HEMS and Social Housing
One of the aspects of the Strategy that has perhaps had less attention than others is that of social housing. In the document there is a small but significant shift in the government's approach to the social rented sector. On page 28 it states that by 2020 "the new Warm Homes standard will help to raise the energy efficiency of social housing from around SAP 59 to at least 70". But are the plans for social housing ambitious or focussed enough?
There are a number of reasons why a Warm Homes Standard and associated target should be welcomed:
- For England it’s a target where there has been no target before, and at 70 it’s a higher figure than the one used to assess fuel poverty under National Indicator 187.
- Furthermore the documents accompanying the strategy describe the Standard as complementing the Decent Homes Standard. Up to now the energy element of housing quality standard in England has provided a rather limited assessment of the efficiency of a dwelling. Now there is a number for social landlords to steer off.
- To provide a realistic prospect of meeting it a wider range of improvements can be considered including solid wall insulation, renewable heat and micro-generation. In turn this is supported by the new energy company obligation to work with social housing providers.
But will this approach work? Simplicity in targeting is to be welcomed, but in the context of improving energy efficiency and reducing carbon emissions it is outcomes that are important. My perception is that the simplifying approach may put this at risk.
A single target of 70 is great as it provides a simple basis for assessment. But is it too simple? The Strategy quotes the English Housing Survey as showing an average SAP of 59 for social housing. This means that the average has to increase by 11 points over approximately 9 years. Sounds like a reasonable approach. But if you check the SAP figure for housing associations on the Tenant Services Authority website, it will tell you the overall 2009 average is 67.9 - only 2.1 SAP points off the target. Now there may be some confusion about whether associations have consistently used the current version of SAP - but will 70 provide enough of a target, and will they be encouraged by this target to improve their properties?
An average target can also be used to hide a multitude of low scoring sins. So while the average target is met it can mask the fact that there may still be many significantly inefficient properties in the stock. A minimum value (perhaps increasing year on year) could be used to combat this.
The limitations of SAP
Then there is the question of the limitations of SAP – it takes no account of where the property is located. Heating a SAP 70 property in the North East costs significantly more than the same property in the South East. So while a simple average is attractive it does not reflect equality in the heating costs of the occupants. The NHER scale was devised to recognise this difference in location.
Similarly setting a SAP target takes no account of actual running costs – so there might still be instances of fuel poverty depending on the property size, number of occupants and any specific energy needs (e.g. caring at home for someone who is ill can require higher than standard temperatures and more laundry). A standard, which is capable of assessing a range of heating and occupancy patterns, could address this.
Will SAP actually encourage investment in the most appropriate measures – particularly in the light of the introduction of Feed In Tariffs. Social landlords may be able to do more to reduce tenants’ fuel bills by investing in renewable technologies – even though the benefit may not be fully reflected in the SAP rating.
Better guidance is required
Finally, the basis of the assessment needs to be clear and explicit. HECA and more recently National Indicator 187 have suffered because such guidance was not forthcoming. This can be addressed by using Energy Performance Certificates. Providing as they do a consistent accredited approach to assessment and lending themselves to being updated to reflect the implementation of improvement work.
So while the Warmer Homes Standard and targeting can only be welcomed it has to be a cautious one, with a number of suggested refinements to ensure it meets its intended aims. What are your thoughts?
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The views expressed in this blog article are the personal views of the author and do not necessarily reflect the views or policies of National Energy Services. When submitting a comment, please be aware of the guidelines provided in our website terms and conditions.