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Warm Arm of the Law

Kelly Greer, Research Director at ACE reflects on the publication of a new report from ACE and CAG consultants, which looks at the extent to which the Housing Health and Safety Rating System (HHSRS) and Minimum Energy Efficiency Standards (MEES) are being proactively implemented and enforced by local authorities across England and Wales[1].

In 2008, while working at Impetus Consulting, the Energy Efficiency Partnership for Homes commissioned Emma Jones and I to research and write a report on HHSRS[2].  As the report details, although HHSRS had given local authorities the power to enforce minimum housing standards related to Excess Cold, the powers were not being used nearly as widely or effectively as they could be.  The opportunity to tackle fuel poverty and reduce carbon emissions at very little cost to the tax payer was not being realised, and there remained great potential for more proactive use of HHSRS.  And here my passion for tackling fuel poverty in the PRS was born…

My joint working with Emma on this topic continued during my time at National Energy Action (NEA) when we published ‘HHSRS: Your power to warm homes in the private rented sector’[3]. Again, we highlighted that HHSRS had the potential – and we showcased some great local action where councils were leading the way – but HHSRS was still not being used nearly as widely or effectively as it could be.

Fast forward to 2018.  HHSRS has been joined by MEES,  and ACE and CAG Consultants (where Emma is now a Partner) have just published ‘The Warm Arm of the Law: Tackling fuel poverty in the private rented sector’, one of two outputs from an Ebico Trust funded research project looking at the extent to which HHSRS and MEES are being proactively implemented and enforced by local authorities across England and Wales.

Unsurprisingly, the headline finding is that local authorities are not doing enough to enforce minimum energy efficiency standards in the PRS. But, quite frankly, who can blame them. In the wake of budget cuts, local authorities have reduced spending on enforcement activity by a fifth between 2009/10 and 2015/16 and key stakeholders expect this trend to continue as further planned cuts in public expenditure start to bite[4].  Those we interviewed as part of the project frequently referenced ongoing budget cuts and a lack of resources within local authorities, together with growing responsibilities as HMO licensing expands and MEES are introduced.  And at the same time, the number of people living in privately rented homes is ever increasing.

The PRS has grown by over 40% in the last ten years and now makes up 20.5% of the housing market in England, compared to just 10% in 1999[5]. And there has been a similar increase in Wales[6]. Figures for urban areas are higher and it is widely accepted that this tenure will continue to expand.

Fuel poverty continues to be a major problem and is particularly acute in the PRS, with an estimated 21.3% of PRS households thought to be in fuel poverty in England[7], and 36% in Wales[8]. Compared with other tenures, the PRS in England has the largest proportion of energy inefficient F and G rated properties and a staggering 45.7% of PRS households living in such properties are in fuel poverty[9].

Research from the Building Research Establishment highlights that cold related illness amongst people living in privately rented properties costs the NHS over £35 million per year[10] – a figure I would say is conservative.  Increasing the energy efficiency of PRS properties is therefore key to reducing fuel poverty and limiting the impact on the NHS. However, achieving this in the PRS has been historically challenging; there is little incentive for landlords to invest in the energy efficiency of their properties given that it is their tenants who will benefit from reduced energy bills. It has long been recognised that minimum standards are key to achieving improvements in this sector.

Parliamentarians often argue against further regulations in the PRS. They state that local authorities have extensive powers to tackle issues. They’re perhaps partially right. Local authorities have a ‘toolbox’ of legislative powers that can be used, but the problem is that these powers are not being used as effectively as they could be. In addition, there are strengths and weaknesses to these legislative powers.

We found mixed views from stakeholders about how useful HHSRS is in terms of improving energy efficiency and reducing fuel poverty in the PRS. Many stakeholders reported that Excess Cold is the most common hazard that comes up in their HHSRS inspection activities. Some considered that HHSRS is a useful and versatile tool, good at dealing with major problems and which, in extreme circumstances where there is imminent risk, can be used to prohibit the use of all or part of a dwelling. There are also no financial contribution limits to HHSRS as the principle objective of HHSRS is to mitigate risk and maximise safety of tenants. Councils also have the power to undertake the works by default and charge the landlord for the improvements. However, stakeholders also considered that HHSRS has many weaknesses. They felt that the guidance is ambiguous around the Excess Cold hazard; in particular, the issue of ‘affordability’ needs to be much more clearly defined. Numerous stakeholders referred to the fact that the statistical evidence relating to energy performance and health outcomes has not been updated since HHSRS was developed, and it was felt that HHSRS is disproportionately weighted towards immediate safety rather than any impact on longer term health effects.

