Developing an Energy Efficiency Standard for Social Housing: consultation
This consultation seeks views on the proposed Energy Efficiency Standard for Social Housing (EESSH) to further improve the energy efficiency of social housing in Scotland.
10. Replying to the consultation and list of questions
10.1 This paper is intended to stimulate further discussion, particularly among social landlords and tenants. We would welcome your views and will take them into account in deciding whether to introduce a new energy efficiency standard for social rented housing and, if so, what form that standard should take.
10.2 The intention is for any finalised standard to set out the required rating or list of measures that need to be met for the main different house types and to provide guidance on potential measures to install, as well as indicative costs.
10.3 Through this consultation, we would welcome your views and comments on the work done so far, including:
- The proposed national standard for the energy efficiency of the social rented housing stock;
- How the standard should inform the setting of investment plans;
- How to benchmark and measure progress in delivering the standard;
- The draft modelling typology showing how different Scottish house types could be improved to meet the proposed standard.
10.4 Social landlords' housing stock differs across Scotland, with urban and rural situations and each with its own thermal properties. We would therefore welcome a wide range of responses from landlords across the country reflecting in their specific circumstances and the impact of the proposed standard on them.
10.5 A list of all the questions in the consultation document is set out below. Please let us have your comments by 28 September 2012. Please use the respondent information form and consultation questionnaire for your response. Please fill in the respondent information form at the beginning of the questionnaire as this will make sure we treat your response in the way you ask. If you ask for your response not to be published we will treat it as confidential.
10.6 This is published as a separate Word document on the website (under 'Associated downloadable documents'). You can save the form as a file on your computer and return to us at eessh@scotland.gsi.gov.uk. Or, fill in a hard copy and send to:
Angus Macleod
Housing Sustainability
Highlander House
58 Waterloo St
Glasgow
G2 7DA
You do not need to answer every question unless you want to. We welcome all responses.
10.7 If you have any questions about responding to the consultation, please contact eessh@scotland.gsi.gov.uk or call 0141 2712476.
10.8 If you give permission for your response to be made public, and after we have checked that it contains no material which could damage someone's reputation, we will make the response available to the public in the Scottish Government Library by 26 October and online by 02 November. You can make arrangements to see the responses by contacting the SG Library on 0131 244 4552. We can also copy them and send them to you. However, we may charge you for this service.
10.9 Please be aware that we are governed by the Freedom of Information (Scotland) Act 2002 and so would have to consider any request made to us under the act for information relating to responses made to this consultation exercise. Please be aware that we are governed by the Freedom of Information (Scotland) Act 2002 and so would have to consider any request made to us under the act for information relating to responses made to this consultation exercise.
Summary of consultation questions
| Question | Page |
|---|---|
| Question 1: Do you have experience, or know of, social landlords acting as 'pioneers' in addressing energy efficiency? Question 1(a): If 'yes', please provide details, including any web links/contact details you may have. |
14 |
| Question 2: For landlords, what is the greatest cause of SHQS exemptions in your stock? Is there anything that the Scottish Government could do to assist in reducing exemptions? | 14 |
| Question 3: What has been your experience in improving properties in mixed tenure estates? Question 3(a): If you have developed solutions to work with owners and/or private sector tenants, please provide details. | 15 |
| Question 4: The Energy Efficiency Standard for Social Housing will directly affect a diverse group of social sector tenants who have individual needs and experiences. In your view, is improving the energy efficiency of social rented housing a priority for tenants? Yes/No Question 4(a): If 'yes', are the suggested 'potential benefits' broadly the right ones? Are there any others you would suggest? Question 4(b): If no, why is this? How would you suggest we increase tenant awareness of the importance of energy efficiency? |
16 |
| Question 5: Do you consider any particular equality groups will be at significant risk as a result of this new policy? If so, please outline what measures you consider appropriate to minimise risk. | 17 |
| Question 6: Do you think the implementation of the Standard will cause an undue financial burden on any particular equality group? If so, we would welcome your views on what action could be taken to minimise that burden. | 17 |
