Calon Cymru Network argues that the best use of public funding to improve energy efficiency of dwellings in Wales is to concentrate on insulation, so that demand for heating falls.
Calon Cymru also opposes the over-emphasis on Energy Performance Certificates to prove dwellings’ energy credentials.
Energy Performance Certificates are awarded after a tick-box exercise leading to standardised calculations. Property owners can easily give false answers to energy assessors, and I have proof of this. For example, a local property’s EPC is graded D, although it has no insulation, single glazed draughty windows and a large hole in the main door frame. The assessor noted that the property has an efficient mains gas boiler, however there is no mains gas available and the heating system was non-functional. There is no come-back against the assessment firm because it was dissolved several years ago.
Calon Cymru believes that there is a role for public money to improve the housing stock, particularly to improve insulation. The government could issue vouchers for purchasing insulation. In 2017-18, according to the Welsh Housing Conditions Survey, 53% of all dwellings, approximately 711,250, had a Standard Assessment Procedure (SAP) score below 65. This score is towards the top of EPC grade D, which extends from 55 to 68. Not all these homes have poor levels of insulation, but many will. Bearing in mind our reservations about the accuracy of EPCs, we would propose £400 vouchers for every dwelling, to be spent on insulation, draught-proofing, and essential repairs to the exterior fabric. This would cost £536.8 million, a realistic sum for such a crucial endeavour.
We support simple systems such the cleanest-burning wood stoves, such as EcoDesign and Eco-Ideal, using renewable fuel and keeping emissions to a minimum. Demand for wood fuel would boost woodland management in Wales. Electric boilers (using renewable power) and solar collectors could replace fossil-fuel boilers. These are cheaper to buy and install than air or ground source heat pumps. While there is public money to contribute to heat pump installations, qualification is complicated and bureaucratic, and may not work at all for people who lack online access. In addition, heat pumps are much better suited to new builds than to retrofits in properties that were not built with energy efficiency in mind.
There are about 80,500 dwellings in Wales rated F or G for energy performance, the bottom of the scale. These are across all tenures, and almost certainly a fair proportion are in the private rented sector, which totals about 180,000 in Wales. Of these, some 104,400 have SAP scores under 65. It is already against regulations to let a property with an EPC below E, but the shortage of rental homes is so acute that tenants will accept properties that make inefficient use of energy. Rather than removing these inefficient homes from the market, the Welsh Government should target grants at landlords of these properties, tied to a commitment to let at a specified rent during the amortization of the investment. Landlords who refuse to improve properties could be obliged to have the work carried out, and a charge placed on the dwellings concerned.
Socially rented homes are on average more energy-efficient than for any other tenure type. Only 31% of socially rented homes in 2018-18 had a SAP score under 65, compared with 58% for owner-occupied and privately rented homes. Yet in ‘Homes Fit for the Future: the Retrofit Challenge’, the investment proposed for improving social housing averages £24,000 per home, compared with £4,700 per privately rented home. This would place private tenants at a disadvantage. Many would like social housing, but the supply is inadequate. A proposal to place a charge – a Property Assessed Clean Energy (PACE) mechanism – on properties that receive funding for energy improvements, and to recover the debt through council tax, would be unfair on tenants because they are generally liable to pay the tax, but the funding would have been provided to the property owner.
Calon Cymru regards as unrealistic a plan for all dwelling to be rated ‘A’ by 2050, unless the assessment methods and criteria change to focus on total emissions per year and are weighted to give credit for low embedded carbon over each building’s expected lifespan. Similarly, a target for all homes to reach EPC level ‘C’ by 2030, and for all social housing and households in fuel poverty to be rated ‘A’, will not be the best use of available resources. Social housing is already more energy efficient than other tenures, and households in fuel poverty do not necessarily equate to homes that are profligate energy consumers. Households are mobile, properties (except for caravans) are fixed.
As outlined above, Calon Cymru Network proposes a focus on measures to limit the need for home energy, measures that are simple to administer and avoid bureaucratic hierarchies, and measures that are not tightly tied to the flawed format of the Energy Performance Certificate.