Will the introduction of MEES help to encourage further action? While some stakeholders considered the introduction of the MEES regulations as a positive step, recognising that the legislation is a world first in terms of introducing minimum standards, we heard mixed views about whether MEES is likely to be effective without amendment and the resources for more robust enforcement.

The key strength of MEES was felt to be its simplicity and the potential for enforcement to be less resource intensive (compared to HHSRS). Reference in the guidance to affordability for tenants was also felt to be a positive.  The future trajectory of the regulations – with PRS properties required to be a minimum EPC band C by 2030 – was considered another major strength as this long-term target should help to promote whole house retrofit approaches beyond EPC band E, thus eradicating fuel poverty from the property for the vast majority of tenants. Unsurprisingly many stakeholders were unsure how effective the regulations will be as they were only just beginning to be implemented. In addition, the regulations in their current form are likely to have limited impact due primarily to the plethora of exemptions for landlords. Stakeholders were frustrated with the lack of ambition in the most recent government consultation[11] and considered that wider housing policy failures should not result in the weakening of energy performance.

There were also questions raised as to whether the regulations would be effectively implemented when so few rental properties comply with the requirement to have an EPC – a Freedom of Information (FOI) request in 2013 found that just over a quarter of PRS properties had an EPC[12]. Ultimately, the poor enforcement of EPC regulations will diminish the effectiveness of MEES.

Stakeholders felt that there was a lack of clarity on how MEES and HHSRS could work together. There is growing evidence that local authorities accept that F and G rated properties are sub-standard and, while recognising that there is not an exact parallel between Excess Cold hazards and F and G rated properties, that action should be taken on inefficient properties. Some councils noted that they will look at taking HHSRS enforcement activity against properties that have registered a ‘no cost’ exemption under MEES. It will be interesting to see how the MEES regulations are implemented and whether HHSRS and MEES are used in combination.

So what can be done to help reduce fuel poverty in the PRS? Our research project identified a number of recommendations around improving the implementation and enforcement of HHSRS and MEES, for government (national, regional and local), landlords and their representatives, tenant advice services and the energy efficiency sector. Priority recommendations included:

  • National government needs to ensure that local government is adequately resourced to proactively implement both MEES and HHSRS and could offer guidance and advice on how these services can be implemented as cost effectively as possible.
  • Local government needs to develop a joined-up approach to implementing HHSRS and MEES. National government could assist by issuing guidance and examples of how best to do this.
  • National government should work with the energy efficiency sector to build the evidence base around the potential benefits to landlords of having highly efficient properties, including reduced rent arrears, reduced void periods and increased rental and asset value.
  • National Government should continue to restate the long-term trajectory of the MEES regulations to help landlords understand their long-term requirements and to support the delivery of whole house retrofit approaches, thus minimising disruption for tenants and avoiding multiple interventions by landlords.

There is great potential for both HHSRS and MEES to be effectively implemented and doing so will not only improve the lives of tenants living in some of the worst properties in the country, it will also offer significant economic and wider societal benefits to the UK, including reducing the burden on the NHS, improved productivity and a reduction in carbon emissions.

Notes

The outputs from the research project  include a policy report and a toolkit. The policy report, aimed at policy makers, industry and wider stakeholders, highlights the opportunities to increase energy efficiency and reduce fuel poverty in the PRS, detailing current practice, where there are barriers and what is needed to overcome these, while the toolkit provides practical advice for local authorities on how to ensure they are realising the full potential of the energy efficiency legislation already in place.

[1] With thanks to the Ebico Trust, who funded the research to produce the report and accompanying toolkit.

