saving materials and the Landlord's Energy Saving Allowance."
(Defra Energy Action Plan 2007)
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5. KEY BARRIERS
5.1 It is self evident that the existence of some nine
million unfilled cavity walls and an as yet unmet potential for
the average household to reduce emissions by some two tonnes means
that the drivers are yet not fully effective.
5.2 Defra's Energy Efficiency Action Plan 2007 states:
"as the Stern Review identified, there are still obstacles
and market failures preventing us realising the full technical
and economic potential for energy efficiency". The Action
Plan categorises some of the broad barriers including:
— the lack of appreciation of, and information about,
the true costs and benefits of energy efficiency measures;
— lack of access to capital and high costs of capital;
and
— split incentives, and lack of motivation, awareness
or interest among consumers.
5.3 For council action, LGA views the key barriers as
broadly grouped into policy, fiscal, regulatory and cultural/behavioural
including:
— Funding approaches (revenue and capital):
The programme based, grant funding approaches with one off
pots of funding make it difficult to gain momentum. Householders
find it hard to negotiate their way through the processes and
councils have to invest hard pressed resources in finding funding
and supporting householders in obtaining funding.
Evidence to our Climate Change Commission stated that:
"the on-off nature of funding and eligibility criteria
for energy efficiency and micro-renewable measures are real barriers
to achievement in carbon reductions in the domestic sector"
— Relative policy emphases/competing priorities:
A holistic sense of purpose in addressing this key sector
is missing at national level, although at local level approaches
to join up through whole house, whole street/area programmes have
demonstrated the effectiveness of a household focused approach.
— Political/cultural at local and national level:
The incremental nature of existing building stock approaches
gives less scope for public impact and makes it harder to gain
high profile political attention.
— Public priorities/level of knowledge and interest:
While the generally higher profile of climate change, coupled
with higher energy prices has been a key driver in raising householder
awareness, translating this into action is harder to achieve.
6. MEETING THE
CHALLENGE—SEIZING
THE OPPORTUNITIES
6.1 Setting out a path towards meeting our objectives
on existing homes emissions means that we need a detailed road
map, not just setting out the technical routes but more describing
the policy route, identifying the barriers and drivers.
6.2 In the LGA's view, the issue of whether existing
homes can be brought up to higher standards expected of today's
new build is not principally about technical issues. For a large
proportion of homes there are readily available, cost effective
measures that can be implemented today. Given the ensuing benefits
not only in terms of environmental improvements but also in direct
terms financially to householders through reduced energy bills
the issue is apparently also not directly to do with rational
economic factors.
6.3 The key barriers appear to be household inertia and
the detailed routes to overcoming this, needs to be explored further.
Possible approaches span a spectrum from, at one end, a centrally
driven programme, with statutory/regulatory teeth, systematically
targetting housing in all sectors, through targetted incentives
or marketing programme aimed at specific segments, down to ramped
up information and advice programmes designed to stimulate individual
responses.
6.4 Clearly these approaches are not mutually exclusive
and some aspects of these approaches are already being adopted.
The key question, as addressed by the LGA Climate Change Commission,
is whether in their current mix they hit the right levers, to
the right extent. The detailed questions the Commission asked
itself and invited evidence on can be summed up as:
— Are there incremental changes we can make to current
approaches—ie is there scope to move faster through a more
overt focus on existing housing stock policies? and
— Are there bolder, more radical approaches we can
suggest for the policy and programme framework? ie Is the current
regulatory/statutory/fiscal framework right and do national policies
have the right local focus?
Our evidence base
6.5 The Commission received a wealth of evidence in written
form and at a number of regional and focus group events in spring/summer
2007 from council officers and members, regional and government
bodies and a wide range of stakeholders. This evidence can be
found at the Commission website. (http://campaigns.lga.gov.uk/climatechange).
6.6 A brief summary of some of the key points include:
— Without visible long-term benefits, improvements
to current planning legislation and the sort of financial incentives
available in other EU countries, significant take up of microrenewables
will remain at "demonstration" level in the UK. Solid
commitment from government is also essential for the renewables
industry if their investment is to continue, to enable costs to
be reduced and take-up increased.
— A common issue raised by councils (and others)
is the need to engage longer-term factors in financial accountancy.
— the support of organisations such as Community
Energy Solutions; Energy Savings Trust and Carbon Trust was considered
very valuable.
— A number of councils commented on the difficulties
and importance of influencing households, particularly in relation
to energy efficiency.
