In March the Scottish Government published Housing to 2040, Scotland’s first ever long-term national housing strategy. It sets out a route map for how, by 2040, everyone will have a safe, high-quality home that is affordable and meets their needs in the place they want to be.
The positive contribution that Housing to 2040 will have on improving health and tackling health inequalities in Scotland must not be underestimated. Realising the right to adequate housing for communities across Scotland is central to the commitments in Housing to 2040 and upholding the right to housing is fundamental to realising the right to the highest attainable standard of physical and mental health.
Public Health Scotland has published Healthy Housing for Scotland, a briefing paper that aims to assist with impact assessing policy developments related to the Housing to 2040 strategy, locally and nationally. It also aims to support public health colleagues who are working locally, regionally and nationally with housing colleagues in the process of designing, implementing and evaluating policy decisions.
The briefing paper seeks to do this by outlining evidence for how housing impacts on health and wellbeing. Evidence informed policy development is key to tackling inequalities and ensuring that resources are used in a way that creates the most impact. Many policies, plans, proposals or decisions have the potential to impact on health and health inequalities.
Estimates vary, but it is widely accepted that health is largely shaped by factors beyond access to health care. Further, the factors that do influence health – the social determinants of health – which include housing, are connected intricately to the other determinants, for example employment, education and income. Building on this, we must consider the evidence base and opportunities to maximise on the impact that policy development can have on addressing inequality and upholding the right to health for communities. We also need to consider unintended consequences which can be negative if not properly scoped and assessed.
Cladding and fire safety
How did the cladding issue come to affect so many flat owners in Scotland?
Article reproduced with the kind permission of Under One Roof.
Initially it was thought problems with cladding were limited to buildings that had Grenfell type “ACM” (Aluminium Composite Material) cladding with a flammable insulation. It subsequently became clear that there were problems arising not just from what materials the cladding was made out of, but also from how the cladding was fixed with inadequate fire stopping.
Issues of balconies with combustible materials, fire escapes, and lower buildings were also brought into the equation. The result was many more owners unable to sell their properties, and increasing insurance premiums.
A process of fire safety surveys evolved – lenders required an External Wall System survey form (EWS1) to be completed. The result of the EWS survey identified those buildings they were happy to lend on, and those which required further, more expert, fire safety surveys.
However, a lack of suitably qualified and appropriately insured experts made it very difficult to get such surveys carried out, and as a result flat owners in buildings that had cladding or balconies made of combustible materials found it hard to sell their properties.
In Scotland, the situation was made worse by the fact that there are multiple owners of each building, each of whom might need a separate EWS1 form.
Scottish Government proposals – Single Building Assessments
On the 19th March 2021, the Scottish Government stepped in with proposals that they would fund a single assessment for every building. The aim is that these Single Building Assessments will provide the evidence that lenders require, and owners will be able to arrange remedial works or sell their properties more easily if no major problems have been found.
Once completed, this will mean owners should not need an EWS1 Form to sell. The combined results of the surveys will also help the Scottish Government assess priorities for their remediation programme.
It’s not compulsory that owners get the Single Building Assessment but buildings which have not had the assessment will not be able to take part in the government-supported remediation programme. The Single Building Assessment will be phased to prioritise those buildings thought to be most at risk.
The government is currently undertaking a pilot phase. Once this is complete the roll out of the Single Building Assessment is proposed to be phased as follows:
- Buildings with an existing cladding or fire risk assessment that highlight risk to life not already included in the pilot programme.
- Buildings with Metal Composite Cladding
- Buildings High Pressure Laminate cladding
- Buildings with Timber Cladding
- Buildings with other combustible cladding types
- Any other buildings with external wall systems
In each of these groups, the programme will start with the tallest buildings and work their way to the lower rise.
Shortly before the separate Scottish Government proposal, the Royal Institution of Chartered Surveyors (RICS) published new guidance on when an EWS1 form would be needed. This new guidance means that lower rise buildings with less risky types of cladding will no longer need EWS1 Forms.
This will allow the resources available for carrying out specialist surveys to be focused on more problematic properties. The impact of this announcement has been somewhat overshadowed in Scotland by the Single Building Assessment but it may be of use to some home owners who need to sell quickly.
Under One Roof has been looking at how useful tenement legislation is to owners in this position. It’s their view that surveys and inspections count as tenement management, which is classed as maintenance for the purposes of decision-making.
They also feel that the vast majority of recladding projects can be counted as replacement work – which also counts as maintenance as far as decision-making is concerned.
