Memorandum from National Energy Action
(NEA) (BDH 23)
SUMMARY OF
COMMENTS FROM
NATIONAL ENERGY
ACTION (NEA)
— NEA's comments focus on the inadequacies
of the Thermal Comfort element of the Decent Homes Standard.
— In several respects the Decent Homes
programme in England is inferior to equivalent programmes in Wales
and Scotland. This is the case both in terms of the heating and
insulation standards mandated and in the failure to specify minimum
SAP targets for energy efficiency in the housing stock.
— The Decent Homes Standard is no longer
tenure-specific and applies also to private housing. However the
Government is currently on target to meet neither social nor private
sector targets.
— Government should recognise the need
to devise new and more rigorous standards for energy efficiency
as set out in a number of previous reports from Parliamentary
Committees.
— High energy efficiency standards can
address social, environmental and economic problems.
— NEA proposes a National Energy Efficiency
Scheme operating across all tenure groups - in effect this would
make the Thermal Comfort element an irrelevance.
— Cuts to the Warm Front budget will have
a negative impact on provision of Decent Homes in the private
sector.
— The Housing Health and Safety Rating
System is not being implemented effectively.
— There is considerable existing evidence
of the benefits of area-based initiatives in delivering fuel poverty
and carbon reduction programmes. NEA sees the Community Energy
Saving Programme as a crucial test of the effectiveness of this
approach and advocates national roll-out of adequately resourced
and comprehensive community energy efficiency programmes.
COMMENTS FROM
NATIONAL ENERGY
ACTION (NEA)
1. Background
1.1 National Energy Action (NEA) is a national
charity working to reduce and ultimately eradicate fuel poverty.
NEA seeks to achieve these objectives through policy development
and representations to key agencies, Government, energy suppliers
and Ofgem. NEA also adopts a campaigning role in pressing for
programmes and resources to meet the needs of vulnerable energy
consumers.
1.2 Fuel poverty results from a combination
of low household income, unaffordable energy prices and poor heating
and insulation standards. Whilst NEA's policy work covers all
three areas we attach priority to policies and programmes to improve
the energy efficiency of the housing stock as the most rational
and sustainable solution to fuel poverty.
1.3 Consequently, NEA welcomes the Communities
and Local Government Committee's inquiry into housing standards
post-2010 as an opportunity to revisit the Decent Homes Standard
as a major force in addressing fuel poverty.
1.4 NEA understands that the scope of this
inquiry goes beyond the Thermal Comfort element of the Decent
Homes Standard but, given NEA's remit, it is inevitable that our
comments focus primarily on the heating and insulation aspects
of the standard. Where relevant NEA's comments follow the specific
questions raised in the Committee Call for Evidence.
2. What lessons can be learned from the Decent
Homes Programme and equivalents in Scotland, Wales and Northern
Ireland?
2.1 In the context of heating and insulation
improvements a number of lessons can be learned from the Welsh
Housing Quality Standard (WHQS) and the Scottish Housing Quality
Standard (SHQS). This is not because either of these standards
is particularly rigorous, it is because the standards established
for England are so weak.
2.2 In the case of Wales, the standard specifies
that all cost-effective opportunities to upgrade the thermal and
ventilation performance of the dwelling must be taken. Heating
systems should be fuel efficient and reasonably economical to
run, all tanks and pipes must be lagged and the standard requires
a minimum of 200 mm loft insulation. Crucially, the standard
also requires that a dwelling should comply with a predetermined
SAP[24]
rating related to the size of the property.
2.3 The Scottish Housing Quality Standard
requires cavity wall insulation to be installed where technically
feasible and appropriate, and a minimum of 100 mm of loft
insulation. A full-house central heating system must be installed
and supplementary measures undertaken to achieve a minimum energy
efficiency rating of NHER 5 or SAP 50.
2.4 In contrast, the Thermal Comfort criteria
of the Decent Homes Standard in England are far less demanding
than these modest requirements set for Wales and Scotland. In
place of whole-house heating all that is required in England is
that the primary heating system should distribute heat to two
or more rooms in the dwelling. 50 mm of loft insulation or
cavity wall insulation is classed as "an effective package
of insulation" in properties heated by gas or oil, and where
the dwelling is heated by electricity, solid fuel or LPG both
cavity wall insulation and 200 mm of loft insulation should
be installed as appropriate.
2.5 No minimum SAP is required although
it is suggested that a SAP rating lower than 35 should be
seen as a proxy for a Category 1 Hazard under the Housing
Health and Safety Rating System. It should be noted that some
15.5% of properties in England (3.4 million dwellings[25])
have a SAP rating below this level.
