An AECB consultation response
This document was written in response to a NICE (National Institute for Health and Care Excellence) 2014 consultation on producing guidelines for health authorities on tackling excess winter deaths and illnesses. It was written (mainly) by me, on behalf of the AECB, teaming up with Severn Wye Energy Agency and the STBA (Sustainable Traditional Buildings Alliance) – who also contributed information.
While at the time of this consultation the deleterious impact of cold living conditions on health were well known – prompting the consultation – poor indoor air quality was less discussed.
Yet of course, air quality can be very poor in cold homes: people will block out any draughts they can – including the intended fresh air supply from a ventilation fan or vent – especially if they are in fuel poverty. This only increases the risk of condensation and mould – already high in a dwelling with cold, uninsulated surfaces. And more and more evidence is piling up of just how bad mould in particular is for people’s health and wellbeing. Continue reading “Cold is not the whole story – what the health services need to know about housing”
Like many others, I am horrified that the government has scaled back aspects of the Energy Company Obligation mid-programme. You can read about some of the immediate, alarming consequences of this in a report from Inside Housing here.
However, as I’ve said before, it seems to me that long-term it makes little sense to restrict the national retrofit programme to what can be funded via a charge on energy bills. In summary, this is why:
- Retrofit is about more than energy bills, it’s about health, education, social welfare and common decency. And about energy security and cutting emissions.
- Because of the state of our housing and therefore, the scale of the need, a high spend is required.
- Because of the scale and the range of the benefits, a major retrofit programme would bring tangible revenue savings to a range of bodies such as those tasked with improving economic, health, social welfare and educational outcomes, and delivering on our carbon targets.
- Paying for retrofit through energy bills is regressive, hitting the poorest proportionally hardest, even at current spending levels.
- The scale of the spending needs to expand many-fold. This would ramp up the regressiveness. In effect, every household, including the poorest, would be paying a substantial chunk of the costs for NHS, social welfare etc via their energy bills. This is not only likely to be politically untenable, it also undermines the accepted approach to progressive taxation in this country.
- The creation of a third party obligation, ‘leaving it to the market’ to decide what to deliver on the basis of a very simplified understanding of costs and benefits, cuts informed stakeholders out of the equation. It excludes them from them any meaningful say over priorities, responsiveness to changing needs, and quality of interventions.
- It also ignores the ‘beneficiary pays’ principle: health, education and welfare budgets would all benefit considerably, on the back of bill payers.
*The ECO recognises only two parameters of benefit, presumed carbon savings (calculated via RdSAP), and “affordability” again, calculated via RdSAP.
This is by way of an open letter to DCLG – which I sent as a covering letter to my response to (questions 1&2 of) the allowable solutions consultation – see previous blog
“I believe the whole idea of (1) “zero carbon” and (2) defining this or any standard not by how well the subject of the standard performs, but how many other people can be bribed to perform well on its behalf, is dreadfully misguided. Continue reading “Allowable solutions – who are they trying to kid?”
Plenty of scorn has been poured on the way that the zero carbon homes target has been watered down, then watered down again, as if it were a homoeopathic remedy for climate change.
Others, notably Nick Grant and Doug King, have led the charge against the very concept of zero carbon buildings as being an illogical concept that diverts construction from what it could be doing best — and I cheerfully count myself among their followers.
However, on the particular point of the current government consultation on the Allowable Solutions element of “Zero Carbon Homes”, I do think it is worth engaging – as there is an opportunity to make the arguments that high fabric standards should be at the heart of the zero carbon policy. Who can say how long the Zero Carbon Homes policy will last? – however, the better the fabric standards we have at the core of it, the better placed we’ll be to replace it with something more sensible.
I have had a look at parts of what DCLG is consulting on, and describe and comment on what I found, in the article below.
Download Article on Allowable Solutions Consultation October 2013 (pdf)
The article also contains the links to the DCLG consultation documents.
STOP PRESS! Doug King has shared his response to this consultation, making the case very thoroughly that “offsetting” energy use and carbon emissions from housing, by reducing energy use and emissions in other sectors, is a nonsense. Those other sectors should be making those cuts anyway – all selling them off as “allowable solutions” does is to pick off the low-hanging fruit from another sector, making it more expensive for them to do what they need to do. The net effect would probably be to reduce energy use an emisissons LESS than you would if proper energy and carbon standards were applied to housebuilding in the first place.
Read his response here: