Memorandum submitted by National Energy
Action (NEA)
EXECUTIVE SUMMARY
— The transition to a low-carbon economy
is necessary and challenging but policy must be designed to maximise
the social benefits from eradicating fuel poverty.
— Delivery of energy efficiency on a greater
magnitude than is the current ambition of the government is necessary
and possible.
BACKGROUND
National Energy Action (NEA) is the major campaigning
organisation on fuel poverty issues in the United Kingdom. NEA
views the causes of fuel poverty as a combination of poor energy
efficiency standards, low household incomes and unaffordable energy
prices.
NEA develops and promotes energy efficiency
services to tackle the heating and insulation problems of low-income
households. Working in partnership with central and local government;
with fuel utilities, housing providers and health services; and
with consumer organisations, NEA aims to eradicate fuel poverty
and campaigns for greater investment in energy efficiency to help
those who are poor or vulnerable.
INTRODUCTION
1. The UK faces significant challenges in
meeting commitments to reduce carbon emissions to comply with
the 2050 target. However, NEA believes that the target can
be met whilst ensuring that associated social and economic benefits
are maximised.
2. Considering the environmental aspects
of the "green economy" in isolation from the social
and economic impacts and benefits may lead to policy measures
that appear advantageous, but in reality result in unintended
adverse consequences for the social welfare agenda. There must
not be a narrow focus from the Government that excludes the potential
impact on equally valid social and economic agendas.
3. A comprehensive overview of the issues
will demonstrate that it is possible to devise policy to meet
the 2050 target whilst simultaneously eradicating fuel poverty
and creating jobs to boost local economies across the country.
4. NEA policy proposal for energy efficiency
have been designed to ensure social, environmental, and economic
benefits.
GREEN NEW
DEAL
What opportunities exist for the creation of a
green new deal whilst pursuing a low carbon economy? Which technologies
have the biggest potential? Has the Government done enough in
its stimulus package?
5. The transition to a low-carbon economy
requires a long-term restructuring, with early action on the easy-wins
that are still available. For the low carbon energy system to
be viable and to enable the decentralisation of energy generation
there must be immediate action in reducing energy demand. NEA
has submitted a proposal to the Government as part of the Heat
& Energy Saving Strategy consultation calling for a new approach
to retrofit of the existing housing stock.
6. The scheme proposed goes further than
the suggested pathway outlined in the Heat & Energy Saving
Strategy consultation which is intended to enable the Government
to meet emission reduction targets through energy efficiency.
7. The NEA energy efficiency programme proposes
that every household should receive a whole-house assessment and
retrofit works thereby improving the dwelling to a minimum standard
equivalent to an EPC Band C. Social housing would be brought to
the higher standard of Band B in the same timeframe.
8. Individual technologies will not be identified.
It is important that the means of delivery is thoroughly planned
and is sufficiently well resourced to deliver on the objectives.
It is NEA's view that the proposed delivery mechanism for energy
efficiency would involve a considerable requirement for installation
of low and zero carbon technologies to ensure the retrofit target
can be met. The whole-house retrofit programme will identify the
basic measures required by the household such as draughtproofing;
double glazing; and cavity and loft insulation. Beyond this, more
costly measures will be assessed including solid wall insulation,
the requirement for renewable/low carbon generation in/on the
property and the potential for connection to district heating.
9. The proposal sketches out a pathway to
be followed by all local authorities to ensure a strategic approach
at the local level in the delivery of energy efficiency and community-scale
low carbon generation, such as district heating and combined heat
and power.
10. Every local authority should be required
to produce heat and energy maps of demand in their locality and
identify the opportunities to improve the efficiency of the existing
buildings and community-scale interventions. From this, and other
data sources, they should produce a timetabled delivery plan for
the retrofit of all homes in their area by 2020 and the development
of community-scale schemes for the provision of heat and electricity.
11. Analysis carried out by Impetus Consulting
on behalf of Greenpeace UK[57]
indicated that the annual expenditure levels of at least £5 billion
proposed by NEA to improve the energy efficiency of the existing
housing stock will create, or sustain, 55,000 direct jobs
with hundreds of thousands of indirect jobs.
