EXISTING
HOUSING AND CLIMATE CHANGE
MEMORANDUM
FROM THE HOME BUILDERS FEDERATION
1. The Home Builders
Federation (HBF) is the principal trade body representing private home builders
in England and Wales. Our members include companies of all sizes, ranging from
major national companies through regional businesses to smaller, local
companies. Between them, our members
are responsible for about 80% of the new homes built each year.
Introduction
2. The companies represented by HBF
primarily build new homes and are not usually involved directly in work to
improve the condition and performance of the existing housing stock. In the
context of current action to tackle climate change, however, we do see a number
of ways in which the work of home builders may also bring benefits in tackling
the energy and carbon efficiency of the existing stock. We seek to explain
these potential synergies in this Memorandum.
Detailed comments
The significance
of tackling the existing stock
3. It is undoubtedly the case that the energy
efficiency of the existing housing stock is a far more important factor overall
in determining the country's ability to reduce carbon emissions than that of
newly built homes.
4. There are some 25 million existing
homes which will still constitute two thirds of the housing stock by 2050 even
allowing for an increased rate of housing supply in the interim. The energy
efficiency of many of these homes is considerably less than that of homes being
built to the current Part L 2006 building regulations and will compare less
favourably still as we move towards the objective of building to a national
zero carbon standard from 2016.
5. As a result of the 2006 Part L
regulations, homes being built today are 40% more energy efficient than those
built under building regulations current 5 years' ago. Taking a longer-term
view, Victorian houses are up to six times less energy efficient than those of
today.
The approach on
new build and its relevance to the existing stock
6. The HBF is working closely with
Government and other stakeholders with a view to achieving the twin objectives
of an improved housing supply of 240,000 annual net additions to the stock and
zero carbon performance standards for all new homes from 2016 onwards. The
HBF's Executive Chairman, Stewart Baseley, jointly chairs the 2016 Task Force
overseeing work on these objectives with the Housing and Planning Minister.
7. The agreed approach in pursuing the
zero carbon standard is to make three further changes to the Part L regulations
so as to increase energy and carbon efficiency standards compared to the 2006
regulations by 25% in 2010 and 44% in 2013 before requiring the zero carbon
standard itself from 2016.
8. This clear set of national steps will
provide the framework within which home builders can work with the supply chain
and energy providers to identify the best solutions for achieving the zero
carbon standard as effectively and efficiently as possible.
9. A number of home builders are already
undertaking projects to explore how to achieve higher standards of carbon
efficiency and, in addition, there will be structured opportunities for
demonstration projects via initiatives such as English Partnerships' Carbon
Challenge and the Government's plans for a number of new eco-towns. HBF and its
members are actively participating in all these discussions.
10. The HBF believes that arising from this
approach there could be a number of opportunities or outcomes that might also
be helpful in seeking improvements to the energy efficiency of the existing
housing stock.
11. The most obvious such opportunity is
likely to result from the further innovations and proving of technologies
inherent in the zero carbon homes objective. While it is common ground between
HBF and many other bodies that the first priority is to make further improvements
to the fabric efficiency of new homes, we do not expect to be able to achieve
the zero carbon standard purely through this means. There will be residual
heating and power needs that will need to be met by appropriate forms of low
and zero carbon generation.
12. Whether such needs can best be met in
particular cases through micro-generation, on site facilities, community energy
supplies or via additional low and zero generation capacity accessible through
the grid is still a matter of some uncertainty. Many of the technologies that
might be used are not yet adequately proven in terms of their performance
outputs and durability in given contexts.
13. An important outcome - if the zero carbon
objective is to be met successfully - will therefore be to establish clarity
about the capabilities of particular technologies and low and zero carbon
energy supply facilities and scenarios. This knowledge should in turn be
relevant and helpful to efforts to improve the energy efficiency of the
existing housing stock which is equally likely to require low carbon solutions
for residual energy requirements over and above what can be achieved through
improvements to fabric efficiency.
14. A more profound potential synergy should
also be actively considered. Since the average new build development is quite
small - perhaps 30 or 40 homes - we think that technically effective and
commercially viable solutions for providing a post-2016 residual energy supply
will often need to be non-site specific. If so, that consideration immediately
opens up the question of how a sufficient critical mass of consumers can be
assembled to underpin investment in new facilities.
15. One way in which this might happen would
be for a facility to serve both existing and new homes in an area. Efficiency -
including via balancing the load of demand as evenly as possible through the
day - could prospectively be further increased by also including non-domestic
forms of demand such as local commercial, retail, office and public amenities.
16. We are currently discussing such
possibilities with Government, energy companies and others via the 2016 Task
Force process. These discussions are at a very early stage so we cannot yet set
down firm conclusions on the scale of opportunity that might realistically be
available. We do believe, however, that where feasible such an approach could
yield significant benefits for all parties.
17. We should add that in order to explore
such ideas it will also be necessary to consider how the regulatory regime
affecting the generation, transportation, trading, balancing and sale of energy
affects the ease and viability of what we might call new forms of
community-wide energy generation and supply. These issues are already being
looked at in the context of the Government's objectives for promoting renewable
energy supply, but the need for a reduced carbon footprint for new and existing
homes is introducing an important new dimension to such discussions. Overall we
do not consider that existing rules are yet sufficient to encourage the
necessary investment flows.
18. A further link to other policy objectives
may lie in the way in which the Energy Efficiency Commitment evolves in future.
In particular, HBF believes it might be helpful and worthwhile to look into how
the future CERT scheme could assist the development of new low and zero carbon
community-wide energy supply facilities of the type outlined above. An
appropriate element of financial contribution linked to such new facilities
through a post-2011 CERT scheme could in principle make them easier and more
viable to bring forward and would seem to be consistent with wider Government
objectives in this field.
Other issues
19. Among other issues raised by the
Committee's inquiry we would wish to draw attention to the importance of
establishing effective and trusted means for accrediting new technologies
relevant to the achievement of energy and carbon efficiency objectives for
housing.
20. It is vital that such assurance
mechanisms are present and robust in order to avoid the risk that public
confidence will be lost in policy objectives and actions to promote energy
efficiency. This is certainly a very material consideration for new build where
we have pointed out to Government that it would be counterproductive for all
parties if inadequately tested technologies and processes were rolled out,
leading to consumer concerns and a loss of confidence in the product and the
process. These concerns would be no less for measures relating to the existing
housing stock.
21. Secondly, we welcome the introduction of
Energy Performance Certificates. We consider these will help to encourage
greater public interest in energy efficient homes although it is not clear at
present that they will rapidly lead to a decisive change in perceptions given
the very pressing concerns that exist about housing availability and
affordability.
HBF
28 September 2007