"Help for the domestic sector has been delivered by the
Energy Saving Trust through its Energy Efficiency Advice Centres
(EEACs). The EEACs have provided a telephone advice line, followed
up by the use of HECs (Home Energy Checklist)[but this] relies
on the general public knowing about the service and making the
first contact either by phone or at an event.
— Council tax reduction for householders installing
energy saving measures received widespread support as an EEC promotion.
— The Decent Homes standard should be upgraded in
connection with the thermal requirements to ensure that the Government
meets its legal duty to relieve fuel poverty as well as achieving
further reductions in carbon emissions from the domestic sector.
— A revival of investment in council house building
is needed and under current policy, theses homes would be built
to Code for Sustainable Homes 3 Star rating, which is a considerable
improvement on current Building Regulations.
6.7 Research: The Commission also commissioned research,
undertaken by the Centre for Sustainable Energy (CSE) *[6] addressing
the issue of how much traction local authorities can have on carbon
reduction in specific areas. The CSE report presents a Local Carbon
Management matrix setting out what can be done inter-alia on domestic
energy efficiency, and how councils can progress through performance
levels.
6.8 This indicated that some of the areas and approaches
to enable councils to have maximum traction include:
— adopting specific programmes to improve private
housing, with grant regimes reflecting these priorities,
— supporting and engaging on EEC/CERT and Warm Front
schemes to promote locally increased take-up, and
— promoting senior strategic engagement within the
council and partners with resourcing and "champions"
with power to act.
6.9 This research also identified some "easy wins,
big strides and lasting impact" measures including:
— distributing energy efficiency advice centre material
regularly;
— endorsing local grant based schemes;
— setting higher thermal standards than in Decent
Homes with a clear programme for achievement; and
— developing clear and tailored corporate strategy
with political buy-in to improve energy efficiency with regular
publicity for activities.
7. PROPOSED SOLUTIONS
7.1 As with many other aspects of tackling greenhouse
gas emissions, there is no magic bullet for tackling emissions
from this sector, rather a combination of renewed vigour to existing
programmes and some potentially more radical solutions.
7.2 The LGA will be considering the Commission's recommendations
around this issue. At this stage, in advance of the publication
of their findings, expected in December, the LGA has outline views
on a number of potential routes for action.
7.3 In broad terms generating action at household level
needs policies to focus both on strategy and implementation.
8. THE BIG
PICTURE—GETTING
THE STRATEGY
RIGHT
8.1 An overarching strategy is needed for this sector,
supported by the statutory frameworks such as the Climate Change
Bill and the Local Government White Paper and embedded in regulatory
structures and national programmes providing resource and financial
support. Specific elements of such a strategy could include, for
example:
— a nationally driven strategy ensuring higher standards
in any retrofitting work done—a regime tightening training
requirements for measures installers, or
— targets to ramp up delivery from the LA sector
aligned to Comprehensive Area Assessment performance framework.
8.2 Within a broad framework, it will be important to
then identify significant windows of opportunity to generate action,
around key intervention points such as house sale, rental or extension/modernisation
building in approaches to maximise individual, community and sector
responses to the broad framework. Interweaving approaches around
key intervention points could help to stimulate individual action
by catching householders with incentives and requirements at the
point where they are likely to be most active in tackling household
fabric issues. Statistics collated by the Energy Saving Trust
indicate that the maximum period for household renovations is
within a few months of a property changing hands. Approaches could
include, for example, use of Energy Performance Certificates to
require homeowners to implement measures within a set timeframe
of change of ownership, targetted information or incentive campaigns
for first time buyers, new tenants etc.
A sectoral strategy
8.3 The current macro policy consideration through the
Climate Change Bill together including, for the first time, attempts
to set out carbon budgets over time, gives a unique opportunity
to address the need for an overall policy framework for existing
housing. This could provide the starting point for a more detailed
sectoral approach, including the adoption of national budgets
for the existing domestic sector.
8.4 A holistic programme for addressing fabric of existing
homes to retrofit homes built prior to 2007 could be effectively
driven by a trajectory set to reduce progressively over successive
budgets the allocation for such pre 2007 homes, and could be a
main driver to move all homes as far as possible to meet the higher
carbon emissions standards of 2006 Building Regulations.
8.5 To support this work the LGA considers that more
modelling of the current homes potential is needed, building on
local housing stock surveys but with a more specific lens focussed
on carbon reduction potential.