[2] Energy Efficiency Partnership for Homes (EEPH), Impetus Consulting Ltd, 2008, Tackling fuel poverty using the Housing Health and Safety Rating System (HHSRS): http://eepb.org.uk/KB/Fuel_Poverty/HHSRS_taskgroup/2008_(April)_EEPH_HHSRS_Report_-_Final.pdf

[3] National Energy Action (NEA), Impetus Consulting Ltd and Blooming Green, 2011, HHSRS: Your power to warm homes in the private rented sector National Energy Action (NEA), Impetus Consulting Ltd and Blooming Green, 2011, HHSRS: Your power to warm homes in the private rented sector.

Toolkit: www.eagacharitabletrust.org/app/uploads/2016/03/HHSRStoolkit2014update.pdf

Policy report: www.eagacharitabletrust.org/app/uploads/2016/03/hhsrspolicyreportaug2011.pdf

[4] Written evidence submitted by the Chartered Institute of Housing [PRS 031]: http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/housing-communities-and-local-government-committee/private-rented-sector/written/74252.html

[5] English Housing Survey 2016-17, Headline Report: www.gov.uk/government/statistics/english-housing-survey-2016-to-2017-headline-report

[6] Shelter Cymru, Fit to Rent: https://sheltercymru.org.uk/wp-content/uploads/2015/02/Fit-to-rent-Todays-Private-Rented-Sector-in-Wales.pdf

[7] Fuel poverty figures for 2015, published by BEIS June 2017, Low income/high cost definition: www.gov.uk/government/uploads/system/uploads/attachment_data/file/623108/Fuel_Poverty_Statistics_Report_2017.pdf

[8] Living in Wales Survey, 2008: http://gov.wales/docs/statistics/2009/091130livingwales2008en.pdf

[9] English Housing Survey 2015-16, Private Rented Sector Report: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/627686/Private_rented_sector_report_2015-16.pdf

[10] BRE, 2011 : www.cieh.org/media/1380/the-health-costs-of-cold-dwellings.pdf. Please note that this study is based on BRE’s HHSRS cost calculator, which has since been updated. BRE also undertook additional analysis using their Category 1 calculator, which put the cost of ill health to the NHS between £37 million and £674 million depending on actual SAP ratings and occupancy levels.

[11] Domestic Private Rented Sector minimum level of energy efficiency consultation, December 2017: www.gov.uk/government/consultations/domestic-private-rented-sector-minimum-level-of-energy-efficiency

[12] In a recent answer to a Parliamentary Question, MHCLG stated that they have no information on the level of compliance of EPCs in the PRS. www.parliament.uk/business/publications/written-questions-answers-statements/written-question/Commons/2018-07-02/159568/

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The Warm Arm of the Law: Tackling fuel poverty in the private rented sector

The ACE Research team, working in partnership with CAG Consultants, have published the Warm Arm of the Law, an Ebico Trust funded research project looking at the extent to which the Housing Health and Safety Rating System (HHSRS) and Minimum Energy Efficiency Standards (MEES) are being proactively implemented and enforced by local authorities across England and Wales.

The PRS has grown by over 40% in the last ten years and now comprises 20.5% of the housing market in England, compared to just 10% in 1999 [1], with Wales seeing a similar increase [2]. Figures for urban areas are higher. It is widely accepted that this tenure will continue to expand.

Fuel poverty continues to be a major problem and is particularly acute in the PRS, with an estimated 21.3% of PRS households thought to be in fuel poverty in England [3], and 36% in Wales [4]. Compared with other tenures, the PRS in England has the largest proportion of energy inefficient F and G rated properties; 45.7% of PRS households living in such properties are in fuel poverty [5].

Research highlights that cold related illness from privately rented properties costs the NHS over £35 million per year [6], while best practice approaches have shown that by improving housing standards, savings to the NHS and to wider society can be delivered.

Increasing the energy efficiency of PRS properties is key to reducing fuel poverty and limiting the impact of cold related illnesses on the NHS. However, achieving this in the PRS has been historically challenging; there is little incentive for landlords to invest in the energy efficiency of their properties given that it is their tenants who will benefit from reduced energy bills. It has long been recognised that minimum standards are key to achieving improvements in this sector.