PUBLIC PROCUREMENT
AND POLICY
What is the potential role for public procurement
and policies such as the 2016 zero carbon homes target in
driving investment, development and job creation?
12. The role of the public sector is significant
in the NEA proposal. The local authority acts as the driver for
development of a local strategic approach to retrofit of the housing
stock and assessing the energy use and generation in the area
they cover. Local authorities will be able to identify the need
in their community for developing skills to deliver on the NEA
proposal which will create a significant number of jobs within
local communities as part of the low-carbon transition. It will
be possible for local authorities to take the lead on local delivery
of demand reduction and local generation.
13. A policy requiring all households to
be improved to a level of a Band C, with the introduction of legislation
making this a mandatory minimum standard after 2020, would drive
investment prior to 2020 in energy efficiency that would
reduce energy demand as part of meeting the first three carbon
budgets. NEA proposes that pre-2020 retrofit be incentivised
to encourage early take-up of measures. The incentives then cease
post-2020 when the mandatory minimum standard comes into
force.
14. Appended to this memorandum is the NEA
policy proposal for a National Energy Efficiency Scheme.
May 2009
APPENDIX
NATIONAL ENERGY EFFICIENCY SCHEME
INTRODUCTION
In 2008-09, Government-mandated expenditure
on domestic energy efficiency and fuel poverty programmes will
total some £5.3 billion. Warm Front and the Priority
Group element of CERT should result in some £850 million
being spent on heating and insulation improvements with a further
£2.7 billion being expended on Winter Fuel Payments.
Historically, NEA has advocated practical heating
and insulation improvements as the most rational and sustainable
approach to affordable warmth, whilst recognising the need for
supplementary action on household incomes and energy prices.
This paper concentrates on the energy efficiency
dimension and attempts to devise a means by which expenditure
in this area can be both maximised and optimised.
There is a strong correlation between energy
efficiency standards and fuel poverty. The average SAP[58]
rating of an existing home in England is 50; the average rating
for a property occupied by a fuel-poor household is 37;[59]
whilst the average house built to current Building Regulations
is around 80.[60]
The pattern of increased domestic fuel prices
began in 2003 and, with rare interruptions, continued to
rise until the winter of 2008-09. As a consequence, fuel poverty
in England rose from around 1.2 million households in 2004 to
4.0 million households in 2009.
The convergence of high energy prices and the
dismal quality of the UK housing stock, compounded by a lack of
consistency, clear direction and boldness in policy setting, has
brought about an appalling crisis in fuel poverty last winter.
The current desperate circumstances will continue,
and may deteriorate, without a major review of domestic energy
efficiency policy.
The Government has placed considerable emphasis
on income measures and low fuel prices as the means to secure
fuel poverty alleviation, but has also invested significant sums
on energy efficiency programmes. However, despite expending £20 billion
on fuel poverty schemes there has not been a significant improvement
in the energy efficiency of the housing stock and certainly not
enough to ensure households are removed from the risk of fuel
poverty.
The current energy efficiency programmes are
failing the taxpayer, consumer, and especially the fuel poor.
They have created a fragmented approach to tackling fuel poverty
reinforced by inconsistency and incoherence across the many initiatives.
The existing array of competing schemes makes for a slow, expensive
and overcomplicated process; whilst the up-front cost of measures
has dissuaded millions of non-fuel-poor households from improving
the energy efficiency of their homes. This represents a major
failure in policy.
In the context of rising fuel poverty and the
need for urgent action to reduce carbon emissions, the UK needs
a systematic roll-out of conventional energy efficiency measures
to the general housing stock, supplemented by deployment of low
carbon/renewable technologies targeted at those households or
communities where traditional energy efficiency measures and heating
improvements are not enough to ensure affordable warmth.
