Memorandum by the Planning Officers' Society
and Local Government Association
1. INTRODUCTION
1.1 The Planning Officers Society (POS)
represents the most senior professionals and managers of planning
authorities in the English Local Authorities. The Society aims
to ensure that planning makes a major contribution to achieving
sustainable development from the national to the local level,
in ways which are fair, equitable and achieve the social, economic
and environmental aspirations of the community.
1.2 The POS, in conjunction with the LGA,
makes the following comments on the issues being considered by
this Inquiry as follows.
2. APPROPRIATE
MEASURE OF
ENERGY EFFICIENCY
2.1 The POS and LGA welcome the review of
the Building Regulations Part L which will further raise standards
of both new build and refurbishment and drive up performance in
relation to energy conservation and the early review of the Regulations
is to be applauded.
2.2 However, building regulations need to
make a step change to achieve the level of energy efficiency in
buildings enjoyed by many European countries especially in terms
of availability and installation of energy efficiency technology.
2.3 If building regulations are to help
deliver energy conservation they must have an explicit and mandatory
role in delivering Government White Paper targets to reduce CO2
emissions and to achieve the targets to reduce pollution set by
the Royal Commission on Environmental Pollution.
2.4 The Government needs to enforce higher
building standards, particularly those of BREEAM and Eco-homes
as developed by the Building Research Establishment. To this end,
a quality mark scheme should be developed to require new buildings
to be zero CO2 rated and a list of Eco-homes and BREEAM
standard contractors publicised. This process could be started
by requiring all publicly funded developments—through public/private
partnerships or direct grants to private industry—to build
these standards as a minimum.
2.5 Many local authorities are currently
seeking improved energy performance for developments through negotiation/use
of supplementary policy, etc. However, in the absence of regulation
or more direct incentives, this will only affect a small proportion
of development where developer interests coincide with those of
the local authority. The Government should therefore seek to implement
a cost-effective solution to the enforcement of both Building
Regulations and the Energy Performance of the Buildings Directive
to ensure compliance.
3. PUBLIC KNOWLEDGE
OF ENERGY
EFFICIENCY
3.1 There is a real and urgent need to raise
awareness across a wide spectrum of stakeholders as well as the
general public about the usage of energy and the real benefits
of energy efficiency. For many energy is relatively cheap and
there are no obvious short-term benefits to be realised. The multiple
benefits of energy efficiency need to be explained together with
the longer term national and international benefits. This may
mean that there is a need for a range of different "messages"
to be marketed to targeted audiences (eg affordable warmth, global
warming, security of supply, business competitiveness and property
marketing).
3.2 The link between climate change and
energy efficiency should be emphasised more effectively to both
consumers and the construction industry. The carbon index, currently
established through the SAP rating mechanism is therefore the
most appropriate measure of energy efficiency.
4. IMPROVING
ENERGY EFFICIENCY
INCENTIVES
4.1 The POS/LGA concur that in order to
achieve the step change in energy efficiency identified in the
Energy White Paper, behavioural change needs to be addressed and
we support the Government's multi-dimensional approach. In order
to deliver such change, all Government agencies charged with facilitating
change need to draw more extensively on front-line experience
through the initiation of a two-way dialogue with local authorities,
installers, retailers and manufacturers. Policy makers, activists,
corporate executives, educationalists, environmental professionals
and others often make assumptions about behaviour and use these
assumptions to explain why people act in a particular way. Funding
for research into how to change environmentally significant behaviour
is therefore critical in ensuring programmes achieve their anticipated
outcomes.
4.2 A number of local planning authorities
are already developing planning policies related to energy efficiency
in design and construction. This energy policy making needs support
and dissemination. Until this happens through the new planning
system (LDFs), the local planning authorities will not have substantial
policies on energy to compel developers. The changes to the planning
system currently taking place will necessarily put a time lag
into the process of policy formulation. Government Offices for
the Region need to actively support such policy development, including
target setting negotiated in consultation with local authorities.
4.3 The Government intends to increase the
level of activity for Energy Efficiency Commitment (EEC). We agree
that this is the most effective vehicle for improvement in energy
efficiency and carbon reduction in the domestic sector. The LGA
welcomes the proposal for the continuation of suppliers being
required to achieve at least 50 per cent of their energy savings
from the "Priority Group". To this end, the LGA does
not see the need or justification for the recent proposal from
Defra for removing those in receipt only of disability benefits
as opposed to income related benefits. Suppliers are currently
finding difficulty in meeting the Priority Group targets and to
remove those in receipt only of disability benefits would seem
counter-productive for social, economic and environmental reasons.