Kelly Greer, ACE Research Director noted that: “There is great potential for both HHSRS and MEES to be effectively implemented and doing so will not only improve the lives of tenants living in some of the worst properties in the country, it will also offer significant economic and wider societal benefits to the UK, including reducing the burden on the NHS, improved productivity and a reduction in carbon emissions”.

The research project has identified a number of recommendations around improving the implementation and enforcement of HHSRS and MEES, for government (national, regional and local), landlords and their representatives, tenant advice services and the energy efficiency sector. Priority recommendations included:

  • National government needs to ensure that local government is adequately resourced to proactively implement both MEES and HHSRS and could offer guidance and advice on how these services can be implemented as cost effectively as possible.
  • Local government needs to develop a joined-up approach to implementing HHSRS and MEES. National government could assist by issuing guidance and examples of how best to do this.
  • National government should work with the energy efficiency sector to build the evidence base around the potential benefits to landlords of having highly efficient properties, including reduced rent arrears, reduced void periods and increased rental and asset value.
  • National Government should continue to restate the long-term trajectory of the MEES regulations to help landlords understand their long-term requirements and to support the delivery of whole house retrofit approaches, thus minimising disruption for tenants and avoiding multiple interventions by landlords.

The outputs from the research project  include a policy report and a toolkit. The policy report, aimed at policy makers, industry and wider stakeholders, highlights the opportunities to increase energy efficiency and reduce fuel poverty in the PRS, detailing current practice, where there are barriers and what is needed to overcome these, while the toolkit provides practical advice for local authorities on how to ensure they are realising the full potential of the energy efficiency legislation already in place.

The project involved desk research, interviews with stakeholders and local authority practitioners and the development of a series of case studies. A steering group made up of the Association of Local Energy Officers (ALEO), the Chartered Institute of Environmental Health (CIEH), the Department for Business, Energy & Industrial Strategy (BEIS), Future Climate, the Local Government Association (LGA) and the Residential Landlords Association (RLA) oversaw the project.

 

ACE and CAG Consultant are very grateful to Ebico Trust for their support for this project.

 

 

[1] English Housing Survey 2016-17, Headline Report: www.gov.uk/government/statistics/english-housing-survey-2016-to-2017-headline-report

[2] Shelter Cymru, Fit to Rent: https://sheltercymru.org.uk/wp-content/uploads/2015/02/Fit-to-rent-Todays-Private-Rented-Sector-in-Wales.pdf

[3] Fuel poverty figures for 2015, published by BEIS June 2017, Low income/high cost definition: www.gov.uk/government/uploads/system/uploads/attachment_data/file/623108/Fuel_Poverty_Statistics_Report_2017.pdf

[4] Living in Wales Survey, 2008: http://gov.wales/docs/statistics/2009/091130livingwales2008en.pdf

[5] English Housing Survey 2015-16, Private Rented Sector Report: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/627686/Private_rented_sector_report_2015-16.pdf

[6] BRE, 2011 : www.cieh.org/media/1380/the-health-costs-of-cold-dwellings.pdf. Please note that this study is based on BRE’s HHSRS cost calculator, which has since been updated. BRE also undertook additional analysis using their Category 1 calculator, which put the cost of ill health to the NHS between £37 million and £674 million depending on actual SAP ratings and occupancy levels.

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Why this fascination with measures?

Parity Projects Managing Director Russell Smith reflects on the energy efficiency recommendations in the National Infrastructure Assessment

The National Infrastructure Assessment, published earlier this week, brings a welcome new perspective on the importance of home energy efficiency.  But it is nowhere near radical enough to deliver the transformation we need.

A key recommendation from the Commission is for the Government to set a target for the rate of installations of energy efficiency measures in homes: 21,000 measures per week by 2020, maintained at this level until a decision on future heat infrastructure is taken.

This is a very significant step change from current activity levels and in that sense is a good thing.  But why this fascination with ‘measures’?  A ‘measure’ doesn’t deliver a fixed energy or carbon saving: this depends also on the context.  A narrative based on measures encourages industry to forget that there are people in homes.  And they matter.

