Consultation Response – Consultation on a new Social Housing Net Zero Standard in Scotland
Consultation on a new Social Housing Net Zero Standard in Scotland (www.gov.scot)
Closing Date: 8 March 2024
Response submitted by: National Insulation Association
For more information, please contact: info@nia-uk.org
About the National Insulation Association
The National Insulation Association (NIA) represents the insulation industry in Scotland and across the UK with a member base comprised of installers, system certificate holders, and manufacturers who provide a wide range of insulation solutions for homes and buildings. The NIA and its members are fully committed to maintaining and raising standards within the insulation industry.
Questionnaire
To what extent do you support the use of a fabric efficiency rating, based on heat demand, in the SHNZS?
Strongly support
The NIA supports the use of a fabric efficiency rating that goes beyond EPCs to focus solely on the building fabric and how well it retains heat and mitigates unwanted heat gains. A well-insulated and airtight building fabric is critical for maximising the efficiency of heating systems and minimising energy bills for residents. By prioritising fabric efficiency, the standard can better ensure that tenants benefit from clean heating systems, particularly for heat pump systems, which can perform exceptionally well in tightly sealed and well-insulated environments, further enhancing the efficiency and reducing the overall energy consumption of homes.
Of the options presented for the fabric efficiency rating, which one do you support for the new SHNZS?
Option 2
The NIA supports a fabric energy efficiency rating based on space heating demand only, to reduce external influences on the rating such as consumer behaviour. Meeting the fabric efficiency rating is essential to ensure social housing across Scotland is ready for the transition to clean heat. The NIA supports providing a target range to account for harder to treat property types. Option 2 mitigates the obvious issue of social housing providers aiming for the lower end of the range by providing an additional target to reach 71 kWh m2/year or better by 2040. That said, staggering this requirement by allowing a further 7 years to achieve the fabric efficiency rating will negatively impact tenants and cause further disruption, including some who may be living within vulnerable circumstances. The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach reduces the risk that having a target range will disincentivising a best-practice, whole house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.
Are there additional options for the fabric efficiency rating that you think should be included? If yes, please describe these here.
The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach reduces the risk that having a target range will disincentivising a best-practice, whole house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.
What, if any, are your views on how performance against the fabric efficiency rating should be measured?
The NIA advocates for a robust process to measure whether the fabric of homes actually meets its target design efficiency under real-world occupancy to protect residents and ensure that properties are ready for the transition to clean heat. Mandatory and accurate real-world performance monitoring (through sampling) is one way of reducing risk. Social housing providers could also make use of innovative technologies to measure performance which consider user behaviour and occupancy to determine actual energy performance. This will also incentivise high quality retrofit and ensure that residents reap the true benefits of retrofit measures in practice. Social housing providers should engage with tenants as early as possible during the retrofit process to effectively manage and implement this.
What are your views, if any, on the proposal for a minimum fabric efficiency standard?
The Scottish Government have recently consulted on EPC reform, therefore we expect the accuracy of EPCs will improve after the introduction of the new metrics that more accurately reflect the fabric efficiency of a home and support the transition to net zero. This will be further strengthened by the introduction of the Home Energy Model which will result in significantly more accurate and effective EPCs. EPCs take into account the individual property characteristics, whereas using a ‘one size fits all’ list that doesn’t consider property-specific characteristics creates a risk that the list of measures will become a ‘tick-box’ exercise that is irrelevant for certain property types.
It must be recognised and considered that properties have differing energy needs, and it is critical to ensure that residents have access to high quality, accessible advice to make sure that they can make informed choices about which measures are the most suitable for their property.
Should the Scottish Government proceed with a list of measures, we believe that solid wall insulation (IWI and EWI) should also be included on it. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that these homes will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without.
The proposed requirements reflect a commitment to providing warmer homes and lower bills for residents. However, they must also be accompanied by funding and support to enable social landlords to meet them. Therefore, the NIA recommends the implementation of additional support, resource and guidance to effectively deliver the proposed measures.
What, if any, are your views on whether homes should not be relet if they cannot meet a minimum fabric efficiency standard?
The proposal that social housing cannot be relet if the minimum standard is not met by 2028 does incentivise landlords to make the required changes, however the impact of this exacerbating housing shortages must be taken into account.
The proposed exemptions in Section 3.5 do mitigate this issue somewhat, however more could be done to ensure that a higher proportion of hard-to-treat properties receive much-needed energy efficiency measures. For example, rather than exempting properties in circumstances where social landlords share buildings with other tenures – if mixed tenure properties are unwilling or unable to contribute – funding streams, such as the Social Housing Net Zero Heat Fund, could include a percentage of funding allocated for ‘in-fill’ properties to mitigate this. This supports an area-based approach, allowing for economies of scale and addresses communities collectively.