THE PROPOSAL
It is time for a radical departure from the
current piecemeal approach to delivering energy efficiency, tackling
fuel poverty and reducing carbon emissions. An integrated and
coherent approach that will tackle fuel poverty and domestic carbon
emissions is essential. The actions needed in this National Energy
Efficiency Scheme are outlined below.
The Government must have a clear vision and
a co-ordinated, cross-departmental approach to energy efficiency,
carbon reduction and fuel poverty. The fuel poverty strategy needs
to be integrated with the Energy and Climate Change Strategy as
an equal priority with tackling climate change. This should enable
the delivery of resources and commitment that can only emanate
from Westminster.
This National Energy Efficiency Scheme should
apply to England and run from 2009 until 2020. There should
be clear milestones for achievement with interim targets. The
Strategy should be backed up with a costed and implementable Business
Plan and full Impact Assessment. There should be a thorough review
in line with the timetable for the carbon budgets that will assess
progress, achievement, costs and benefits of the scheme. Annual
reporting on progress by the Government should also be required.
The final review stage should set in place a revised Strategy
and Business Plan to run from 2020 until 2050 toward
an ambition of near zero carbon homes and decarbonised energy
generation.
The territorial extent of this National Energy
Efficiency Scheme is limited to England. The devolved administrations
should be asked to consider and adopt a Scheme of similar ambition
and magnitude.
THE BENEFITS
— Compliance with Government targets to
eradicate fuel poverty.
— Community approaches lead to a better
take-up of measures.
— Local authorities have the flexibility
to tailor schemes to meet need in their area and use local knowledge
to introduce not only individual house solutions but also community
solutions where appropriate.
— Ensures that no area, is a "no-go"
area for energy efficiency help, no matter how remote or hard
to treat.
— Addresses the problem of communities
and household types that are over-represented amongst the fuel
poor but under-represented in take-up of energy efficiency assistance
eg rural areas, ethnic minorities.
— Uses local employees and businesses to
deliver the service where possible, meaning money is reinvested
in the community and local jobs created. In turn, this improves
take-up of services through trusted local organisations.
— Develops a more consistent and stable
market for insulation installers and new technologies rather than
the current stop/start approach and funding uncertainty which
have led some companies to cease trading.
— Efficiencies achieved by competition
at a tendering level for the contract, and in competition between
local companies for jobs, and ring-fenced budgets. Local authorities
can link up to bulk-buy micro-generation or other technologies
to achieve economies of scale.
— Ensures every home, wherever possible,
meets common minimum energy efficiency standards.
— Provides simplicity for consumers and
uses the brand of trusted local councils.
— Overcomes issues surrounding data sharing
and stigma as all homes are targeted in a systematic door-to-door
approach, though sharing data at a local level can help target
the most deprived areas first.
— Schemes could be reliably monitored and
verified, using a common method, ensuring consistently high standards.
— Does away with the notion of a maximum
grant—and satisfies equity criteria being based on ability
to pay.
— Overcomes current problems with eligibility.
Currently around 33% of fuel-poor households are not eligible
for assistance under Warm Front (eg households marginally over
the income threshold and the 30% of older households who fail
to claim their entitlement to Pension Credit).
DELIVERY
One of the key aspects of the Scheme is the
proposed means of delivering energy efficiency retrofit. The current
approach of individual applications, individual processing of
applications and individual installation of remedial measures
by different funders/scheme managers is sub-optimal and leads
to higher costs and a lack of coherent delivery. The current system
loses all the potential benefit of economy of scale and lacks
a strategic approach to energy efficiency.
The model for delivery under the Scheme should
be an area-based scheme led by local partnerships involving local
authorities. The local authority can choose whether to deliver
the scheme in-house or through a partnership with a managing agent;
but it needs to be locally led, with local accountability. There
should also be scope for groups of local authorities on a regional
or sub-regional basis to administer and deliver a scheme.
The onus and obligation for delivery should
be placed on the local authority as the key point of delivery
with a local community partnership to shape the delivery of the
scheme to suit the local situation. The council-led approach is
key to the Scheme to improve strategic delivery and foster local
partnership and community involvement.
