Good evening! This week's edition comes from Dr Keith Baker, member of the Common Weal Energy Policy Group and research fellow at the Department of Civil Engineering and Environmental Management, Glasgow Caledonian University. To receive the newsletter direct to your inbox every week click here.
If Scotland had the powers and access to the finance, by far the best way to get Scotland's homes ready for net zero would be a major programme of public works so households don't individually have to foot the bill.
In the absence of that, the cost is going to fall on you and the way that will happen is through the Heat in Buildings (HiB) Bill. It is therefore important that the legislation is fit for purpose; it is not.
Way back in 1987, the City of Berkeley, California, passed the world’s first Residential Energy Conservation Ordinance (RECO). This, like the HiB, was intended to leverage reductions in greenhouse gas emissions by mandating owners to make energy efficiency upgrades at certain "trigger points" – point of sale, change in tenancy, and extensions of over 25% of floor area.
The policy was so successful that it was credited with helping California recover from its 2001-2002 electricity crisis, and RECOs have since been adopted by other states and countries.
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On the surface, the HiB and a RECO appear very similar, but if energy efficiency regulations were cars then a RECO has been on Pimp My Ride, whilst the HiB got its engine from a second hand Lada and I wouldn’t want to trust the wheels in a race to net zero.
A RECO’s engine is the requirement for detailed inspection and certification, something the HiB consultation rules out. The wheels are the measures it covers, something a RECO takes a holistic approach to and ensures that they are realistic and reasonably affordable, whereas the HiB proposes a basic set of six "simple measures" with a vague and potentially very long list of exemptions.
Even putting those exemptions aside, I have tried to come up with defensible numbers for how many homes will be covered by each of the measures, but I’ve largely drawn a blank, and I doubt that Patrick Harvie (the minister responsible) could do any better. Let’s start with one of them, cavity wall insulation.
The Scottish House Condition Survey reports that as of 2021, 78% of homes with cavity walls have CWI installed. This leaves us with roughly 356,400 dwellings (around 13% of the housing stock) with unfilled cavities.
However, some indeterminate number of these will have cavities that, for various reasons, cannot or should not be filled. This in itself is hardly ambitious, but it also ignores those properties with CWI where the insulation has settled or been damaged by water ingress and so needs replacing. We’ll never know how many homes need this as we won’t be inspecting them, and given that poor maintenance is a fundamental problem for improving energy efficiency, it’s a glaring omission that the word maintenance appears not once in the entire consultation document.
Or we could take another measure, draught proofing. This is so lacking in definition in the consultation that it could apply to almost all or none of the entire housing stock. A similar argument could be made about what is meant by "heating controls" – the lack of definition throughout the consultation is painful.
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Having responded at length to the consultation I have to conclude that the Scottish Government has only the faintest idea of the scale of the task, insufficient data on which to base the policy solutions, very little understanding of even basic energy efficiency measures, and no real idea of where the money to implement them will come from.
Returning to RECOs, top of my long list of pet hates of Scottish Government policy making is the regularity with which ministers take a perfectly good policy proposal and butcher it. I don’t know if those behind the HiB were aware of RECOs, although I did recommend that the Scottish Government adopt one in a 2012 report for them.
We’ve seen this with the National Investment Bank, the National Care Service, the use of zoning for deploying district heating without first implementing a Heat Supply Act (something Denmark passed in 1979), and many more examples.
I understand that many people may baulk at the idea of being forced to upgrade their properties, but if we don’t tackle energy inefficiency we can kiss our climate change targets goodbye. However, the measures we will be made to install must be appropriate, affordable, and result in measurable improvements. The proposals in the HiB are way off meeting these criteria and, in some cases, may leave householders with problems such as overheating.
What is needed now, as Common Weal set out in the Common Home Plan, is a major programme of public works to future-proof our buildings to 2045 that ensures no one gets left behind. This will not come for free, but it’d be cheaper and more effective than leaving our society and economy exposed to the impacts of climate change and a volatile global energy market.
We can, and we must, do better.
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