8.6 Performance frameworks for councils under Comprehensive
Area Assessment processes, including outcomes on climate change,
should prove to be a powerful driver for LA action. However we
need further worked up modelling, measurement and tracking of
the potential and actual impact, together with a process for ensuring
area wide co-operation through Local Strategic Partnerships and
Local Area Agreements if this driver is to have maximum impact.
LGA would welcome further work with CLG and Defra on how a community
emissions outcome could most effectively become fully embedded
in LAA processes.
9. UNDERPINNING THE
STRATEGY—IMPLEMENTATION
9.1 A number of the key elements supporting implementation
of a strategy on existing housing stock are examined below, focussing
on:
a) programmes b) fiscal approaches c) regulatory approaches
d) information advice and marketing e) links to planning for new
build f) skills and training and g) links to fuel poverty issues.
(a) Existing programmes
(i) EEC/CERT
9.2 Currently the most significant source of funding
for energy efficiency, impacting on LA action, is the Energy Efficiency
Commitment/Carbon Emissions Reduction Target (EEC/CERT). LGA supports
the continued expansion of this and the supplier obligation which
continues to focus on supplier delivery, since this is currently
where there is the most potential to dovetail energy demand and
fiscal approaches. However, in the longer run the potential to
shift the responsibility, in parallel, to the consumer needs to
be considered, with appropriate safeguards.
9.3 There are issues remaining over the operation on
EEC approaches. For example, evidence to the Climate Change Commission
stressed problems with EEC2 funding:
"the energy companies have currently met their Ofgem
targets under EEC2, and are no longer releasing monies for the
domestic sector, causing immense problems for local projects that
were already underway and using this source of funding".
9.4 Evidence to the Climate Change Commission also stated
that:
"A far more effective use would be to focus on funding
to local authorities, allowing them to work with local partnerships
to pool budgets and innovation, in order to deliver whole community
aims and targets to tackle climate change, rather than top down
national and regional solutions. This would not just be looking
at domestic energy conservation, but community buildings, businesses,
transport, local food production."
9.5 LGA agrees that the use of EEC/CERT funding to assist
LA work needs further consideration. Currently the LA role is
to facilitate achievement of carbon reduction targets for the
ESI, providing the ESI with assistance in meeting targets which
is missed would have significant bottom line impacts for the companies.
The lever/driver for LAs to participate is currently less direct—being
partly a sense of leadership and partly access to small scale
funding. The barriers are significant—for a resource strapped
small council attempting to access funding requires in-house expertise
and liaison with potentially a number of different suppliers.
9.6 LGA considers that more effective use of such significant
amounts of funding could be achieved by integrating LAs more closely
into delivery, at the very least through informal mechanisms for
partnership such as that being worked up by the LGA with the energy
supply industry. A development beyond this could involve LAs more
centrally in delivery of schemes and the LGA will consider any
Commission recommendations on this issue closely.
(ii) Existing Programmes—Low Carbon Buildings Programme
9.7 The Low Carbon Building Programme is a significant
programme and provides key signals of government commitment. LGA
welcomes the improvements to the application process to ensure
that energy efficiency measures are in place before grants can
provided for installation of supply technologies but notes that
there is a considerable over demand for a relatively small pot.
Evidence to the Climate Change Commission stressed that:
"renewables funding is also somewhat erratic and insubstantial.
Originally available under the Clear Skies and Solar PV programmes
and now amalgamated under the Low Carbon Buildings Programme the
levels of grant funding are still not adequate to encourage greater
uptake by either the domestic or business sectors".
(iii) Existing Pogrammes—Warm Front
9.8 In addition LGA notes the success of programmes such
as Warm Front and would welcome further consideration of how these
approaches, targeting specific groups, can be holistically interwoven
with a wider approach to tackle emissions in parallel with fuel
poverty aims.
Evidence to the Climate Change Commission highlighted problems
with existing approaches:
"Warm Front, the Government's main grant-funded programme,
is available only for households meeting certain criteria. This
can miss out a huge sector of the population which is neither
"rich enough" to pay for energy efficiency measures
themselves, or "poor enough" to meet the criteria for
grants. This sector may also be the part of the population most
likely to possess the motivation to take action if they were encouraged".