Councils have an unequalled, in-depth knowledge
of their locality and the needs of householders enabling them
to be best placed to deliver a national housing retrofit programme.
Local authority involvement also enables the integration of other
public services such as fire safety, crime prevention, income
maximisation and water efficiency. Local authorities are also
more trusted by householders than energy suppliers.
Local authority involvement provides a line
of accountability currently absent from existing schemes such
as Warm Front.
The involvement of local authorities will ensure
a strategic approach to energy use, generation and efficiency.
Local authorities currently produce Affordable Warmth Strategy,
Climate Change Strategies and Action Plans and a whole raft of
other documents intended in their design to deliver a degree of
the ambition that underlies this Scheme. There is a need for an
integrated, strategic approach from local authorities to develop
an "Energy and Climate Change Strategy" with an accompanying
Delivery Plan that will form the basis for the delivery of this
Scheme in their area.
Many local authorities have signed up to NI186 in
their Local Area Agreements to reduce per capita carbon emissions
in the local authority area. This could be utilised as the basis
for developing a strategy that will address energy use and energy
efficiency in the context of reducing emissions. It should be
noted that NEA places equal weighting on reducing carbon emissions
and tackling fuel poverty in this Scheme and this would need to
be reflected in the national strategy and in each local authority
plan.
The delivery would incorporate multiple phases
in line with the following. Some of these may run concurrently,
but are identified in a sequential manner. This list is purely
representative of some of the stages involved and is not exhaustive.
1. Local authority assessment of their area using
heat and energy use mapping to:
(a) identify areas where there is potential for
community scale low carbon/renewable generation or community heating
(b) identify areas of high use for further investigation
2. Pre-survey a representative sample of the
housing stock to identify the archetypes and potential suite of
measures that could be required to ensure the local supply chains
and industry can be prepared for the delivery phase.
3. Identify the potential partners in the community
who are key stakeholders in the Scheme
4. Using DWP benefits data, EPC data, identifiers
of deprivation, local knowledge and the pre-sample data and mapping
to develop targeting for the roll-out of delivery
These preparation stages would be followed by
delivery of a full whole-house energy audit of the property and
the householder energy use. The householder would receive a pre-EPC
check and full SAP assessment (or equivalent depending on further
development of the whole-house assessment required) that would
identify a list of measures that would outline the percentage
improvement measures would make, the impact on the SAP/EPC rating,
the CO2 savings and the cost of the measure. This
is purely indicative of the information on the retrofit that could
be provided.
Alongside the audit for energy efficiency the
householder will receive advice on how to use their current heating
system and an assessment of their current expenditure on energy.
Along with an indication of the income level of the household
it will be possible to determine if there is potential for fuel
poverty.
An assessment of benefit entitlement would be
carried out to determine if the household is eligible for grant
funding under the scheme. If the householder is eligible they
will be offered the income maximisation service, which would guide
their application through the DWP to ensure the householder is
claiming and receiving the benefits they are entitled to.
Other community initiatives that can be delivered
at this time include assessing under HHSRS for Category 1 hazards
and referring to the appropriate local authority department and
the local Home Improvement Agency to rectify these.
The householder would also be offered (if the
local authority decides to deliver these alongside the energy
efficiency scheme):
— fire safety measures such as smoke alarms
and fire blankets or extinguishers;
— crime prevention measures such as better
door and window locks, spy holds, door chains and other such measures;
and
— water efficiency measures
These measures would be installed at the same
point at the energy efficiency measures are installed.
Delivery of the scheme, where appropriate, will
follow the principles of area-based, zonal schemes such as Warm
Zones. Systematic assessment of identified, targeted areas would
take place, progressing ward-by-ward, street-by-street, door-to-door.
Every household in the area would be visited. This will require
return visits and timing the visits to fit with the lifestyle
and work patterns of the residents.
The aim is to deliver a whole-house solution
to the householder whilst taking into account the wider requirements
and needs of energy at a community level rather than the current
focus on individual households being treated in isolation. This
is where a council-wide energy use and heat mapping study to identify
the potential for local generation of heat and electricity is
key. A wide suite of measures will be considered and not just
the easy wins of cavity wall insulation and light-bulbs.
