Memorandum submitted by the Chartered
Institute of Housing (EEFP 41)
1. INTRODUCTION
1.1 The Chartered Institute of Housing (CIH)
is the professional body for people involved in housing and communities.
We are a registered charity and not-for-profit organisation. We
have a diverse and growing membership of over 21,000 people—both
in the public and private sectors—living and working in
over 20 countries on five continents across the world. We exist
to maximise the contribution that housing professionals make to
the wellbeing of communities. We are also founding members of
the Existing Homes Alliance, a stakeholder coalition calling for
urgent action to transform the UK's existing housing stock and
make it fit for the 21st century.[164]
1.2 We welcome the scope and the timing
of this inquiry, since fuel poverty has now reached critical levels
and is likely to worsen in the current economic climate. Fuel
poverty is less likely to be an issue affecting newer properties,
since they will have been built to relatively high energy efficiency
standards. As such the issue of fuel poverty is closely related
to the bigger question of tackling the energy (in-) efficiency
of our existing stock. The issue becomes even more pressing given
the fact that the vast majority (more than three quarters) of
existing homes will still be in use by 2050. Thus, we believe
that there needs to be a radical shift in policy, with the twin
aim to reduce the carbon footprint of homes and eradicate fuel
poverty at the same time.
2. A GREEN HOMES
TARGET
2.1 Whilst we are aware that fuel poverty
won't be an issue across the whole of the existing stock, we nevertheless
would advocate a more holistic policy approach, which would not
only benefit the fuel poor, but also help to achieve significant
carbon savings. Bearing in mind that the majority of the 27% of
CO2 emissions will be from existing homes[165],
tackling these will be crucial in meeting the government's target
to reduce emissions by a minimum of 60% by 2050. It also needs
to be noted that the climate change impact of housing is an area,
which compared to other sectors such as aviation for instance,
is "relatively easy" to tackle.
2. It is to this end that we would like
government to set a long-term "green homes" target for
reducing carbon emissions from the existing stock in line with
emission reduction trajectories set by the Office of Climate Change
and supported by a comprehensive programme. We believe that this
will give industry the much needed certainty for investment decisions
and crucially ensures that the supply chain is ready to deliver
the products and technology on the large scale needed. It will
mitigate against further energy price increases by reducing energy
demand and thus help alleviating fuel poverty. As an added bonus
it has the potential to support a construction sector which has
been hit hard by the "credit crunch", resulting in job
losses on a large scale, by focusing on new market opportunities.
2.3 In this context we welcome the recent
government announcements to insulate all homes by 2020, but it
is not going far enough, since these measures for instance won't
benefit those living in so called "hard-to-treat" homes.[166]
It is estimated that half of all fuel poor households occupy such
homes.[167]
It is important to move beyond an approach which only focuses
on the most cost-effective retrofitting measures if we are to
make considerable inroads in reducing both fuel poverty and CO2
emission levels and thus must include low- and zero-carbon technologies.
2.4 A number of recent studies have shown
that with the right policy instruments, carbon reductions of 80%
from the existing stock by 2050 are achievable.[168]
Moreover, there are numerous examples of homes that have been
refurbished to achieve 60-80% of carbon reduction, many of which
are classed as hard-to-treat[169].
2.5 Although a nation-wide programme to
deliver steep carbon cuts from our existing stock will be a massive
and by no means an easy undertaking, it isn't an altogether unfamiliar
scenario. Identifying a £19 billion backlog of repairs in
the public sector stock, the Chartered Institute of Housing was
instrumental in developing the decent homes standard to address
this issue. A daunting challenge at the time, only 10 years on
the decent programme has achieved a tremendous amount by upgrading
hundred of thousands of homes and giving whole communities a new
lease of life. Whilst this time the challenge is even bigger and
considerably more costly[170],
there are some valuable lessons to be learned from the decent
homes programme, not least in terms of clear leadership from government.
2.6 With any potential programme, supporting
the most vulnerable must remain the first priority, without loosing
sight of the bigger picture. At the same time, rather than focusing
on individual properties, we should be looking at whole street/neighbourhood
retrofitting schemes, along similar lines to the "enveloping"
schemes of the 1970s. In this context, energy suppliers under
a post-2011 carbon emission reduction target (CERT) system should
be required to focus on whole streets/neighbourhoods rather than
on individual households. Local authorities, as part of their
strategic housing function and place shaping role, are in an ideal
position to identify "priority" areas. In order to build
up a comprehensive picture of the energy (in-) efficiency of the
housing stock in an area, local authorities should have access
to Energy Performance Certificates (EPCs). Any potential data
protection issues which may arise from this need to be resolved
swiftly.
3. ADDITIONAL
COMMENTS
3.1 We support the assertion that a feed-in
tariff from smaller scale-renewables could contribute to tackling
fuel poverty. Low- and zero-carbon technologies will be important
in tackling "hard-to-treat" homes. Supported by the
tariff, local authorities and housing providers could target invest
to "fuel- poverty proof" these properties, both on an
individual dwelling or community level (such as district level
heating systems). Housing organisations could do this in partnership
with local authorities and others through the establishment of
energy services companies (ESCOs).
3.2 On the whole, the energy efficiency
of the social housing stock is higher than most of its private-sector
equivalent. This is largely down to the decent homes programme
but also due to the relatively young building stock. The requirement
by the Housing Corporation on housing associations to achieve
a certain EcoHomes rating (now Code for Sustainable Homes) as
a pre-condition for funding will have a bearing on the higher
average SAP ratings for the sector. Whilst regulation is an important
driver, another factor is that social landlords anticipate a long
relationship with their housing stock. Unlike the owner-occupied
sector with an average turnover of seven years, social landlords
take a more long-term perspective, aligned to the typical 30-year
business plan. Furthermore, there is the moral imperative to safeguard
and improve the wellbeing of residents and communities, which
also provides a rationale to engage with the climate change agenda.
This is most evident in social landlords' efforts to tackle fuel
poverty amongst residents.
3.3 Whilst the decent homes standard (DHS)
has repeatedly been criticised for not being strong enough on
energy efficiency, it nevertheless played a significant role in
tackling fuel poverty. We recognise that the standard could go
much further and it is to this end that the Chartered Institute
of Housing will over the coming months explore the potential for
a DHS Mark II with stronger sustainability components. It is envisaged
that this standard would be complementary to a longer-term green
homes target and programme.
Chartered Institute of Housing
October 2008
164 http://www.existinghomesalliance.org/ Back
165
New homes account for around 1% annually. Back
166
Such homes can have any or a combination of characteristics such
as solid walls, inaccessible loft space, off the gas grid. In
England alone for instance, there are 2.5m pre-1919 terraced houses
which fall in this category. Back
167
http://www.eeph.org.uk/sector/hardtotreat/ Back
168
See for example WWF, 2008, How Low-Achieving optimal carbon
savings from the UK's existing stock, Boardman B, 2007, Home
Truths: A low-carbon strategy to reduce UK housing emissions by
80% by 2050 Back
169
See for instance the Old Homes, Superhomes' network run
by the Sustainable Energy Academy http://www.sustainable-energyacademy.org.uk/ Back
170
Estimates to cut carbon from the existing stock by 80% by 2050
are currently in the regions of £2.6-£13.9 billion per
year (UK Green Building Council Existing Home Project http://www.ukgbc.org/site/news/showNewsDetails?id=97
) Back
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