Developing an Energy Efficiency Standard for Social Housing: consulation analysis

2 Introduction

2.1 This report analyses the responses to the Scottish Government's three month consultation on the Energy Efficiency Standard for Social Housing (the standard), which ran until 28 ^th September 2012.

Background to the consultation

2.2 The consultation document was developed with the Sustainable Housing Strategy Group, whose members include leading housing, fuel poverty, environmental and consumer interests. The development process included meetings and a workshop as well as discussion of an early draft of the consultation document.

2.3 The consultation was undertaken as part of the development of the Government's wider Sustainable Housing Strategy ( SHS) which aims to provide for warm, high quality, low carbon homes, and contribute to the establishment of a successful low carbon economy. The standard is designed to improve the energy efficiency of social housing and so help reduce energy consumption, fuel poverty and the emission of greenhouse gases. The standard will build on the work landlords have achieved in delivering the Scottish Housing Quality Standard ( SHQS), and so further improve the energy efficiency of the social rented housing stock.

2.4 The proposed Energy Efficiency Standard for Social Housing has been based on modelling work and through consultation with working groups. The proposed standard is to establish a minimum Energy Performance Certificate ( EPC) rating, which the government proposes should be the Environmental Impact ( EI) score which every social rented dwelling will be required to meet by 2020. The standard will be different for different dwelling types and fuel types.

2.5 A baseline energy rating, based on the building type and space heating fuel, has been derived for a set of standard or common building types covering a large majority of the social housing stock, assessed using the Reduced data Standard Assessment Procedure ( RdSAP). This will enable the Scottish Government to measure reductions in emissions against the baseline.

2.6 It is appreciated that not all dwellings fit with these standard types, and alternative approaches for calculating the standard for non-standard dwellings are proposed.

2.7 The purpose of the consultation document was to seek views on the following:

• Work done to date to improve energy efficiency in the social housing sector;
• Why the Scottish Government thinks a new energy efficiency standard is necessary;
• Options considered for an Energy Efficiency Standard for Social Housing;
• The financial implications of introducing a new standard;
• How progress towards any new standard would be measured and monitored; and
• The timetable for implementation.

2.8 In addition, a series of consultation events were run by a number of stakeholder groups across the country (and supported by Scottish Government). The accompanying equalities impact assessment was published on the Scottish Government website.

The response

2.1 In total, 86 responses were received to the consultation. Respondents have been grouped into five broad categories, drawing on the information provided by respondents to question 4 of the respondent information form ( RIF) ² . The simplified classification into these respondent types was agreed with Scottish Government. The breakdown of those responding is shown on Table 1 and described further below. The organisations within each category are listed in Annex A.

Table 1: Simplified respondent groups

Simplified Category	Number of respondents	Percentage of respondents
Local authorities	22	26%
Housing associations	42	49%
Private sector	10	12%
Other organisations	9	10%
Individual	3	3%
All respondents	86	100%

• Local authority sector - Local authorities and representative organisations (Convention of Scottish Local Authorities ( CoSLA) and Association of Local Authority Chief Housing Officers ( ALACHO))
• Housing associations sector - Housing associations and representative organisations (Scottish Federation of Housing Associations ( SFHA)and the Glasgow and West of Scotland Forum of Housing Associations ( GWSF))
• Private sector - Businesses and their representative organisations, such as the Federation of Master Builders and the National Federation of Roofing Contractors
• Other organisations - Such as third sector organisations, representative organisations for professionals, a statutory body, and other organisations.
• Individuals

2.2 Table 1 clearly shows that the bulk of the responses to the consultation were received, as might have been anticipated, from local authorities and housing associations, together with their representative bodies. The next largest group or respondents was the private sector, a number of which were organisations with an interest in environmental products.

2.3 Not all respondents responded to each question. However, with a small number of exceptions - notably questions 30, 24, 25 and 22 - the general level of response was high, typically well over 70%. The overall level of response to each question is shown on table 2. Typically respondents from the housing association sector and the local authority sector answered all or most questions. The response rates from the other respondents varied, with some covering most of the questions, others focusing on key questions of particular interest to their organisation. Typically, the views expressed in the report reflect this profile. For the sake of brevity in the reporting, we have only highlighted significant variations from this pattern.

Table 2 - Response by question

Question	Number of responses	Response rate	Question	Number of responses	Response rate
Q1	76	88%	Q16	68	79%
Q2	65	76%	Q17	73	85%
Q3	70	81%	Q18	71	83%
Q4	80	93%	Q19	76	88%
Q5	61	71%	Q20	72	84%
Q6	62	72%	Q21	70	81%
Q7	71	83%	Q22	57	66%
Q8	76	88%	Q23	73	85%
Q9	76	88%	Q24	40	47%
Q10	70	81%	Q25	48	56%
Q11	74	85%	Q26	70	81%
Q12	74	86%	Q27	62	72%
Q13	61	71%	Q28	66	77%
Q14	64	74%	Q29	67	78%
Q15	71	83%	Q30	28	33%

Methodology

Administration of the consultation

2.4 The Scottish Government circulated the consultation document widely, via its standard circulation list and posted it on their website. In addition, a series of consultation events was supported by Scottish Government policy officials. Respondents were invited to respond to the questions using the standard questionnaire available on-line. Most respondents used the questionnaire provided. A small number of responses were received in non-standard form - for example as email text, reports and letters; these were analysed where they were accompanied by a RIF. In some cases, consultees' responses did not conform to the questionnaire structure/numbering, or responses on similar topics were given under a number of different questions. The data processing stage sought to collect all the comments and views relating to each question together; so that they could be reported accurately and succinctly.

2.5 All responses were received by Scottish Government, given a unique number and passed to Liz Shiel Associates ( LSA) for checking and processing. On publication of the report LSA's copies of the responses will be deleted.

Analysis

2.6 The analysis was undertaken in two stages.

2.7 First the analysis of the responses to the closed parts of each question -the yes/no or helpful/unhelpful components - was undertaken. Those respondents using the questionnaire for their response had a tick box facility for the closed questions. In some cases, respondents did not tick the box (or their preferred variation, such as deleting the unwanted box), but wrote their preference in the comments box below. If the respondent clearly wrote the text of their preference in the comments box, this was included with quantitative analysis. However, if the respondent did not tick the box/clearly state their preferred option, we did not input a value for the closed question based on an interpretation of their comments for that question.

2.8 The data were entered into an Excel spreadsheet and around 15% of the inputted data were rechecked for errors. The tables produced from the quantitative data are presented in Annex B, with summary tables incorporated as appropriate throughout the report.

2.9 The main focus of the analysis was qualitative, concerned with understanding the range and nature of respondents' views, reflecting the nature of the consultation exercise. An analytical framework was developed, based on an initial review of a cross-section of responses to each of the questions. The analytical framework identified the key themes and issues for each question. This enabled us to set up a matrix for each question within which we were able to systematically read and analyse each response; identifying and exploring the themes, key issues, cross-cutting issues in more detail. The analytical framework was flexible, and could be modified as new themes or key issues emerged as the analysis progresses. In the final stage of the analysis, where appropriate, the information from the quantitative analysis was integrated with the qualitative analysis.

Consultation events

2.10 The consultation was supported by a number of events attended by Scottish Government policy officials. These will be reported separately.

Structure of the report

2.11 The rest of the report is structured as follows

• Chapter 3 contains the summary quantitative data and the emerging themes from the analysis of the consultation responses.
• Chapter 4 contains emerging cross-cutting themes
• Annexes contain a list of respondents and the tables from the quantitative analysis.