Fixating on ‘measures’ might help to shape a delivery mechanism but it has wholeheartedly failed to excite customers, who react to comfort, health or control.  No customers; no industry.  But if you can get customers excited, they will pay for improvements themselves, if they can (and if the right sort of finance is made available).

Rather than taking a ‘programme delivery’ perspective, why not think instead in terms of asset management?  From this perspective, it is critical to build an infrastructure, competencies and a narrative that provides a plan to all households, and soon.  Whether a single measure is the first activity or the whole house is renovated in one hit, the up-front assessment and design approach is identical.  It shows the householder the journey that they are on, and can be used by industry to illustrate the end-point: the high performance home that delivers what the householder wants.

Will this approach work?  I know it does because we use it for all our customers.

Another Commission recommendation is for the allocation of £3.8 billion of public funding between now and 2030 to deliver energy efficiency improvements in social housing.  More public funding to support investment when the household is not able to pay is very much needed, but why target the tenure that is already performing the best?  Is it because it is thought to be easier, given the procurement capabilities of the landlords concerned?  Taking the easy route may get the money spent, but is it the best way to address the fuel poverty problem?

The Commission wants to see Government continuing to trial innovative approaches for driving energy efficiency in the owner-occupier market. On the face of it a good idea, but when we start talking about ‘early days’ and delivering results in a few years’ time, I start to worry: we need Government incentives to nudge renovation choices sooner rather than later – innovations can accelerate the change as they come in.

Last, but not least, the Commission wants the Government to set out, by the end of 2018, how regulations in the Private Rented Sector will be robustly enforced and tightened over time.  I wholeheartedly agree!  The introduction of MEES to date has been half-hearted at best, with far too many built-in get outs for less responsible landlords.

So; a mixed bag.  But back to that original point about 21,000 measures per week until a decision on future heat infrastructure is taken.  What then?  Whatever the heat infrastructure decision, we must use less.  We need responsible retrofit at scale, starting now and continuing until all our homes are high energy performance, delivering the home environment that we want.

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Indoor Overheating – From the Distant Past to a Cooler Future

Dr Argyris Oraiopoulos writes about the need to re-think how we define, assess and address indoor overheating.

Overheating problems from past centuries and the birth of the overheating criteria

16th October 1834: the ancient Palace of Westminster is destroyed by fire. The temporary replacement formed an experimental chamber where several different, ground-breaking ventilation strategies were tested, for delivery of the optimal thermal comfort conditions for debating. Design and testing was assigned to David Boswell Reid, a Scottish physician and Professor of Practical Chemistry at the University of Edinburgh. Reid’s ventilation system was designed following direct observations of thermometers, located in the chamber, and consultation with MPs during sittings. In summer 1839, Reid’s chief attendant of the ventilation system, Benjamin Riches, was ordered to keep the interior temperature at a level that would not exceed 67°F (19.4°C) – above this, the debating chamber was considered at risk of overheating, as the complaints from MPs would increase significantly1.

Fast forward about 100 years: the development of steel construction allowed a trend towards high-rise office buildings with large areas of glazing. The increased solar gains during summer months, however, increased employee discomfort and led to calls for summertime thermal criteria for buildings.

The studies that followed over the next decades, in assessing and attempting to predict this discomfort in these office spaces, interestingly included spot internal temperature measurements in unoccupied rooms… Parts of the indoor overheating criteria that resulted are still in use for offices but also for homes and hospital wards.

New Insights given by easier and more accurate measurement

Recent technological developments have given us small, low cost and relatively accurate sensors that can be deployed to capture long-term thermal conditions in homes through large-scale, nationwide studies.  At the same time, qualitative data from smaller scale surveys, combined with quantitative data on indoor temperatures, have started to shed light on what constitutes indoor overheating, and how it is perceived in homes across the UK2. These studies have revealed that the variety of temperatures sought by people in their homes in UK homes, are not captured by the past and current definitions of indoor overheating.

Recently, the criteria for overheating in living rooms moved from a static temperature threshold to an adaptive method, but failed to recognise the potential for adaptation in bedrooms during sleep.  Recent studies have confirmed that there are adaptive actions that can be taken to mitigate discomfort during sleep, similar to daytime choices (for example, reducing bed covers, opening windows, using fans), that do not cause significant disruption to sleep patterns. These actions are only beginning to be documented, and have not yet been reflected in overheating criteria or design methodologies.