Even if there is an element of improvement in the work, this is incidental to the replacement and doesn’t affect the decision-making process. Maintenance decisions can be taken by a majority of owners – but do check your own title deeds provisions as these will take priority over tenement legislation.
Energy Performance Certificates & improving energy efficiency
Energy Performance Certificates (EPCs) provide information on how energy efficient a property is. Properties are rated on a scale from A to G, with A being the most efficient. Information is also provided on measures which could be made to improve the energy efficiency and an indication of the cost for each improvement.
The EPC rating is a measure of the cost to heat and power the home based on a set of assumptions about occupant behaviour. The higher the cost the lower the rating. Therefore homes heated by expensive on-peak electricity will in most cases perform worse than homes heated by cheaper gas or renewable resources like biomass. Equally, properties which don’t retain heat will be more expensive to heat and therefore have a lower EPC rating than properties which are well insulated.
Landlords are required to have an EPC which is less than 10 years old at the point they market a property for rental to new tenants.
EPCs need to be produced by qualified and accredited assessors. You can search for a local EPC assessor at https://www.scottishepcregister.org.uk/assessorsearch
Some properties might already have an EPC which is less than 10 years old. You can use these even if they were produced for someone else e.g. a previous owner of the property. You can search for existing EPC certificates for your property at https://www.scottishepcregister.org.uk/CustomerFacingPortal/TermsAndConditions
The assessor will visit the property to gather information including the age and construction of the property, the property size, the heating system, type of lighting and windows and the presence of any floor/wall/loft insulation. It is a non-intrusive survey so the assessor will only be able to record features they can see or obtain visual evidence of. Robust documentary evidence of features that aren’t visible e.g. wall insulation can also be used. The data is then entered into a specialist computer system which generates the EPC.
The EPC rating must be included in any adverts. The EPC must be made available to prospective tenants, provided to new tenants and displayed in the property. If you don’t comply with these requirements, you could be fined up to £1000.
The EPC doesn’t need to be renewed until both of the following apply:
The Scottish Government has committed to introducing regulations requiring private rented sector properties to meet a minimum energy performance certificate (EPC) rating before they can be let to tenants. It is likely that these will require properties to have a minimum rating of D
It is likely that the regulations will provide for some exemptions, including where:
• It is not technically feasible to carry out improvements
• Where other owners in a block of flats refuse consent to do work to common parts of the building
• Where tenants refuse consent for work
• Where permission to carry out work to a property which is listed or in a conservation area can’t be obtained
• Where the cost of improvements needed exceeds £10000
It is proposed that landlords will only be required to carry out work where the cost of purchasing and installing it can be financed by means of funding provided by a grant or loan from Scottish Ministers.
Local authorities are expected to be responsible for enforcing the standard and granting exemptions. It is proposed that fines could be levied on those owners who don’t comply with the minimum standard or provide false or misleading information on the exemptions register.
Improving the EPC rating Below are 11 suggestions of ways to increase the EPC rating of your property. As a very general rule you can expect the following improvements to the EPC rating (there are roughly 10 points in each of the A-G EPC bands):
• More efficient/cheaper to run heating – up to 40 points
• Better heating controls – up to 5 points
• Install wall or loft insulation – up to 11 points
• Higher performance glazing – up to 4 points
• Low energy lighting – around 1 point
- Scrutinise the EPC – unfortunately assessors sometimes make errors and unnecessary assumptions when carrying out the EPC and this can have a big impact on the rating. For example, if they don’t check whether there is insulation in the loft space of a house or top floor flat built before 1955 then the EPC software will assume there is none, yet 94% of properties in Scotland do have at least 10cm of insulation. We therefore recommend you ask to see all the data entries they used when making the assessment and challenge any that you know are incorrect. The assessor is only allowed to input information that they have evidence is correct so there must be visual or robust documentary evidence.
- Fit a more efficient boiler – older boilers can be less than 70% efficient whereas modern condensing boilers are over 90% efficient. Boilers account for about 55% of what occupants spend in a year on energy bills, so an efficient boiler makes a big difference. The typical cost of replacing a boiler is in the region of £2000.
- Fit modern electric storage heaters (i) Fan assisted storage heaters – fan storage heaters are smaller, better insulated and more responsive than traditional storage heaters. (ii) High heat retention electric storage heaters – these retain more heat than other models and claim to be 27% cheaper to run than comparable static storage heaters. Modern storage heaters should also incorporate better controls than traditional models. For example, there is usually a thermostat so that the heater switches off when it has reached a certain temperature. Many models also have automatic charge controls which will control how much heat they store overnight depending on the heater’s internal thermostat as well as changes in daily weather patterns.
