In April, Bright Blue launched its Green Conservatism research project. One of the strands they are taking forward is on renewed home energy efficiency policy. We submitted our response to the stakeholder consultation in May.
data,Energy Company Obligation,Green Deal
Liz Warren is a founder and director of SE2, a small consultancy helping individuals, communities and organisations build their capacity to respond to climate change. You can find out more about their work at www.se-2.co.uk.
DECC recently published statistics on the take-up of energy efficiency measures by households during 2015. In this blog post, we unpick some of the data, exploring the good, the bad and the frankly baffling within the rich data set provided. How did policy announcements affect the market? Have whole-house energy assessments unlocked energy efficiency opportunities? And could we have found the elusive answer for improving the private rented sector?
The Treasury was strongly criticised this week after a Panorama investigation revealed that over 9,000 people in England and Wales died from living in cold homes last winter.
The Panorama programme, ‘Too Poor to Stay Warm’, broadcast on Monday, cited research by academics at UCL which shows that a fifth of the 43,900 Excess Winter Deaths in Winter 2014/15 were due to people living in cold homes.
Yet Government support for energy efficiency has crashed by 80%. Making homes energy efficient is considered by experts as the only long term solution to fuel poverty, which affects over 4 million households in the UK. The UK has one of the oldest and least energy efficient building stocks in Europe.
In our own research published earlier this week, also reported in The Guardian, we found that:
- the number of energy efficiency measures installed in British homes has fallen by 80% since 2012
- the number of households helped with energy efficiency measures has crashed by 76%
- investment in home energy efficiency has declined by over 50%
We also found that the very low level of energy efficiency support now on offer is set to continue for the rest of this Parliament. During the last Parliament 5 million households were helped but we estimate that only 1.2 million households will receive energy efficiency measures this Parliament.
The Government axed Warm Front during the last Parliament, and the Green Deal and Green Deal Home Improvement Fund last year. It also axed the UK’s zero carbon policy for new homes. Only the Energy Company Obligation is left, a levy on energy bills that was slashed in the Spending Review in December 2015.
A major alliance of 200 organisations and businesses under the Energy Bill Revolution banner is calling on the Government to make home energy efficiency an infrastructure priority. It is the most popular energy solution in the UK today with support across Parliament.
But the Treasury has refused to allocate one penny of the £120bn infrastructure budget to make homes energy efficient, despite the fact energy efficiency is classified as infrastructure by both the International Energy Agency and the European Investment Bank. According to the Government’s own economic data, making homes energy efficient also provides comparable economic returns to other infrastructure projects like roads and railways.
Jenny Holland, Head of Campaigns at ACE, said: “Our research findings are truly shocking. The UK has some of the worst housing stock in Europe, with levels of fuel poverty unheard of in much colder countries like Sweden. And UCL’s findings make clear that our cold homes were responsible for 9,000 avoidable deaths last winter. But Treasury help to upgrade our freezing homes has been slashed to the bone. The Government has pledged to make all fuel poor homes energy efficient by 2030, but without new funding, it will take them 94 years to meet their pledge. This is simply not good enough. By making energy efficiency an infrastructure priority, the Treasury could transform the lives of some of our most vulnerable citizens, making their fuel bills affordable and greatly reducing the risk of cold-related illness.“
Ed Matthew, Director of the Energy Bill Revolution alliance said: “The decision by Treasury to decimate energy efficiency support will cost lives. Yet making UK homes energy efficient provides strong economic returns, as much as any other infrastructure project. But Osborne has chosen to invest £50 billion in HS2, £30 billion in road building and not one penny of the infrastructure budget in retrofitting the crumbling UK building stock. Perhaps he thinks there are more votes for the Conservatives by shaving a few minutes off a railway ride than saving the lives of the fuel poor.”