The delivery of energy efficiency measures will
be coordinated locally so the contractors are able to benefit
from the economies of scale of retrofitting multiple properties
in the same street These savings come into there own when considering
installing solid wall insulation on a series of terraced properties
or retrofitting a block of flats.
The Scheme will aim to cluster delivery of measures
to households to ensure that economies of scale can be realised.
To encourage economies of scale, reduce costs, and provide certainty
to the industry there can be an element of pooled purchasing of
measures through the Scheme or regional/sub-regional groupings.
Social housing should adopt a stock-based approach
and work with the local authority to improve the energy efficiency
of the entire stock, with priority being given in the targeted
areas.
The delivery of the Scheme in the local authority
will be a one-stop-shop. This will become the access point to
the energy audit and advice; impartial help and advice on energy
tariffs, payment methods, switching supplier; income maximisation;
and other community services; whilst being the means to access
grant funding and the financing mechanisms proposed to fund up-front
costs for landlords and owner occupiers. The one-stop-shop also
provides a means to promote and ensure take up of other incentives
such as Feed-in Tariffs and Renewable Heat Incentives.
There is a requirement for a central coordinating
and reporting body that reports to government. This body will
be responsible for:
— delivering the national communication
campaign and ensuring coordinated launch, communication, and working
across the regional and local partnerships that will develop under
the NEA proposal;
— sharing of best practice and producing
guidance for local delivery partnerships
— ensuring appropriate use of data on the
housing stock in line with data protection legislation; and
— acting as a body local authorities report
to on their progress under the national programme;
FINANCIAL MEASURES
The current funding landscape in this area is
complicated and confused. There needs to be a simplification and
reassessment of the current myriad of schemes. This Scheme advocates
a single funding for tackling fuel poverty, reducing carbon emissions
and improving energy efficiency that can be accessed fairly by
all regions and devolved nations.
There are several funding streams incorporated
into this Scheme, but importantly they are all accessed through
one point, the local delivery scheme which will be a one-stop-shop
and will identify the eligibility for grant funding and provide
access to the appropriate stream of funding for upfront costs.
This Scheme makes the current programmes under
Warm Front, CERT and the future Supplier Obligation obsolete.
These would be disbanded in their current form.
NEA estimates the Treasury would need to commit
at least £5 billion of central government money per
year up to 2020. A full assessment of the impact of this scheme
is required from the government. This funding would be directed
to the following:
— grant funding whole-house installations
in those households deemed eligible under the Scheme;
— enforcement and compliance costs for
Building Regulations and the new Code for Sustainable Existing
Homes;
— funding other fiscal incentives proposed
such as the Landlord Energy Saving Allowance and VAT cuts;
— regulatory costs associated with the
Energy Performance Certificate Scheme;
— the delivery of the national communications
plan; and
— additional funding to local authorities
to enable proper enforcement of HHSRS and funding to ensure the
scheme can be properly resourced in the set up years before becoming
self-sustaining during the delivery phase.
The government grant/subsidies should be effectively
targeted at those who are the most in need due to being vulnerable
or on low incomes. A proportion of this funding will need to be
directed to social housing, especially local authority owned,
so they are able to fund the works required. Households below
an EPC Band E should be automatically assessed for government
grants. Those on low incomes and certain benefits should be eligible
for grant funding.
The private rented sector should be treated
as a collection of businesses, large and small, by government
and have a separate means of securing financing through interest
free loans similar to the Energy Efficiency Loans offered by the
Carbon Trust. There is a need for the private rented sector to
professionalise and act as the businesses they are. They should
be funded through similar financing mechanisms offered to other
businesses and be incentivised through the tax system.
The owner occupier segment should have access
to a "pay as you save" type scheme to finance the up-front
costs of the retrofit. This should be linked to the household
and careful consideration needs to be made of which route for
payment is decided by government. There are two options: repay
through the DNO; or repay through a payment to the local authority.
