Care & Repair Cymru have responded to the Welsh Government Consultation ‘Decarbonisation of housing: decarbonising the private housing sector’. You can view our full written evidence here.
What is decarbonisation?
Decarbonisation means to either increase the reduction, or the full removal, of carbon dioxide (CO2) from our atmosphere. To ‘decarbonise housing’ means to stop as much CO2 as possible getting into the atmosphere through poor housing. Decarbonisation measures for homes include analysing the energy use of a home, heating upgrades and solar panels.
What is the Optimised Retrofit Programme?
The Optimised Retrofit Programme was created under the Fifth Senedd, and aimed to take a whole-house approach to decarbonising existing homes across Wales. This means looking at the building materials, the geography of the home and the people in the home, and making sure that the initiatives that are suggested to improve the home also benefit the family and the location. This scheme is still in its learning and adapting phase – currently, the Optimised Retrofit Programme is running in three phases, with phase 2 running from 2021-2022, which does not include owner occupied housing. We have asked for the clarification of plans for phase 3, to enable us to be in the best position to assist with the rollout of the Programme to our client base.
Care & Repair Cymru’s view
Care & Repair believe that decarbonisation of the current housing stock is beneficial to the public and the climate of Wales. It is a strategy that can, if rolled out correctly, ensure that homes that are at the worst level of disrepair, have vulnerable occupants or those in the most severe of fuel debt, get the long-term, whole-house support they need.
Care & Repair are of the opinion that:
- The current rollout of the scheme does not tackle ‘worst first’, and instead aims to target low-hanging fruit and homes that are the simplest to retrofit and decarbonise
- Those on the lowest incomes, with the most vulnerable families or with the highest fuel debt are not being targeted adequately
- There is currently no plan for the long-term effectiveness of these decarbonisation efforts to be measured, or the current success rate of these
- The scheme is currently only being carried out on a very small number of homes with very similar specifications, so there is little guarantee that the leaning gained from these retrofits will be applicable to the wider housing stock
- Older people and vulnerable households have not been considered when needing to retrofit their homes
- The upheaval of moving homes whilst the project is underway may deter many from wanting to undertake retrofitting
- Specific access needs will need to be considered when retrofitting a home that belongs to or is lived in by someone with a physical disability
Summary of Care & Repair Cymru’s PRIMARY recommendations:
- For the Optimised Retrofit Programme to be carried out on a wide range of existing homes of different ages, locations, construction types and energy efficiency ratings, to assess its suitability on the wide range of dwelling types
- For Welsh Government to release an interim report of retrofit effectiveness, that includes a full data set and explanation as to the types of houses that have been targeted under the Programme
- For the ‘worst-first’ approach is targeted at the four individual groups mentioned, with those households in each of these groups that are in severe fuel poverty targeted first as a priority
- Apply the Welsh Housing Quality Standards principles and research to the private rented sector also
Reinstate the Welsh Housing Conditions Survey
The Welsh Housing Conditions Survey (WHCS) was an annual survey and subsequent report on the state of homes across Wales. It looked at levels of disrepair, hazards and overall quality of the home, and allowed Welsh Government, Housing Associations and landlords (both social and private) to make the necessary repairs and adjustments needed to make sure their properties are secure and habitable. The WHCS was scrapped by Welsh Government in 2018, and nothing has replaced it. This means that all the data that is currently held on the current condition of housing across Wales is at least four years old, and we do not have an accurate or up-to-date picture of the landscape.
Implement a multi-measured Whole House approach to retrofitting
Whole house and fabric first are general terms used to describe the depth of retrofitting and decarbonisation work that is taken on a house. Fabric-first looks solely at the structure and the building itself, whereas whole-house looks not only at the home, but also the way the home is used and who lives in the home. This allows a more detailed look at the home to be made, and more accurate recommendations for retrofitting initiatives to be suggested.
Create and introduce a ‘TrustMark’/standards organisation that exists in Wales solely to regulate retrofitting projects and provide assurances to clients
In order for homeowners and owner-occupiers to be confident in the retrofit work and ensue that the contractors and companies they use are reputable, we recommended that Welsh Government develop a separate standards organisation to only oversee and regulate retrofitting work across the country. For many older people or more vulnerable people who may be looking for ways to insulate and take care of their home, they will be looking for contractors to undertake retrofit work. This is a potentially growing area for scammers and unreliable businesses to take advantage. To protect vulnerable consumers, we propose that this standards organisation is created, and follows a similar line of structure and responsibility as TrustMark.
Welsh Government to fund an initial formal retrofit assessment for private sector housing landlords and owner-occupiers, in line with the PAS2035 guidance
We recognise that retrofitting can be expensive, and often there can be a significant cost outlay to even have the initial retrofit assessment done. This financial disincentive means that those who may be eligible for decarbonisation measures may not opt to have them. However, with the introduction of funding for this initial assessment to be undertaken free of charge, Care & Repair believe that this will encourage
Care & Repair’s full list of recommendations:
- Clarification from Welsh Government on the plans for phase three of the Optimised Retrofit Programme
- For the Optimised Retrofit Programme to be carried out on a wide range of existing homes of different ages, locations, construction types and energy efficiency ratings, to assess its suitability on the wide range of dwelling types
- For Welsh Government to release an interim report of retrofit effectiveness, that includes a full data set and explanation as to the types of houses that have been targeted under the Programme
- For the ‘worst-first’ approach is targeted at the four individual groups mentioned, with those households in each of these groups that are in severe fuel poverty targeted first as a priority
- Apply the Welsh Housing Quality Standards principles and research area the private rented sector also
- Reinstate the Welsh Housing Conditions Survey
- Implement a 3-year funding cycle to ensure that the Programme is able to sustain the level of retrofit operations that is able to both make an impact and adapt with learning and need
- Introduce a ‘cost cap per county’ based on known data on costs and property type, or target to get the most used areas of homes up to EPC C initially.
- For a retrofit grant to be made available, and available to all vulnerable households, irrespective of savings
- For Welsh Government to create guidelines and formal definitions surrounding the practicality and possibility of retrofitting, and utilising ‘as far as is reasonably practical’ on a case by case basis
- Implement a multi-measured Whole House approach to retrofitting
- Create resources for homeowners and landlords that are easy to understand and applicable to their living situation, so parties are able to make a fully informed decision before entering a contract to retrofit.
- Create and introduce a ‘TrustMark’/standards organisation that exists in Wales solely to regulate retrofitting projects and provide assurances to clients
- Welsh Government to fund an initial formal retrofit assessment for private sector housing landlords and owner-occupiers, in line with the PAS2035 guidance
- Engage the UK government in dialogue to work towards more sustainable solutions.
- Bringing renewable energy production closer to Wales would influence the social responsibility and income generation opportunities stemming from these organisations working collaboratively with the Welsh Government.
- Making the rollout of decarbonisation methods an example of good practise for leaders of other nation governments to follow