Display Energy Certificates,Energy Performance Certificates,European Energy Performance of Buildings Directive,Zero Carbon Homes
Our response to the European Commission’s consultation on the Energy Performance of Buildings Directive
This consultation forms part of the evaluation of the Energy Performance of Buildings Directive. Under the terms of the Directive, the Commission is required to carry out this evaluation by 1 January 2017, with assistance from a Committee of Member States’ representatives. The evaluation should reflect the experience gained and progress made since the adoption of the Directive. If necessary, the Commission should make proposals on the basis of the evaluation.
The evaluation also follows on from the Energy Efficiency Communication of July 2014, which indicated that additional measures to be introduced to improve energy efficiency would need to primarily address the energy efficiency of buildings and products if progress is to be made by 2030. The Energy Performance of Buildings Directive is the main legislative instrument in force at EU level covering the energy efficiency of buildings.
With a primary focus the UK energy efficiency market, our response to the consultation highlights: the uncertainty following the abandonment of the zero carbon trajectory; the missed opportunities with respect to driving higher rates of renovation; the low level of compliance with EPBD’s provisions and the virtual absence of enforcement; the question marks hanging over Display Energy Certificates; the need to make EPC data more widely accessible; and the need to plug skills and capacity shortages in the energy services and energy auditing sectors.
Our response to APPG for the private-rented sector’s inquiry into energy efficiency in private-rented housing
The All-Party Parliamentary Group for the private-rented sector launched an inquiry into energy efficiency in private-rented housing. Along with Friends of the Earth and Citizens Advice, ACE led a widely supported civil society campaign in 2010/2011, which led to the 2011 Energy Act placing a duty on the Secretary of State to introduce a minimum energy efficiency standard for private rented housing from April 2018 at the latest. We were also a member of the DECC advisory working group which met throughout 2013 to advise Ministers on the detail of the regulations that would be needed to bring the minimum standard into force.
The group’s inquiry follows the government’s decision not to renew the landlord energy savings allowance in the March budget. This had originally been introduced to encourage landlords to improve the energy efficiency of the properties they let but was dropped because of low take up.
Announcing the inquiry, the group’s chairman, Oliver Colvile, member of parliament for Plymouth Sutton and Devonport said: “With the winter months just around the corner, improving the energy efficiency of rented housing is a crucial issue.
“The group’s inquiry will look to develop new ideas that will support landlords to meet their new target; save tenants money on their bills and help improve standards. I would encourage all those with an interest to submit their suggestions.”
The Government has today published its new fuel poverty strategy for England. While welcoming the intention to bring the homes of the fuel poor up to a high energy efficiency standard, we believe the target date of 2030 is far too long to wait. We also believe that all low income households – not just those that are fuel poor today – should be improved.
It is cost-effective and practicable to improve the homes of all 6 million low income households to a C energy rating by 2025 – with 2m improved to this level by 2020. If we just focus on fuel poor households, other low income households will simply drop into fuel poverty if their circumstances change negatively or fuel prices rise.
Finally, we are worried about the caveat that households will only be improved ‘as far as reasonably practicable’. This should be removed or at the very least tightly defined to ensure that it cannot be used by future Governments as an excuse for failing to implement the strategy. While there may occasionally be circumstances in which reaching the target is impossible or prohibitively expensive, a blanket caveat is simply a recipe for delay and inaction.
We raised all of these concerns when the Government published and consulted on its draft strategy last year. We are disappointed that our concerns, shared by countless others in the NGO and academic communities, have been ignored.
Secretary of State for Energy and Climate Change Ed Davey is finally laying regulations before Parliament that are intended to bring the coldest and leakiest private-rented homes up to a minimum Energy Performance Certificate of Band E by April 2018. Having long campaigned for minimum standards for the sector, we welcome this overdue breakthrough. This campaign has had to overcome considerable resistance to minimum standards, and we agree with what Ed Davey says in the Guardian today:
“Not everyone in this government wants more regulation. But in energy efficiency, regulations play a crucial role.”
