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

Use of New Technology

The current EESSH Guidance for Social Landlords states that if landlords are satisfied that an innovation provides tangible benefits for energy efficiency and is in the best interests of tenants, they can consider a measure which, on paper, does not meet the relevant EESSH rating. Landlords must be satisfied that they have robust evidence to support this decision.

This approach is proposed to continue through EESSH2. Additionally, as with other energy efficiency measures, it is proposed that when implementing any new or innovative approaches, effective monitoring and evaluation is crucial in assessing/measuring the effectiveness of an intervention. To ensure a robust evidence base is developed, such assessment must be standardised and independently analysed where possible.

The consultation paper also noted that tenants should be involved and empowered as part of this monitoring process.

Views about the proposed approach to recognising new technology in EESSH2

Question 10 - What are your views about the proposed approach to recognising new technology in EESSH2?

Some respondents noted their support for the proposed approach, with further comments that the approach will give landlords the leeway to try new technology. The importance of taking advantage of emerging technologies and energy supply models which benefit tenants was also noted:

We support the recognition of new technology, particularly where this can reduce energy costs for households.
Third sector respondent

The relationship between new technology and the SAP was highlighted:

…it is not clear in the consultation how the installation of new technologies would assist RSLs to attain EESSH2 standard if it is not recognised by SAP methodology.
Housing Association respondent

There was a concern that the use of EPC scores could actively discourage the use of new technologies, and in response it was suggested that new technology that is proven to work should be recognised through the SAP. A building component manufacturer or services respondent noted their frustration that their:

…products and their performance have been robustly evidenced to reduce carbon emissions and assist alleviating fuel poverty for individuals, yet this approach does not attract the recognition within SAP that it warrants.
Building component manufacturer or services respondent

There were a number of SAP-related issues about which clarification was sought. These were:

• The extent to which new technologies that are not SAP listed are acceptable, including the likely energy or carbon reduction percentage sought as proof of effectiveness.
• What will be deemed to be robust evidence in terms of proof of savings. It was suggested that there must be an agreed method before landlords can invest with confidence.
• Whether multiple, complementary interventions could be used as a cumulative improvement.
• Whether measures which are not recognised could be funded under Energy Company Obligation 3 (ECO3) or Home Energy Efficiency Programmes (HEEPS).

Ideas about how the proposal might be taken forward were:

• If new technology fitted is shown to provide affordable warmth but is not SAP accredited, a property should be given a pass and not an exemption.
• Having regular technology updates for the RdSAP and/or an interim method of allowing the use of new technologies that are not recognised in RdSAP.
• Recognising the role of low carbon fuel types, particularly renewables.

However, there was also a concern that any deviation from SAP as the default mechanism for measuring performance against EESSH would be problematic and lead to inconsistency across the sector.

Other issues relating to the use of new technology were: robust monitoring and evaluation of the effectiveness of the technology will be key, as will standardisation of approach to assessment and evaluation. The consultation paper's reference to a 'standardised and independently analysed' assessment of the effectiveness of these interventions was noted and was taken to mean that third parties would be involved in the assessment. A specific proposal was that the Scottish Government should continue the process of assessing new technologies through the British Research Establishment and Appendix Q. It was also suggested that tenants should be involved in any testing, through tenant-led inspections for example.

Respondents also identified other ways in which they thought landlords could be helped or encouraged to make use of new technology:

• Support and guidance should be provided. It will be important to encourage a collaborative approach and the sharing of good practice, for example through guidance produced. A specific proposal was the development of peer groups, including RSLs, to share experiences and guide future investment.
• Funding should be provided. Specifically, there should be seed funding and support for small to medium sized landlords to encourage these providers to try new technologies they have been unable to access thus far.
• Ensuring that the necessary Wi-Fi is in place to support the delivery and monitoring of new technologies.
• Giving consideration to difficulties faced by, and the limited opportunities available to, rural, remote and island communities.

It was also thought that information on any innovative technologies that have been installed should be made available to the sector, and that a 2032 milestone review could look at how technological advances have helped in reaching the required standards.

Other comments about the use of any new technologies were:

• It will be important to ensure they are easy to use, for example by providing user guides and avoiding the use of overly complicated settings and controls.
• Educating tenants about the use of any new technology will be key. There is too much focus on new technology and its theoretical performance, and not enough on supporting tenants to buy and use energy wisely.

There was a concern about 'experimenting' with money raised from tenants, with smart meters cited as an example of technology that may have only a negligible impact on household energy consumption.

A conservative approach to allowing exemptions for new technologies was proposed, with these limited to:

• Technologies requiring substantial area-level interventions and where a reasonable timescale for completion is set out.
• Interventions where the innovation is process-based, such as the application of new technologies in hard-to-treat properties where the proposals and justification for the exemption include long-term on-site measurement, and monitoring and evaluation of the technology.
• Other new and innovative technologies or products where the proposals and justification for the exemption include long-term on-site measurement, and monitoring and evaluation of the technology.