(iv) Existing Programmes—Area Based Approaches
9.9 Defra programmes under the Community Energy Efficiency
Fund focusing on an area approach and connecting up EEC and Warm
Homes programmes are welcome but LGA would wish to see the current
schemes analysed in detail to ensure any lessons from this approach
are learned and can be rolled out more widely. Currently there
is no clarity on how the use of this funding can be extended beyond
what is effectively a pilot phase. *[7]
9.10 Clearly the able to pay sector remains a challenge
and the solution is not about scarce grant funding going to the
able to pay sector in increasing proportion, more it is imperative
that we find better levers for this sector. Again no one magic
bullet is likely to succeed but rather it will be a combination
of information, regulation and fiscal incentives.
9.11 In addition, there are specific issues related to
the hard to treat properties, as quoted in our Climate Change
Commission evidence:
"neither of these grants schemes [warm front/decent homes]
has helped some of the worst housing stock in the UK because the
criteria have never covered the truly hard to heat homes, ie those
properties with solid walls that require external or internal
thermal insulation as opposed to cavity wall insulation, including
the increasingly popular residential park homes".
9.12 Evidence to the Climate Change Commission suggested
that LA programmes can have a key influence:
"Herefordshire Council Private Sector Housing department
found that when they ran their Special Energy Efficiency Scheme,
the addition of a further £1,000 to add to the then £400
available under Clear Skies, and the availability of an interest
free loan, made a considerable difference to take-up of the installation
of solar thermal".
(v) Existing Programmes—Decent Homes
9.13 The Decent Homes programme requires a higher thermal
comfort standard to have a significant impact on the energy efficiency
levels of homes. The suggestion from a House of Commons Select
Committee that a new Decent Homes Plus standard be introduced
post 2020 to include a much more ambitious thermal comfort criterion,
in line with Building Regulations at the time the new Plus Standard
is set. The LGA would wish this approach to be considered further
along with other key policies in the Fuel Poverty Strategy and
for funding for the different programmes to be closely co-ordinated.
(b) Current fiscal approaches
9.14 HMT has introduced a number of fiscal measures in
budgets over the past few years, for example in relation to the
private rented sector in recognition that this sector is not on
track to meet the emissions reductions targets required. Such
properties have low energy efficiency levels compared to the rest
of the housing sector and typically produce 500 kg of carbon dioxide
per year more than other houses.
9.15 Recognising a potential market failure, with split
incentives deterring landlords from installing measures which
would accrue benefits not to themselves but to their tenants,
HMT introduced the Landlords Energy Saving Allowances (LESA) in
2004 offering a deduction against taxable profits for landlords
installing energy efficiency measures with an extension of the
allowance in subsequent budgets addressing some limitations of
the original scheme.
9.16 There is potential to assess the impacts of such
schemes and explore pro-actively the potential for wider ranging
fiscal incentives. Included in a range of approaches which LGA
will be considering further are:
(i) Council tax issues
9.17 As a property based tax, the council tax offers
an obvious area for linking the energy efficiency of the property
with the level of tax. It would be theoretically possible to band
this so that it is progressive by stepping up the cost through
the band levels linked to the energy efficiency levels (along
the lines of EPC certificate bands). LGA recognises that council
tax "rebate/discount" schemes adopted by some councils
using EEC funding have been popular. LGA has considered that technical
issues surrounding the use of this kind of pass through of ESI
funding need to be addressed, but that this needs to be done in
the context of the wider issues of council tax reform post Lyons
review.
(ii) Stamp Duty
9.18 We welcome the linkage of zero carbon new homes
to zero stamp duty and would welcome consideration for this to
be developed for existing homes so that on sale there is a discount
for the most energy efficient homes. This could have significant
impacts but clearly also has significant costs.
(iii) VAT
9.19 The 5% VAT rate applicable to installation of specific
energy saving materials is helpful, as is the extension of the
list of qualifying technologies, such as air source heat pumps
and micro combined heat and power units in recent budgets. LGA
welcomes government moves to work with the EU to minimize VAT
application on energy efficiency products and services and recommends
that this be pursued vigorously.
(c) Regulatory approaches
9.20 Regulatory approaches are a key component in addressing
emissions with two key examples impacting on homes being:
trading standards officers enforce regulations on misleading
claims ensuring that consumers can be confident in selecting the
most sustainable, environmentally friendly products and services.
With the proliferation of labelling schemes and "green"
claims this is increasingly important. Additionally the introduction
of EPCs for home sales and rentals will mean an extended role
over energy efficiency information provision.