4. Improve central heating controls (programmers, TRVs and room thermostat)
4.(i) Room thermostat – where a dwelling does not have a room thermostat, the heating system may not switch off when the dwelling is up to temperature. A room thermostat will automatically turn off the boiler when the dwelling reaches the temperature set by the occupant. Wireless thermostats are available to prevent the need for any wiring back to the boiler and cost around £200 fitted.
4.(ii) Programmer – where the dwelling does not have a programmer (or a time clock) to control when the heating comes on and goes off, the use of the heating is controlled simply by an off‐on switch. Fitting a programmer allows the hours of operation of the heating system to be better controlled to suit the needs of the occupant and should cost around £120 fitted.
4.(iii) TRVs (thermostatic radiator valves) – unlike a room thermostat which gives a centralised control over the dwelling temperature and can shut the boiler down when the dwelling is up to temperature, TRVs control the temperatures in individual rooms, and only shut down individual radiators. Fitting TRVs provides better control of temperature across the whole dwelling. In a property with eight radiators the cost would be around £250 to fit TRVs.
- Replace/remove secondary heating – if dwellings have a secondary form of heating e.g. a gas fire in the living room, the EPC software will assume that this is used for some of the heating in the dwelling. Secondary heating appliances are often extremely inefficient e.g. solid fuel open fires are typically less than 30% efficient while mains gas decorative fuel effect fires open to the chimney typically have a 20% efficiency rating. Removing these appliances can mean that the EPC software assumes all of the heating comes from the main heating system which is usually much more efficient and therefore improves the EPC rating. Alternatively, secondary heating can be replaced with something more efficient e.g. a solid fuel stove which can have an efficiency rating of around 65%
- Fit insulating jacket to hot water tank – according to the Energy Savings Trust, fitting a good quality jacket around the hot water cylinder will cut heat loss by more than 75%. They cost as little as £15 and yet will typically save more than this each year in fuel cost savings
- Fit thermostat to hot water tank – the presence of a cylinder thermostat will stop the boiler supplying heat to the tank once it reaches the desired temperature. This reduces the energy consumed in heating the hot water. Cylinder thermostats should be installed by a boiler engineer and should cost around £120 fitted.
- Cavity wall insulation – if your property has a cavity wall this is another really cost effective improvement you could consider. The cost is around £400 and should pay for itself within 5 years in energy savings. The insulation is installed into the cavity through small holes drilled in the mortar joint between the bricks. To find an installer go to the National Insulation Association – http://www.nia-uk.org/consumer/. Cavity wall insulation is not suitable for all cavities and can lead to very serious damp problems if it is installed in unsuitable properties, if unsuitable materials are used or if it is installed badly. Make sure you use a reputable installer who carries out a thorough pre-installation assessment and provides a long term guarantee.
- Loft insulation – suitable for houses or top floor flats, this is one of the most cost effective improvements which should pay for itself in fuel savings within 2 years. It can lead to energy savings of up to 20%. The cost for an average house tends to be around £300. To find an installer go to the National Insulation Association – http://www.niauk.org/consumer/.
- Double glazing – this is not a particularly cost effective improvement when viewed purely on the basis of installation cost vs annual energy savings as the typical payback period is often more than 15 years. However, it can improve the comfort of the home and noise transmission from busy roads etc. and is usually popular with tenants, making it easier to let the property. If your property is listed or in a conservation area you will need consent from the local authority.
- Fit low energy lightbulbs – although low energy lightbulbs will only make a small difference to the EPC rating, they are cheap and easy to fit and suitable for all properties so are worth doing, especially if your property is on the threshold between two EPC ratings.
Further advice Please note that the EPC recommendations report is NOT a reliable tool to use to work out what improvements to do to get to a particular EPC rating. Landlords should seek further advice before installing measures to ensure that they are suitable for their particular property and find out what the likely impact on the EPC rating will be. EPC providers can model your property with different improvement measures and tell you what the effect on the rating will be, before you spend any money on improvement works.
To find an EPC assessor or retrieve a copy of the current EPC for your property go to https://www.scottishepcregister.org.uk/.
Funding For information on funding which is available to landlords in Scotland visit the Energy Saving Trust “support for landlords” page at www.energysavingtrust.org.uk/scotland/businessesorganisations/landlords or call Home Energy Scotland on 0808 808 2282. Funding may also be available based on the status of tenants, particularly if they are elderly or on low incomes. To find out more about whether this might apply tenants should contact Home Energy Scotland for advice on 0808 808 2282.
Take care and stay safe,
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