ECC Inquiry: Fuel poverty in the Private Rented and Off-grid Sectors
ACE have submitted a written response to the Energy and Climate Change Committee inquiry into Fuel Poverty in the Private Rented and Off-grid Sectors
1. The Association for the Conservation of Energy has long been concerned about the poor standards of energy efficiency (and large concentrations of fuel poor and vulnerable households) in the private rented sector (PRS). Throughout the passage through Parliament of the Energy Act 2011, we (along with Friends of the Earth and Citizens Advice) therefore led a 40-strong coalition of organisations in a campaign calling for the introduction in 2016 of a minimum energy efficiency standard in the PRS to make it illegal to re-let a property with an Energy Performance Certificate (EPC) rating of F or G.
2. While we welcomed the introduction of such a standard at the Bill’s Second Reading in the Commons, we were – and continue to be – extremely disappointed that, for no good reason, it will only be introduced in 2018. In the particular context of fuel poverty, this is especially perverse. The Government have repeatedly stated that the minimum standard is intended to tackle fuel poverty in the rented sector, but it does not come into force until two years after the date – 2016 – by which they have a statutory obligation (under the Warm Homes & Energy Conservation Act 2000) to end fuel poverty. We therefore believe that the minimum standard should be brought forward to 2016. In addition a major loophole in the Act – whereby landlords will not in every case have to bring their property up to an E rating – needs closing without delay.
3. The other relevant provision in the Act will mean that, from 2016, landlords cannot refuse requests for “reasonable energy efficiency improvements” from their tenants. However, for a number of reasons we believe that this provision will have negligible impact. In particular, we believe that, without protection from retaliatory eviction, tenants will be significantly deterred from using this new power.
4. In addition to taking steps to strengthen the Energy Act provisions in relation to the PRS, we believe that the Government should increase the level of funding available through the ECO to tackle fuel poverty in the PRS and more generally. In particular, we call upon them to use, post-2013, the revenues from the EU Emissions Trading Scheme and the carbon floor price to provide additional spending on energy efficiency programmes, prioritising the homes of the fuel poor and vulnerable.
5. Finally, the Government should take some simple steps to ensure the more proactive use by local authorities of their powers under the Housing Health & Rating System to ensure the improvement of PRS properties that contain a Category 1 hazard of ‘excess cold’. Alongside this, they should increase the level of the Landlords’ Energy Saving Allowance and do more to promulgate information about it to landlords, in part through the mechanism of an enhanced EPC Register.
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