Is it time to re-think indoor overheating?

Why should we rethink the definition/description of indoor overheating? A number of questions arise for policy makers, researchers and practitioners.

  • The developments detailed above suggest that there is no one-size-fits-all comfort state. There are different expectations and opportunities in homes, offices (and schools) and hospital wards that relate to comfort, productivity and health respectively. Why should there be a one-definition-fits-all when it comes to indoor overheating in all these indoor environments?
  • Summertime heatwaves will undeniably generate high levels of short-term heat stress to those indoors, but chronic, long-term overheating is already an issue in many settings. Are these two faces of the same coin? Are the same stakeholders interested in the impacts of both of these problems?
  • SInce the criteria are mainly applicable to naturally ventilated indoor spaces, why is humidity not taken into account, since it plays a significant role in thermoregulation in the human body?
  • If the definition of indoor overheating is not to be trusted and therefore the risk of overheating often misunderstood and inaccurately identified, then how can one develop and maintain successful policies for the mitigation of the overheating risk?

Are we storing up trouble for the future?

The latest research shows that in UK homes there is an overarching scepticism regarding the risk of summertime overheating. In many instances, it is seen as a one-off, short-term discomfort event that is easily and quickly dissolved3 since the UK has not been getting regular heatwaves on an annual basis.

But the latest climate projections confirm the long-standing predictions of more frequent and severe heatwaves during summertime4. Alongside this, the significant need for more housing, and the requirements of the building regulations are driving construction of small, low ceiling height, air tight flats with limited potential for effective natural ventilation.

Does this mean we are storing up trouble for the future?

These heatwaves can have adverse health impacts, particularly on vulnerable people, and cause significant costs to the NHS.  They can also create an unprecedented demand for instant cooling in homes which, if satisfied by air conditioning units, will increase energy use, with detrimental consequences for carbon emissions and energy security.

The cost of these units has fallen considerably and is now comparable to other products that were once considered luxuries (for example, large screen TVs).  It is not difficult to imagine how a series of hot spells, followed by further price reductions, could drive sales of air conditioning units in a pattern similar to that of large-screen TVs (which have tripled in less than 10 years).

Is there a solution? Suggestions for policy makers, researchers and practitioners

As comfort expectations rise and tolerance of temperatures outside very tight boundaries is diminished, occupants (in homes, offices, schools, hospitals), if not educated and prompt appropriately, will seek to restore their comfort as quickly and as effortlessly as possible. And that is highly likely to involve energy intensive mechanical means.

In the UK, we do not regulate to ensure that the risk of overheating in naturally ventilated spaces is mitigated.  The European Energy Performance of Buildings Directive does however mention the need to reduce air-conditioning demand, since this is a much bigger issue especially in the South of Europe where temperatures often climb above 35ºC during summertime.

Strict regulations for the installation of air conditioning units do exist in some parts of the EU (Switzerland), where one has to prove that the indoor space needs air conditioning as the last resort in providing cooling. These however require strong political will and robust mechanisms in monitoring and enforcing legal actions.

An alternative to air conditioning units is the much less energy intensive solution of ceiling fans and external window shutters/louvres, a combination that has been used in the Mediterranean for many decades now.  Long-running research has shown the benefits of installing ceiling fans and their potential in providing cooling. However, the more passive methods of cooling require more planning ahead and a better understanding of building physics.

In the Mediterranean, this comes from long term exposure to heat and therefore experience. In the UK it must come by other channels such as education, engagement, communication, awareness, research and policy.

  • Education and Engagement

Residents of different indoor environments could be better informed of their passive choices in restoring thermal comfort and enabled to take these choices. Local government has a key role to play here, in engaging with local residents and supporting those most vulnerable to heat.

  • Communication and Awareness

Effective and timely advice is vital if people and businesses are to prepare for heatwaves and hot spells.  Simple heatwave alerts as part of a weather forecast will not prompt enough people to take actions in time. Prevention is a better strategy, and this relates to solar gains, at the building scale and also at the area-wide level.