| Question 7: What else would you suggest to help tenants better manage their energy consumption? | 17 |
| Question 8: Do you think that example case studies will be helpful or unhelpful in taking forward the Standard? If you think they are helpful: Question 8 (a): Are these the right range of dwelling types to be represented as case studies? Question 8 (b): Are there any other types (including hard to treat) that you would like to be included as a case study? Yes/No Question 8 (c): If yes please state type and say why you think they should be included? |
20 |
| Question 9: What are your views on using the SAP/ RdSAP methodology for regulating energy performance in the social rented sector? | 21 |
| Question 10: Do the 'Baseline: 1990 Measures' accurately reflect the energy efficiency performance of dwellings at that time? Yes/No If not, please provide details. |
23 |
| Question 11: Are the suggested improvements in the 'Further Measures' and 'Advanced Measures' columns of the case studies realistic and feasible? Yes/No Question 11 (a): Please provide further explanation of any measures that you think should not be included within the modelled case studies. Question 11 (b): Please provide further explanation of any measures not currently included in the case study modelling that you would like to see included? |
24 |
| Question 12: Taking into account the reasons above, do you agree that establishing a minimum Environmental Impact Rating for the main dwelling types is the most practicable format for the standard? Yes/No. If not, please explain why. |
26 |
| Question 13: If you think that the standard should be a minimum Environmental Impact rating, do you think that there should also be a safeguard that the dwelling's current Energy Efficiency rating should not reduce? | 26 |
| Question 14: In assessing your stock against the proposal for a new standard for social housing, do you foresee any significant challenges in obtaining individual property details across your stock? Yes /No If yes, please explain why. |
26 |
| Question 15: Do you think that the ratings above are suitably challenging? Yes/No If not, please give explanations why not and suggest more suitable ratings. |
28 |
| Question 16: Do you think the suggested energy efficiency rating for electrically heated detached homes and bungalows undermines the SHQS? Yes/No. Please explain your choice. | 28 |
| Question 17: What are your views on whether all social rented dwellings should be heated by gas, electricity or renewable heat sources by 2030? | 28 |
| Question 18: Do you think that either of the options above should be reconsidered? Yes/No. If yes, please explain which option you prefer and why. |
29 |
| Question 19: Do you agree that the standard should apply to all individual homes and not be aggregated across a landlord's stock? Is this practicable? | 29 |
| Question 20: Do you agree that the approach to unusual dwellings outlined above could offer a reasonable way forward for applying a standard to these dwellings? Question 20(a): Do you agree that the percentage reduction should correspond to Climate Change targets and be set at 42%? Yes/No. If not, at what level do you think the reduction should be set that will be achievable but provide a meaningful contribution to the improved energy efficiency of social rented housing? |
31 |
| Question 21: Do you think that there should be exceptions to the proposed energy efficiency standard? If so, how should they be treated? | 31 |
| Question 22: Are there any other relevant sources of funding that can help social landlords improve the energy efficiency of their stock? | 36 |
| Question 23: Given the range of financial assistance available to landlords, do you agree that the standard can be achieved without disproportionate cost? If not, please explain why. | 36 |
| Question 24: We see an opportunity to advance gender equality in the creation of jobs to undertake the retrofitting works in industries that have traditionally been male-dominated. Your views on how we can maximise gender equality in job creation would be welcome. | 36 |
| Question 25: Are there any other data sources you could suggest to monitor the proposed energy efficiency standard? | 39 |
| Question 26: Would you welcome the SHR monitoring the proposed standard both in the interim period and longer-term or would you prefer an alternative body to carry out this role? If so, who and how? | 39 |
| Question 27: Are there any other costs associated with monitoring landlords' progress towards the energy efficiency standard? | 39 |
| Question 28: Should there be regular milestones to measure progress towards 2050? If so, what dates would you suggest? | 40 |
| Question 29: Do you agree that setting the longer-term milestones should be deferred until progress towards 2020 can be reviewed? | 40 |
| Question 30: Do you consider there to be any further opportunities within the Energy Efficiency Standard for Social Housing to promote equality issues. If so, please outline what action you would like us to take. | 40 |
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