Energy Efficiency Standard for Social Housing: guidance for social landlords

2.0 Developing the EESSH

2.1 A working group was set up in 2011 to develop a draft EESSH for public consultation, including representatives from the Scottish Government, Local Authorities, Registered Social Landlords ( RSLs), the Energy Saving Trust ( EST), the Scottish Federation of Housing Associations ( SFHA), the Glasgow and West of Scotland Forum of Housing Associations ( GWSF), the Convention of Scottish Local Authorities ( COSLA) and the Scottish Housing Regulator ( SHR). The remits, agendas and notes of meetings of the different stakeholder groups are available on the Scottish Government website ³ .

Building up from the case studies

2.2 Draft case studies were produced to profile the most common constructional types and age bands of the housing stock. The age bands represent typical levels of thermal performance for that period, where revisions to building regulations have increasingly improved these levels. The mix of bands also reflects the Scottish House Condition Survey ( SHCS) categories of housing stock. It was recognised that the built form of the dwelling also has a bearing. For a house, this is likely to be a semi-detached, end-terraced or mid-terraced. Detached houses were not modelled as they represent less than 1% of the stock. For flats, modelling was done on top, middle and ground floors. Modelling for the draft case studies was done for both gas central heating and electric storage heating. Further dwellings for example, non-traditional building typologies, which can often be harder (or at least more expensive) to treat were also modelled. The modelling work has also been peer reviewed by external technical experts.

2.3 These modelled case study examples form the backbone of the proposed standard, and for these reasons it was important that the original work was peer reviewed and in effect 'validated'. The peer review was undertaken at the same time as the consultation, so that respondents had the opportunity to tell us what they saw as the 'Harder-to-Treat' dwelling types. This was to show what could be done to improve the energy efficiency of these dwellings.

Other fuels

2.4 Other fuels such as Solid Mineral Fuel (for example coal); Liquid Petroleum Gas ( LPG), Oil and Biomass were also modelled. Selected case study examples, which were more likely in a rural setting (such as semi-detached and four-in-a- blocks) were modelled and compared against EESSH Electric ratings, as an initial proxy, as was the case originally for SHQS.

Consultation process and key findings

2.5 The consultation took place in the summer of 2012. It attracted 86 responses from social landlords and the private sector and others. We have listened carefully to the views of a wide range of stakeholders through both the formal consultation exercise and a series of consultation events. In light of the independent consultation analysis findings ⁴ , and further discussions with stakeholders there is a preference to monitor the proposed standard using the Energy Efficiency ( EE) Rating, rather than the Environmental Impact ( EI) Rating, which was proposed in the original consultation. As improving the energy efficiency of a home, also has a positive effect on the environment, as less energy is consumed and therefore less carbon emissions are produced, it is recognised that we are still addressing climate change.

2.6 We have also looked closely at the views expressed around regulation and the setting of ratings. We have worked closely with the Scottish Housing Regulator ( SHR) to develop a proportionate approach to monitoring compliance with the EESSH. A simplified rating was also requested. We have listened to stakeholders and we have reduced the number of categories and subsets.

2.7 We conducted further detailed consultation with key stakeholders over the second half of 2013 and into early 2014 to test cost assumptions against the anticipated availability of funding for energy efficiency measures. Further feedback from this exercise resulted in several amendments being made to provide assurance to social landlords on financial risk. We recognised the need to introduce, in certain defined circumstances, temporary exemptions from the EESSH. We also agreed to conduct a substantive review of EESSH in 2017 to look at actual progress achieved, and the impact on landlord finances from the UK governments' welfare reform changes and changes to funding provided through Energy Company Obligations ( ECO).

Impact assessments

2.8 Three impact assessments were undertaken to support the EESSH: The Business and Regulatory Impact Assessment ( BRIA), the Equalities Impact Assessment ( EQIA) and the Strategic Environmental impact Assessment ( SEIA).

2.9 The BRIA incorporated a modelling exercise involving a representative number of social landlords. It concludes that implementation of the EESSH over and above meeting the SHQS and Business as Usual ( BAU) programmed upgrades would cost in the region of £310 million to achieve compliance of 90% of all current social housing stock with EESSH by 2020. It also indicates that it is potentially possible for landlords to achieve 99% compliance of all current social housing stock at a cost of around £900m by 2020. Social landlords are eligible for funding through the Energy Company Obligations ( ECO) and Scottish and UK government supported programmes.

2.10 The EQIA shows that it is unlikely any equality groups will be significantly disadvantaged due to the implementation of EESSH. In fact, it concludes that all social tenants, including those with protected characteristics are likely to benefit from the new standard as it aims to improve the energy efficiency of the social housing stock in Scotland. In particular, it has the potential to help those living in fuel poverty as they should be able to heat their homes more cost effectively.

2.11 The SEIA process helped identify where environmental objectives might be affected. It recognised that the implementation of the EESSH would have a positive impact on climatic factors. Other environmental interests assessed in the report relate to the potential impacts on bats, pine martens and birds - It is clear however from the measures already in place to protect these species, including licensing requirements as appropriate, that it is highly unlikely the new standard would have significant environmental impacts on these species.