  • Research

More research is needed to better understand where overheating is leading to discomfort, together with further mapping of vulnerable populations and buildings that are at risk of overheating. This will require the collection of qualitative data in direct combination with quantitative data, in the same fashion as Professor David Boswell Reid did, some 180 years ago.

  • Policy

The Government needs to be aware of the potential growth in the air-conditioning market and consider how this can be regulated. At the same time, it needs to develop and implement policies to improve the energy performance of building envelopes and ensure that landlords and building owners provide passive and affordable methods of cooling. Last but not least, it will need to work with the electricity providers to allow for an economic tariff during hot weather to protect those most vulnerable to increased indoor temperatures who cannot meet their comfort needs through natural cooling.

 

It is almost certain that the UK will be further challenged by future extreme weather events. It is also certain that technical, political, financial and behavioural solutions exist and can be deployed in time to prevent significant increases in electricity demand and a growing summer stress for the NHS, ensuring that the nation’s emissions’ targets are not jeopardised and the health of the population is not put at any further risk.

 

 

  1. Schoenefeldt, H. The Temporary Houses of Parliament and David Boswell Reid’s architecture of experimentation. Archit. Hist. 57, 173–213 (2014).
  2. Morgan, C., Foster, J. A., Poston, A. & Sharpe, T. R. Overheating in Scotland: contributing factors in occupied homes. Build. Res. Inf. 45, 143–156 (2017).
  3. Wright, D. L., Haines, V. J. & Lomas, K. J. Overheating in UK homes: Adaptive opportunities, actions and barriers. Windsor Conference Proceedings (2018).
  4. https://defradigital.blog.gov.uk/2017/03/17/using-climate-projections-in-your-decision-making/

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ACE welcomes aims of ECO3 consultation

Kelly Greer, Research Director at the Association for the Conservation of Energy (ACE) welcomes the aims, targets and aspirations outlined within the Energy Company Obligation ECO3: 2018-2022 consultation.

ACE welcomes the focus on fuel poor households and in particular the extension of eligibility criteria for families and disabled households, the continued focus on rural fuel poverty and the focus on insulation as a primary measure. We also welcome the government’s intention to support the targeting of fuel poor households by sharing data between public authorities and energy suppliers and the potential extension of flexible eligibility for local authorities.

Since the government has proposed to drop the CERO target within the obligation, there is now no longer funding to support the wider decarbonisation of homes. It is critical that Government and industry now work together to develop a wider energy efficiency policy to meet the carbon reduction targets outlined within the Clean Growth Strategy.

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Why ACE supports the Homes (Fitness for Human Habitation and Liability for Housing Standards) Bill

On Friday 19th January 2018, Karen Buck MP’s Homes (Fitness for Human Habitation) Private Members’ Bill will have its Second Reading in Parliament.

Why is this Private Member’s Bill needed?

According to the latest English Housing Survey, 16.8%, approximately 797,000 households, of private tenanted properties have Category 1 HHSRS hazards, these are classed as a serious risk to the occupiers’ health.  There are a further 243,000 social tenanted properties which have Category 1 HHSRS hazards.

That means that over a million homes in the social rented sector and private rented sector have at least one Category 1 hazard, affecting approximately 2.5 million tenants, including children.

This Private Member’s Bill revives a clause which exists in an old piece of legislation, requiring homes to be ‘fit for human habitation’ at the start of the tenancy and to remain so throughout. Extraordinarily, this is a not a protection currently enjoyed by any renter – social or private – in England.

Landlords have responsibilities to do repairs under the Housing Health and Safety Rating System (HHSRS), and from April 2018 Minimum Energy Efficiency Standards (MEES), but there are omissions including, for example, damp and mould caused by the structure of the building. Landlords have to repair the structure of their property, and keep in repair the heating, gas, water and electricity installations, but this only applies where something is broken or damaged.

What does the Bill do?

The Bill aims to complement existing local authority enforcement powers, by enabling all tenants – no matter what tenure they live in – to take action. .

The central aim of the Bill is to make rented homes ‘fit for human habitation’ and applies to all areas of a building ‘in which the landlord has an interest’, including communal areas.

