UK residential dwellings are currently responsible for 15% of UK greenhouse gas emissions (or around 22% including electricity consumption) and so form a major problem for our net-zero carbon ambitions. This inconvenient but incontrovertible truth is well recognised by government in terms of increasing the energy performance (EPC Band rating) of all dwellings: 

“In 2017, the government set out in the Clean Growth Strategy (CGS, p75) our aspiration for as many homes as possible to be upgraded to EPC Band C by 2035. In the Private Rented Sector (PRS), the CGS committed to upgrade as many homes as possible to EPC Band C by 2030, where practical, cost-effective and affordable.“ 

Recognising that low-carbon comfort is a systemic rather than a heat technology problem matters because it can only be fixed by a combination of: 

1. 1. Stringent fabric-first design and retrofit standards to significantly reduce the amount of energy required to achieve comfort and… 
   2. Reducing the carbon intensity of the energy that is still required to (net)zero. 

Despite some commentary to the contrary the detailed version of the Prime Minister’s 10-point plan makes clear reference to current and future policies that are designed to do both. We therefore welcome the integrative aspects of the plan which set out both fabric-first efficiency and low-carbon energy supply interventions. 

The policies in play 

For clarity, we have summarised the policy responses to date in the table below and break them down by the tenure/sector they are trying to address. We have also included our back of a fag packet estimates of the cost of upgrading the current stock to at least EPC Band C based on published English Housing Survey 2018-2019 data and upgrade estimates. To aid comparison with the figures cited in each consultation, the EHS 2018/19 Energy report (Chapter 3“Energy improvement works in English homes”, p 34) estimated: 

• • average ‘upgrade‘ costs for bands A-E = ~£13,300 
  • average ‘upgrade‘ costs for bands F&G = ~£26,800 

As you can see: 

• • these figures vary considerably from the costs modelled in the Private Rented Sector Regulations consultation in the table;  
  • setting stringent new standards for new builds addresses a very small percentage of the current and future dwelling stock and 
  • we are going to need a lot of capital from non-public sources unless the public investment commitments increase substantially. 

Table 1: Estimated number of dwellings to be upgraded, estimated cost and policies under development to deliver it 

	N dwellings (England, 000s)	% below EPC Band C	Estimated cost of upgrade to Cbased on EHS 2018/19 cost modelling	Policies and interventions
New builds	~ 240k per year(MHCLG) or ~ 1% of the existing dwelling stock	0% (hopefully)	£0 (hopefully)	Future Housing Standard (consultation closed 7/2/2020)  fabric first standards envisaged for new builds from 2025 (2023?)  target final energy kWh/m2 (not yet set) and carbon emissions (similar to EPC)  “We expect that an average home built to it will have 75- 80% less carbon emissions than one built to current energy efficiency requirements“
Existing: Social rented	4,073k	44%	£24 billion	£3.8 billion Social Housing Decarbonisation Fund for ‘retrofitting social housing at scale’  Funds Local Authorities to upgrade housing stock  £50 million demonstrator programme (July 2020)
Existing: Private rented	4,805k	67%	£46 billion	Private Rented Sector Regulations under consultation  should minimum EPC be raised to C?  Proposes fabric first approach, consulting on how to achieve it  “Under proposals set out in this consultation our modelling indicates that on average, landlords will spend ¬£4,700 per property to reach EPC C”
Existing: Owner occupiers	15,294k	71%	£154 billion	£3bn Green Homes Grantprogramme  grant for up to 100% of costs insulation, double glazing etc & low carbon heating
All existing dwellings:	24,172k		£226 billion	<- big number

Data source: English Housing Survey, 2018-19 (We intend to keep this table updated over time so bookmark this post)

Other relevant policy updates 

• • EPC Action plan (September 2020) – a BEIS & MHCLG response to a call for evidence on the effectiveness of EPCs focussing on non-compliance, reliability, accuracy and ‘freshness’, data access, guidance and their value as a future welling purchase/rental choice differentiator. 

In addition, expected soon are: 

• • Heat and Buildings Strategy 

• • “We expect to launch a further consultation in the coming months addressing existing domestic buildings” (Future Housing Standard consultation p14) 

Our views 

We have summarised our research-informed views on much of the above in a series of consultation responses where you can find references to relevant supporting research papers: 

• • Our initial response to the 10 point plan (November 2020) focusing on energy efficiency, standards gone AWOL, the hydrogen red herring and the problem with heat pumps; 
  • ECCD team response to the Business, Energy and Industrial Strategy (BEIS) Committee’s inquiry examining the path to decarbonising heating in homes. We emphasised the role of people, technologies, local authorities and the need for funding at the appropriate level to support net zero. 
  • An additional response to the Business, Energy and Industrial Strategy (BEIS) Committee’s inquiry from Dr Ben Anderson emphasising the need to focus on low-carbon comfort; 
  • Dr Ben Anderson and Dr Tom Rushby’s response to the Energy Networks Association’s consultation on ‘flexibility’; 
  • Dr Ben Anderson’s response to The Climate Change Commission’s ‘The Sixth Carbon Budget and Welsh emissions targets – Call for Evidence‘; 
  • Dr Ben Anderson’s response to Ofgem’s (2019) Access and Forward-Looking Charges Significant Code Review – Winter 2019 working paper. 

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