Scotland's Sustainable Housing Strategy: Analysis of Responses to 'Homes that Don't Cost the Earth' Consultation

1 Analysis of Responses: Vision

1.1 Question 1 seeks guidance on the vision and objectives for the Sustainable Housing Strategy:

Q1 Are the vision and objectives as set out in sections 19 and 20 appropriate for Scotland's Sustainable Housing Strategy?

1.2 Almost all respondents answered this question or made relevant comments in a non-questionnaire response (91%). A large majority answered 'Yes' (80%), with strongest support amongst the local authority (100%) and RSL groups (79%). Nearly half offered generally supportive comments and the WWF campaign response welcomed the Strategy's vision for "warm, high quality, affordable, low carbon homes." However, concerns about implementation were expressed by two thirds of respondents.

1.3 Key issues were: energy supply and energy costs related to fuel poverty; funding, impact on sales and private renting; scope of sustainability strategy and ambition; need to emphasise behaviour change; and technical aspects of improvements to buildings.

1.4 Energy supply and energy costs related to fuel poverty RSL and 'other' group respondents suggested that the strategy should address reliance on fossil fuels and peak oil issues, while a private sector organisation suggested that promoting mains gas was not in Scotland's long term interest. The Energy Saving Trust called for the NRP to include advice on income maximisation and fuel bill reduction. Some highlighted the need to influence energy companies' pricing and advice to customers. Views on the fuel poverty target varied: some suggested removing it from the list of objectives because price increases create a moving target, while others suggested increasing funding to meet the target; private sector and 'other' group organisations suggested that the strategy should include consideration of post-2016 avoidance of fuel poverty.

1.5 Funding, impact on sales and private renting Respondents pointed to the need for significant investment for existing housing. Several questioned reliance on the Green Deal and ECO, and a few feared that the schemes might disadvantage rural homes. Some RSLs felt they must prioritise scarce funds for housing maintenance rather than energy improvement. There were calls both to impose standards on private landlords, and to change rent-setting and valuation processes so that landlords and developers get a return on their investment in energy efficiency.^[1] Some private sector respondents were concerned that rising energy-related building standards may deter investment in new build, and reduce the availability of rural affordable housing, whilst the priority should be improvements to existing buildings.

1.6 Scope of sustainability strategy and ambition Respondents suggested expanding the strategy to cover: water efficiency, waste of materials, embodied energy and life cycle analysis, fire safety, and planning and transport issues. Some considered the proposals to be optimistic because transforming markets would require major cultural change. Others called for higher targets, suggesting: a requirement for an average EPC rating 'B' in 2030; a cut in housing emissions by 42% rather than 36% to compensate for other sectors; for the milestones set out in the first report on proposals and policies (RPP1) to be updated in the second report (RPP2); and a call for Government commitment to the Sullivan report recommendations.

1.7 Technical aspects of improvements to buildings Professionals highlighted the need for appropriate ventilation levels to avoid condensation due to insulation and consequent damage to buildings and occupant health, while private sector respondents called for awareness that properties should be in a good state of repair ahead of energy efficiency improvements.

1.8 Emphasise behaviour change There were some calls for education about efficient energy use, including support for house-holders to avoid the 'rebound' effect, and for smart metering to help vulnerable people to understand energy use.