Housing Health and Safety Rating System (HHSRS)—local
authority officers assess premises using the HHSRS. They can require
owners/landlords to undertake work to protect occupants from excess
cold, or damp and mould affecting the property. This can often
contribute to alleviating fuel poverty and/or improving energy
efficiency.
9.21 LACORS (the Local Authority Co-ordinators of Regulatory
Services) published in 2007 a Climate Change toolkit for regulatory
services containing a number of case studies and information on
how councils can help householders to reduce emissions (www.lacors.gov.uk)
(d) Information/advice/marketing
9.22 Local Authorities have a useful role in the provision
of carbon reduction advice and this needs further support both
in terms of inhouse resources for councils to provide services
but also for external agency support to assist the general public
and councils in delivering advice services.
9.23 There are a number of useful support packages for
councils wishing to access advice themselves on how to promote
domestic energy efficiency—for example the Nottingham Declaration
Action Pack (*9), and the IDeA/Beacon toolkit (*10) However these
resources need to be maintained alongside other support packages
such as the BERR Energy Measures report and Guidance for Local
Authorities (*11)
9.24 Marketing approaches such as EPCs are welcome and
the LGA would like to see a timetable published for their extension
to all homes marketed for sale or rent. We would also like CLG
to assess the potential to extend their use beyond a marketing
tool, for example with mandatory implementation of energy efficiency
measures identified or incentives such as preferable mortgage
conditions for homes implementing measures. Local Authorities
should also be given access to the data collected for EPCs to
provide a cost effective source of information for tartgetting
LA programmes.
(e) Planning
9.25 The use of planning policies to relate to existing
buildings is developing. Extensions of refurbishment applications
can be required to include energy efficiency improvements to compensate
for the additional energy and carbon dioxide resulting from the
building. This approach takes advantage of a key intervention
point on existing homes and enables the cost effective installation
of measures.
Example
Uttlesford District council requires cost-effective energy efficiency improvements to be carried out on dwellings when they are extended. The first LA in the UK to introduce a requirement of this kind, UDC has used the planning system to address existing homes with a time limit of six months from completion of the extension (or first use if earlier) to complete the measures.
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(f) Skills and training
9.26 A key factor in delivering objectives for upgrading
existing housing stock as well as new build will be the development
of a structured strategy and implementation programme for significantly
scaling up skills in the planning, construction, retrofitting
trades as well as in priming supply chains to meet increased demand
for products. LGA would like to see a national strategy to deliver
on this at all levels, with an early assessment of likely key
deficits in specific sectors and geographical areas assessed.
It is also important to ensure high levels of quality assurance
processes, including necessary accreditation schemes, to enable
householder confidence in investing in energy efficiency measures
and renewable technologies is maintained.
(g) Fuel poverty
9.27 In view of national objectives to eradicate fuel
poverty, the impacts of energy efficiency/carbon reduction programmes
on fuel poverty need to be assessed explicitly.
9.28 The Government needs to take a more holistic approach
to identifying those in fuel poverty and linking them up with
the programmes available. Given the range of contacts from LAs,
the NHS and DWP with most of these households, a pro-active, integrated
approach to link up the data held and maximise the use of existing
contacts is needed. LAs have a key role here which can be maximised
further.
9.29 Fuel poverty targets should be included in the new
LA performance framework and it is important that Local Area Agreements
should give reasonable priority to fuel poverty.
9.30 While the Decent Homes Standard has been very helpful
in raising energy efficiency standards in the social sector, the
low thermal comfort/energy efficiency provisions means that many
homes meeting the Decent Homes Standard will still, have very
significant carbon emissions and will leave households in fuel
poverty. The Decent Homes Standards are lower than those of Warm
Front, the Government fuel poverty programme for the private sector,
which requires a SAP rating of 65 wherever practical. The social
sector standard should be similarly demanding and set at the same
level as the private sector standard of 65 since public funds
are being used in both cases.
9.31 The Fuel Poverty Advisory Group (FPAG) is recommending
that in the period to 2010 a SAP of at least 65 should be achieved
wherever practical if Decent Homes Standard work is in any case
being carried out in a Social Housing Dwelling. For the post 2010
period all Social Housing should have a SAP of at least 65, either
by a change in the Decent Homes Standard or through a duty on
landlords to achieve a SAP of 65 by 2016.