Regarding the practical options for improved interaction with
EEC and Warm Front, to date, the scheme has been based on the
optional involvement of energy companies with local authorities
and there has therefore been a lack of co-ordination with other
initiatives such as the Warm Front fuel poverty programme or initiatives
of local authorities in the same area at the same time. This has
led to competition and confusion on occasions. Better focus on
resources will be achieved when consultation is made a principle
of the scheme and when resources can be combined and targeted
at all homes in each area. Without this, many gaps will remain
in the delivery of energy efficiency in the domestic sector and
these will become increasingly expensive to tackle retrospectively.
4.4 The failure to undertake energy rating
of existing dwellings under the Government WarmFront Fuel Poverty
Programme has created a situation where there is no real proof
of benefits to the tenant or owner of the house that the energy
efficient improvements will lead to affordable running costs.
Examples can be provided. We also have to get energy rating into
refurbishment and assessment models done as good practice.
4.5 There is a need for more research at
the local level to assist local practitioners to address energy
efficiency. Such research should address the effectiveness to
date with the EEC.
4.6 The Government will need to consider
carefully the problem of hard to heat housing, ie housing with
solid walls and those with no access to the gas network. Improving
energy efficiency in these homes has implications for a number
of key policy areas of social and economic regeneration, including:
— Fuel Poverty (Fuel Poverty Strategy
2001).
— Climate Change (mitigation against
further climate change).
4.7 It is unlikely that the Government will
be able to achieve its targets in these key areas without addressing
the issue of hard to heat housing. Consideration should be given
to consultation with Ofgem on how these measures may best be incentivised
through EEC.
4.8 Hard to treat homes is a major factor
for social housing as well as the private sector. The key problem
with many homes is that even when they are sealed, the ventilation
issues are not dealt with and heat recovery systems are not installed.
Without the correct ventilations many homes improved under energy
efficiency suffer from increased condensation and mould growth.
This is also true of the warmfront programme which has no provision
for adequate ventilation including heat recovery fans. Leicester
City have been installing heat recovery systems since 1994 (City
Challenge Programme case study available). This is not new technology.
5. POTENTIAL
FOR TECHNOLOGY
IMPROVEMENTS
5.1 Planning practitioners need help to
develop their technical knowledge on what technologies there are,
how they work, the suitability for application, procurement and
delivery, the relative costs/benefits and after management options.
5.2 Cutting edge technology already exists
throughout the EU in terms of energy efficiency goods and products,
but in the UK we are suffering from a construction skills shortage
and a lack of public knowledge about available options. Most of
the retro-fitting of energy efficient goods is therefore installer-led
and based on previous practise. As domestic householders are not
aware of the latest technology available to them, there is also
little demand to achieve change from the customer perspective.
The current nation-wide skills shortage exacerbates the problem
of a low quality of energy efficient housing stock. As building
standards require a step-change to reach the highest standards
for maximum reduction of CO2 emissions the Government
urgently needs to address the problem of skills shortages and
inadequate training and focus on aspects that will deliver energy
efficiency quickly and effectively.
6. ENERGY EFFICIENT
CONSUMER GOODS
6.1 There is a real opportunity to help
the consumer choose energy efficiency when purchasing goods ranging
from new homes to white goods. Whilst energy efficiency is not
marketed, this means that energy efficiency in construction and
design is not considered an essential element. This needs to change.
6.2 The promotion and take-up of these goods
by consumers can be stimulated at a national level through various
means of environmental fiscal reform. The LGA supports the increased
introduction of financial incentives: there needs to be a much
greater use of environmental taxes or levies raised on unsustainable
energy activities in order to encourage and fund sustainable alternatives
where practical. To this end the LGA has supported in the past,
the introduction of measures to promote and motivate energy efficiency
and energy saving, as outlined by the Association for Conservation
of Energy (ACE) in its submission to the Government's past consultation
on Economic Instruments to Improve Household Energy Efficiency.
With evidence gathered from 108 local authorities, the measures
suggested by ACE included:
— Reduced VAT to 5 per cent for the
supply and installation of energy efficient products or materials
in non-grant schemes when householders employ contractors.
— Capital allowances and 100 per cent
first year enhanced capital allowances for companies eg Energy
Service providers, who invest in energy-saving equipment to lease
to social landlords and households.
— A "domestic business tax allowance"
allowing private landlords to claim investment in energy-saving
materials against profits.