3. Where targeted housing fails to reach
the Decent Homes Criteria by 2010, how should the backlog be addressed?
3.1 Although the Thermal Comfort element
of the Decent Homes Standard was cited as the Government's main
programme to address fuel poverty in the social rented sector,
and this programme was to be complete by 2010, NEA understands
that only 95% of the target will be reached and that extensions
have been agreed for those social landlords failing to comply.
It is unclear how much of this failure can be attributed to Thermal
Comfort failure.
3.2 NEA would emphasise that the Decent
Homes Standard is no longer tenure-specific and that a much greater
failure may yet emerge from targets set for vulnerable households
within the private sector.
3.3 In the 2002 Spending Review, the
Decent Homes Standard was extended to include all private sector
homes occupied by vulnerable households. The Department for Communities
and Local Government defines a vulnerable household as one in
receipt of a disability-related or means-tested benefit.
3.4 Targets for vulnerable households
The Government set the following targets for
vulnerable households:
— There is a year on year increase in the
proportion of vulnerable private sector households in decent homes
— The 2006-2007 English House Condition
Survey shows the proportion of vulnerable households in decent
private sector homes to be more than 65%
— The 2010-2011 English House Condition
Survey shows the proportion of vulnerable households in decent
private sector homes to be more than 70%
— The 2020-2021 English House Condition
Survey shows the proportion of vulnerable households in decent
private sector homes to be more than 75%.
3.5
VULNERABLE PRIVATE SECTOR HOUSEHOLDS IN DECENT
HOMES 2007[26]
3.6 The table above shows the Government
on course to meet its targets within the owner occupied sector
and failing badly in the private rented sector.
3.7 However, NEA believes that now is the
time to stop agonising over target dates for compliance with Decent
Homes regardless of tenure and start working towards the next
phase of improvement to the general housing stock, but with a
serious programme that can achieve both Decent Homes and fuel
poverty targets.
4. Should minimum acceptable social housing
standards be amended to take account of environmental standards,
fuel poverty and the estate?
4.1 The unique virtue of energy efficiency
improvements in addressing fuel poverty is the simultaneous contribution
that is made to other social, environmental and economic objectives.
Where energy efficiency programmes are sufficiently ambitious,
properly designed and adequately funded they will deliver affordable
warmth; compliance with carbon reduction targets for the domestic
sector; and community regeneration through the creation of green
jobs and the release of consumer spend in the local community.
4.2 The real issue is not whether standards
should be amended but at what level the revised standards should
be set and how these standards should be implemented. The model
for community-based programmes to address fuel poverty and carbon
emissions is discussed later in this response.
4.3 NEA notes that the issue of higher standards
within the Thermal Comfort element of the Decent Homes Standard
has been a matter of concern virtually since the inception of
the standard. Certainly NEA asserted strongly that the standard
was not fit for purpose. This view has subsequently been endorsed
in a number of formal inquiries.
4.4 An ODPM Committee inquiry[27]
in 2004 recommended establishment of a Decent Homes Plus
standard post-2010 in the form of: "a much more ambitious
thermal comfort criterion which is in line with building regulations
in force at the time when the new Standard is set. Policy development,
evaluation and funding for this criterion must be closely integrated
with other key policies such as the Fuel Poverty Strategy.
4.5 The final EFRA Committee inquiry into
fuel poverty[28]
also strongly supported much more rigorous energy efficiency standards:
"Decent Homes has clearly been an effective vehicle for
raising standards in social housing. However, the low level of
requirements set for thermal comfort means that significant scope
remains for improvement in energy efficiency levels."
The Committee further added: "We do not accept assertions
that it is not practical to achieve a SAP 81 level. We recognise
that higher SAP levels will not be feasible for all types of construction
but that does not mean that policy should set targets at the levels
achievable for poorer housing stock. We recommend that Government
assess the cost and feasibility of introducing a SAP 81 standard
as the basis of an improved thermal comfort standard for all social
housing."
4.6 NEA would concur with this view whilst
adding that we see no reason why SAP 81 should not also be
established as at least an aspirational target across all tenure
categories of the housing stock. The case for SAP 81 is strongly
endorsed in a recent research report from Consumer Focus[29]
which claims that 83% of fuel-poor households could achieve affordable
warmth through rigorous energy efficiency standards.
5. Do the management organisations—councils,
including via ALMOs, and housing associations—need to change?
Will they have sufficient funds?
5.1 Since NEA's engagement with the Decent
Homes Standard concerns only the Thermal Comfort element and,
by extension, the Housing Health and Safety Rating System as it
applies to health hazards resulting from cold homes, we will not
comment on wider funding issues.
