October 2024
Executive Summary
Retrofitting means making changes to a building. It’s about installing features to update an existing home that weren’t there when the home was built. This could include insulation, double glazing, changing the energy source and much more. Retrofitting will be a key part of fighting the climate crisis and ensuring our homes are not leaking energy, and are comfortable and healthy to live in.
As a community union representing low and middle income people, ACORN understands the need to retrofit our country's homes, not just to tackle the climate crisis but to alleviate fuel poverty and bring up living standards.
In order for retrofitting to be carried out in a fair and just way to the maximum benefit of our communities, our union is well placed to call for action on 4 key areas:
- Improving standards in rented homes
- Policies to prevent ‘renovictions’ as homes are improved
- Tackling EPC fraud
- A public information, advice and recruitment campaign
A separate document has been put together on the green energy transition and some areas of this intersect with retrofitting.
Improving standards in rented homes
Almost a quarter of private rented households live in fuel poverty. In the social sector energy efficiency is generally better but there are still over a million households with an energy efficiency rating of D or worse. In 2018 the government introduced Minimum Energy Efficiency Standards (MEES) which made it illegal to rent out or sell a home with an EPC rating of E or worse. But there were loopholes; private landlords were exempt from meeting the standard if they could prove they had spent £3500 on improving the home so far.
Private renters’ rights to a warm decent home is severely undermined by a weak regulatory system which favours landlords. If a tenant complains about anything in their home, a broken boiler, a broken window, poor heating etc. they could just be issued a Section 21 no fault eviction, leaving tenants in fear of raising issues and asking for repairs or improvements to the home. A further problem is that local authorities, the people who are responsible for upholding standards, have had their capacity cut after 14 years of austerity and don’t have the resources to police standards in the sector properly. In order to improve the energy efficiency and standards of rented homes the government must:
- Through the Renters Rights Bill: end section 21 no fault evictions and close any loopholes that could be exploited by private landlords to carry out evictions by the back door; bring in a national register of landlords as a database holding information about standards; properly resource local authorities to allow them to enforce standards and remove barriers to introducing schemes like local landlord licencing
- Bring in regulations raising the minimum energy efficiency standard for all private and social rented homes to an EPC rating of C to be announced without delay
- Support landlords to improve homes with means tested grants but ensure this is coupled with protections for tenants against ‘renoviction’
- Abolish the spending ceiling of £3500. (Landlords are exempt from meeting the current minimum energy efficiency standards if they can prove they have spent this amount on improving a home)
Preventing ‘renovictions’
Fuel poverty in the private rented sector is the worst of all tenures and private tenants have the least control over improving the energy efficiency of their home.
As a starting point, we need regulations requiring landlords to bring private rented homes up to a minimum EPC rating of C to be announced without further delay and robustly enforced:
- Tenants should be able to claim rent back from landlords who fail to meet the minimum standards of energy efficiency, and
- In more serious cases local authorities should be able to reclaim homes through compulsory purchase orders.
Means tested financial support should be available to landlords to assist them in meeting this target, but this must be paired with protections relating to the tenant, who must see the benefit of these improvements. We must make sure that tenants do not go through the upheaval of work to the home, only to be evicted while the landlord sells or rents the home for a higher price. To achieve this there should be:
- a freeze on evictions and rent rises during any improvement works and after they have been completed for a certain period, in order to ensure tenants feel the benefits of these improvements and make sure that costs are not passed onto them.
- Where a tenant pays rent with bills included, their rent should go down where energy saving measures have been introduced.
Combatting EPC fraud
All homes need to have an Energy Performance Certificate which rates the home from A - most energy efficient to G - least energy efficient. In theory, the better the EPC, the greener the home and the lower the bills. Once an EPC is awarded it lasts 10 years.
To get a certificate, home owners/landlords/housing providers instruct private companies who send out assessors. The assessors take account of things like the size of the home, the type of windows, the age of boilers and heating appliances, the physical location of the home ie. a middle terrace or top floor flat, and other things to arrive at an EPC rating.
In 2018 it became illegal to rent out or sell a home with an EPC lower than E and there are plans to increase this requirement to C.
