Energy Action Scotland Response to “The Energy Efficiency and Micro-Generation Bill Proposal” by Sarah Boyack MSP

Introduction

Energy Action Scotland (EAS) is the Scottish charity with the remit of ending fuel poverty. EAS has been working with this remit since its inception in 1983 and has campaigned on the issue of fuel poverty and delivered many practical and research projects to tackle the problems of cold, damp homes. EAS has worked with both the Scottish Executive and the UK Government on energy efficiency programme design and implementation. EAS is a member of the Scottish Executive’s Fuel Poverty Forum and was previously on the Scottish Executive’s Central Heating Advisory Group.

EAS welcomes this consultation paper and is supportive of the need to continue to have energy efficiency and warm, dry, affordable to heat homes at the front of the drive to eradicate fuel poverty, and to limit the impact that the housing sector has on the environment. This proposed bill would significantly reduce the instance of fuel poverty and further prevent future homes from the susceptibility of it. EAS recognises that a great deal of progress has been made since the Scottish Parliament was brought into being and that the range of initiatives introduced by the Parliament has gone a long way to raise both public and political interest in fuel poverty and home energy efficiency. However, as stated in the consultation document, more must be done.

General Comments

Fuel poverty saw a dramatic downward push between 1996 and 2002 with some 452,000 households being taken out of fuel poverty according to the Scottish House Condition Survey 2002. However, in that period only 15% of households were removed from fuel poverty by means of energy efficiency measures, while households were removed by the reduction in fuel prices, and 50% were removed by increases in household incomes. Since 2002 fuel prices have risen steeply and, based on Community Scotland’s figures*, EAS has calculated that this has resulted in some

* Source: Fuel Poverty in Scotland –Further Analysis of the Scottish House Condition Survey published April 2004.

140,000 Scottish households have been taken back into fuel poverty. To prevent an on-going fuel poverty ‘see-saw’ households need to become more energy efficient thus reducing their exposure to the changes in fuel price. A major means of reducing energy demand is by better insulation but for many Scottish homes this is not a viable option due to their built form. It is therefore necessary that other means to reduce consumption from the grid is found for these homes. EAS welcomes and supports the Green Micropower proposals.

Specific Comments

The following specific comments are given in order of the questions outlined in the Consultation paper.

1. What do you consider are the benefits of the legislative approach in promoting small scale renewable energy production in both existing buildings and new developments?

EAS is supportive of the need to introduce legislation which would amend the Scottish building standards and promote the uptake of micro-generation in existing dwellings. New buildings should be required, via the building standards, to produce a set percentage of their overall energy demand from micro-generation technologies. EAS would suggest that this percentage be set at 15% of demand. Builders would be able to reduce the overall demand for energy within the building by increasing the thermal efficiency of the building to match or exceed the building regulations in force. All new buildings have a Standard Assessment Procedure (SAP) rating which shows the indicative energy use of the building; the builder would then be required to calculate how 15% of this indicative energy demand could be achieved from micro-generation. The higher the insulation standards, the less demanding the micro-generation requirement would be.

For example, a home with a three bedroom house in Glasgow with a SAP rating of 65 would require an indicative energy demand of 71 GJ/yr for its space and water heating whereas a similar home with a SAP rating of 90 would only require an energy demand of 53.13 GJ/yr. Based on the home generating 15% of its own energy demand through renewable of micro-generation technologies, the first home would require to provide 10.65 GJ/yr while the second home would only require to produce 7.97 GJ/yr. A simple technology like the solar twin hot water system would be capable of providing 3.6 GJ/yr while a Swift turbine would be capable of producing 10.8 GJ/yr giving a combined total of 14.4 GY/yr ie almost double the requirement of 15% for the more efficient home.

Having these technologies built in when the house is under construction would reduce any associated costs. While streamlining the planning process to allow technologies such as these to be either exempt or fast tracked would support the growth of these products and the industry required to install them.

While this approach to changing the building standards would have impact on all new dwellings it would do little to increase the take up of micro-generation in existing dwellings. Further legislation would be needed to set local authorities HECA*-like targets for the total number of homes within their area which would be capable of delivering a percentage of their overall energy demand by micro-power. This of course would need to be resourced by grants and other fiscal incentives to generate action by householders. 