5.2 NEA's policy position paper on a National
Energy Efficiency Scheme (see brief outline at 9.6) sets out a
funding mechanism to deliver major energy efficiency improvements
across all tenure groups. In effect, the NEA programme and funding
proposals would remove the Thermal Comfort element of the Decent
Homes Standard as the aspiration for energy efficiency improvement
to the housing stock. This is discussed later in relation to the
question on local examples and post-2010 applicability.
6. What are the implications for decent housing
of the Government's proposal, currently out for consultation,
to move to a devolved system of council housing finance?
6.1 No comment.
7. How should the Decent Homes target for
private sector homes occupied by vulnerable people be taken forward?
7.1 Again, in the context of fuel poverty
and affordable warmth, NEA refers to the proposal for a National
Energy Efficiency Scheme as the optimum vehicle for delivering
heating and insulation improvements to vulnerable private sector
households.
7.2 We note the mismatch between the timescale
for providing decent homes to vulnerable private sector households
and the requirement under the Warm Homes and Energy Conservation
Act that all such households should be removed from fuel poverty
by 2010. Government policy requires only that 70% of private sector
dwellings should comply with the existing minimal Thermal Comfort
standard by 2010 with 75% compliance by 2020-21.
7.3 The Warm Front scheme is the main Government-funded
programme to improve heating and insulation in private sector
housing. Clearly this programme has the potential to deliver the
Thermal Comfort element of the Decent Homes Standard to these
tenure groups; however funding for the programme will be subject
to significant reductions in 2010-2011. The Warm Front budget
in that year will total £200 million compared with £400 million
in 2008-2009 and £374 million in 2009-2010. Recent
revisions to the scheme have significantly increased the maximum
Warm Front grant; however, whilst these increases are to be welcomed
it must be noted that the negative consequence will be even fewer
installations completed in 2010-11.
7.4 Over the period mid-2000 to mid-2005,
between 194,000 and 259,000 dwellings occupied by vulnerable
private sector households were made decent as a result of Warm
Front interventions.[30]
8. Are adequate arrangements in place for
the future regulation of minimum acceptable housing standards?
8.1 Other than the minimum fitness element
required under the Housing Health and Safety Rating System the
Decent Homes Standard has no legislative authority and is underpinned
by exhortation on the part of Government, and social landlords'
awareness of a duty of care to their tenants. In this context
NEA observes that, to some extent, landlords have compensated
for the inadequacy of Government prescription by voluntarily adopting
higher energy efficiency standards than those required under the
Decent Homes Standard.[31]
8.2 This research carried out by BRE on
behalf of the Department for Communities and Local Government
indicated that: "the vast majority of social landlords are
carrying out work well in excess of the thermal comfort standard
with 80 per cent planning to install both cavity wall insulation
and loft insulation in homes with gas or oil programmable heating.
The survey estimates that by 2010 around 85% of lofts in
social rented homes will have at least 200mm of insulation.
8.3 Whilst it is to the credit of social
landlords that they voluntarily adopt and implement higher standards
than those required by Government, their actions confirm that
the original specification for the Thermal Comfort element was
unacceptably low. NEA believes that what constitutes acceptable
energy efficiency standards should be both demanding and prescribed
by Government rather than being left to the enterprise and discretion
of landlords.
8.4 In the context of minimum housing standards
NEA notes that the 2007 English House Condition Survey reports
that 2.25 million dwellings pose a Category 1 Excess
Cold Hazard to their occupants. Whilst this degree of hazard applies
to 4% of social housing the figures for owner-occupied and private
rented properties are 10.6% and 15.2% respectively.
8.5 It is a continuing source of concern
and dismay to NEA that little or no action is being taken by local
authorities to identify and remedy circumstances where a dwelling
poses such a degree of threat to the health and wellbeing of the
occupants—particularly those tenants in the private rented
sector.
9. Are there local examples of innovative
best practice with wider post-2010 applicability?
9.1 There are numerous examples of existing
good practice in delivering community-wide energy efficiency programmes.
The best known of these area-based models is that of Warm Zones
where a community is identified for receipt of a comprehensive
assistance package including: practical heating and insulation
improvements; energy advice; information on benefit entitlement;
and help in making a claim.
9.1 A delivery programme is then devised
for this community with assistance prioritised to those individuals
and areas identified as being in the greatest need. Once the programme
has served those areas of higher deprivation it can move on to
other sectors of the community thereby ensuring that all households
can benefit from the Warm Zone approach.
9.2 Warm Zones use a mix of funding sources
including the Carbon Emissions Reduction Target and other energy
supplier support, Warm Front and regional and local grant assistance.