Due to the nature of the involvement of the local authority in
this scheme it seems sensible that local authorities be the route
of repayment, collecting alongside the council tax and using the
same systems already in place in town halls across the country.
This funding should be financed through green
bonds. NEA advocates the establishment of a Green Infrastructure
Bank which would raise funds for the delivery of the scheme from
the private sector. This financing would fund the "pay as
you save" scheme for owner occupiers, the Energy Efficiency
Loans for the private rented sector, housing associations to source
capital for their retrofit programme on top of money from government;
whilst providing a source of financing for local authority to
develop community heating and low carbon/renewable generation.
TARGETING
Whilst it will be recognised that improving
the energy efficiency of the housing stock is essential to meet
carbon reduction targets and ease the burden of meeting national
renewable targets, the Scheme should provide a focus on the poorest
households and those communities who are most likely to be fuel
poor.
The scheme should prioritise those communities
where reducing energy bills through energy efficiency measures
will alleviate fuel poverty. They should be identified using the
pre-sampling, data sourcing and mapping referred to under the
delivery section.
There will be clusters of housing stock that
will be of poor quality and have a low SAP rating. These can be
identified by the local authority carrying out pre-assessment
by property archetype and enable the local authority to determine
which areas to assess first.
The scheme will be open to all households from
the outset in the local authority area, but will initial audit
and assess the areas where those on low incomes and who would
benefit more from earlier intervention. There will still be a
means for the able-to-pay outside of the areas being assessed
in the systematic way advocated in this scheme so those "early
adopters" who wish to have works done sooner are able.
STANDARDS AND
REGULATION
The Scheme has an ambitious target that all
homes will be near zero carbon by 2050. There is a need for interim
targets that have some relation to the carbon, fuel poverty and
renewable targets the government has signed up to meet in the
years approaching 2020. This proposal lays out the scheme until
2020 and does not assess the requirement of the scheme from
2020 to 2050.
The Scheme requires the establishment of a Code
for Sustainable Existing Homes with the standard tied to the bandings
of Energy Performance Certificates. All existing homes should
reach at least an equivalent to an EPC Band C by 2020.
Supplementing this standard, social housing
should achieve a higher standard by 2020—equivalent to an
EPC Band B. Since social housing is both a public good and likely
to house those on the lowest incomes or at the greatest disadvantage
this policy would deliver major social and environmental benefits
and could serve as a model for subsequent developments in the
private sector.
To create other access points to work, other
than sale or void of a property, Building Regulations should be
amended to demand consequential works to improve the energy efficiency
of the entire property to reach the appropriate level in the Code
for Sustainable Existing Buildings when renovation, refurbishment
or extension takes place.
Local authorities should be required under planning
laws to consider the energy efficiency level of the whole house
and to require the owner of the dwelling to meet the specific
standard as a condition of receiving planning consent to extend,
refurbish or renovate a domestic property.
At 2020 it is proposed the EPC Band C minimum
on the Code for Sustainable Existing Homes becomes a mandatory
requirement to be met prior to the sale or rental of the property.
In the preceding years up to 2020 the energy efficiency works
should be incentivised by the government to encourage uptake at
the high levels required. Beyond 2020 the incentives should
be removed. With an early indication on regulation from the government
and ensuring householders and landlords will be incentivized to
reach the standard before 2020, this should encourage take-up.
If they fail to participate pre-2020 and their property remains
below the standard they will not be able to sell or rent after
2020 until the property is brought up to the required standard.
This should provide one of the necessary motivations for households
to take up a whole-house retrofit. Announcing this intention early
on in the scheme (2010), so there is adequate notice to householders
will give further encouragement.
Prior to 2020 there should be enforcement
of the minimum standards in the HHSRS to ensure there are no homes
with a Category 1 hazard failing on the thermal comfort element.
No property that falls below an EPC Band E should be allowed to
be rented and those in the owner occupier segment should be prioritised
for retrofit pre—or post-sale depending on the view of the
owner and prospective owner.
