Written evidence submitted by Mears (HEA0124)

 

  1. Mears provides and manages 17,000 homes for local and central Government and is also responsible for keeping 750,000 social housing homes in the UK in good repair. Mears has 5,400 employees and a footprint across the country. Our social housing renovation and retrofit programme helps future-proof housing to comply with government legislation, creating sustainable homes and improving tenants’ lives.

 

  1. This submission has been produced in partnership with ECD Architects.

 

Discussion

 

  1. The Government has set an ambitious target to cut carbon emissions to net zero by 2050. Housing contributes around a fifth of all greenhouse gas emissions, largely from the oil and gas used for heating and hot water. Around 10% of these emissions come from the social housing sector.

 

  1. Building new homes to higher environmental standards is obviously part of the solution, but 80% of the homes we will live in in 2050 have already been built. This means that making social housing more energy efficient and decarbonising existing homes will be critical if the sector is to cut its carbon footprint and the UK is to achieve its net zero goal.

 

  1. As a provider of housing management and maintenance services, Mears is a source of positive influence in our sector with landlords, tenants and supply chain partners. The UK has set ambitious targets around carbon reduction, and housing is at the forefront of this. Social Housing stock specifically has to achieve a step change in its energy efficiency by 2030.

 

  1. The implications for local authorities and housing associations include a requirement to retrofit existing social housing stock to ensure it meets new carbon reduction standards.

 

  1. There is however a lack of coherent government strategy on how this will be achieved. This strategy must contain science-based standards, built from an independent evidence base, and ensure Local Authorities have targets to ensure they are achieving the required pace of retrofitting.

 

  1. These local plans should be produced in consultation with local stakeholders, residents, businesses, community groups and NGOs. However, in order to avoid unnecessary bureaucracy and an overly complex landscape, central government should produce draft templates for plans, so Local Authority plans across the country are set to the same standard.

 

  1. The government should also set a base level of minimum energy performance certificate standards in different types of property. This should include the Passivhaus standard for all new buildings. This would ensure that robust targets are set, and if regulated correctly, adhered to. Examples such as Minimum Energy Efficiency Standards (MEES) demonstrate the ability for this to be implemented, but this could be rolled out across all tenures where reasonable, practicable and cost effective.

 

  1. Raising the bar for the standard of new buildings is a simple and practical change to make.  Most new homes are built to low-mid range EPC band B now, which are likely to require some form of retrofit before 2050 if we are to achieve our net zero targets as a nation.

 

The planning system

 

  1. One of the biggest barriers to retrofit work is the planning system. This is especially difficult in many heritage homes, especially those in conservation areas, where restrictive planning rules prevent essential retrofitting work. According to research from LETI, this could be the case for up to a quarter of UK homes.

 

  1. These rules both slow down retrofitting projects and increase the costs.

 

  1. The government could ease some of the confusion by producing central guidance around Permitted Development Rights. The government should also reduce and relax planning rules around retrofitting, to include more sustainable technologies within Permitted Development Rights.

 

Other Barriers

 

  1. While companies like Mears are carrying out retrofitting there are some barriers slowing the speed of delivery, which the government could address.

 

  1. The lack of an overarching government strategy and clear national low energy targets mean there is a lack of local government attention on this issue in some parts of the country. Confidence in the sector is growing that there is a funding pipeline in place for the work, however, recent policy changes within each round of funding have hampered long term investment.

 

  1. Like in many other industries, the costs of both labour and materials are rising; however, cost caps of projects and grant funding have not yet increased to acknowledge this. Indeed, in many projects the aim is often to tackle the ‘worst first’ homes with the grant; these often cost far more to retrofit, but the grants are not always sufficient.

 

  1. By reducing VAT on energy efficient products, including DIY and home improvement products, the government would help to reduce the overall financial burden of retrofitting. 

 

  1. There are other steps the Government should take, such as early adopter incentives, to drive scale production modelled on previous schemes such as the feed in tariff. They should also work with the financial sector to develop and expand innovative products to individuals – such as green mortgages.

 

Skills

 

  1. One of the consequential issues of the pipeline and timelines for projects being short, is that it is difficult to upskill the workforce to a high enough level, in the short time frame. Longer timeframes would assist in this, as would industry specific training programmes backed by regional funding, and the implementation of the recommendations of the Green Jobs Taskforce.

 

  1. The government should commission a review into the short delivery windows for projects.

 

EPC and standards

 

  1. We do not believe the current EPC framework helps consumers make decisions on the transition. While they are useful as a guide, real world performance is often significantly different than predicted by the EPC rating. A higher standard of performance measurement is required to give consumer confidence and personalise recommendations.

 

  1. For most purposes the EPC is reduced to a single letter, which is entirely based on the cost of running the home. This does not help consumers compare environmental impact. Some EPCs suggest entirely inappropriate upgrades, with unrealistic capital costs and bill savings.  This does not help with consumer decision making, nor those trying to implement more detailed and appropriate measures.

 

  1. Simple government produced guidance could enhance customer choice and decision making, with the Energy Advice Service available to offer bespoke solutions based on individual circumstances.

 

  1. There is also the need for greater understanding of the linkages between certain construction types and PAS2030/2035 rules.  At the moment, some non-traditional house types are at risk of being left behind.

 

  1. This is evidenced by instances where a weatherboarding façade is required under the installation of External Wall Insulation.  At present, this type of material is deemed as ‘cladding’ under PAS2030:2019, and not permitted. However, in many instances, achieving this façade is required for planning permission being granted. The system is technically correct for the house type, however it will not fall into the category of EWI at present – and therefore not qualify for funding via the Social Housing Decarbonisation Fund or other government grants.

 

  1. The Government should implement new Passivhaus standards for new homes, whilst taking a pragmatic approach for listed buildings and buildings of historical importance.

 

August 2023