2. What disadvantages, if any, do you think there might be with this approach?

EAS can see no real disadvantages, however, it is aware that any such legislation would not be popular with house builders and with local authorities given the existing burdens placed upon them. If the required financial support was not made available to support the delivery of targets then they would simply become meaningless and unachievable. 

3. What are your views on the following specific measures as outlined in the paper?

i amendment of building standards;

EAS has consistently called for building standards to not only be increased but increased to a level that will ‘fuel poverty proof’ homes. EAS is therefore very supportive of this proposal.

ii setting targets and annual reporting of progress;

Targets for local authorities must be carefully set. Local information on energy use has already been calculated by establishing a 1996 base load and no account of changing base load has been

* HECA – Home Energy Conservation Act

used for reporting mechanisms such as HECA. While a local authority may take into account demolition of homes, the base load will not change to take into account new homes built within the local authority boundary. So a simple percentage target would require the establishment of a new base load which may change every year as new homes are built.

A more effective target would be to have a percentage of all homes within the area having a percentage of their energy demand produced by micro-generation by a certain date. This target/requirement must be backed up with resources at both a national and a local level. A criticism often made of HECA is that no additional resources were given to local authorities and therefore the results from HECA have been very hit and miss, with some local authorities achieving far more than others.

Annual reporting can become very onerous and over-burdensome, as was seen in many English local authorities’ HECA reporting. The production of the report became the focus of the work rather thannot the achievement of targets. EAS’s view is that biennial reporting, as with Scottish HECA, reporting would be more practical.

iii encouragement of local authority measures;

Local authorities have a vital role to play in promoting the role that micro-generation has to play. As providers of public buildings and services they can both stimulate the growth in the market by having micro-generation installed in both new and existing buildings, schools, libraries, swimming pools and local authority offices.  Local authorities have power over local planning guidelines and can actively promote national and local initiatives. Scottish local authorities, as landlords, control around 30% of all homes, homes which they repair and maintain. They have substantial investment programmes for fabric repairs and improvements and these could be harnessed to ensure effective delivery of micro-generation measures to their own housing stock. 

iv administrative and financial incentives.

Undoubtedly the Scottish Community and Householders Renewables Initiative (SCHRI) programme has gone some way to raising the public awareness of micro-generation in Scotland. The programme has been oversubscribed and is failing to keep up with public demand. Due to the costs associated with the installation of micro-generation, little market growth would be possible without the provision of grants similar to the SCHRI. 

4. Please elaborate on any views you might have on any existing small scale renewable energy policy initiatives, north and south of the border, and how these might relate to what is being proposed.

There are many good examples of initiatives both north and south of the border that have failed to make micro-generation a mainstream activity due to inadequate funding and from a failure to learn from their successes. A prolonged and consistent approach is required to bring micro-generation into the mainstream of energy conservation and supply. The SCHRI is to undergo a review of its funding and EAS would hope that this would allow for an expansion of the scheme as it would be an ideal vehicle to act as a launch pad for the proposed Bill. The Borough of Woking has also provided an excellent example of Planning, setting targets for the building industry.

5. What in your view would be the financial costs, if any, of what is being proposed?

There may be some additional costs to new homes where the introduction of micro-generation technologies would be in addition to the planned costs. However, this is the same when any amendments are made to the building regulations; builders are required to use more energy efficient measures or means to achieve the standards. These costs are passed on to the homeowner, but better standards in energy efficiency will make the home less costly to run, therefore the homeowner will recoup their outlay in the long run.

For existing buildings the installation and purchase costs of the micro-generation technology will again be an additional outlay. But here too the reduced running costs of the home will be off-set against the direct costs to the occupier. In addition, streamlining the planning process should have a positive impact on local planning and reduce costs within local authorities.

6. Do you consider there to be any equalities issues raised by what is being proposed? If yes, please elaborate.

EAS does not see any issue of equality.

In Conclusion

EAS is very supportive of the need to bring forward legislation that will both tackle fuel poverty and increase the energy efficiency of Scotland’s homes. EAS believes that micro-generation has an important role to play in this and is happy to support the measures outlined in this consultation.