INCENTIVES
There needs to be appropriate incentives for
householders to take up the scheme to ensure widespread delivery
and enable economies-of-scale and clusters of work in an area.
Incentives are particularly important for the private rented sector
where a split-incentive is currently resulting in poor uptake
of energy efficiency measures.
The Landlords' Energy Saving Allowance uptake
of the £1500 tax allowance up to 2015 should be
extended to 2020 and be extended to cover low-carbon and
renewable technologies. The Allowance should be conditional on
a pre-EPC check and an EPC produced post-installation. The level
of the Allowance should also be increased to a level that will
make it more of an incentive for landlords to take up whole-house
measures. The Allowance should be promoted among private landlords
further by disseminating information via letting agencies and
the Landlord Tenancy Deposit Scheme. As part of delivery of the
scheme the Allowance should be included in documentation sent
to private landlords after the assessment of the property along
with information on the proposed loan scheme for private landlords.
The government should considered if central
government funded council tax rebates for taking up a whole-house
retrofit is appropriate and not an undue burden on the Treasury.
Other incentives to consider include stamp duty rebate on properties
being sold that have been retrofitted under the Scheme.
Feed in Tariffs and Renewable Heat Incentives
should be promoted by as part of the assessment for financing
and incentives the householder/landlord can apply for. Householders
should be assisted in claiming these after retrofit of appropriate
measures by local authorities delivering the scheme.
All incentives for the Scheme (excluding FIT
and RHI) should run until 2020 to act as an incentive for
early take up prior to regulation.
ENFORCEMENT
To ensure effective delivery of the strategy
there will need to be enforcement of the standards to ensure local
authorities, social housing providers, private landlords and owner
occupiers are delivering on their obligations and that householders
are bringing their properties up to the required standard.
HHSRS—there should be amendments to the
Housing Health & Safety Rating System. A referral process
from delivery agents to the relevant local authority team needs
to be put in place in each local authority as part of the scheme
to deliver the strategy on a local basis. As part of the enforcement
of a minimum standared in the scheme up to 2020 local authorities
should seek to identify Category 1 hazards and prosecute
private landlords who fail to bring their properties up to the
minimum standard of a Band E. HHSRS should be amended to take
into account the requirement for all households to have an EPC
rating. Those households falling below a Band E (SAP 38 or
lower) should be deemed to be at risk of Excess Cold and be classed
as a Category 1 hazard. There should be further reassessment
of the relevance of HHSRS in the longer term.
A Home MOT should be established where all homes
should require an energy efficiency MOT which incorporates a full
audit every 10 years to ensure they continue to meet the
current standard laid down by the CfSEH and regulations. This
would act to update the EPC and provide a point to intervene with
further energy advice. If a property fails a pre-EPC check in
its Home MOT the owner should be required to bring the property
up to the required standard and issued the EPC after completion
of works. This should be applicable across all tenures. The results
of the Home MOT (and updated EPC data) should feed into the energy
efficiency database.
The onus should fall on local authorities to
ensure compliance with the CfSEH as part of their planning, building
control and environmental health functions.
OBLIGATION AND
COMPETITION
The current approach of a supplier obligation
is not an appropriate mechanism for delivering this National Energy
Efficiency Scheme. The obligation for delivery should rest with
local authorities rather than energy supply companies.
With 130 out of 150 Local Area Agreements
including carbon reduction targets the majority of local authorities
are taking action to reduce emissions. Local authorities are the
central point of delivery through partnerships in their community
with a key role in reducing carbon emissions, tackling fuel poverty,
and providing a strategic approach to local energy planning. Local
authorities should be the bodies obligated to deliver the scheme.
The need to ensure the majority of the housing
stock is retrofitted to a higher energy efficiency standard warrants
an expanded programme. This is best delivered through local led
partnerships where the local authority should have the responsibility
for reducing the carbon emissions in their locality. This would
also provide independence from energy suppliers which may enable
other means of generation such as CHP and community heating to
gain more traction. Local and community renewable and low carbon
generation, such as CHP, are currently mostly local authority
owned and could be considered a threat to the centralised provision
of gas for heat. This is essentially undermining the business
model of the energy companies so they may not necessarily be enamoured
with delivering these options.