But today’s development does not go far enough. Given Britain’s status as the ‘Cold Man of Europe’ (see the Guardian’s infographic, based on our earlier briefing), and that energy efficiency support for households, particularly fuel poor households, has collapsed this winter, we cannot stress enough that the regulations have got to go further in at least two important respects (see our response to the domestic PRS consultation for more):
- The minimum standard should not have been based on the principle of ‘no net or upfront costs’ to landlords. It is quite wrong, as a matter of both law and practice, that a regulatory framework should be dependent upon a set of financing mechanisms – i.e. the Green Deal and Energy Company Obligation – that may not even exist in 2018. We therefore believe that all properties within scope of the regulations should be required to meet a minimum standard of EPC Band E, up to a maximum spend of £6,000. More broadly, all domestic private rented properties should be within scope of the minimum standard regulations, not just those with a valid EPC.
- Government should have today set a trajectory for increasing the minimum standard to EPC D in 2022 and to EPC C in 2026. An EPC rating of E is only the best of the worst, and a trajectory would have encouraged landlords to go further in one go, which in countless properties is easy and sensible to do.
We look forward to working with the next government on making sure these regulations become as meaningful and forward-looking as they can and should be to match the challenge our housing stock and fuel poverty poses.
Energy Efficient Buildings,Zero Carbon Homes
One of the great triumphs of genuine private/public co-operation has been the work of the non-profit Zero Carbon Hub. Ever since its formation in 2008, it has proved to be the acknowledged entity to which everyone turns – companies and Ministers alike – to consider how best to progress towards ensuring that only the most energy and carbon-efficient new buildings are constructed.
But the vast majority of the buildings we shall be living and working in forty years from now have already been built. Precious few of these are even vaguely zero carbon; most waste bucketfuls of energy every day. By common consent we have one of the oldest, and certainly one of the least energy efficient, building stocks in the entire western world.
It is clear that one of the main challenges over the ensuing decades will continue to be to dramatically improve the energy performance of these buildings. This will need to happen at a rate long aspired to. But – as has been shown in the case of the flagship Green Deal Finance policy – right now falling woefully short of even its cost-effective (let alone technical) potential.
Energy Performance Certificates,Private Rented Sector
ACE has submitted written responses to The Department of Energy and Climate Change consultations on private rented sector energy efficiency regulations, for the domestic and non-domestic sectors respectively. Following a campaign by ACE and its allies, the Energy Act 2011 placed a duty on the Secretary of State to bring into force regulations to improve the energy efficiency of buildings in the domestic and non-domestic private rented sector in England and Wales.
On the domestic sector consultation, delays have caused concern and uncertainty for an energy efficiency industry gearing up to deliver improvements. We are pleased therefore that the long-awaited consultation has finally been published. However, the Government’s proposals contain a number of key flaws, which must be remedied if the minimum standard is to be enforceable by local authorities and to deliver improvements up to an Energy Performance Certificate Band E in all cases.
We have similar concerns regarding the non-domestic sector regulations. Moreover, as former ACE Director Andrew Warren wrote on September 9, what is deeply worrying is that a very large number of non-domestic buildings have not yet had an Energy Performance Certificate (EPC) issued despite the leaseholder having altered (a state of affairs which is in breach of the law). Many of these are likely to be poor performers on the EPC scale. The knock-on problem is that these illegally un-certified buildings are not captured by the regulations for minimum energy performance.
Private Rented Sector
Joint statement issued today calling for tough, enforceable regulations in the private rented sector
ACE has today joined with nearly 30 other civil society organisations in issuing a joint statement calling on the Government to lay without delay tough, enforceable regulations to introduce a minimum energy efficiency standard in the private rented sector. The sector has the highest proportion of the very worst homes (those in EPC Bands F and G) – with nearly half the households living in them suffering from fuel poverty. The Energy Act 2011 required the Government to bring forward regulations to introduce a minimum energy efficiency standard, expected to be set at Band E. However, these regulations look likely to be laid at least a year later than expected, leaving landlords and tenants alike facing uncertainty and confusion. We are therefore calling on the Government to lay the regulations as soon as possible, to specify that the standard will be Band E in all circumstances and to ensure that exemptions will be kept to an absolute minimum.