9.32 Local Authorities need access to the information,
which will enable them to locate those who could benefit from
the fuel poverty programmes, or who might also be helped by advice
on Benefit Uptake. LAs should have access to the energy efficiency
data of the Energy Performance Certificates so that they can effectively
target information on both fuel poverty and energy efficiency
programmes.
9.33 Current legal uncertainties mean that some councils
do not feel able to access the data held within their own Authority
on Council Tax and Housing Benefit recipients for the purpose
of targetting the fuel poverty programmes. With FPAG we are urging
the Government to clarify the legal situation to allow access
for Local Authorities to their own data for the purposes of the
fuel poverty programmes.
9.34 The Home Health and Safety Rating System and the
Houses in Multiple Occupation Legislation will be important potential
tools for acting on fuel poverty as well as on energy efficiency
in the private rented sector. This legislation needs to be implemented
effectively, with the necessary resources made available, and
CLG could helpfully promote the use of the provisions for HHSRS
inspections to be imposed on landlords refusing Warm Front or
EEC low income group measures.
10. CONCLUSIONS
10.1 Achieving significant improvements in emissions
from the existing housing stock are not an optional extra if we
are to meet national objectives on reducing emissions.
10.2 Current research clearly indicates that there is
significant untapped potential to make improvements with existing,
cost effective technologies—and that these can be delivered
quickly given the right impetus.
10.3 A holistic strategy for tackling this sector is
needed, on the back of carbon budget approaches for sectors, with
a holistic focus on fuel poverty in parallel to tackling climate
change issues.
10.4 Local Authorities' pivotal role in delivering real
impacts on reducing emissions from our housing stock has been
recognised however there is further scope to focus emissions reductions
through the agency of councils.
10.5 Future developments such as the new performance
framework proposed by the Local Government White Paper, the introduction
of the Energy Measures Report under the Climate Change and Sustainable
Energy Act 2006 and the development of the leadership role of
councils to secure the environmental well-being of their areas
are all central to the embedding of councils at the heart of this
agenda.
10.6 The LGA is looking forward to examining in detail
the recommendations of the Climate Change Commission later this
year and to use these as an informed basis for further development
of LGA policy.
10.7 In parallel the LGA is keen to work with government
departments to look at how the policy interfaces between housing,
energy, local government and planning can be joined together to
maximize the potential of LAs to generate householder action and
how devolution to local level can help deliver on national agendas.
Local Government Association
26 September 2007
REFERENCES
[1] Defra 2001 figures, published 2006 http://www.defra.gov.uk/environment/statistics/supp/spkf23.htm
(2006)
[2] http://www.defra.gov.uk/environment/statistics/globatmos/kf/gakf07.htm]
[3] Energy Saving Trust: The Rise of the Machines 2006 http://www.energysavingtrust.org.uk/aboutest/publications/?mode=review—listing&p=4&pid=884
[4] DTI Energy White Paper 2007
http://www.berr.gov.uk/files/file39564.pdf
"We will continue to ensure that energy suppliers work with
householders to save energy and carbon emissions. We launch alongside
this White Paper our statutory consultation on a Carbon Emission
Reduction Target (CERT) for 2008-11. This is the new name for
the Energy Efficiency Commitment and reflects the new scheme's
focus on reducing carbon emissions. The consultation proposes
that energy suppliers double their current effort. Longer term,
from 2012, we want to develop this scheme to support a transformation
in the way suppliers view their relationship with the end consumer,
helping their customers save energy, by shifting their focus to
the provision of energy services, rather than simply selling units
of energy."
[5] Defra Energy Efficiency Action Plan
http://www.defra.gov.uk/environment/climatechange/uk/energy/efficiency.htm
[6] Centre for Sustainable Energy research for LGA climate
change commission
"Council Action to Combat Climate Change ; Key Issues for
Local Authorities"
http://campaigns.lga.gov.uk/climatechange/research/cse_report/
[7] Defra Area Based Approaches—Community Energy Efficiency
Fund
http://www.defra.gov.uk/environment/climatechange/uk/household/fuelpoverty/energy-efficiency-assistance.htm°1
[8] LACORS Climate Change Toolkit
www.lacors.gov.uk
[9] Nottingham Declaration On Line Action Pack
www.nottinghamdeclaration.org.uk
[10] IDeA Beacon Toolkit
http://www.idea.gov.uk/idk/core/page.do?pageId=6756580
www.idea.gov.uk
[11] BERR Energy Measures report—published early Sept
07.
http://www.dti.gov.uk/energy/environment/measures/page41270.html
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