Sustainability Committee

Inquiry into Carbon Reduction in Wales: Residential Carbon Reduction

Response from Wales & West Housing Association Ltd

General Questions

1. Is the proposed 3 percent annual reduction target by 2011 “In areas of devolved competence” sufficient to enable Wales to make its full contribution to meeting UK-wide targets? If not, what targets should be put in place?

It is unlikely that the 3% annual reduction target will be sufficient to enable Wales to fully contribute to the all UK target without sustained focus and major investment into marketing, initiatives, grant assistance, and infrastructure development (including manufacturing) to enable and support the delivery of savings. However, the 3% target is considerable due to its annual cumulative nature.

2. Should the emission reduction target be based on Welsh consumption, or production, or both (i.e. Should it take into consideration the Carbon Dioxide generated in Wales (production), or the Carbon Dioxide emissions that Wales’ residents are responsible for, regardless of their source(consumption)?

Ideally, the emission reduction target should be based on both consumption and production. However, the inclusion of production would require the regulatory assistance of central government as Wales does not control main stream energy production. This does not necessarily mean that a hybrid approach for production inclusion is not possible by only including renewable technologies in accordance with the aspirations of the “One Wales” agreement – Energy Strategy, Energy Route Map et al.

Issues associated with recording actual reductions include the current inconsistencies in measurement, data collection and compatibility across the various responsible organisations – HECA, EEC, HEES, local authority Building Control/agency building control, plus private upgrade programmes. Therefore, introducing a measurement definition based on pure consumption rather than estimated carbon reduction resolves a number of consistency issues.

Questions specific to household emissions of Carbon Dioxide:

3. What particular challenges does Wales face in reducing Carbon Dioxide emissions from households, and how can these challenges be overcome?

The main challenges facing Wales to achieve Carbon Dioxide emissions reduction include:

Non devolved responsibilities in terms of control and enforcement e.g. building control and energy production – requires Assembly action and canvassing;

Geography in terms of access to the gas network – this is both a challenge and an opportunity in terms of micro renewables;

Age of existing housing stock, including solid walled dwellings – requires grant targeting and possible regeneration schemes;

The target date of 2011 – the preparatory aspects of achieving the target is possibly underestimated and will require management and other resource to ensure delivery and credibility;

The willingness of the industry to grasp the challenge – whilst this challenge is not specific to Wales, saving the planet may be of limited interest in the short term when financial and commercial pressures are here and now!;

Assembly Government ability to enable and fund the necessary infrastructure – difficult to determine the requirement!

4. To what extent has the Welsh Assembly Government been successful in utilising the powers available to it in order to reduce household Carbon Dioxide emissions?

The Assembly Government has been as successful as England in reducing recorded household carbon emissions and has raised HEES funding this year. This is reassuring given that England has greater enabling powers.

The Assembly Government has also been successful in raising awareness amongst householders and the industry although the emissions reduction is difficult to quantify.

In terms of registered social landlords, the historic emphasis on higher standards has delivered emission reductions and the introduction of the EcoHomes assessment model has/will deliver greater reductions than those dwellings only meeting current Building Regulation standards. The achievement of these additional standards does come at a cost and this has viability implications in a commercial land acquisition and development environment when the “One Wales” agreement commits to increasing the supply of affordable housing “by at least 6,500 over the next four years.”

The inequality of imposing additional requirements on registered social landlords and not on private house builders has long caused difficulties and concern for the social housing movement. New EcoHomes Excellent aspirations and zero carbon deadlines has the potential to be very damaging in an increasingly commercially competitive environment if the same requirements are not also applied to private developments.

5. Could alternative targeting of Welsh Assembly Government financial resources lead to greater household emissions reduction than is currently being achieved? If so where could additional resources lead to greatest impact? (Please provide detail to support your evidence)

More resource should be applied to raising the standards of existing private stock, especially the hard to treat homes through simple energy upgrade programmes to achieve a base standard (WHQS level) before using micro generation initiatives. It is been estimated that raising the energy efficiency of 3% of existing stock is equivalent to benefits of 100% annual new build programme.

VAT on WHQS and private housing upgrade works should be reduced to 5%.

6. What examples from other administrations (devolved, UK, and overseas), where other means have been used to achieve reductions in household Carbon Dioxide emissions, could be adopted in Wales under current powers?

A great deal of comparison research has been carried out on approaches adopted by UK, European and other parts of the world and the results and measures should be examined by the Assembly Government as a central body. This will inform the establishment and sharing of best practice and identify pitfalls to eliminate waste associated with knowledge evolution stages. Presumably this will form part of the Route Map and Strategy.

The Low Carbon Buildings Programme has been successful for recipients in England but not so much for Welsh recipients. Accordingly, Wales should consider negotiating an equitable share from central government and running its own programme (similar to the Scottish Community and Householder Renewables Initiative.)

7. In the context of the Government of Wales act 2006, which further means of reducing Carbon Dioxide emissions from households could only be achieved with the introduction of further legislative competence for the National Assembly for Wales

Devolving Building Regulations to the Assembly Government would ensure that enhanced standards could be applied to all new build development and works to existing stock. This would harmonise with the sustainability aspirations/requirements of the local authorities enforced through the planning approval process. This also has the potential to improve whole house energy efficiency for existing stock when making significant changes or improvements (as long as this requirement did not have such an impact that no improvements would be carried out!)

EcoHomes assessment system or a Welsh version of the Code for Sustainable Homes should be a requirement for all new developments.

It should be noted that there are concerns in introducing an alternative set of Welsh requirements and reporting regimes as expressed by the CBI. The CBI wants a cross-border regulatory regime established to reflect business investment cycles so that environmental targets can be better achieved. They also consider that “renewable energy and emissions are well handled within UK and EU proposals and, as such, additional and Wales-specific measures which incur a greater cost burden for Welsh business would be a major concern.”

Any concern needs to be positively addressed to ensure that the introduction of further legislative competence has strong industry support and does not have a damaging effect.

8. If specific Carbon Dioxide emissions targets are to be set for Wales should those targets be subdivided into shares by sector? If so, what share of the total should reductions by household comprise?

Sector targets should be introduced for reducing household emissions and based upon achievability. However, it will be difficult to establish the targets.