Energy Efficiency Standard for Social Housing post-2020 (EESSH2): consultation analysis

2040 Vision

The consultation paper suggests that by 2040 poor energy efficiency should be removed as a driver for fuel poverty in social housing and as far as reasonably practical all social housing should be carbon neutral. This vision should reduce fuel costs for tenants and maximise the energy efficiency potential of the social housing stock.

This approach supports the vision set out in the Energy Efficient Scotland Route Map, that by 2040 our homes and buildings are warmer, greener and more efficient, and will also contribute to emissions reduction targets.

Comments on the EESSH 2040 Vision

Question 11 - Do you have any comments on the EESSH 2040 Vision for
(a) poor energy efficiency to be removed as a driver for fuel poverty and for
(b) social housing to be carbon neutral?

(a) poor energy efficiency to be removed as a driver for fuel poverty

Some respondents noted their agreement with the vision for poor energy efficiency to be removed as a driver for fuel poverty. Further comments were that everyone should be able to afford to heat their home and that if EPC B, or even EPC C, is achieved across the stock then homes would be energy efficient.

A small number of those who agreed with the vison raised queries, such as whether it might be possible to meet the vision before 2040. Similarly, others thought 2040 is too late and suggested the timescales be shortened. An alternative date proposed was 2032.

However, other respondents had concerns about the vision. For example, while the aspiration to remove poor energy efficiency as a driver for fuel poverty is commendable, it will be challenging, or is not realistic. Reasons given were high costs, a lack of appropriate technology and a lack of options for upgrading stock. It was also felt that the new definition of fuel poverty:^[3]

…fails to recognise the importance of the rural Minimum Income Standard despite repeated requests from many rural high fuel poor.
Housing Association respondent

As at previous questions, there was a concern that meeting the vision would simply result in replacing fuel poverty with rent poverty. An associated proposal was that the vison might be achievable if the Scottish Government can secure and enable the distribution of sufficient funding.

Other ideas for how landlords could be supported to remove poor energy efficiency as a driver for fuel poverty were:

• Providing a clear and realistic goal for poor energy efficiency.
• Bringing organisations working in different areas together to assess progress and to promote knowledge sharing.

It was noted that actual energy use is influenced by a wide variety of issues including household make up, education, needs and budget. It was thought that informed heating and energy use decisions by tenants will be required, and there was a call for the Scottish Government to ensure that appropriate help and advice is made available to tenants.

The difference between fuel poverty and poor energy efficiency was noted, with a view expressed that energy efficiency alone will not tackle fuel poverty. Factors such as low income were noted as contributing to fuel poverty and it was felt that encouraging people to switch energy providers and tackling energy costs will also have a role to play. On the latter point it was noted that the cost per unit of energy is not in the main within the direct control of social landlords, and that:

….it is highly probable that by 2040 unless (there is) significant market reform that the cost of energy will be as or perhaps more beyond the reach of many RSL customers.
Housing Association respondent

It was also reported that tenants may choose to self-disconnect and it was suggested that consideration be given to a minimum temperature within the social rented stock, with tenants charged through their rent for that minimum standard to be achieved.

(b) social housing to be carbon neutral?

Some respondents noted their support for the vison for social housing to be carbon neutral by 2040:

Agreed 100%, it is the only way to go to take direct action on the global climate platform.
Individual respondent

A smaller number thought that, while the aspiration to be carbon neutral is commendable, it is very challenging, or is not realistic in practice:

The aspiration is commendable. Whether it is achievable will be heavily reliant on the funding the Scottish Government is willing to commit and enhancements in technology.
Local Authority respondent

Further reasons given were:

• The characteristics and age of much of the social housing stock, and particularly stock owned by local authorities, may make reaching the target difficult or impossible.
• If the carbon cost of the materials used to upgrade properties is taken into account, the vison becomes undeliverable.
• Energy supply will be the primary driver. Gas is by some margin the main heat source at present, and improvements will be dependent on any future UKG announcements on the decarbonisation of gas grids and the use of hydrogen.
• As yet, landlords are not taking a joined-up approach to the market place.

Other concerns about being carbon neutral by 2040 were:

• The consultation paper suggests that after every possible endeavour has been taken, approximately 60% of social housing stock might meet the 2032 EPC B target. This would indicate that carbon neutral is unlikely to be a universal standard by 2040.
• It will be very costly and would have to be funded through tenants' rent. It was also suggested that the number of new properties being built would have to be curtailed.
• The carbon footprint of many social housing landlords will be infinitesimal compared to homes in the private sector and commercial properties.

One proposal was that being clear as to what is meant by carbon neutral, and what is meant by reasonably practical, could encourage or support landlords to become carbon neutral.

Further queries were whether 'embedded carbon' from the construction of the building is to be considered, and whether being carbon neutral can be delivered at a national strategic level by ensuring all electricity generated and consumed in Scotland is from green or low carbon sources. On the subject of carbon neutral green energy, it was proposed that electricity generated from renewables needs to be recognised as such.

Other ideas as to how landlords can be helped to meet the vision were:

• Setting out a clear vison so that landlords and the supply chain can plan for future works.
• Removing interim targets and having a single target of 2040, thus allowing landlords to invest to meet that target. An alternative perspective was that a 2032 review to assess technological updates would be welcome.
• Ensuring the link is made to neighbourhood and estate plans.
• Making the work part of a wider housing investment strategy. With particular reference to tenement stock, it was proposed that fire safety, layout, facilities and noise insulation should also be considered as part of a single investment strategy.
• Looking at 'whole house' solutions that, whilst more expensive in the short term, can offer savings for both landlord and tenant over a longer period.
• Consideration should be given to the issues faced by remote rural Scotland such as lack of mains gas and a poor supply chain.
• Making funding available.
• Taking a national approach to tenant engagement and education on this topic.

It was also suggested that:

…a more balanced aspiration may be around 'off-setting', through appropriate planting or other activities to sequester carbon and reduce the impact of emissions.
Local Authority respondent

Finally, it was pointed out that there is a tension between the two elements contained within the vision: that the improvements required to remove poor energy efficiency as a driver for fuel poverty and those required to make social housing carbon neutral are not necessarily the same. It was thought that the Scottish Government should be clear on which element is the most important and that clarity on this would be critical when they are considering the cost-effectiveness of delivery measures.