This coordinated approach enables Warm Zones to overcome what
is often seen as a major flaw in energy efficiency and fuel poverty
programmes—the confusing and fragmented nature of available
assistance which can result in different agencies competing to
provide the same services to the same client group.
9.3 The London Warm Zone (LWZ) Annual Review
for 2007-2008 cites the example of its work with the West
London Housing Partnership in delivering both Decent Homes and
multiple ancillary benefits:
LWZ has always promoted the utilisation of a
wide-ranging tool-kit of measures for successful delivery of its
sub-regional Decent Homes programmes. This means that as project
managers we need to work with a variety of other programmes and
funding regimes, such as CERT and Warm Front, to ensure maximum
delivery on our projects and as much help as possible to households.
Climate Change, fuel poverty, decent homes and
income maximisation are all related issues when addressing wider
sustainability development and quality of life issues.
This has been quantified recently in our Decent
Homes programme with the West London Housing Partnership (WHLP).
Upon completion of the 2006-2008 WHLP programme LWZ achieved
the full spend of the WLHP funds for decent homes (mainly heating)
to vulnerable households of £3.6 million. However, by
the integration of measures and other programmes LWZ also achieved
the following:
— £2 million CERT funds levered
— 1,500 Warm Front grants with a leverage
of £1.2 million
— More than 500 Fire Safety Surveys
with a value of £12,500
— £640,000 of additional income
benefits
— More than £400,000 of additional
funds from the DEFRA CEEF programme
The integrated approach of LWZ has resulted in
£4,252,000 of additional outside leverage being brought
into the WHLP programme, giving the project a total value of £7,852,000.
This is not only very cost effective to the capital funding but
offers real quality of service to the boroughs and households.
9.4 In fact the Government's Community Energy
Saving Programme (CESP) will provide invaluable evidence of the
merits of the area-based fuel poverty and energy efficiency programme.
CESP, which is due to become operational in autumn 2009, closely
follows the Warm Zone model in its priority assistance to disadvantaged
communities:
— Partnership working between local authorities,
energy suppliers and community organisations
— Targeting of communities suffering particularly
high levels of deprivation
— A whole-house package of measures intended
to deliver the maximum feasible energy efficiency improvements
to individual dwellings
9.5 The success of the Community Energy
Saving Programme will be quantified in terms of carbon reduction
and abatement but, given the nature of the participating communities,
there is no doubt that this programmes serves as a test of an
affordable warmth model that can be implemented across the country.
Initially it is proposed that some 100 communities and 90,000 households
may benefit from this three-year, £350 million programme,
but a successful outcome will encourage replication on a national
basis.
9.6 Whilst NEA welcomes the innovative approach
of CESP, we also recognise the urgent need to develop a National
Energy Efficiency Scheme that can reduce domestic carbon emissions
and provide decent homes and affordable warmth for all. Consequently,
NEA has been working extensively to develop a model appropriate
to national implementation.
9.7 The key elements of NEA's proposal comprise:
— A single national energy efficiency programme
bringing together the existing significant but disparate sources
of energy efficiency and fuel poverty funding, although there
will need to be additional financial support from HM Treasury.
— Local authorities with their unique knowledge
of their communities are, directly or indirectly, responsible
for delivery of the programme.
— The programme will act as a one-stop-shop
for advice and practical assistance on heating and insulation;
the efficient use of energy; benefit entitlement and the claim
process; and crime and accident prevention.
— Whole-house energy efficiency improvements
will be undertaken with priority given to improving properties
in the most disadvantaged communities.
— A target based on the Energy Performance
Certificate will be set for all housing. The target for social
housing will be set at EPC Band B (SAP 81+) in recognition of
the current comparatively high standard of social housing and
also of the low household income of the majority of the occupants.
For all other housing a target of EPC Band C (SAP 69+) will be
required.
September 2009
24 SAP is used as a measure of the energy efficiency
standard of a dwelling. SAP operates on a scale of 1-100 where
the higher the score the greater the energy efficiency of the
home. Back
25
Impact Assessment of proposals for implementation of the Community
Energy Saving Programme (CESP), DECC < May 2009 Back
26
English House Condition Survey 2007: Headline Report, Communities
and Local Government, 2009 Back
27
Decent Homes, ODPM: Housing, Planning, Local Government and the
Regions Committee, April 2004. Back
28
Energy efficiency and fuel poverty, Environment, Food and Rural
Affairs Committee, June 2009 Back
29
Raising the SAP: Tackling fuel poverty by investing in energy
efficiency, Consumer Focus, May 2009. Back
30
Housing Research Summary No. 237, CLG, 2007. Back
31
Implementing Decent Homes in the Social Sector, CLG, 2007 Back
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