The new obligation on all local authorities
to reduce carbon emissions in their locality through working in
partnership under the banner of a national programme for a conversion
to a low carbon economy should include
— energy and heat mapping to identify areas
where provision of community heat or electricity generation is
preferable;
— the systematic retrofit of the entire
housing stock in all sectors within their locality;
— the delivery of energy advice, income
maximisation by ensuring maximum take-up of benefits entitlement,
and delivery of other community measures; and
— access to retrofit grants for those eligible
and to financing mechanisms for landlords and owner occupiers
The current obligation and other schemes delivering
have limited competition and in some case it is arguably a monopoly
position enjoyed by the contracted managing agent also owning
the contractors that are delivering the measures.
This proposal seeks to enhance competition by
altering the point in the market where competition occurs. Under
present schemes competition is limited with the only access being
for large businesses tendering for the contract to deliver the
energy suppliers obligations and the government national scheme.
This scheme would move competition to the local level and enable
smaller, accredited local businesses and installers to tender
for contracts for, amongst others
— provision of energy audits and advice;
— installation of measures;
— data management and infrastructure to
enable delivery;
— heat and energy mapping;
— provision of energy infrastructure; and
— billing and management services of district
heating.
This approach will enable new entrants into
the market to deliver on energy efficiency and low carbon/renewable
generation.
This local authority obligation would not separate
the social and environmental objectives. The delivery mechanism
through a one-stop-shop approach of whole-house retrofit available
to all under the one scheme with access to the appropriate financing
mechanism for their segment of the market will address both objectives.
The onus for delivery of the government social and environmental
objectives is taken off the energy supply companies and private
sector and the reliance on a flawed principle that the market
can deliver, and it is placed firmly in the public sector through
local authorities.
REPORTING
Progress against delivery should be monitored
at a local level and collated nationally to enable proper assessment
of progress to inform the need for any amendments to the scheme
in future years to ensure all homes are retrofitted by 2020. The
Government should require local authorities to report on progress
in delivering energy efficiency improvements in their area in
terms of raised standards in the housing stock and reduction of
carbon emissions.
Government should be required to report to Parliament
on progress towards improving the housing stock and feed into
the reporting process for the carbon budgets and the reduced carbon
emissions achieved from the housing stock.
A housing stock energy efficiency database should
be established that will enable local authorities to report back
to central government on progress towards meeting the target.
The database should include the SAP/EPC rating pre-measures and
details of improvements installed and a post-measure SAP/EPC rating
with expected reductions in carbon emission and energy use. It
should be a requirement that householders should have a full EPC
assessment and post-measures update (see delivery) and be obliged
to report the improvements to their local authority.
Local authorities should be required to report
back (through a housing stock database) on the improvements within
their area based on the number of households where measures have
been installed, the numbers removed from fuel poverty and the
average EPC band (and SAP rating) by tenure, ward etc.
The local authority will be required to report
on the number of homes with Category 1 hazards under HHSRS
and failures of the Home MOT.
COMMUNICATIONS
The scheme requires a comprehensive national
communications strategy to create a recognisable brand that will
be used by local authorities to co-brand their scheme. This will
tie in the national offering with the local delivery and will
ensure that householders are aware that every household will be
receiving the same offering and measures up to 2020.
The national coordination body will be responsible
for rolling out the communications strategy and ensuring that
the local delivery across the country is communicating the same
messages and offerings in a coordinated fashion. Combining a national
launch and programme with local strands that are timetabled to
ensure households are receiving messaging and motivation from
numerous sources that will encourage them to participate in the
scheme.
Each local delivery scheme will require its
own communications plan for marketing the offering locally and
ensuring uptake.
The central national body could provide templates
of materials and advice to local authorities to ensure there is
no duplication of effort and a coherent brand is maintain across
the country.
The communication strategy should aim to engender
trust in the scheme and drive take up of installations.
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