The Bill text reflects the list of 29 hazards from HHSRS, which avoids creating two parallel standards for conditions. This means that additional regulations will not be placed on private landlords (as these are standards they should already be meeting), and as a result the Bill has support from the Residential Landlord’s Association (RLA) and the National Landlords Association (NLA).

The Bill would empower tenants giving them the right to take their landlord to court if they fail to take action to resolve a problem. This is particularly important for local authority tenants, who currently have no truly effective means of redress over poor condition.

Link to the House of Commons research briefing:

http://researchbriefings.parliament.uk/ResearchBriefing/Summary/CBP-8185#fullreport

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ACE’s response to the Mayor of London’s draft London Housing Strategy

Our response to the Mayor of London’s draft London Housing Strategy consultation can be read here. Further details about the draft strategy can be found here.

ACE welcomes the vision and principles of the draft London Housing Strategy and agrees with the Mayor that London’s housing crisis is a barrier to prosperity, growth, and fairness for Londoners.

Improving the energy efficiency of London’s housing can deliver prosperity and growth, by supporting economic growth in the environmental goods and services sector, supporting London’s transition to a zero carbon city; and fairness by lowering energy bills of both new and existing homes and eradicating fuel poverty across the capital. Action to improve energy efficiency can also support activity to improving air quality.

ACE’s response to this consultation focuses on four of the five priorities set out in the draft Housing Strategy:

  • Building Homes for Londoners;
  • Delivering genuinely affordable homes;
  • High quality homes and inclusive neighbourhoods; and
  • A fairer deal for private renters and leaseholders.

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Combatting ‘rogue landlords’

ACE’s response to the Communities and Local Government Committee inquiry: Private Rented Sector: Combatting ‘rogue landlords’ can be read here.  Further details on the inquiry can be found here. A wide variety of organisations have also responded, which can be read on-line here.

Key points in our response

  • Fuel poverty in the private rented sector continues to be a major problem across England and Wales.
  • The Housing Health and Safety Rating System (HHSRS) gives local authorities the power to enforce minimum housing standards related to Excess Cold, thus tackling fuel poverty. However, research has found that HHSRS is not being used nearly as widely or effectively as it could be.
  • Approximately 300,000 properties will be impacted by the introduction of mandatory Minimum Energy Efficiency Standards (MEES) in 2018, however ACE has significant concerns in relation to the effectiveness of the implementation of these regulations.
  • It is essential that both minimum standards are effectively implemented, however there are many obstacles to effective intervention, including limited awareness and resources to implement legislative requirements, and a lack of information to strategically target properties.
  • ACE considers that selective licensing is an important tool in raising both energy efficiency and wider housing standards.
  • Complaint mechanisms are not functioning for tenants facing problems in their homes and tenants fear retaliatory eviction.

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ACE’s response to the Mayor of London’s draft London Environment Strategy

ACE welcomes the vision and principles of the Mayor of London’s draft London Environment Strategy and the ambition for London to be a zero-carbon city by 2050.

We agree that the city’s most pressing environmental challenges are harming Londoners’ health and the city’s economy, and that the current pace of change is too slow. The Mayor highlights that big problems need ambitious responses. Therefore, we would like to see the Mayor’s activity and focus on air quality continue, but also expanded in relation to improving the energy efficiency of buildings, improving the lives and reducing health inequalities of those households that are in fuel poverty, whilst supporting economic growth in the environmental goods and services sector.

Our full response to consultation on this strategy can be found here.

 

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ACE’s response to the Mayor of London’s draft Fuel Poverty Action Plan

ACE welcomes the publication of the Mayor of London’s draft Fuel Poverty Action Plan for London to help support the eradication of fuel poverty across the capital. We agree that fuel poverty remains at unacceptable levels and that it has not received the attention that the issue deserves.

ACE’s response covers four key topics:

  • Supporting the roll-out of borough referral networks.
  • Improving the energy efficiency of London’s homes, with a particular focus on improving standards in the Private Rented Sector.
  • Energy for Londoners.
  • How the Mayor should work with the UK Government.

Our full response can be found here.

 

 

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