Developing an Energy Efficiency Standard for Social Housing: consulation analysis

4 Conclusion

4.1 A number of general themes emerged during the study.

4.2 Overall, respondents tended to agree that generally the standard was achievable at a reasonable cost, although detailed costings have yet to be produced and translated into asset management plans by landlords. Nonetheless, clear concerns were expressed about achieving the standard in some specific types of stock and locations: typically hard-to-treat stock (for example solid wall/hard to fill cavity properties), multi-storeys, listed building/conservation areas, and properties not on the gas grid. At this stage it is not yet clear what the standard will be (and how it will be set) for these properties. Some landlords raised the possibility that otherwise sound stock may have to be disposed of where it proved too expensive to bring up to the standard.

4.3 There were real concerns about funding. The transition to new funding approaches should be underway shortly, but details of funding levels are still not available; while the shifts from grants to loans and from payments to householders rather than to landlords were not welcomed by landlords. The impact on overall funding levels and budget scheduling is uncertain but respondents do not expect increasing funding, and landlords generally expect to bear the brunt of the higher costs themselves. Many noted the constraints on increasing rents to support such expenditure - committed expenditure, commitments to reduce fuel poverty and the impacts of forthcoming welfare reform.

4.4 Respondents welcomed the modelled case studies, which set out the impact of different energy efficiency improvements, as well as the likely cost of installation for the most common house types. They were in accord with proposals to produce further case studies for non-traditional/hard to treat properties and other fuel types. However, some queries were raised about the accuracy of the costings data within the case study and around the assumptions used to underpin the 1990 baseline.

4.5 Respondents were also in broad agreement with the monitoring arrangements as set out in the document, not least because of the level of continuity with existing systems. The core datasets ( EPCs) and methodology ( SAP/ RdSAP) were familiar to landlords and were generally considered fit for purpose. However, the data requirements are potentially considerably more onerous than is currently the case under SHQS, and several respondents requested that these be clarified/reviewed. Respondents welcomed the proposal that the SHR be responsible for performance measurement, although there was some confusion as to how the logistics will be handled until the Social Housing Charter is revised. There was also agreement that a series of interim milestones would enable effective monitoring of progress to the 2050 target. However, there were mixed views on how best to achieve this: to set all the milestones at the start to provide a firm basis for business planning; or to set the milestones on an incremental basis so that they are informed by progress to date, technological developments and relative fuel prices.

4.6 Respondents were supportive of the government's carbon reduction objectives but were clear that in many cases tenants' priorities were around energy efficiency and, in particular, reducing fuel costs. As organisations, many were concerned with delivering measures that did not compromise their fuel poverty objectives and make tenants worse off overall; generally their preference was that the improvements should result in an increased level of thermal comfort for the tenant without a rise in rent. There were some concerns that the financial impacts could be greater on some groups, such as vulnerable groups who spend more time at home and who have low incomes, as well as people living in properties with low target ratings/properties granted exceptions.

4.7 A key issue facing landlords is delivering improvements in mixed tenure properties/multi-tenure estates. Many report difficulties securing co-operation from owners with respect to SHQS works. The decline in grant funding following the introduction of the scheme of assistance was seen as a contributory factor. Key concerns for landlords hoping to secure opt-in from owners for the standard were that limited grant funding would be available (although other funding may be) and that some works would be costly. A common view was that extending the standard to the private sector would be helpful.

4.8 A number of respondents raised questions regarding whether maintaining their stock to the standard will be a legal requirement and, in particular, whether landlords will be permitted to let properties that fail to achieve the standard. The proposals contained within the document are for a set of targets to inform investment planning not the definition of a new condemnatory standard.