What, if any, are your views on whether ventilation and monitoring strategies should be required where MVHR is not installed?
The NIA supports the proposition that landlords should be required to devise a ventilation and monitoring strategy to accompany energy efficiency interventions in cases where mechanical ventilation isn’t installed.
In particular, there should be a focus on monitoring to provide essential data to identify potential risks and ensure that air quality meets required standards under real-world occupancy – contributing to the well-being, comfort and health of tenants. Effective ventilation, backed up by stringent monitoring, will protect social housing tenants from health risks associated with damp and mould. The PAS 2035 process sets out clear ventilation requirements, hence it is vital that social housing retrofit is carried out by qualified installers subject to PAS standards. This is integral to an effective ventilation strategy.
Enforcing a mandatory ventilation and monitoring strategy would help to mitigate unintended consequences. There should be a clear process in place to ensure regulations are consistent and guidance and support should be put in place to assist landlords with implementing this.
To what extent do you support the need for landlords to have an element of discretion to ensure measures are cost effective and in the best interest of tenants?
Strongly support
The measures installed should always be in the best interest of tenants, and landlords should ensure that appropriate advice and guidance is provided to make sure that tenants are not in any way negatively impacted by measures, particularly financially. This includes considering disruption to tenants. Early and ongoing engagement throughout the retrofit process is crucial to achieve this.
A report issued by BEIS (now DESNZ) highlighted that tenant behaviour and lack of education and advice is a major barrier to social housing retrofit.1 Landlord discretion must be regulated and monitored to ensure the outcome is best for the tenants.
What, if any, are your views on whether targets should be varied by guidance from the Scottish Government in specific circumstances?
The NIA advocates for meeting the higher end of the fabric efficiency rating and incentivising social housing providers to complete all works at once. This is the most effective way to retrofit homes both in terms of cost and quality, and minimises disruption to residents. We would support enforcing the higher end of the range by 2033, in properties where this is cost effective and feasible to do so. This approach mitigates the risk of the target range disincentivising a best-practice, whole-house approach to retrofit in easier to treat properties where this is feasible. Flexibility and/or additional time could be granted in harder to treat properties where meeting the higher end of the range is not cost effective or feasible with the requirement to reach 120kWh/m2/year as a minimum.
For the minimum fabric efficiency standard, The NIA supports including solid wall insulation in the list of proposed measures. This is essential to make sure that solid wall homes are not left behind on the transition to net zero. For many solid wall properties, most or all of the measures on the proposed list will not be relevant, meaning that they will be subject to weaker energy efficiency standards. There is a risk that this will create a two-tiered society whereby those with solid walls will be subject to higher energy bills and colder homes than those without. Insulating solid wall homes will ensure that residents experience lower bills and higher levels of thermal comfort. It will also ensures that all of Scotland’s social housing sector is ready for the transition to clean heat. Further time could be given to insulate solid wall properties given the additional costs and complexities.
1 Department for Business, Energy and Industrial Strategy (2018). What are the Barriers to Retrofit in Social Housing? Available at: Barriers to retrofit in social housing (publishing.service.gov.uk)
To what extent do you agree that the new SHNZS should apply to mixed tenure properties?
Strongly agree
The NIA agrees the SHNZS should apply to mixed tenure properties and that more should be done to ensure that a higher proportion of mixed tenure properties are included. For example, rather than exempting properties in circumstances where social landlords share buildings with other tenures – if mixed tenure properties are unwilling or unable to contribute, funding streams, such as the Social Housing Net Zero Heat Fund, could include a percentage of funding allocated for ‘in-fill’ properties to mitigate this. This supports an area-based approach, allowing for economies of scale and addresses communities collectively.
To what extent do you agree that the new SHNZS should apply to Gypsy/traveller sites?
The NIA recognise that Gypsy/travellers have poorer outcomes than the settled population across a range of outcomes. These homes have been notoriously hard to treat within government funding streams due to a lack of clear guidance. To protect the most vulnerable residents, a solution must be found to include Gypsy/traveller sites in the SHNZS and further consultation should be sought on this.
What are your views on the timetable for introducing the new SHNZS?
Ensuring the required advice, guidance and support is in place in advance of standards being implemented is crucial to success. Therefore, the NIA accept the timetable for introducing the new SHNZS, to provide adequate time to consider enforcement, build resources and guidance and sufficiently consult and engage with a range of stakeholders. Timelines are already very tight, with minimum fabric efficiency standards due to come into force in 2028. Hence, it is critical that the Scottish Government implements the SHNZS as soon as possible to give social housing providers and the retrofit supply chain sufficient time to meet the regulations. Delays to this timeline would cause significant impact and hinder progress towards crucial net zero targets.
