Developing an Energy Efficiency Standard for Social Housing: consultation

8. Measuring and monitoring progress of the energy efficiency standard

This chapter looks at:

• The Scottish Social Housing Charter and the potential role of the Scottish Housing Regulator
• The available data sources for measuring progress towards the Energy Efficiency Standard

The Scottish Social Housing Charter

8.1 Social landlords and their tenants have recently contributed to the development of the first Social Housing Charter. The Charter sets the standards and outcomes that all social landlords should aim to achieve when performing their housing activities. The Charter was approved by the Scottish Parliament on 14 March 2012 and came into effect from 1 April ⁴² .

8.2 Whilst the Charter doesn't have a specific reference to the energy efficiency standard, it does make clear that social landlords should be thinking about improvements beyond the SHQS to provide even warmer homes for their tenants.

Social landlords manage their businesses so that:

tenants' homes, as a minimum, meet the Scottish Housing Quality Standard ( SHQS) by April 2015 and continue to meet it thereafter, and when they are allocated, are always clean, tidy and in a good state of repair.

This standard describes what landlords should be achieving in all their properties. It covers all properties that social landlords let, unless a particular property does not have to meet part of the standard. Beyond SHQS, landlords should be looking for cost-effective ways of achieving higher energy-efficiency standards for their properties, to provide warmer homes for their tenants and help to meet climate change targets.

During this Charter's lifetime, the Scottish Government will consult on higher standards. If adopted, these new standards will form part of the next Charter.

8.3 The energy efficiency standard will form part of the next Charter, and therefore be included in future annual monitoring returns that landlords provide to the Scottish Housing Regulator ( SHR - see below for more detail). However, this is not likely to take place until 2017-18 at the earliest and the standard is not currently included in the returns. Some form of data collection will be required in the interim period to monitor progress towards the standard.

Data sources

8.4 The main possible data sources which could help monitor the proposed energy efficiency standard include the Scottish House Condition Survey ( SHCS); and the Home Energy Efficiency Database ( HEED), as well landlords' annual returns to the Scottish Housing Regulator.

8.5 At present, all EPCs which are produced for existing dwellings are lodged on the Energy Saving Trust's Home Energy Efficiency Database ( HEED). HEED is designed to help monitor and target carbon reduction and fuel poverty work. It is an activity database hosted by the Energy Savings Trust, which tracks house-by-house energy efficiency characteristics. Social landlords can use this to upload EPCs when dwellings are re-let. Also, when suppliers undertake relevant work they are supposed to enter this into the HEED activity database. As an activity database it is useful, however this only represents the self-reported work, which is not necessarily all the relevant work undertaken. It may be possible to work with social landlords to stress the importance of data uploading. The percentage coverage varies widely by housing attribute, with attributes like property age and type being far better populated than attributes like microgeneration technologies installed. More details can be found at the EST website http://www.energysavingtrust.org.uk/Professional-resources/Existing-Housing/Homes-Energy-Efficiency-Database. A bespoke database is being developed which will allow EPCs for non-domestic buildings to be lodged. This facility will help to deliver a number of Government policies which are using EPCs as an energy measure - Green Deal, Renewable Heat Initiative. The data held will be instrumental in developing future policies.

8.6 The Scottish House Condition Survey ( SHCS) is a continuous sample survey designed to provide data that is representative of the household. This is the data source tracking the overarching SHQS progress. The SHCS will therefore continue to provide a strategic measure on an annual basis. SHCS also provides energy per dwelling, energy per m ² , emissions from space and water heating and lighting as well as total emissions by fuel type. SHCS data is suitable for use as a baseline analysis. More details can be found at the SHCS website: http://www.scotland.gov.uk/Topics/Statistics/SHCS/LA0810

The Scottish Housing Regulator

8.7 The Scottish Housing Regulator ( SHR) is an independent body and it will carry out its functions according to the Social Housing Charter. The SHR continues to be responsible for monitoring SHQS compliance. Within this there is an energy efficiency element and social landlords are already reporting progress to the Regulator. There is therefore a logical argument for the independent SHR to monitor the proposed energy efficiency standard, as annual returns are already made to the Regulator to report progress. This will continue in the form of the Annual Return on the Charter ( ARC). For future versions of the Social Housing Charter, it would be possible to include the energy efficiency standard. For these reasons, discussions are ongoing with the SHR to ask if it would consider monitoring the standard on behalf of the Scottish Government.

Question 25: Are there any other data sources you could suggest to monitor the proposed energy efficiency standard?

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?

Costs associated with monitoring

8.8 As the SHR will continue to monitor SHQS compliance, there is a case that costs can be minimised to all parties if the Regulator also monitors the new energy efficiency standard.

8.9 In addition to the submission of annual returns, social landlords also incur the costs of generating and lodging an Energy Performance Certificates ( EPCs) for new lets, where a valid EPC does not exist. This is a legal requirement, in which case these costs would be part of existing business running costs.

8.10 The cost of generating (as opposed to lodgement) of an EPC for a dwelling is around £30. The actual cost of EPC lodgement itself is minimal ⁴³ , and landlords may decide to do this, even when not required to do so.

8.11 The capacity to generate energy assessments using RdSAP software may be an option for some social landlords, particularly if they have the technical capacity to do this. Many social landlords are training their staff to undertake EPC assessments, as this could be a more cost-effective option, rather than outsourcing.

Question 27: Are there any other costs associated with monitoring landlords' progress towards the energy efficiency standard?