Fuel poverty charity workers are concerned that the EPC system is easily open to fraud as only 1 in 100 certificates are audited and because as the assessments are done on the private market this can incentivise inspectors to give a good rating or lose business. Assessors ask landlords what rating they are hoping for when they start the assessment. Further to this, since the law came into force in 2018, the number of PRS homes listed as middle floor flats has rocketed and the general square meterage of PRS homes recorded has reduced. (The smaller sq m, the better the EPC; being a middle floor flat automatically improves the EPC). Charity workers found examples of a 120msq home listed as 20msq and lots of top floor flats listed as middle. They also found that the evidence needed for an audit is very non-specific. Photos of heating gadgets or appliances are taken close up with nothing to identify them with the home in question.
Once an EPC above E is awarded, renters have no legal recourse to call for energy efficiency improvements to their home for 10 years. Many will be paying extortionate bills due to energy leaking properties but have no ability to do anything about this. Living in a home with a falsely high EPC rating also makes them ineligible for public or charitable schemes to relieve fuel poverty as many are linked to EPC ratings.
In order to prevent EPC fraud the government should:
- Bring EPC assessments in house to prevent business competition and pressure
- Ramp up the scale of auditing
- Change the rules of auditing to ensure that any evidence submitted must be unequivocally identifiable as the home under inspection
Public information, advice and recruitment campaign
Retrofit grants and schemes are generally only being taken up proactively by individual homeowners. Those in the greatest fuel poverty are by and large not accessing grants, or getting their homes retrofitted, especially without third sector support.
A key problem faced by the sector is mistrust and disinformation. The powerful oil and gas lobby has the means to spread disinformation about the efficacy, cost and complexity of retrofitting schemes.
Another issue is that the people facing the harshest fuel poverty are already struggling through the cost of living crisis, and often don’t have the mental energy to research retrofitting schemes.
Finally, retrofitting can be complicated, and it’s not always presented in the most accessible of ways. New energy tariffs for example will be more complicated, and in order to get the most money saving out of them users will need to understand the best time of day to use different appliances.
In order to ensure the communities we live in and represent can access the full benefits of retrofitting we are calling for:
- a government public information campaign about retrofitting which lets people know what schemes are out there, how they work, what they cost and how to access them. This can dispel any misinformation or media bias.
- The information campaign should also be a recruitment drive to bring new workers into the retrofit industry. We need boots on the ground if we are going to succeed in retrofitting our homes on a mass scale.
- A local authority run free one stop shop advice service which can support people right from considering retrofit, to getting works done, to making the most out of them
- Energy companies send customers a wealth of information to promote the uptake of smart-meters, they should be compelled to send information about retrofitting options to customers too.
Some key principles and other useful findings
Below are some other key learnings we have gleaned from conversations with experts and organisations.
Often the most successful retrofit projects are community run and locally controlled. An ideal model would be schemes run by the local authority or local Community Interest Companies, as these would also have the information and relationships to be able to target the people in fuel poverty.
It is important to look at a building holistically when retrofitting. Single measure schemes (such as grants for just loft insulation) have failed in the past because they have only targeted a single area of the home which has led to increased emissions or problems in other places ie. build up of mould and damp or overheating in other rooms or floors. So we should be careful about campaigning for single use funding.
The technology and solutions are out there and environmentalists feel that EPC C by 2030 is nowhere near ambitious enough. A key blockage isn’t the technology, but needing to recruit to the workforce in order to implement the changes. There are currently around 140,000 working in retrofit - we need over 2 million to meet the current targets on time.
Embodied carbon is the term used to describe the carbon emissions produced in the construction process of a building, from sourcing the raw materials to transport to engineering work. In the new build sector there is already some focus on reducing the embodied carbon of new sites, but there aren’t targets for this in retrofitting. To make retrofitting the greenest it can possibly be, targets should be set to reduce embodied carbon by using, for example, less synthetic materials for insulation.
In most cases, retrofit is currently being looked at by government and policy makers on a home by home basis, but actually looking at communal solutions and schemes could make much more sense. For example, many voices cite difficulty in transitioning away from central heating to heat pumps in blocks of flats, but this becomes much less of a barrier when you think about having communal heating systems rather than a system for each individual household.