— A stamp duty rebate for house purchasers
who make energy efficiency improvements to their home within six
months to a year, for example.
— A tax allowance for companies training
installers of energy-saving equipment.
— Greater use of energy labelling for
homes would help to raise public awareness and to incentivise
demand for improved energy performance in residential stock.
7. COMBINED HEAT
& POWER SCHEMES
7.1 The context for the importance of establishing
CHP as the balance of imports and exports in energy is set to
change dramatically in the coming years. As the UK's oil and gas
supplies decrease, we will no longer be a net energy exporter,
but become a net importer of energy. It is estimated that by 2020
the UK will be importing about three-quarters of its primary energy
needs, (Energy White Paper, February 2003) unless we effectively
and urgently invest in and achieve a diverse, decentralised mix
of energy generation, including renewables and CHP. Local authorities
can ensure that micro CHP and renewables are further promoted
and developed in new build through development control, but will
need targeted support, advice and information including improved
incentives for developers to consider CHP.
7.2 Generally speaking, government programmes
include action programmes and milestones which do not correspond
with broader government targets as set out in the Energy White
Paper. For example, Community Energy funding for promoting district
heating and CHP only runs until 2006. This inconsistency sends
the wrong message and in itself is not sustainable.
7.3 The time it takes to design a scheme
or implement a scheme needs to be taken into account. Many government
schemes in the past have been time related and this creates major
pressures and burdens to meet what in many cases is unrealistic
time scales. (Carbon Trust LAEF Project came out in December 2003
just before Christmas with a very short bidding period).
7.4 Many scheme pilots have already proven
what works and how to do it, but there are no programmes that
are just about replication of good practice. This is what is needed.
Proven ideas and technologies with handholding and expertise to
implement at local level.
7.5 All programmes need to correspond with
government targets to encourage local authorities and the private
sector to make investment in local actions.
7.6 Current national programmes simply amount
to a "cherry picking" approach—resources for pilots
need to be directed to mainstream programmes which enable action
and progress towards national targets to become widespread and
to gain economies of scale.
7.7 There should also be encouragement for
other agencies to be involved like EEACS, and Energy Agencies,
also utilise the energy networks in Europe like Energie Cite and
FEDERENE.
7.8 With regard to local authority procurement
and CHP, currently each individual local authority has to spend
limited time and resources procuring a small Solar PV or Solar
Thermal panel when collectively a national scheme could procure
a long term contract which could be called down by local authorities
as their refurbishment or building programme allow. The saving
of local authorities' resources would be significant, such as
officer time spent responding to calls for tender and the legal
issues of contracting with the supplier. This process can be used
for boilers, CHPs, heat pumps, heat recovery, in fact there would
be no limit. But the freedom for local authorities and community-based
schemes would result in significant increase in local schemes.
The industry could also gear up based on a long-term contracts
and this would be reflected in lower prices: a national procurement
facility for anything that features on the enhanced capital allowance
list should be established.
8. FUNDING AND
CO-ORDINATION
OF RESEARCH
8.1 Research into energy efficiency needs
to emphasise the practical outcomes so that professionals and
practitioners have access to a wide range of best practice and
advice.
8.2 In its sustainable energy policy document,
the LGA supports the need for independent research, measurement
and monitoring of progress against national policies: there is
a need for independent monitoring of the level of penetration
of national programmes, and supporting evidence such as energy
consumption data in the local authority's area, to inform subsequent
policy decisions.
8.3 Leicester City Council are carrying
out research at the moment through the EST Innovation Programme
to investigate how to finance large scale town wide or city wide
implementation of energy efficiency measures. We call this "Just
In Time Funding" as most of the schemes available to local
authorities requires the identification of match funding in real
terms. This research will be available in December 2004 but already
it has highlighted the complications of local authorities using
the Prudent Borrowing. What needs to happen is a clear strategy
be set out for guidance on financing for local authorities with
regard to energy efficiency improvements.
8.4 Good guidance exists on "Invest
to Save" (GPG 312) this needs to be disseminated better in
the form of training and awareness raising as it clearly demonstrates
how the whole life costing works and the benefits to local authorities
taking a long term view of the benefits of correct procurement
and getting it right.
8.5 Procurement is one of the most powerful
tools to energy efficiency. Public Authorities must utilise the
opportunity to procure the right product at the right time for
meeting the needs of energy efficiency and carbon savings. This
submission has mentioned national procurement but awareness needs
to be raised of how to procure correctly for energy and energy
efficiency.
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